ML20215G996
| ML20215G996 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/1987 |
| From: | Cilimberg R, Stone J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20215G977 | List: |
| References | |
| REF-QA-99900383 NUDOCS 8704170363 | |
| Download: ML20215G996 (10) | |
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ORGANIZATION: NUCLEAR ASSURANCE CORPORATION NORCROSS, GEORGIA REPORT INSPECTION INSPECTION N0.: 99900383/87-01 DATE: 2/23-27/87 ON-SITE HOURS: 60 CORRESPONDENCE ADDRESS: Nuclear Assurance Corporation ATTH: Mr. P. E. Shutt President 5720 Peachtree Parkway Norcross, Georgia 30092 ORGANI7.ATIONAL CONTACT: G. N. Dixon TELEPHONE NUMnER- (404) 447-1144 NUCLEAR INDUSTRY ACTIVITY: Designer, supplier and owner of nuclear waste transportation casks.
f e ASSIGNED INSPECTOR: j -
M E7
- 1. L. Cilimberg, 55eci Projects Inspection Date Section (SPIS)
OTHER INSPECTOR (S): K. C. Leu, SPIS D. J. Lynn, Consultant APPROVED BY: - d. f/6[f7 James C4' Stone, Chief, SPIS, Vendor Program Branch 'Da'te/
INSPECTION BASES AND SCOPE:
/. BASES: 10 CFR Part 71.
SCOPE: Follow-up on an allegation concerning a pressure gage supplied by the Nuclear Assurance Corporation (NAC) for testing the 0-ring seals on the NAC-1E cask. Review implementation of the quality assurance (0A) program pertaining to testing of transportation casks for spent fuel.
PLANT SITE APPLICABILITY: All NAC casks are presently leased to the l'.S.
Department of Energy (DOE).
DO [khhj 87041o 99900383 ECNAC PDR
ORGAN 1ZATION: NUCLEAR ASSURANCE CORPORATION NORCROSS, GEORGIA REPORT INSPECTION
- 1n - QQ000101/97 01 PFSUITS- PAGF 2 nf 10 A. VIOLATIONS:
None.
B. NONCONFORMANCES:
- 1. Contrary to NRC Certificate of Compliance (C of C) Number 9183, Revision 4, dated July 30, 1986, and paragraph 71.125 of Subpart H of 10 CFR 71, " Control of measuring and test equipment," a pressure gage used to perform the 30 psig test on cask NAC-1E was not calibrated for use over the range 0 to 30 psig, and would not indicate pressures greater than 12 psig because the spring installed internal to the gage that resisted movement of the pointer above 10 psig was misadjusted and at 35 psig the gage indicated 12 psig.
(87-01-01)
- 2. Contrary to C of C 9183, Revision 4, the 30 psig pressure test of the 0-ring seals on the NAC-1E cask at Sandia failed the pressure drop requirement and following corrective action the test was not repeated before shipment. (87-01-02)
- 3. Contrary to C of C 9183, Revision 4, and Nuclear Fuel Services (NFS) drawings E 10080 sheets 1 through 4, Revision 21, the lid was welded to the NAC-1E cask because the 0-rina seals failed the 30
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psig pressure test. (87-01-03)
- 4. Contrary to Section 5.1 of NAC procedure 155, " Measuring Equipment Calibration and Records," Revision 4, dated March 1982, the location of hydrostatic test aage P-101) was listed on the Equipment CalibrationLog(ECL)asbei19intheNACofficebutthegagewas physically missing. (87-01-l14) i 5. Contrary to Section 5.5 of NAC 155, Revision 4, a dial indicator identified by serial number GT-41 was not listed on the ECL.
(87-01-05)
- 6. Contrary to Sections 9.3, 9.4, and 9.5 of NAC 155, Revision 4, the calibration of six microneters and three dial indicators was ont performed at 25, 50, 75, and 100% of full scale as specified.
l (87-01-06)
- 7. Contrary to Section 9.2 of NAC 155, Revision 4, the NRC inspectors did not find a Calibration Certification Report (CCR) from outside vendors performing calibrations which contained the required i
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ORGANIZATION: NUCLEAR ASSURANCE CORPORATION NORCROSS, GEORGIA REPORT
- INSPECTION MO -
4400nin?/R7-01 DFSUITS-PAGF 1 nf 10 information for the measuring or test equipment used for the calibration. (87-01-07) 8.
Contrary to C of C 9183, Revision 4, and Section 4.2.8 of NAC procedure 532, "NAC-1 Cask Annual Institute of Nuclear Energy Research (INER) Maintenance Procedure," Revision 1, dated July 1985, the 1986 annual maintenance (AM) reports for casks NAC-10, NAC-1C, NFS-4A, and NFS-4B contain no information as to whether or not the cavity relief valve tests were performed. (87-01-08) 9.
Contrary to Sections 2.0 and 6.14 of NAC 532, Revision 1, a 0-1000 ft-lb torque wrench was used to tighten the assembly nut for the 1986 AM of NAC-1A and IE casks. (87-01-09) 10.
Contrary to Section 4.2.2 of NAC 532, Revision 1, the serial numbers of the replacement cavity relief valves were not recorded on the 1986 AM reports for casks NAC 1A, IC, and 10 and NFS 4A and 4B and the 1987 AM report for cask NAC-1E.
(87-01-10) 11.
Contrary to Section 4.0 of the AM report form attached to NAC 532, Revision 1, torque wrench information was not provided on the 1986 AM reports for casks 4A, 48, ID, and IC. (87-01-11) 1 12.
Contrary to paragraph 1.7 of Section 18.1 of the NAC OA manual (QAM),
NAC did not perform an external audit at the Precision Instrument Company.
C. UNRESOLVED ITEMS:
None.
D.
STATUS OF PREVIOUS INSPE'CTION FINDINGS:
None.
OTHER FINDINGS OR COMMENTS:
- 1. Er, trance and Exit Meetinos n
NAC Management representatives were informed of the scope of the inspection during the entrance meeting. The inspection findings and Februa observaticns ry 27, 1987.were summarized during the exit meeting on L
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0RGANIZATION: NUCLEAR ASSURANCE CORPORATf0N NORCROSS, GEORGIA REPORT INSPECTION NO.- 000nn1P1/R7-01 RESULTS- pAGF 4 nf in
- 2. Backaround This inspection was conducted to follow-up on allegations made to the NRC concerning an alleged (ALGD) gage that was used to perform a pressure test on the NAC-1E cask at Sandia National Laboratories (Sandia) in New Mexico during July, 1986. Additionally, the inspection examined implementation of the NAC OA program in meeting the requirements of NRC C of C 9183, Revisicn 4, and the provisions of Subpart H of 10 CFR 71.
The nonconformances in Section B of this report were written against C of C 9183, Revision 4, which requires that the general license provisions of 10 CFR 71.12 apply to the NAC-1 casks. The Model NAC-1 shipping package includes NAC casks IA, IB, 1C, ID and IE and Nuclear Fuel Services (NFS) casks 4A and 4B. All casks are owned by NAC, leased to DOE and covered by NRC C of C 9183, Revision 4
- 3. Alleaation An allegation was received by NRC which stated that the testino of a cask at Sandia during 1986 was suspect because the ALGD gage that was used could not be calibrated for use in the range of 0 to 30 psig. It was further alleged that the ALGD gage does not indicate pressures above 10 psig because an " engineered stop" prevents the pointer from moving past the stop. The ALGD gage was not identified with a serial number or any marking that would inform a user that the ALGD gage would not indicate pressures greater than 10 psig.
On October 17, 1986, an investigation was initiated by NAC in response to allegations made to NAC concerning the ALGD gage. The NRC inspectors determined from information provided by NAC that the ALGD gage was manufactured by Marshalltown Instruments in Marshalltown, Iowa. The ALGD gage is a retard gage that was designed and manufactured to register pressures from 0 to 10 psig with high accuracy and from 10 to 30 psig with greatly reduced accuracy. Physical examination of the ALGD gage revealed that a l spring was installed internally when the gage was manufactured by l Marshalltown Instruments. The spring resists movement of the pointer on the ALGD gage between 10 and 30 psig.
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.. ORGANIZATION: NUCLEAR ASSURANCE CORPORATION l NORCROSS, GEORGIA 1 l
REPORT INSPECTION NO - 000nn1A1/A7 01 DF9HiTR- PACF F cf 10 The ALGD gage was not identified with a serial number or any marking other than the word " retard" on the face.
On March 24, 1987, an NRC inspector observed testing of the ALGD gage by the General Electric Company (GE), 2825 Pacific Drive -
Suite A, Norcross, Georgia 30071. GE applied pressures from 0 to 35 psig on the ALGD gage in the as found condition. The ALGD gage indicated a pressure of 12 psig when the applied pressure was 35 psig with a dead load pressure tester (DLPT). The pointer on the ALGD gage was offset below zero in the as found condition. When corrections to zero were made for the offset the ALGD gage indicated a pressure of 17 psig when the applied pressure was 35 psig with a DLPT. The pressure tests of the ALGD gage at GE provide data that indicates that the ALGD gage was not
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calibrated for use in the range 0 to 30 psig, and the spring installed internal to the gage resists movement of the pointer above 12 psig prior to the zero adjustment made at GE.
Based on the above information, this allegation is partially substantiated, and Nonconformance 87-01-01 was confirmed.
- 4. NAC-1E Cask-ALGD Gage NAC advised the NRC inspectors that the ALGD gage was selected from inventory at NAC, hand carried to the Precision Instrument Company for calibration, hand carried to Sandia, and exposed to a pressure of 35 psig in the test manifold on the NAC-1E cask at Sandia on July 22, leS6. The ALGD gage indicated 10 psig while a second gage supplied by Sandia indicated 35 psig. This information indicates that an improper gage was selected by NAC to perform the 30 psig pressure test required by C of C 9183, Revision 4. The ALGD gage was not identified with a serial number or other marking to indicate either acceptability or nonacceptability for use.
Nonconformance 87-01-01 was identified during this part of the inspection.
- 5. NAC-1E Cask-Pressure Test of Seals NAC advised the NRC inspectors that the NAC-1E cask seals were pressure tested at 30 psig using a Sandia gage after removing the ALGD gage. The pressure drop requirement of C of C 9183, Revision 4 was not achieved due to leakage of the 0-ring seals and following corrective action, the test was not repeated before shipment.
ORGANIZATION: NUCLEAR ASSURANCE CORPORATION NORCROSS, GEORGIA
'EPORT INSPECTION LO - opon0191/R7 01 R F<til TS - PAGF 6 of 10 Nonconformance 87-01-02 was identified during this part of the inspection.
- 6. NAC-1E Cask-Welded Lid NAC advised the NRC inspectors that the lid of the NAC-1E cask was welded by Sandia personnel because the 0-ring seals leaked during the 30 psig pressure test. The weld on the lid was liquid penetrant tested but no leak test was performed to determine if the weld would leak. This weld does not comply with C of C 9183, Revision 4.
Nonconformance 87-01-03 was identified during this part of the inspection.
- 7. Control of Measuring and Test Equipment The NRC inspectors reviewed the NAC QAM and NAC procedure 155, Revision 4, relative to the requirements of paragraph 71.125 of 10 CFR 71 as specified by C of C 9183, Revision 4. Review of the implementation of NAC 155, Revision 4, indicated the following nonconforming areas.
- a. A review of the ECL indicated that hydrostatic test gage P-1011 was located in the NAC facility at Norcross, Georgia.
A search of the NAC facility determined that gage P-1011 was physically missing.
Nanconformance 87-01-04 was identified during this part of the inspection.
- b. A physical check of measuring and test equipment at the NAC facility indicated that all of the eouipment was listed on the ECL except a dial indicator identified by serial number GT-41.
l Nonconformance 87-01-05 was identified during this part of the l
inspection,
- c. The actual calibration results for six micrometers and three dial indicators were compared to the 25, 50, 75, and 100% of full scale requirements of Sections 9.3, 9.4, and l
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ORGANIZATION: NUCLEAR ASSURANCE CORPORATION
. NORCROSS, GEORGIA REPORT INSPECTION MO - 00000197/97-01 RESULTS- PAGE 7 of 10 l
9.5 of NAC 155, Revision 4 The actual calibration records show that the instruments were not calibrated at the specified points.
Nonconformance 87-01-06 was identified during this part of the inspection.
- d. Six CCRs from outside vendors were reviewed to determine if the CCRs contained the identification of the equipment used for calibration as reouired by Section 9.2 of NAC 155, Revision
- 4. None of the CCRs listed the actual piece of measuring or test equipment used for the calibration, its identification number, noun nane or abbreviation, manufacturer, make, model and serial number, and last date of calibration as required by NAC 155. Revision 4.
Nonconformance 87-01-07 was identified during this part of the inspection.
- 8. Annual Maintenance of Casks The NRC inspectors reviewed NAC procedure 532, Revision 1, with respect to the requirements of C of C 9183, Revision 4. Review of the implementation of NAC 532, Revision 1, indicated the following nonconforming areas.
- a. The 1986 AM reports for casks NAC-1D, NAC-1C, NFS-4A, and NFS-4B contain no information as to whether or not the cavity relief valve tests were performed in accordance with Section 4.2.8 of NAC 532, Revision 1.
Nonconformance 87-01-08 was identified during this part of the inspection.
- b. The 1986 AM reports for NAC 1A and IE casks list the availability of a 0-1000 ft-lb torque wrench. The 0-1000 ft-lb torque wrench could not have been used to indicate the 10 ft-lb (+5,-0) torque on the assembly nut required by Section 6.14 of NAC 532, Revision 1, because the minimum graduation on the wrench was 20 ft-lbs.
Nonconformance 87-01-09 was identified during this part of the inspection.
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ORGAN 12ATION: NUCLEAR ASSURANCE CORPORAT10N
- NORCROSS, GEORGIA REPORT INSPECTION Mn - Qoonn'401/R7 01 DF9ftTS- PAGF A of 10
- c. Review of the 1986 AM reports for casks NAC 1A, IC and 10 and NFS 4A and 4B and the 1987 AM report for cask NAC 1E determined that the serial numbers of the replacement cavity relief valves were not recorded as required by Section 4.2.2 of NAC 532, Revision 1.
Nonconformance 87-01-10 was identified during this part of the inspection,
- d. Review of the 1986 AM for casks NAC-10 and 1C and NFS-4A and 4B determined that torque wrench information was not provided.
Nonconformance 87-01-11 was identified during this part of the inspection.
- 9. Audits
- a. DOE Ouality Assurance Audit of NAC The DOE Savannah River Operations Office has conducted a OA audit of NAC to assess the implementation of the NAC OA program for the Fuel Movement Project (FMP).
The first audit was performed during the week of August 5, 1985 which resulted in one noncompliance in the drawing
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control system and five observations. NAC's response dated September 24, 1985 committed to correct / revise the documents by October 11, 1985. DOE verified the implementation of corrective actions by NAC on January 16 and 17, 1986 and commented in the letter dated January 28, 1986, that the revision of procedures was issued on January 15, 1986 and not October 11, 1985 as committed. DOE also expressed concerns about the attitude NAC has towards implementing a OA program for work being performed for Savannah River.
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The second audit was conducted on September 23-26, 1986 of NAC Contract No. DE-AC09-84 SR 11042 to evaluate the inple-mentation of the requirements of DOE /SR order 5700.6B,
- " Quality Assurance." The audit identified four noncompliances and seven observations. Two of the noncompliances were l considered as significant in that the internal audit was not performed commonly and that the pressure gages used in activities affecting the quality of items were not properly l
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ORGANIZATION: NUCLEAR ASSURANCE CORPORATION NORCROSS, GEORGIA REPORT INSPECTION ,
Nn . 000001P1/97.01 QFRtHTR. P ArJ 0 nf 10 identified, controlled, calibrated and adjusted at a stated frequency. NAC's response dated October 31, 1986 provided corrective actions and implementation dates for each non-compliance and observation.
The third DOE audit was conducted on February 3,1987 to verify the implementation of the corrective actions contained in the NAC letter of October 31, 1986. NAC had not received the DOE response to the NAC corrective action as of February 27, 1987.
- b. External Audits The NRC inspectors obtained a NAC qualified vendor list which contained 29 qualified vendors to perform services such as manufacturing, machining, and non-destructive examination.
The NRC inspectors selected six vendors from the list for audit records review. One vendor (Excelco Development, Inc.)
was found to have its last audit done in 1977 while NAC still placed purchase orders with the vendor in 1978 and 1980.
Although Section 18.1 of the NAC OAM does not specify the fraquency for external audits, it does require that follow-up audits should be made on a continuing basis.
The NRC inspectors noticed that 11 vendors from the list were qualified based on past performance. While good performance in the past can be used as a reference, the OAM requires that systematic follow-up audits be performed. NAC external audit records were examined for compliance and implementation of the NAC OAM. The NRC inspectors selected the Precision Instrument Co. (PI) for review and found that PI was never audited by NAC. NAC stopped using PI en October 15, 1986. NAC purchased services from PI on purchase order (P0) 1956 for tool calibration, dated December 11, 1980, and P0 4303 for pressure gage calibration dated July 30, 1986. PO 4303 was alleged by NAC to be the PO used to purchase calibration service for the ALGD gage discussed in Sections 2, 3, and 4 above.
Nonconformance 87-01-12 was identified during this part of the inspection.
- c. Internal Audits NAC internal audit reports were examined for the years 1981-1986 to determine compliance with the NAC QAM. The audit
ORGANIZATION: NUCLEAR ASSURANCE CORPORATION NORCROSS, GEORGIA REPORT INSPECTION k!O - 4QQOn1R1/97 01 DFRI4TS- PAGF 10 nf 10 reports contained the review of the 18 point criteria in Subpart H of 10 CFR 71 against the NAC OAM, and a systen audit to verify the implementation of 0A procedures.
The scope, summary, findings /open items and recommendations of the audit report are in compliance with Section 5.3 of NAC OAM 18.1. However, the internal audit was not conducted in 1984 which i. contrary to the QAM requirement which states that internal audits shall be performed at least annually.
Internal audit report conclusions indicated that NAC emphasize the development and implementation of QA procedures. A noncon-formance was not identified for failure to conduct an internal audit in 1984 because it was reported in the DOE audit report discussed in Section 9 (a).
F. PERSONS CONTACTED:
L. Danese
- G. Dixon, Jr.
R. Ragsdale
- P. Schutt
- C, Thorup J. Viebrock
- D Webster
- Attended exit meeting.
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