ML20217D646
| ML20217D646 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 04/07/1998 |
| From: | Dawson D TRANSNUCLEAR, INC. |
| To: | Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20036E376 | List: |
| References | |
| 72-1004-97-209, DMD-98-023, DMD-98-23, NUDOCS 9804270007 | |
| Download: ML20217D646 (13) | |
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T ggg TRANSNUCLEAR, INC2 TN WEST DMD-98-023 April 7,1998 Dr. Susan Frant Shankman Acting Deputy Director Spent Fuel Project Oflice Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Response to NRC Inspection Report #72-1004/97-209
REFERENCE:
VECTRA Supplementary Response to the Demand for Information dated
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June 5,1997
Dear Dr. Shankman:
Transnuclear West Inc. (TN West) is providing its response to the NRC Inspection Report #72-1004/97-209. This letter provides the following information:
Response to the Inspection Repon #72-1004/97-209 Summary of the restan plan for limited fabrication e
Limited fabrication activities Request for concurrence to proceed with limited fabrication e
Response to Insocction Report
'IN West provides the attached response to NRC Inspection Report #72-1004/97-209. This response
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is provided in four parts as follows: -
Resolution of the four concerns identified in the Executive Summary of the
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Report, including a description of how TN West will support and improve its i
safety culture Completion of the five actions identified in the Executive Summary of the Report -
Presentation of TN West's Fabrication Restart Plan Completion of remaining corrective actions for the various corrective action items f
(CAI's) as identified in the NRC Inspection Report
]I. - Affidavit Pursuant to 10CFR2.790 TN West is committed to follow through with the actions identified in the DFI response as well as associated actions coming from the NRC inspection. In the referenced DFl response, TN West e
L committed to 44 corrective actions, a number of which were to be completed prior to restaning 1
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TRANSNUCLEAR WEST INC. e 6203 San Ignacio Ave., Suite 100 e San Jose, CA 95119 gd /94 Tot 408-629-9800 e Fax:408-281 4186
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TRANSNUCIEAR, INL TN WEST fabrication activities. He NRC inspection #72-1004/97-209 identified a number of corrective actions that wen incomplete and noted the need for further action in several cases.
f TN West has now completed the outstanding CAI generic corrective actions required to initiate limited fabrication activities. In QA Audit IPA-0043 (Enclosure 1),'IN West has confirmed satisfactory completion of these actions.
Actions required for individual projects are being completed during the prerequisite activities for each project. These corrective actions require project specific planning and documents and will be completed separately as each project approaches its limited fabrication restart. These activities are explained further in Attachment 3 of this response.
In each part of the response, TN West has included the appropriate analyses, procedures, training and other documents to demonstrate satisfactory completion of the actions taken. TN West has now implemented sufficient and effective generic corrective actions to warrant resumption oflimited fabrication activities. The generic corrective actions completed are:
Completed the generic actions associated with our corrective action program and those identified e
in the NRC insoection report.
Development of plans to complete all project specific actions prior to the lifting of the stop work order for fabrication on each project. The lifting of the stop work order for fabrication (for each
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project and each component) will occur after successful completion of the fabrication readiness 1.
reviews.
Upgrade and revision of many of our key quality assurance procedures, including the corrective i
action program, safety evaluation program, and design change program.
Upgrade of our quality control inspection and surveillance program.
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l Review of our past activities associated with corrective action, design control and license I
compliance.
Based on these efforts, TN West has demonstrated its ability to begin resumption of limited fabrication. The processes and culture are in place to provide a high degree of confidence in our j
ability to properly conduct our fabrication activities.
I Summary of Restart Plan The scope of the Restart Plan is the definition of the TN West process and actions to resume production and fabrication ofits general license NUllOMS@ system components. The Restart Plan will commence with TN West's response to NRC Inspection Report #72-1004/97-209. This I
resumption of fabrication will occur according to the plan provided in Attachment 3 of the response.
TN West's resumption of fabrication includes the lifting ofits stop work order on fabrication 2
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TRANSNUCLEAR WEST INC. e 6203 San Ignacio Ave., Suite 100 e San Jot.a. CA 95119 Tet 408429-9800 e Fax:408-201-6186
TRANCNUCLEAR, IN3.
TN WEST I
activities in a phased manner. The lifting of the stop work order will be performed in accordance with TN West Quality Procedure QP 2-6 and the associated " checklist for lifting the stop work order" developed for SWO-97-01.
The resumption of production and fabrication will be performed in two phases.
The first phase is a " limited fabriention" phase that covers a period over which TN West will complete a full run of fabrication activities for its general license dry shielded canister (DSC) component and its general license horizontal storage module (HSM) component and will conclude with issuance of CoC's.
This phase of operation allows TN West to return to its production mode of operation in a very controlled manner. The limited fabrication of general license NUllOMS@ system components will be performed with a phased restart of projects and will provide an opportunity for NRC inspection.
TN West will inform the NRC of scheduled activities to allow for inspection of specific activities as requested by the NRC. TN West will initiate several projects during the limited fabrication to allow I
for demonstrating the efTectiveness of the revised procedures and for incorporating lessons learned I
into these procedures. Upon successful completion of a full run of fabrication on the IISM's and DSC's, TN West will notify the NRC of readiness for resumption of full fabrication.
The majority of the Restart Plan deals with the TN West activities during this limited fabrication period.
The second phase of the restart is " full fabrication". This period of operation provides for TN West to resume its normal operation. TN West will have demonstrated its effective implementation ofits corrective actions in response to the NRC DFI during the limited fabrication period and will return to an operating mode with standard NRC oversight ofits activities.
Limited Fabrication Activities Limited fabrication (to be performed by project and by component) involves the following activities:
Completion of project specific activities related to fabrication e
Completion of a fabrication readiness review which includes both the supplier and the customer e
Lifting of the stop work order for the component fabrication e
Fabrication r,f the component (including fabrication activities, QA/QC surveillance and e
oversight, ated disposition of non-conformances, etc.)
Delivery and acceptance of the component (TN West component CoC) e The resumption oflimited fabrication will occur in two steps. First, the resumption oflimited fabrication applies for the NUllOMS@ horizontal storage modules (llSM's). Second, the resumption oflimited fabrication applies for the NUllOMS@ dry shielded canisters (DSC's) and will occur after completion of the re-verification of the DSC structural calculations.
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TRANSNUCLEAR WEST INC.
6203 San Ignacio Ave.. Suite 100 e San Jose. CA 95119 Tel:408429-9800 e Fax:408-281-6186
i TRAN2 NUCLEAR, INC2 TN WEST The limited fabrication phase for the 11SM's is currently planned to consist of the following sequence of projects as discussed in Attachment 3:
Completion of the PP&L Susquehanna llSM's and Toledo Edison Davis-Besse HSM's currently on hold at Bayshore Concrete Products.
Initiation and completion of additional HSM's for Duke Oconee Repair ofIISM's at GPUN Oyster Creek e
There will also be a planned fabrication ofilSM's for the pending site specific license for the DOE at INEEL utilizing the same processes and procedures that apply to the general license system. TN West expects to provide notification ofits intention to resume full fabrication for the llSM's at the completion of the first of these additional llSM's for Duke.
The limited fabrication phase for the DSC's will commence after completion of the DSC structural calculations and is currently planned to consist of the following sequence of projects as discussed in :
Repair of previou;ly fabricated and in-process DSC's (Duke Oconee, Toledo Edison Davis-e Besse and GPUN Oyster Creek)
Initiation and completion of DSC's for PP&L Susquehanna e
There will also be a planned fabrication of DSC's for the site specific licenses utilizing the same processes and procedures that apply to the general license system. TN West expects to provide notification ofits intention to resume full fabrication for the DSC's at the completion of the first DSC for PP&L.
Reauest for Concurrence At this time,1N West is providing notification to the NRC ofits readiness for limited fabrication of its NUHOMS@ 11SM components. A discussion of these activities is provided in Attachment 3. A summary of activities to be performed over the next two months is provided here for clarification.
The activities relative to limited fabrication of the HSM's are:
Completion of project specific activities for the PP&L HSM's Initiation of fabrication readiness review for PP&L e
Also, procurement and fabrication of HSM's and DSC's for the DOE INEEL pending site specific license project will be initiated. Relative to the DSC's, the structural calculations are scheduled to be completed for the standard 24P design by the end of April. This design is applicable to the repair of the Duke and Toledo Edison DSC's. TN West will notify the NRC ofits readiness for limited fabrication of DSC's at the completion of these calculations. The structural calculations for the 52B design that is applicable to PP&L and GPUN will be completed by the end of May. Activities relative to fabrication on that project will be initiated after completion of the 52B calculations.
4 TRANSNUCLEAR WEST INC.
6203 San Ignacio Ave., Suite 100 e San Jose, CA 95119 i
Tet 408429-9800 Fax: 408-281-6186
TRANZNUCLEAR, IN2Do TN WEST Additionally, there are several activities not related to the limited fabrication phase that TN West will initiate within the next month. These activities are defined here to provide for completeness of our activities in the near-term.
Procurement oflong lead time materials for DSC's Disassembly of DSC's requiring repair e
Preparation for re-assembly of repaired DSC's e
Inspection activities (CAI 43) for DSC's and 11SM's.
e These activities will be performed in accordance with the TN West Quality Procedures.
TN West requests NRC review of this response and concurrence that TN West is ready to resume limited fabrication. In the interim, TN West is proceeding with activities such as checklist preparation, drawing transmittals, etc. that are prerequisite to limited fabrication ofilSMs. TN West will not lift its Quality Assurance Fabrication Stop Work Order or conclude a fabrication readiness review until we receive your concurrence.
Please call either Mr. Walter Bak (408-281-6132) or me (408-281-6037) with any questions.
Sincerely, David M. Dawson President and Chief Operating Officer theket 72-1004 cc:
Mr. C. IIaughney (USNRC, SFPO)
Mr. T. Kobetz (USNRC, SFPO)
Mr. T. McGinty (USNRC, SFPO)
NU110MS @ Owners Group 5
TRANSNUCLEAR WEST INC. + 6203 San Ignacio Ave.. Suite 100 e San Jose. CA 95119 Tet 408-629-9800. Fax:408-281-6186
TRANSNUCLEAR, INC.
TN WEST TN WEST RESPONSE TO NRC INSPECTION REPORT #72-1004/97-209 Resolution of Four Concerns in Executive Summary NRC Inspection Report Response - Attachment 1 Page 1 of 7
CONCERN 1: SHORT-TERM PROCESS TO ASSESS, NURTURE & REINFORCE NEW SAFETY CULTURE Establishing and maintaining a strong safety culture is a long-term evolutionary process that typically requires years, not months, to achieve. It involves a number ofinterrelated tasks that when properly implemented will collectively produce the desired safety culture performance. As a result, evaluating the effectiveness of a new safety culture can only be accomplished by periodic evaluation of the overall results of the collective tasks (i.e., by a measurement of the actual safety culture itself). The short-term effectiveness in implementing an individual task is measured by whether the task itself has been completed (i.e., is the organization sufficiently committed to the new safety culture such that it follows through on its commitments). Corrective action task CAI #36 involves the nurturing and reinforcement of safety culture concepts. That CAI requires TN West to establish a self-assessment program (refer to of this response). This self-assessment program involves management assessment of specific work processes along with a mentoring and coaching of the associated TN West personnel. On a daily basis, TN West management reinforces the safety culture concepts through its routine discussions with employees and its setting of work priorities.
In the referenced DFI response, a number of the corrective actions (CAls) related to establishing and maintaining a strong safety culture. For each of these CAls a monitoring system was identified which involved the long-term evaluation by one or more of the following:
Periodic Safety Culture Index survey to measure key leading indicators Evaluation of specific parameters captured by an event (corrective action) reporting system, with e
the input data being employee prepared corrective action and nonconformance report and findings from QA audits /surveillances Periodic Common Cause Assessment to evaluate the company's progress towards reducing repetitive events The initial Safety Culture Index survey was conducted in May 1997 and the next is planned for the 2nd quarter of 1998. Development and implementation of the event reporting system is proceeding as planned and is discussed in detail in the response to CAls 32,33 and 34 provided in Attachment 4 of this response. The initial Common Cause Assessment was conducted in the 1st quarter of1997 and the next is planned for the 4th uarter of 1998.
q TN West has accepted and is committed to completing the CAI corrective actions defined in the referenced DFI response. More specifically, the CAI corrective actions related to establishing and maintaining a strong safety culture are being completed as planned. Refer to the attached Safety Culture Plan (Enclosure 2) for a further discussion of these CAls. In addition, those corrective actions requiring completion prior to initiating limited fabrication activities have been completed as discussed in of this response.
TN West is implementing the original cal corrective action commitments, including the systems and processes for evaluating the effectiveness of the new safety culture. As such, this demonstrates that TN West is matching issues with appropriate procedures, programs and actions. TN West considers these actions adequate to monitor the implementation ofits safety culture and no further actions are believed necessary at this time.
I NRC Inspection Report Response-Attachment i Page 2 of 7
CONCERN 2: ASSESS EFFECTIVENESS OF TRAINING ON SAFETY CULTURE IMPROVEMENT & ilUMAN ERROR REDUCTION As stated in the response to Concern 1, establishing and maintaining a strong safety culture is a long-term evolutionary process that typically requires years, not months, to achieve. Further, it involves a number ofinterrelated tasks such as training that when properly implemented will collectively produce the desired safety culture performance. The short-term contribution of a single training program to the overall effectiveness of a new safety culture cannot be accurately measured, nor would any results necessarily be indicative of the long-term performance of the safety culture.
The process for monitoring the effectiveness of the new TN West safety culture is provided in the response to Concern 1. The specific corrective action involving human error reduction training (described in cal #30 of the referenced DFI response) includes a long-term monitoring system that states " Deficiencies identified by all employees will be ee"gred in the events reporting system to capture them for evaluation and trending so that corrective actSn aan be taken to reduce the recurrence of events." In addition, the attached Safety Culture Plan describes how the various TN West corrective actions, including human error reduction training, contribute to the overall performance of the TN West safety culture. of this response (CAI #30) discusses the actual training itself. The various training sessions, regardless oflength, have covered the same information and utilized the same materials as the original training. The employees who had not previously received this training have now completed same. In addition, training for new employees and vendors and periodic refresher training is discussed in. TN West is implementing the original CAI #30 corrective action commitment, including the associated monitoring system, as originally committed. TN West considers these actions adequate for this training subject and no further actions are believed necessary at this time.
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NRC Inspection Report Response - Attachment 1 Page 3 of 7
CONCERN 3: DSC DESIGN CALCULATION RE-VERIFICATION The DSC calculation re-verification effort is a corrective action associated with TN West Corrective Action Report CAR.97.063. This calculation re-verification effort is being performed to address discrepancies identified in the structural calculation of the DSC by several independent reviews of the general license NUHOMS@ design calculations to address potential license compliance issues with the DSC designs. While evaluations have determined that there is no safety impact for the discrepancies identified, the calculations are being re-verified to ensure compliance of the NUHOMS@ DSC with the license basis. These calculations are currently underway. This discussion provides the direction and
. status of the DSC calculation re-verification efforts.
Scope of Evaluation TN West is performing a complete set of structural analysis calculations for the DSC to verify license compliance. The first step is the preparation of a design document to identify and define all requirements of the general license relative to design of the DSC. The design document provides the material propenies, loading conditions, design criteria, and methods of analysis for use in the evaluation of each DSC. The second step is the structural evaluation of the DSC. There are three sets of calculations:
Long cavity PWR DSC (long cavity 24P) e Each calculation set consists of two calculation packages. The first calculation package is the shell evaluation of the particular DSC and includes the analysis of the shell, cover plates, shield plugs, lugs, and support rings. The second calculation package is the basket assembly evaluation and includes the analysis of the support rods, spacer discs, guidesleeves (for PWR systems), poison sheets (for BWR systems), and attachment welds or assemblies for the various components.
The next step in the re-verification is the preparation of safety evaluations under Condition 9 of the license to demonstrate that the DSC's are compliant with the license. There will be one Condition 9 safety evaluation performed for each DSC type (standard PWR, standard BWR, and long cavity PWR).
These re-verification calculations and SEs will form the design and licensing basis of the NUHOMS@
system.
Direction of Re-verification Effort The strategy for the revised DSC calculations is to document acceptable stress, and if stresses exceed allowables, identify design changes that satisfy the criteria and methodologies in the current license basis as defined by the Certificate of Compliance (CofC), Safety Evaluation Report (SER), and the Certified Safety Analysis Report (CSAR). The design changes will be defined such that they can be incorporated through the Condition 9 process of the CoC. The design changes are also defined to provide when possible for additional reduction in calculated stresses.
The above direction applies to the fabrication of future general license DSC's. Strategies are also being developed for the existed loaded DSC's and those that are in various stages of fabrication. These NRC Inspection Report Response-Attachment 1 Page 4 of 7
strategies are being defined to address license compliance with these components. The safety of these components has been demonstrated through prior review and evaluation associated with CAR.97.063.
Status of Calculation Re-verification The status of the calculation re-verification effort is that all analysis are proceeding with a phased completion of the various DSC designs. The current schedule for submittal of the DSC calculations packages to the NRC is:
Standard 24P DSC --- May 1,1998 Standard 52B DSC --- June 1,1998 e
Long Cavity 24P DSC --- June 1,1998 e
l NRC Inspection Report Response - Attachment 1 Page 5 of 7 l
l CONCERN 4: INDEPENDENCE OF THE QUALITY ASSURANCE ORGANIZATION FROM TIIE TN WEST LINE MANAGEMENT in its report, the NRC raised a concern regarding independence of the TN West Quality Assurance organization from the line organization. This concern was identined in several sections of the report dealing with inspection of the following corrective actions:
CAI #16, Establish audit schedule to baseline TN West internal performance, including inspection / surveillance CAI #18, Establish Corrective Action Review committee chaired by QAM to review & approve e
CAR & AFR corrective actions CAI #22, Update Readiness Review checklist e
CAI #24, Establish Safety Review Committee for SRS/SE proetss - revise procedure TN West has evaluated this concern and taken the following actions to eliminate any question regarding independence of the TN West QA organization:
Revised procedure QPFS 3-63 (now QP 3-12) to remove the QA Manager from the Safety Review Committee. Refer to CAI #24 in Attachment 4 of this response.
Revised procedure QP 16-1 to clarify the CAR Committee's responsibilities and timing ofits activities. Refer to CAI #18 in Attachment 4 of this response.
Revised QPFS 7-1.1 (now QP 7-4) to delete the requirement for QA Manager Gnal approval of the Fabrication Readiness Review Checklist. Refer to CAI #22 in Attachment 4 of this l
response.
Revised QP 2-8 to replace the DCQA audit of the QA Program with a requirement that the QA Manager arrange for such audits and to provide a reference to procedure QP 18-2. Refer to CAI
- 22 in Attachment 4 of this response.
Revised procedure QP 18-2 to require the use of an independent organization to perform the Management QA audit (i.e., independent of the QA organization). Refer to CAI #16 in of this response.
Contracted with an independent organization to perform the Management QA audit which l
included an audit of the TN West QA organization's activities. Refer to CAI #16 in Attachment 4 of this response.
Completed the Management QA audit as scheduled. Refer to CAI #18 in Attachment 4 of this l
l response.
In the Management QA audit report, the audit team concluded there is not a concern regarding l
independence of the QA organization. The report stated:
i "Having the QA function report to the senior manager in charge of the Fuel Services operation, whether as President of VECTRA or a TN VP, appears to be appropriate for the size of the company.
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In addition, the QA organization (both past and planned) is such that the audit functions independent from the QA organizations involved in procurement, software, design, document reviews, etc., so that independence should not be compromised. Since the DCQA position and, therefore, the DCQA audits, have been eliminated there is an appearance that the Manager QA is auditing the performance of the QA organization and thus himself. However, this organizational arrangement is not unusual in smaller companies and with a separate organization with the QA organization responsible for audits, NRC Inspection Report Response - Attachment 1 Page 6 of 7
this should not be a problem. Further, both the Q/ si and QPs require that auditors have no direct involvement in the areas they are auditing. These controls are considered to be sufficient to maintain independence. During review of the internal audits (see the Audits Section of this report) no independence problems were noted."
TN West agrees with this conclusion in the Management QA audit. Although there may have been the appearance of a lack ofindependence between the QA organization and line organization, there was never any intent that the QA organization be influenced by the cost and schedule concerns of TN West.
Together with the actions described above, TN West believes there should be no further concern regarding QA independence.
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NRC Inspection Report Response - Attachment 1 Page 7 of 7
h TRANSNUCLEAR, INC.
TN WEST TN WEST RESPONSE TO NRC INSPECTION REPORT #72-1004/97-209 i
i Completion of Five Actions Identified in Executive Summary i
NRC 1nspection Plan Response - Attachment 2 Page1of2
COMPLETION OF 5 ACTIONS IDENTIFIED IN EXECUTIVE
SUMMARY
In the Inspection Report on page v of the Executive Summary, the NRC identified 5 actions to be evaluated prior to resuming any fabrication activities. All of these actions have been addressed in this response and the following provides the location for that information:
- 1. Completion of the root cause procedure and subsequent training of affected staff.
Refer to the response to CAI #s32, 33 and 34 in Attachment 4for the root cause procedure (guideline) and CAI #31 in Attachment 4for training ofthe staff 2.
Revision of the procedure governing corrective actions to clearly prohibit verbal approval to implement corrective actions.
Refer to the response to CAI #15 in Attachment 4for theseprocedure revisions.
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3.
Development of a milestone schedule for interim and long-term corrective actions.
Refer to Attachment 4for CAI Corrective Action Completion.
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4.
Completion of the validation of fabrication checklists. Refer to CAI #19, CAI #22, and CAI #43 ofAttachment 4for the discussion ofinspection/ surveillance checklists Fabrication Readiness Review checklists, and HSM/DSC reinspection checklists, respectively.
- 5. Completion of the position description for the Quality Assurance Manager.
Refer to the response to CAL #35 in Attachment 4for the revisedposition description.
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NRC Inspection Plan Response - Attachment 2 Page 2 of 2
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