ML20214C563
| ML20214C563 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1986 |
| From: | Cilimberg R, Jocelyn Craig NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20214C542 | List: |
| References | |
| REF-QA-99900251 NUDOCS 8602210178 | |
| Download: ML20214C563 (18) | |
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. ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY t REPORT INSPECTION INSPECTION NO : 99900251/86-01 DATE: 1/13-17/86 ON-SITE HOURS: 114 CORRESPONDENCE ADDRESS: Joseph Oat Corporation ATTN: Mr. Maurice Holtz Vice President 2500 Broadway Camden, New Jersey 08104 ORGANIZATIONAL CONTACT: Mr. John Renckert, QC Manager TELEPHONE NUMBEP: (609) 541-2900 NUCLEAR INDUSTRY ACTIVITY: Heat exchangers, fuel storage racks, and defueling canisters 10f AA 4
ASSIGNED INSPECTOR: /R. L. CiTimberg, Spec)fl Projects Inspection k/J[ff bate Section (SPIS) V OTHERINSPECTOR(S): C. Abbate, SPIS J. Thomas, TMI Program Office B. Brown, EG&G R. Pettis, SP!S APPROVED BY:
' John W. Craig, Chief, SPIS,(fendor Program Branch
/3 ae k
INSPECTION BASES AND SCOPE:
A. BASES: 10 CFP Part 21 and 10 CFR Part 50, Appendix B.
B. SCOPE: Review fabrication activities, the Joseph Oat QA and QC programs and their implementation, and compliance with the requirements of 10 CFR Part 21 and 10 CFR Part 50, Appendix B during the fabrication of fuel and knockout canisters to be used during the TMI-2 defueling effort. The QA (continued on page 2)
PLANT SITE APPLICABILITY: TMI-2 (50-320).
8602210178 860219 PDR GA999 EfWJOAT 99900251 PDR
ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 2 of 12 B. SCOPE: (continued) requirements and applicability of 10 CFR Part 21 were specified in Bechtel purchase order TC-022111, Rev. O dated August 7, 1985, and Bechtel Technical Specification 15737-2-M-101A(Q), Rev. 2, dated June 18, 1985.
A. VIOLATIONS:
None.
B. NONCONFORMANCES:
None.
C. UNRESOLVED ITEMS:
None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (Closed) Violation (85-01, Item A.1):
Contrary to Sections 21.21(a)(1) and (2) of 10 CFR Part 21, the Joseph Oat procedure SP-1552, " Procedure fnr Reporting Defects and Noncompliances" dated January 15, 1979, does not adequately address a procedure to be followed by Oat personnel to inform the licensee or purchaser of a defect, and does not address the issue of informing a director or responsible officer of deviations reportable to the NRC, purchaser or licensee.
The NRC inspectors determined that procedure SP-1552 " Standard Procedure for Reporting Defects and Noncompliances" Rev. I dated December 24, 1985, the latest revision, includes a procedure to inform the licensee or purchaser of a defect and a procedure to inform a responsible officer of deviations reportable to the NRC, purchaser or licensee. This item is considered closed.
- 2. (Closed) Nonconformance (85-01, Item B.1):
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Section 4.2.2 of the Oat Quality Assurance Manual, Revision 8, dated June 26, 1985, a description did not exist in the traveler for the installation and removal of lifting lugs.during the fabrication of the fuel canisters.
ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 3 of 12 During this inspection it was observed that the shop travelers for the remaining fuel canisters to be fabricated have been revised to address the installation and removal of lif ting lugs. In addition, the traveler references " Procedure for Placement of Temporary Lif t Lugs on J-2476," Rev. O dated September 26, 1985. This item is considered closed.
- 3. (Withdrawn) Nonconformance (85-01, Item B.2):
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Section 4.2.2 of the Oat QAM, the shell of canister 2476A2 was fortred with a steel bar and a hammer to achieve a concentric fit-up between the shell and the lower head without a description in the traveler for this operation step in the manufacturing process.
As discussed in section E.3, discussions with welders and welder /
fitters during this inspection confirmed that the term " fit-up" in the traveler is the written description for forming with a steel bar and hamer. This activity was determined to be within the skill of the individuals assembling the canisters. This item of nonconformance is withdrawn.
4 (Closed) Nonconformance (85-01, Item B.3):
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 4.3.3.1 of Bechtel Technical Specification 15737-2-M-101A, Revision 2, dated June 19, 1985, Turco Dy-Check Remover No. 3 was being used for cleaning canister parts and welds before obtaining Bechtel's approval for the procedure which permits the use of this cleaner.
Oat Job Procedure JP-2476-1, " Cleaning Procedure for Fuel and Knockout Canisters," was revised (October 24,1985) to permit the use of Turco Dy-Check Remover No. 3; the revised prncedure was approved by Bechtel. This iten is considered closed.
- 5. (Closed) Nonconformance (85-01, Item B.4):
Contrary to Criterion XVI of Appendix B to 10 CFR Part 50, Special Condition 19 to Bechtel P0 TC-022111, and Section 9.1 of Oat 0AM, conflicting documentation existed which lef t the quality of the recombiner elements in the lower heads in question.
i
ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION Nn.- 99900251/86-01 RF?SULTS: PAGE 4 of 12 The inspectors reviewed a letter to Oat from the supplier, NES Manufacturing, dated September 30, 1985, and a letter to Oat from the buyer, Bechtel, dated October 4, 1985, which provided assurance that the issue had been reviewed. Bechtel stated that the required quantity of catalyst had been installed in the recombiner elements and that the quality of the catalyst was sufficient to function as designed. This item is considered closed.
- 6. (Closed) Unresolved Item (85-01, Item C.1):
A chemical reaction between water and the concrete resin was observed to take place within one hour of the concrete resin being placed in water. This reaction weakened the concrete resin and led to questions concerning the suitability of the material in the fuel canisters when exposed to water.
The inspectors reviewed a letter dated November 21, 1985, from Bechtel to Oat. This letter contained Babcock & Wilcox (B&W) test results which stated that the concrete resin met design specifications after being in contact with water. This item is considered closed.
- 7. (Closed) Unresolved Item (85-01, Item C.2):
Upon inspection of the catalyst in the lower heads supplied by NES, there were indications of overheating and weight discrepancies. (The resolution of the weight discrepancies was discussed in nonconformance 85-01, Item B.4.)
The inspectors reviewed a letter from Bechtel to Oat dated November 21, 1985 which stated that catalyst discoloration from heating was not expected to be a concern. As discussed in Item E.7, this area has been evaluated. The conclusion of the evaluation is that the catalyst was acceptable for use. These two itens are considered closed.
- 8. (Closed) Unresolved Item (85-01, Item C.31: '
After shipping canister shells from NES to Oat, it was determined that 40 longitudinal welds had one radiograph view missing, and one longitudinal weld had no radiographs.
The NRC inspectors verified that Oat was reradiographing the sections of pipe with the missing radiographs as the individual canisters were needed for fabrication. This item is considered closed.
. ORGANIZATION: JOSEPH 0AT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 5 of 12
- 9. (Closed) Unresolved Item (85-01, ! tem C.4):
After reviewing the concrete resin pour, it was determined that the procedure did not address whether continuous pouring is required.
The inspectors reviewed Oat procedure QC-82, Rev. 3, dated January 8, 1986, " Concrete Pouring Procedure" which states that pouring will occur within one hour after mixing. This item is considered closed.
- 10. (Closed) Unresolved Item (85-01, C.5):
The applicability of Joseph Oat invoking the provisions of 10 CFR Part 21 upon Air-Oil Systems Incorporated was an unresolved item.
After discussion with Oat staff members, it was determined that these items were standard catalogue listed fittings and that the modifi-cations, although listed on the purchase order, were made by Oat and not by Air-Oil Systems Incorporated. This item is considered closed.
E. INSPECTION FINDINGS AND OTHER COMMENTS: -
- 1. 10 CFR Part 21 During the inspection the NRC inspectors reviewed procedure SP-1552,
" Procedure for Reporting Defects and Noncompliances," Revision 1 dated December 24, 1985. This revision included the delineation of responsibilities of Oat personnel when a nonconformance or defect is found at various stages of the manufacturing process. The procedure also described the steps to be followed when a defect or noncon-formance is identified af ter shipment including customer notification. Records of such notifications will be kept by the CC Manager.
As a result of this review, Oat's procedure was determined to be adequate; Violation 85-01-01 is considered closed.
- 2. Lifting Lugs The NRC inspectors reviewed shop travelers for fuel canisters at various stages of fabrication and found that a revision had been made to include the steps for installation and removal of lif ting lugs.
The traveler also referenced " Procedure for Placement of Temporary Lif t Lugs on J-2476," Revision 0 dated September 26, 1985. The procedure included an outline of the welding procedure to be used, and a drawing which indicated where the lifting lugs are to be placed.
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' ORGANIZATI0f t: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY ,
' REPORT INSPECTION e NO.- 99900251/86-01 RESULTS: PAGE 6 of 12 Standard Procedure SP-1609 dated July 6, 1978, is used for the removal of the lugs. A liquid penetrant examination of the area where the lifting lug had been welded to the canister is then performed.
Asaresultofthisreview,Nonconformance$501-01isconsidered closed.
- 3. Control of Special Processes The NRC inspectors reviewed 14 Oat procedures to determine whether special processes were being conducted by qualified persrnnel using qualified procedures and equipment. A review of 12 travelers relating to fabrication of 10 fuel canisters and two knock-out canisters revealed that all individual operations were properly initialed and dated. The traveler package contained a weld and heat sketch and record sheet which identified bill of material iter, numbers, heat numbers, weld numbers, welding procedure specification numbers, welder stamp, and filler metal heat numbers. Op'eraticn descriptions in the traveler described fabrication steps and identified the approved drawings which contained weld notes and joint details.
While observing the fit-up of lower heads to several canister shells the NRC inspectors questioned the Oat welders a1d welder / fitters concerning what description in the traveler described the use of a steel bar and hammer on the canister shell. All Oat personnel stated that the term fit-up, referenced in the travelers, allows the necessary forming to achieve the proper dimensions specified on approved drawings. Also, the inspectors noted that this process is consistent with fabrication recuirements and within the skill of the individuals assembling the canisters. Based upon the above, Nonconformance item 85-01-02 is withdrawn.
- 4. Canister Cleanliness >
Canister shells are stored indcors at the Oat facility under clear plastic sheets with rubber end caps on the empty shells. The cold weather has resulted in split end caps which are being taped on an as needed basis. Cleaning operations are described on fabrication travelers by reference to Job Procedure No. JP-2476-1, Rev. 3.
Cleaning is being performed in accordance with written procedures.
The NRC inspectors reviewed JP-24761 1 , Rev. 3 and determined that Turco Dy-Check Remover No. 3 is pennitted for use by this procedure which is on the list of procedures that have been approved by Bechtel.
Nonconformance 85-01-03 is considered closed as a result of this i
review.
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ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 7 of 12
- 5. Recombiner Catalyst During the previous inspection a nonconformance was identified involving conflicting documentation supplied to Oat from both Bechtel and NES concerning the recombiner catalyst. Af ter identification of this nonconformance, Joseph Oat issued Deviation Notice 2961 dated September 27, 1985. This documented the condition which was adverse to quality and initiated actions to resolve the discrepancy resulting from the conflicting documents. The inspectors reviewed a letter tn Oat from NES Manufacturing, dated September 30, 1985, and a letter to Oat from Bechtel dated October 4,1985. These letters provided assurance to Joseph Oat that the issue had been reviewed and certified that the required quantity of catalyst had been installed in recombiner elements.
In addition, this issue was reviewed by the NRC Three Mile Island Cleanup Project Directorate (TMICPD) which has lead regulatory responsibility for safety evaluation of the defueling canister design; and GPU Nuclear Corporation, the end user of the defueling canisters.
Acceptable resolution of the catalyst loading issues is discussed in NRC letter NRC/TMI-85-086 dated November 8, 1985 to GPU Nuclear Corporation, docket 50-320, and GPU Nuclear letter 4410-85-L-0229 dated November 12, 1985 to NRC:TMI Program Office. This nonconformance is considered to be an isolated incident of personnel error, thus no further corrective action is deemed necessary to prevent recurrence.
Nonconformance 85-01-04 is considered closed.
- 6. Durability of Concrete Resin The inspectors reviewed a letter from Bechtel to Joseph Oat dated November 21, 1985 which was in response to a Joseph Oat letter of October 7,1985 which addressed the issue of concrete resin durability.
The letter transmitted a test report by the canister designer (Babcock
& Wilcox) and confirmed that the refractory cement is acceptable for use and meets the design specifications. Testing performed by the designer determined that the cement exhibits considerable reduction in compressive strength after immersion in water, but still retains sufficient strength to exceed the design specifications for the fuel canister.
In addition, the NRC TMICPD staff reviewed the results of additional testing of the refractory cement performed by Rockwell
- ianford Operations which verified that any material leached from the cement by immersion in water would not adversely affect catalytic recombiner operation. Based on the above, Unresolved Item 85-01-01 is considered closed.
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ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 8 af 12
- 7. Inspection of Recombiner Catalyst in Lower Heads The inspectors reviewed a letter from Bechtel to Joseph Oat dated November 21, 1985 which informed Oat that catalyst discoloration from heating had also been observed at other canister vendors. This letter stated that discoloration was not expected to be a concern but was being evaluated, and Oat should proceed with catalyst installation. This issue was subsequently reviewed by the NRC TMICPD technical staff with GPU Nuclear and Rockwell Hanford Operations, who designed the recombiner elements. It was determined that catalyst heating due to welding of the retention screens would not adversely affect the Englehard catalyst. Significant heating of the AECL catalyst would degrade the catalyst but would also cause an obvious charred appearance to the silicone coating which had not been observed. Based on the above, Unresolved Item 85-01-02 is considered closed.
- 8. NondestructiveExamination(NDEl Nondestructive examinations of the TMI-2 Defueling Canisters must meet the requirements set forth in the 1983 Edition of ASME Code Section VIII, Subsection UW (lethal), paragraphs UW-50, UW-51, and UW-53 as required by Bechtel Specification 15737-2-M-101A(Q).
- a. Since the previous inspection conducted on September ?3-27, 1985, several NDE procedures were revised and/or added to the list of Bechtel approved Oat procedures. The following NDE procedures were reviewed and found to meet the applicable Code requirements:
- 1. " Ultrasonic Inspection Precedure for Circ. Pipe Weldments,"
QC-2476-70, Rev. 2, dated January 15, 1986. This procedure was revised and added to the list of approved procedures.
Revision 2 now contains ultrasonic instrument gain settings for scanning, search unit overle ->f at least 105, and the rate of search unit movement for examination not to exceed six inches /second unless calibration is verified at increased scanning speeds.
- 2. " Ultrasonic Examination Procedure, Addenda dl, to QC-2476-70,"Rev.1, was written and approved to govern the ultrasonic examination of the base materials for the bulkheads on the fuel canisters and the top heads on the knockout canisters.
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ORGANfZATION: JOSEPH OAT CORPORATION o CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 9 of 12
- 3. " Procedure for Qualification of Liquid Penetrant Examination Techniques at Nonstandard Temperatures," dated September 14, 1976. This procedure was used to qualify QC-2476-10,
" Liquid Penetrant Examination of Welds," Rev. O, dated July 25, 1985, for liquid penetrant examinations with component and material temperatures down to 40 F. With the penetrant procedure certified for 40 F, it was still necessary to preheat the components and materials before penetrant examinations could be performed at the fabrication area of Oat during this NRC inspection.
- b. Ultrasonic examinations are either parformed under subcontract by Eastern Testing and Inspection, Inc. (ETI) of Pennsauken, NJ, or by an Oat Level II ultrasonic examiner. Individual training and certification records, including eye examination results, were reviewed for one Oat Level II exaininer and one ETI contractor.
During disCJssions, Oat personnel stated that these are the only two Level TI examiners which will be used for ultrasonic exami-nation of canisters. The certifications for each examiner were found to be in compliance with SP-1576, " Requirements for Qualification and Certification of NDE Personnel" (0at), Rev. 4, dated September 1,1983; CP-101, " Procedure for Qualification and Certification of NDE Personnel" (ETI), Revision 3, dated June 1,1981; and the guidelines of SNT-TC-1A.
- c. Radiographs, technique sheets, and inspection reports for the following bottom-head welds were reviewed: J 82476-C61, J #2476-C62, J d2476-C63, J-*2476-C64, J-#2476-C65, J 42476-C66, and J-*2476-C68.
It was reported that these were the only bottom-head weld radio-graphs available since the previous radiographs had been shipped with the completed canisters. No rejectable indications were noted. The inspection reports, the radiograph technique, quality and densities were determined to meet the applicable ASME Code requirements.
- d. An in-progress liquid penetrant examination on canister pipe 116P-2 at the Oat fabrication area was observed. Although the temperature at the fabrication area was less than 40'F, the materials and parts were preheated to a temperature greater than 40 F during examination. Liquid penetrant examinations on the weld prep areas of knockout canister top-heads D-61, D-36, D-32, D-13, and D-45 were also observed in the inspection area. All of
.o
. ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECT!)N NO.- 99900251/86-01 RESULTS. PAGE 10 of 12 the above liquid penetrant examinations were done by certified Level II personnel using approved procedures and certified materials.
- e. During the inspection, interviews were held with Oat personnel regarding the missing radiographs on canister pipe longitudinal welds. Each full length of pipe was radiographed with twenty location markers. The pipes were then subsequently cut in half.
NES or B&W received one half of the pipe and maintained the radiographs applicable to their piece. Apparently, this resulted in one view missing since the cutoff point on the pipes is at the midsection of the 10-11 location markers. Oat is reradiographing the sections of pipe with missing radiographs as the individual canisters are fabricated. The following replaceme1t radiographs were reviewed and found acceptable:
34P-2, 47P-2, 48P-1, 63P-1, 20P-2, 30P-2, 40P-1, 118P-2, 121P-1, 56P-1, 82P-2, 125P-1, and 140P-1.
Unresolved Item 85-01-03 is' considered closed as a result 0f the above discussions. ,
- 9. Concrete Resin Pouring The NRC inspectors reviewed information sent to Oat from Bechtel concerning the concrete resin. This information included a B&W test report dated October 10, 1985. The report outlines the curing process and states that one day curing at room temperature forms the hydraulic bond and sets the shape. Curing continues 20-30 days after pouring at which time the bond is at full strength.
Dat procedure OC-2476-82, " Concrete Pesin Pouring Procedure," Rev. 3 dated January 3, 1986 was reviewed and was determined to be acceptable.
Section 4.1 states that pouring will begin 15 minutes after mixing and that the mixture will be used within one hour of mixing. Thus, the procedure allows a delay in pouring (less than one hour) which would not result in deterring the curing process. Unresolved Item 85-01-04 is considered closed as a result of this review.
- 10. Procurement Document Control At the time of the inspection, no purchase orders (P0s) had been written for material needed for the fabrication of fuel or knockout canisters. However, two P0s had been written for machining services.
P0 19643 to Permutit Co. was for machining work to be done on material 1
^
ORGANIZAT10N: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 11 of 12 supplied by Oat. Bechtel Specification 6400, Rev. 2 and 10 CFR 21 were imposed on Permutit and certificates of conformance were required.
P0 19518 to Beaver Tool was a change notice to the original P0 dated September 9, 1985. The change notice called for machining to be performed on the bulkhead weld prep and pipes supplied by Oat. All requirements on the original P0 applied to the change notice. These two suppliers are on the Oat Active Qualified Suppliers List.
The inspectors reviewed Bill of Material (BOM) M-7949 for-the fabri-cation of 107 knockout canisters. This material was shipped from NES Manufacturing's facility in Greensboro, NC to Oat. The inspectors verified that the BOM had been prepared by Oat from the Bechtel purchase order, technical specification, and drawings.
TFe inspectors discussed the issue of Oat invoking 10 CFR Part 21 on Air-Oil Systems Incorporated with Oat staff. Purchase order 19515 indicated that the Hansen pipe fittings were to be modified and therefore 10 CFR Part 21 would be applicable since these commercial grade items were subject to' specification requirements unique to the canister application. However, Rev. 1 to P0 19515 deleted the requirement for modification of the part, and materials actually supplied to Oat were standard catalogue fittings. The modifications were subsequently made by Oat in accordance with the QA plan.
Unresolved Item 85-01-05 is considered closed as a result of the above discussions.
- 11. Lower Heads On January 6,1986, Joseph Oat received a letter from NES Manufacturing indicating that ten canister lower heads may have been sent to Oat without the required welding and NDE traceability, or contained catalytic recombiners that had been centaminated with liquid penetrant inspection materials. The letter identified the subject heads by NES ID numbers. Oat notified Bechtel of the potential defect l that same day. By January 9, 1986, Oat had completed a review of
- records and determined that four of the heads had been used in fabri-l cation, notified Bechtel, and requested further instruction on disposition of the matter. Oat also issued a deviation notice that would initiate action to prevent further use of any of the identified heads with potential defects.
l The inspectors reviewed the correspondence relating to this matter i and determined that Joseph Oat's actions were prompt, proper, and in j full conformance with the QAM.
l l
CRGANIZATION: JOSEPH 0AT CORPORAT10N CAMDEN, NEW JERSEY REPORT INSPECTION NO.- 99900251/86-01 RESULTS: PAGE 12 of 12 F. PERSONS CONTACTED:
Joseph Oat Corporation
- M. Holtz
- J. Benckert C. Leonard B. Badaili J. Boyer J. Muschek B. Hutchinson M. Madera R. Ewing Bechtel R. Emrich T. McKearney Hartford Steam Boiler A. Mcdonald GPU J. Campbell
- attended exit meeting 1
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