ML20217L880

Insp Rept 99900541/97-01 on 970429-0502,0707-18 Re Tritium Target Qualification Program.No Violations Noted.Major Areas Inspected:Review of Implementation of Selected Protions of PNNL QAP

ML20217L880
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Issue date:	08/14/1997
From:	NRC (Affiliation Not Assigned)
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ML20217L866	List: ML20217L860 ML20217L880
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PROJECT-697, REF-QA-99900541 NUDOCS 9708190167
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION-Report No:-

99900541/97 01 Project 697 Organization:'

Pacific Northwest National Laboratory Richland, Washington

Contact:

Jerry Ethridge, Project Manager Tritium Target Qualification Project (509) 372 4991 Nuclear Activity:

Fabrication of the Tritium Producing Burnable Absorber Rods for the Tritium Target Qualification Project, Lead -

Test Assemblies Dates:-

April 29 - May 2,'1997 July 711,1997 July 1418,1997 Inspectors:

Steven M. Matthews, Team Leader, VIS/PSIB/ DISP Robert M. Latta Kenneth C. Heck Approved by:

Gregory C. Cwalina, Chief Vendor inspection Section Special Inspection Branch Division of Inspection and Support Programs Robert A. Gramm, Chief Quality Assurance Section Quality Assurance and Maintenance Branch

-Division'of Reactor Controls and Human Factors 9708190167 970814 PDR OA999 EXIBMNL 99900541 PDR.

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1 INSPECTION

SUMMARY

During this inspection, the inspectors reviewed the implementation of selected portions of Pacific Northwest National Laboratory's (PNNL's) quality assurance (OA) program for supplying Tritium Producing Burnable i

Absorber Rodc (TPBARs) for the Tritium Target Qualification Project (TTOP),

- Lead Test Assemblies (LTAs). The inspection was focused on the review of PNNL activities related to the design and manufacture of the TPBARs for their subsequent use in Westinghouse designed burnable poison rod assemblies (BPRAs).

The inspection bases were:

Appendix A, "Goneral Design Criteria for Nuclear Power Ploots,"

General Design Criteria (GDC) 10, " Reactor Design," and GDC 12,

" Suppression of Reactor Power Oscillations," to Part 50 of Title 10 of the Code of FederalRegulations (10 CFR Part 50)

Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 10 CFR Part 21, " Reporting of Defects and Noncompliance" Tennessee Valley Authority (TVA) Nuclear Quality Assurance (NOA)

Plan (TVA-NOA-PLN89-A), Revision 6, dated August 31,1995.

PNNL's TTOP, " Quality Assurance Plan," ETD 003, Revision 4, dated July 1997 During this inspection, several nonconformances to NRC requirements were identified. However, PNNL's corrective actions, taken prior to the end of the inspection, resulted in the team closing the nonconformancec. No issues remain open at the time of this writing.

2 STATUS OF PREVIOUS INSPECTION FINDINGS This was the first NRC inspection of PNNL activities related to the TPBARs.

.3 FINDINGS FROM THIS INSPECTION 3.1 QualityProgram During the weeks of April 29 through May 2,1997, and July 7 through 11, 2

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1997, the team evaluated the acceptability.of.the QA provisions established to control the design and fabrication of the TPBAR LTAs. This evaluation -

involved the review of TTOP project documents that described the quality -

and technical requirements imposed on PNNL by the host utility (TVA) for these safety related compoaents. - The team also examined the adequacy

- i and implementation of PNNL's quality assurance plan described in EDT-003,

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" Tritium Target Qualification Project, Quality Assurance Plan," Revision'3, l

dated July 1997. Sections 3.1.1 through 3.1.6 provide the team's assessment of controls consistent with TPBAR component safety-classification; QA program adequacy; and QA program implementation in the areas of audits, corrective actions, training, and design control.

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- 3.1.1 Safety _ Classification i

On December 4,1996, the Department of Energy (DOE) submitted for the staff's preliminary review PNNL topical report " Topical Report on the Evaluation of Tritium Producing Burnable Absorber Rod Lead Test Assembly" (PNNL-11419/UC 731), dated November 1996. The purpose of r

this report was to provide technicalinformation related to the anticipated irradiation of TPBARs in a commerciallight water reactor, in particular, the report provided a description of the TPBAR design and fabrication requirements, as well as general quality provisions and an evaluation of the safety issues associated with the irradiation of these assemblies in a commercial light water reactor.

Based on NRC's review of the report, a request for additionalinformation (RAl) was forwarded to DOE on' January 3,1997. DOE responses to the g

RAI were provided in letters dated January 21 and February 14,1997. Both responses asserted that the TPBARs did not perform a safety-related function and were, therefore, considered to be non safety related. The I

topical report, however, indicated that PNNL would " voluntarily" comply with 10 CFR Part 21 provisions and would apply the PNNL QA program to those items which were considered to meet the requirements of 10 CFR 50,

' Appendix B. By letter dated February 13,199_7, the staff conveyed to DOE lts position that the TPBARs were part of a basic component and that, as such, were subject to compliance with the provisions of 10 CFR Part 21 and the quality assurance requirements of 10 CFR Part 50, Appendix B.

l.

In response to the staff's position regarding the safety classification of the TPBARs, PNNL forwarded a revised response to the staff's RAI on March 7,

- 1997, acknowledging that the design and fabrication of TPBARs would_ be-accomplished under.a quality assurance program that complies with the requirements of 10 CFR 50, Appendix B. However, the initial inspection of 3-t

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PNNL, conducted from April 29 through May 2,1997, found no apparent connection between the safety classifications described in TVA's Nuclear Quality Assurance Plan, TVA NOA PLN89 A, and PNNLs "importance factors" described in procedure TTOP 1-046, Revision O.

Subsequent to a June 4,1997, public meeting between the NRC and TVA, the staff provided further amplification on the specific safety function of the TPBARs in a letter to Mr. O.D. Kingsley (TVA) from Mr. F.J. Hebdon dated, June 14,1997. This letter underscored the NRC's position that the fuel and control rod assemblies were required to be considered basic components subject to 10 CFR Part 21 that, by definition, were required to be designed and manufactured under a quality assurance program that complied with the requirements of 10 CFR Part 50, Appendix B, and that parts thereof (e.g.,

burnable pc' son rods and TPBARs) were regarded similarly because of their safety function. The letter further stated that the NRC has always considered burnable poison rods in their entirety to be safety related and that, as such, this position includes the TPBARs in their entirety (end plugs, getter, cladding, plenum spring, etc.),

a. Inspection. Scope Tc evaluate the acceptability of PNNL's safety classification process for TPBAR components, the team reviewed PNNL's controlling procedure TTOP 1-046," Tritium Target Qualification Project, TPBAR Component Characteristics and Related importance Factors," Revision 3, dated July,1997. The following paragraphs summarize the results of this review,

b. Observations _and_ Findings As determined by the team, procedure TTOP-1046, Revision 3 had been revised to comply with the NRC's position that the TPBAR components were safety-related; TPBAR components were listed with corresponding safety functions, and controlling critical characteristics. Specifically, the TPBAR critical characteristics were defined as those important design, material and performance characteristics necessary to provide reasonable assurance that the item will perform its intended safety function. Table 1 of TTOP-1-046 designates those TPBAR components and critical characteristics, as either Category A or B.

As defined in TTOP-1-046, Category A characteristics are those that could affect the ability of the lead test assembles (LTAs) to perform their safety function of maintaining the core in a safe condition. Category B 4

characteristics are defined as those that could (1) significantly affect the mechanical integrity of the TPBAR, or (2) result in incremental tritium releases and either onsite or offsite doses, or (3) result in localized core power peaking. During the review of TTOP 1-046, the team noted that the designated inspection criteria for Category A and B components appeared to be consistent with their relative importance to safety,

c. Conclusion

Based on subsequent reviews related to this area, the team determined that procedure TTOP 1046 provided an adequate basis for controlling the design, procurement, fabrication, assembly and handling of the TPBAR LTAs and that appropriate provisions for the component safety classification had been implemented.

3.1.2 Quality _ Assurance. Plan PNNL's project quality assurance program is described in procedure ETD-003, " Tritium Target OuNification Project, Quality Assurance Plan,"

Revision 3. This TTOP project QA plan encompasses all quality activities related to the TPBARs, including design, procurement, process development, fabrication, inspection, testing, verification and assessment,

a. Inspection _ Scope The team ovaluatM the adequacy of PNNL's quality assurance program with respect Appendix t u.

O CFR Part 50 requirements, b.

Observations _and_Eindings NRC Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)," Revision 3, dated August,1985 conditionally endorses ANSl/ASME NOA 1-1983 Edition, " Quality Assurance Program Requirements for Nuclear Facilities," as an adequate basis for complying with the quality assurance requirements of Appendix B to 10 CFR 50. The additional conditions that are imposed by the Reg Guide 1.28, Revision 3, involve qualification of inspection and test personnel, quality assurance-records, and audits.

The team reviewed procedure ETD-003, which is based on ANSI /ASME NOA-1-1989, and the referenced documents which implement the TTOP project QA program. The team also examined PNNL's OA procedures with respect to the conditions imposed by Reg Guide 1.28. Additionally, the team performed a comparison of the programmatic requirements contained in ANSI /ASME NOA 1-1983 versus those of ANSI /ASME NOA-1-1989 in order to determine if PNNL's quality assurance program appropriately addressed the Regulatory Positions contained in Reg Guide 1.28.

c. Conclusions Based on the team's review of ETD 003, Rev 3, and the implementing QA program procedures, it was determined that PNNL's TTOP project QA program adequately addressed the requirements of 10 CFR Part 21 and Appendix B of 10 CFR Part 50.

3.1.3 InternaLAudiLProgram

a. inspection Scope The team reviewed selected internal assessments and surveillances of PNNL activities controlled by the quality assurance program,

b. Observations and_Eindings Criterion XVill, " Audits," of Appendix B to 10 CFR 50 requires that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the g agram. Contrary to this requirement, the team determined that not all aspects of the quality assurance program had been audited. Although, this deficiency had been previously identified during an internal PNNL assessment conoucted in May 1996, the team concluded that adequate corrective actions had not been implemented in F

that internal audits had not been performed during fiscal year 1997 and 7

none had been scheduled until after project completion.

Subsequent to the team's identification of this issue, PNNL promptly initiated corrective action report (CAR) 97.-010. This CAR addressed this deficiency and, as documented by CAR 97-010, PNNL attributed the root cause to its reliance on internal assessments, surveillances, and on external audits conducted by Westinghouse and TVA to sufficiently evaluate QA program elements.

The team reviewed PNNL's corrective actions taken to resolve this deficiency and to prevent recurrence. This review included evaluating the following documents. _ _ _ _ _ _ _ _ _ _

(1)

Section 18 " Audits" of the QA Plan (ETD-003) has been reviaed (Revision 4, July 1997) to include:

Management participation in audit scheduling, review of audit findings, and corrective actions taken to resolve them, f

Responsibility for scheduling annual audits and assuring that they are performed and reported to management has been assigned to the project lead quality engineer.

(2)

Internal audit procedure TTOP-7 048 has been issued which describes the planning, scheduling, preparing, performing, and reporting of internal audits. The method for reporting audit identified deficiencies, follow up action, and re-audit of deficient areas is also described in this procedure.

(3)

A fiscal year annual audit schedule has been issued, which assures that all aspects of the quality assurance program are audited.

Additionally, audits of all activities, with the exception of Organization (Criterion I), OA Records (Criterion XVil), and Audits (Criterion XVill) will be conducted prior to shipment of the TPBARs to the Watts Bar nuclear plant. Audits of the three excepted areas are scheduled for August 1997.

(4)

An annual audit schedule for fiscal year 1998 has also been issued.

(5)

An evaluation of the impact which the lack of formal audits may have had on the project has been performed. As determined by the team, this evaluation takes into consideration the conduct of internal assessments, surveillances, and external audits performed in fiscal year 1997. The evaluation concluded that there were no direct adverse impacts on the project as a result of not having performed internal audits because the subject areas had been alternatively 4

evaluated.

c. Conclusions Based on review of the above documentation, the team concluded that

. appropriate corrective actions had been implemented in response to this nonconformance. The team, therefore, closed this nonconformance.._.

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= 3.1.4 CorrectiveAction. Program -

a. InspecNon. Scope -

In order to evaluate the adequacy of PNNL's corrective action program, the team reviewed the status of actions taken to correct identified deficiencies, in particular, the team examined deficiencies that had been identified during an internal assessment conducted on May 1-9, 1996, deficiencies identified by an external audit conducted by Westinghouse on November 18 21, 1996, with a follow up audit conducted on June 2-5,1997, and other deficiencies identified by an external audit conducted by TVA on March 24-27,1997.

L. Observations and.Ending.s The internal assessment report dated May 14,1996, indicated that PNNL's corrective action programs were not being used because the tracking system employed by the QA department was cumbersome.

The Westinghouse audit conducted in November 1996 found that identified problems were being tracked by a TTOP project specific action tracking system, but that the tracking system was not described by the QA program.

Additionally, the Westinghouse follow up audit determined that the corrective actions taken in response to this audit finding had not been i

effective.

The TVA audit which was performed in March 1997 also found that the corrective action program was not being effectively implemented.

Nonconformance reports and deviation reports were not being used.

Consequently, trending, root cause, and extent of condition evaluations were not being performed.

The team reviewed the actions that had been taken to correct the identified conditions and to implement an effectUe corrective action program. As a result of this review, it was determined that the following project procedures had been issued:

TTOP-7-045, " Corrective Procedure," Revision 0, dated July 1997.

TTOP-7-037, " Corrective Action Processing Procedure for Deficiency Reports and Corrective Action Reports for the Tritium Target Qualification Project," Revision 2, dated July 1997, 4

TTOP 7 040, "Nonconformance Reports" Revision 0, dated May 1997.

The team reviewed a recently developed TTOP project corrective action tracking system printout. Based on the review of this printout the team found that the actions responsive to TVA's audit finding on the corrective action program were being tracked under item number CAR 97 OO1.

However, the status of TVA audit findings at the time of the inspection remained open, pending verification activities by TVA, as documented in a letter from the TVA Project Manager to the TTOP Project Manager, dated July 3,1997.

The team reviewed the corrective actions procedures identified above, which had been revised or issued after the TVA audit. These procedures were determined to contain appropriate requirements, such as provisions for trending, root cause determination and extent of condition evaluation. The team also determined that the procedures prescribed appropriate requirements and responsibilities for identifying, documenting, tracking, evaluating and correcting deviations from established quality assurance requirements and program controls.

Additionally, the team reviewed the corrective action tracking status report and determined that deficiencies were being reported for all active project tasks, including material suppliers, design, and fabrication, Based on an examination of the issue dates for reported deficiencies, the team concluded that organizations performing active project tasks were using the system effectively,

c. Conclusions Based on evaluation of the TTOP corrective action program, the team determined that it was generally acceptable. However, the team noted that PNNL was not taking full advantage of the trending program, since a trend analysis had not been perforrned.

3.1.5 Training

a. inspection.. Scope in order to determine the adequacy of the TTOP training program, the team reviewed the governing procedure TTOP 7-011, " Training and Qualification Plan for the TTOP-7-011 Project," Revision 1, dated February 1997...

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Additionally, the team reviewed a surveillance corSducted on training for _

I fabrication personnel and examined selected training records,

-- b. - Observations.and_Eindings A Westinghouse audit conducted in November 1996 reported weaknesses in-

-maintaining training records for project personnel. To strengthen this area,.

responsibility' for training had been transferred to the TTOP project office, t

To verify the accessibility and retrievability of training records, the team requested the training records following issuance of TPOP 7-037 on June 25,1997 --The project office provided a listing of personnel and dates on which training had been completed. Based on a comparison of this list with a listing of TTOP personnel for June 1:'97, the team determined. hat training records were being adequately maintained.

The team examined surveillance report SR 2 05, which reviewed the training requirements for personnelin the fabrication facility. The surveillance report found that fabrication personnel had met all training requirements and were j

qua_lified to perform __ associated fabrication activities. The team also noted, during their inspection of the fabrication facility, that a matrix of training requirements and the current training status for fabrication personnel was posted prominently at the entrance.

c. Conclusion

Team inspection results confirmed that fabrication personnel satisfied the training requirements for job performance and that appropriate training records were maintained and retrievable, i

3.1.6 Task _L_ Design e

a. Inspection _ Scope in order to confirm the adequacy of methods used by PNNL, TVA, and

- Westinghouse to exchange design information, the team reviewed current

' Design interface Agreements, which were determined to appropriately designate single points of contacts for information used to transmit and develop formal design outputs.

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b. Observations anc. Findings The team reviewed the design verification process with the Task 1 Manager and'a TVA project representative, Additionally, the team examined pertinent audits and assessments of design activities that had been conducted internally _ by PNNL (#97 01) and externally by Westinghouse and i

TVA.- These audit and assessment reports were reviewed for content-relative to specific findings and to determine the adequacy of the corrective actions related to design activities.-

_ Task 1 procedures reviewed included:

h TTOP 1017. " Design Analysis / Calculation and Associated

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Independent Review", Revision 1, dated June 1997 TTOP 1019, " Design Change Control", Revision 0,- dated January i

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TTOP-1021, " Design Interface Controls Process", Revision 1, dated June 1997 1:

TTOP 1-022, " Design Requirements", Revision 1, dated June 1997 l

TTOP 1058, " Design _ Change impacts on Technical and Functional Requirements", Revision 0, dated March 1997 PNNL TTOP 1580, " Functional Requirements for the TPBAR",

Revision 2, dated June 1997 The team also examined TVA's letter to PNNL concerning, " Verification of TVA Plant Specific Design Information," dated May 27,1997, and TVA's letter to PNNL concerning, " Westinghouse Changes from Cycle 2 Analysis,"

dated June 19,1997.

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- Additionally, the team reviewed selected calculations related to the design-and procurement of TPBAR LTA components, associated with the TPBAR i

cladding and end plugs in order to confirm the appropriate implementation of design control processes, The team' interviewed representatives from PNNL's Task 1 design organization in order to gain insights into the TPBAR design verification -

process. As a result of these ' discussions, it was ascertained that all PNNL j

- design _ inputs and engineering documents have been reviewed _for app _roval l e

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by a Design Review Board (DRB) consisting of representatives from PNNL, TVA, and Westinghouse The DRB review process, which was completed at the time of the inspection, concluded that an adequate design basis had been established for the TPBAR LTAs to be installed in the Cycle 2 core of the Watts Bar Unit 1 nuclear plant.

As determined from interviews, a ~ design report was being prepared and was scnedu!ad to.be reviewed for adequacy by a design review team prior to the Cycle 2 reload Subsequent to the approval of the design report, any future changes will be reviewed for adequacy and impact on the safety and operation of the Cycle 2 core by TVA.

The team reviewed the current status of the observations and findings that resulted fro n internal assessments and external audits of the design control program. As determined by the team, all corrective actions had been appropriately tracked and no significant design related corrective actions remained open.

The team examined eleven calculation files selected from a list of 4

engineering calculations related to the design and fabrication of TPBAR cladding and end plugs. As a result of this review effort, it was determined that all design input information had been properly verified and the team did not identify any deviations from either the administrative design requirements or the technical / functional requirements.

c. Conclusions Based on the team's reviews of design control documents, audits and assessments, and interviews with engineering management personnel, it was determined that an adequate design control process had been established for the design of the TPBAR LTAs.

3.2 Procurement _ Activities

a. -inspection. Scope

The team evaluated ' procurement activities for selected critical component parts of the TPBAR lead test assemblies (LTAs) to determine whether applicable regulations were imposed, material specifications were met, and

-procedures followed.,

b. Observations _and_Eindings PNNL's procurement process is defined in Section 4.0, " Procurement," of its Commercial Light Water Reactor (CLWR), Tritium Target Qualification Project (TTOP), Quality Assurance (QA) Plan, documented in ETD 003. To

- evaluate the acceptability of a component part, the team used PNNL's critical characteristics as defined in procedure TTOP-1-046, Revision 3.

In order to evaluate the procurement activities, the team reviewed PNNL's acquisition of the stainless steel material for the TPBAR cladding tubes and end plugs, and the Lithium Aluminate (LIAIO,) pellets. The following paragraphs summarize the results of this review.

b.1 316 Stainless Steel Material PNNL procured the stainless steel bar stock material from Westinghouse Hanford, that had originally procured the material for use in DOE's Fast Flux Test Facility (FFTF). The material was procured to material specification TTOP-1003, " Specification for 316 Stainless Steel Seamless Cladding 4

Tubes," Revision 1, dated May 1996. TTOP-1-003 complied with ASTM Standard A 771-88, " Standard Specification for Austenitic Stainless Steel Tubing for Breeder Reactor Core Components," that, according to PNNL, reflects the fabrication and technical data gained over two decades of cladding development and procurement for the FFTF.

The team determined that both ASTM A-771 and TTOP-1-003 require double vacuum melted feed stock, and chemistry and inclusion limits on the product. The products to be produced from the 316 bar stock procured from Westinghouse Hanford for PNNL fabrication was TPBAR clad tubing and end caps.

PNNL verified the adequacy of the stainless steel materialin accordance with TTOP-2-001, " Material Verification Procedure for the Tritium Target Qualification Project," Revision 0, dated May 1996. However, on the basis of the team's review of the certification of the starting bar stock material, the team determined that the Material Reverification Record, signed and certified by PNNL, was not complete and that procedure TTOP 2 001 failed to adequately establish requirements for the completion and certification of that document. The team identified this issue as a nonconformance.

Subsequently, PNNL issued TTOP Deficiency Report (DR) 07 066, dated May 1,1997. The team reviewed PNNL's corrective actions that included revising procedure TTOP-2-001 to address the weaknesses identified and l.

l correctly completing the Material Reverification Record. The team found these corrective actions adequate and closed the nonconformance.

During this review the team also determined that TTOP-1-046 failed to adequately describe the actual sample size PNNL used to confirm the chemistry and inclusions of the stainless steel cladding bar stock or the actual characteristics verified during PNNL's reverification process, in addition the team determined that material specification TTOP-1-004,

" Specification for Target Rod End Cap Bar Stock Material," failed to agree with the importance factor sampling plans specified in TTOP 1046 and that TTOP-1046 did not adequately address the use of the ASTM standard sampling frequencies, where applicable, that PNNL actually used during its reverification plan.

Subsequently, PNNL issued DR 97 068, dated May 7,1997. That DR defined the deficiency as follows:

The 316 stainless steel bar stock dedication activity which was performed in the fall of 1996 is inconsistent with the sampling requirements specified in TTOP-1046, in addition, both the sampling requirements and nomenclature used to describe characteristics in TTOP-1-004, Revision 1, " Specification for Target Rod End Cap Bar Stock Material," are inconsistent with the sampling requirements and nomenclature used in TTOP 046.

On the generic basis of this nonconformance, PNNL required all of its material specifications to be compared to TTOP-1-046 to assure agreement in all cases.

The team reviewed the effectiveness of this corrective action and determined that the actions taken by PNNL were adequate to address the specific item issue and the generic implications of this issue. The team therefore, closed this nonconformance.

b.2 Lithium Aluminate Pellets PNNL procured the Lithium Aluminate pellets from ICI Advanced Ceramics.

The pellets were procured in accordance with TTOP-1009, " Specification for Enriched, Annular LiAIO, Pellets," Revision 3, dated April 1997. That specification provided that the seller shall be capable of showing with 95%

confidence, at least 95%,90%, and 75% of the pellets in a lot meet the specifications for the characteristics defined in Table 3, " Classification of.

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Pellet Characteristics for Sampling Plans." That table listed the

- confid6nce/ inspection level (95:95, 95:90, or 95:75) for each characteristic of the pillet to be verified. In addition, the specification required ICl to submit to PNNL the sampling plan for review and approval prior to use.

In a memorandum to PNNL dated May 1,1997, ICI specified the sample sizes associated with the inspection levels as follows:

Inspection. Levels:

SamplaJ3ize:

95:95 15 pellets 95:90 7 pellets 95:75 3 pellets According to ICl, the sample sizes were verified by the QC curves found in ANSI /ASOC Z1.91993, " Sampling Procedures and Tables for inspection by Variables for Percent Nonconforming." The team determined that ASOC Z1.9 sample sizes are based on the assumption that the data represents a normal distribution. Therefore, in order for PNNL to use this standard to determine sampling sizes, PNNL would have to show a documentation of ICI's past performance of complying with the critical characteristics as the basis to support PNNL's assumption that the data represents a normal distribution.

On the basis of its review of PNNL's procurement, receiving inspection, and acceptance of the Lithium Aluminate pellets, the team identified the following concerns that constitute a nonconformance:

i (a)

PNNL failed to document its basis for the assumption that ICI's data represents a normal distribution and therefore the appropriateness of using the small sample sizes to verify critical characteristics of the pellets.

(b)

PNNL failed to include these sampling sizes in the inspection / Test Instructions (Itis) used Dy the QC inspectors to verify the adequacy and acceptance of the pellets for use in the TPBARs.

PNNL iesponded to the team's concerns by taking the following corrective actions:

(a)

In a memorandum dated July 18,1997, PNNL adequately documented its previous procurements from ICl and established its y

basis for using the small sample sizes to accept the pellets.

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(b)

The Itis for receipt inspection for all pellets for LTA lots received were revised to address the sampling matrix and; confidence / inspection levels specified in TTOP 1009.

The team reviewed the effectiveness of these corrective actions and determined that PNNL's actions taken were adequate to address the issues.

The team, therefore, closed this nonconformance,

c. Conclusions The team identified concerns with the procurements cf the stainless steel material for the TPBAR cladding tubes and end plugs, and the Lithium Aluminate (LIAIO ) pellets. These concerns constituted nonconformances.

2 However, PWNL respondeu with corrective actions that adequately addressed the team's concerns and resulted in the team determining that the nonconformances were closed.

3.3 TRBAR_ Fabrication. Activities

a. Inspection _ Scope During this portion of the inspection, the team evaluated the material control for the TPBAR fabrication, handling and storage of cladding tubes, welding of the upper end caps, and pencil assembly activities for the TPBAR LTAs to determine whether adequate quality assurance provisions were established and procedures followed. PNNL's fabrication process and quality plan is defined in TTOP 2-013, " Manufacturing and Quality Plan for Tritium Producing Burnable Absorber Rods for the Tennessee Valley Authority Lead Test Assemblies," Revision 1, dated June 1997, and in TTOP 2 014,

" Tritium Target Rod Fabricating Process Plan," Revision 1, dated June 1997.

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b. Observation.and_FJndings To evaluate the acceptability of the fabrication process, the team initially reviewed the established procedure and QA plan for the process and then observed PNNL's activities in performing the process activity. The following sections describe the results of this review.

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1 ib.1 Material Control-PNNL's material control process is described in the following:-

TTOP 2101, " General Receiving for the Tritium Target Fabrication

- Facility (TTFF)," Revision 0, dated February 1997 1

TTOP 2102, " Handling of Miscellaneous Components," Revision 0, dated February 1997 TTOP 2-105, " Control and Inventory for Received Storage,"

Revision 0, dated January 1997

_ TTOP-2106, " Control and Inventory for Accepted Storage,"

i Revision 0, dated January 1997 TTOP-2-109, " Control and Inventory for Rejected Storage,"

-Revision 0, dated January 1997 1The team reviewed the established measures for material control contained in TTOP procedures and interim change notice (ICN) 2-101 01, completed July 8,- 1997, and determined that the measures established were adequate.

i The team reviewed the Component inventory Ledger and the Transaction Log Sheet for each of the ' material control cages (received, accepted, and rejected storage cages) and found that adequate controls were in place and that all entries reviewed matched with existing inventory. The team also verified that the colored tags found on many items in the TTFF were appropriately documented and controlled in accordance with established -

- procedures, b.2 Cladding Tubes PNNL's process for handling cladding tubes were documented in TTOP '

103,~ " Handling of Empty Cladding Tubes," Revision 0, dated February 1997, TTOP 2-104, " Handling of Loaded Cladding Tubes," Revision 0, dated F

- February 1997, and TTOP 2-211, " Inspection / Test Instructions for-Inspecting Cladding Tubes," Revision 0, dated March _1997. The team reviewed the established measures for the control of cladding tubes in TTOP-2-103 and -104 and determined that the measures established were

adequate, l :

The team reviewed the Transaction Log Sheet and tags for the empty cladding found in the TTFF and determined that adequate controls were in place and that all documents and tags reviewed matched with existing records.

b.3 Welding PNNL's process for welding qualification, performance, and inspection were documented in the following:

TTOP 2 018, " Qualification Plan for End Plug Welding," Revision 1, dated June 1997 TTOP 2 024, " Radiography inspection Procedure Qualificaoon Plan,"

Revision 0, dated June 1997 TTOP 2117, " Top and Bottom End Plug Welding," Revision 0, dated June 1997 TTOP 2-303, " Weld Visual Inspection," Revision 0, dated May 1997 TTOP 2 310, " Radiography Inspection," Revision 0, dated June 1997 The team reviewed the established measures for welding qualification, performance, and inspection and determined that the measures established were adequate.

The team witnessed the real time radiography (RTR) of the 12 end-cap welds used to qualify the end-cap welding process and determined that the process was adequately controlled and perforrned in accordance with established procedures, The team also reviewed the radiographs taken of the 12 end-cap welds which were used by PNNL as additional information regarding the adequacy of i lng process. The radiographs were produced by X raying the w w

,cordance with Westinghouse Hanford Nondestructive Examination '

- s ' Manual WHC CM-4-38, Section NDT-RT-4000, " General Radiograp.,

'9 tion Procedure," Revision 2, dated January 15,1994. Specifically,,

x C, " Capsule, Fuel, and Absorber Pin Radiography," Revision 1, dateo.aly 16,1994, was followed to achieve the radiographs of the 12 end-cap welds using the beam filtered tangential radiography technique. The team found the radiographs and the processes used to produce them to be adequate.

s On July 17,1997, the team reviewed the completed welding qualification report for the qualification of the end plug welding qualification. That report was documented in TTOP 2-023, " Qualification Report for End Plug Welding," Revision 0, dated July 1997. The team found the report to be well documented and very thorough. Overall, the team found PNNL's welding qualification package to be excellent.

On July 18,1997, the team witnessed actual production welding of the second set of 8 top end-cap welds. The activity was well controlled and the welding processes were performed in accordance with the established procedures, b.4 Pencil Assembly PNNL's process for performing the pencil assemblies were documented in TTOP-2125, " Pencil Assembly Loading," Revision 0, dated May 1997, and TTOP 2 225, " Pencil Assembly inspection," Revision 0, dated May 1997.

The team reviewed the established measures for the control of pencil assembly and inspection and determined that the measures established were adequate.

The team witnessed the pencil assembly process for several pencils and determined that adequate controls were in place and that all documents and tags reviewed matched with existing records. The team noted and commented on the extreme care and precision exhibited by PNNL's staff performing the pencil assembly and inspection activities,

c. Conclusions For the fabrication activities reviewed, the team found that PNNL performed those activates with great care and attention to detail and that the personnelinvolved followed established procedures. No adverse findings were identified by the team.

4 ENTRANCE AND EXIT MEETINGS In the entrance meeting on April 28, 1997, the NRC inspectors discussed the scope of the inspection, outlined the areas to be inspected, and established interfaces with PNNL management. In the exit meetings, on July 11 and July 18, 1997, the inspectors discussed their findings and concerns.

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PARTIAL LIST OF PERSONS CONTACTED RNNL-

J. Ethridge.

l G.' Sorensen R. Latorre;

. S. English D. Sensor C,. Painter L. Erickson S. Bales l

D. Rittenhouse C.; Thornhill R. Guenther IVA'

'J. Chardos

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DOE l

M. Clausen

+

20-p g

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