ML20005A254

Responds to NRC 810423 Ltr Re Nonconformance Noted in QA Program Insp Rept 99900039/81-01.Corrective Actions:Quality Procedures Established to Ensure Control of Insp Activities in Accordance W/Ansi Requirements

ML20005A254
Person / Time
Site:	Black Fox
Issue date:	05/25/1981
From:	Sluis B A RHINE-SCHELDE-VEROLME ZWARE APPARATENBOUW
To:	Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20005A249	List: ML20005A254
References
REF-QA-99900039 KD-81022, NUDOCS 8106300106
Download: ML20005A254 (7)

Text

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RSV Zware Apparatenbouw b.v. l

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l Rotterdam Heavy Equipment l l

' United States Nuclear Regulatory ,

Commission Region IV Il 611 Ryan Plaza Drive, Suite 1000 )

ARLINGTW, Texas 76011 -

U.S.A. ASV Att.: Mr.Uldis Potapovs, Chief Vendor Insgection y an_ch.

Your ref. Our ref. KD/81022 Rotterdam,25th May, 1981.

Tel. +31 10 872874 Your letter dated April 23, 1981.

Your Docket _No. 99900039/_81-0 E _

Gentlemen, This is to acknowledge receipt of your letter dated 23rd April,1981 with enclosure, w51ch we received May 4th.

Please find listed in this letter our detailed response to the reported finding as requested in your letter.

Documents containing information as evidence to your response you will find attached to this letter.

NRC finding :

Criterion XIII of Appendix B to 10 CFR Part 50 states : " Measures shall be established to control the handling,~ storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration. When necessary for particular products, special protective environments, such as inert gas atmosphere, specific noisture content levels, and temperature levels, shall be specified and provided". i Contrary to the above, measures have not been established to control storage I and preservation of the Black Fox Unit No. 1 reactor vessel in accordance with work and inspection instructions, to prevent damage or deterioration, while the completed vessel is being stored prior to shipment. (See Details Section, paragraph B.3.a.).

RSV-A response :

1. We agree that no written instructions were available for controlling inspection of ctorage and preservation of the Black Fox I RPV prior to shipment, since shipment of subject vessel was unexpectedly held up.

A Quality Procedure (PQ 9.15.02 (E)) has been established and is now issued to all co?icorned to ensure control of inspection activities in accordance with ANSI requirements (see attachment I to this letter).

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, united Stat:0 Nuclear Regulttory RSV Zwcro Apptrct:nb:uw b.v.

Cosmiccion Kegion IV Rotterdem Hoevy Equipment ARLINGTON, Texas 76011 Page 2 of 2 25th May, 1981.

2. To prevent recurrence we issued a memo to the Manager Manufacturing (see attachment II to this letter).

3. QP 9.15.02 (E), rev. O has been 3saued 27th April, 1981. 7' We hope our response is satisfactory to you. .

When you need any additional information, please contact us.

Sincerely yours, RSV Zware App' ouw b.v.

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Ir.B.J.A.Sluis Manq;ing Director -

Prepared by :

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Ir.M.Lodder Manager QA i

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• Attechment II to RSV Zwcro App:rct::nbodw b.v. xn/81022 w}

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Soort document: IM 11oc. nr. KD/81023 Rev. O Blad 1 van 1 litaden Document hentemd wwar: Bespreking te DR - bespr. rapp. TR - techn. upp. ,,,,,,,g;,, :

IR - intern rapp. RV - teisverslag Dattam ,,pg 1981.03.30 IM - int. meded. LO - lit, undert.

TG - tel, gesprek Samensteller  : S.A.Hulshoff 5

Onderwerp: Kopicen bestemd voor:

Afd. Naam Aant. ,

Instruction and Procedures .

Mr.P.C.le Ruiter, Manager Manufacturing

- Mr.C.P.J.Vester, QA Shop Engineer.

Order / project nr.:

Bestemming:

Volg nr.:

• Info Memo Aktie door:

During NRC inspection on March 23rd - 25th,1981, it was found that no written instructions were available for the control of inspection of the storage of the Black Fox I reactor vessei.

You are requested to remind the personncl concerned that according to Chapter 15, par. 2 of the QA Manual control of inspection of storage and preservation must be carried out according to written instructions.

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• By eer besprekings. of reisverslag en een telefoongesprek de gesprekdeelnemer(s) a vermelden.

Attcchment I to KD/01022 P g] 1 cf 4

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P.SV zware Apparatenbouw b.v. Quality Procedure no.: 9.15.02 (N) l Rotterdem Heavy Equipment .

R . O Date  : 1981.04.27 l

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l Sutdect : Storags requirements for Reactor Pressure Vessel Components and Items.

Distribution See Quality Procedure No. 9.03.01.

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Pcg3 2 cf C RSV zware Apparatenbouw b.v. Quality Procedure no.: 9.15.02 ('E)

Rotterdem Heavy Equipment RSV-A Storage requirements for Reactor Pressure Vessel (RPV) components and items.

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1. Definition of storage Storage is the act of holding RPV compontents and items at the manufacturers -

site.

The storage time starts immediately af ter completion of the last work ( ar: _ed out on the RPV components / items assembly to be stored and ends with shipment.

2. Applicable documents 2.1. ANSI N 45.2.2-1972 (packing, shipping, receiving, storage and handling of items for Nuclear Power Plants).

2.2. AN3I N 45.2.3-1973 (housekeeping durincr the construction phase of Nuclear Power Plants) .

2.3. Applicable customer's specifications.

3. Preserving status at start of storage time RPV components and items shall have received the sarface preparation, cleaning, preserving and packing status in accordance with the applicable documents of par. 2, as laid down in detail in the applicable RSV-A procedure specification which shall have been prepared for and approved by the customer.

4. Levels for classification of RPV components and items, in accordance with.

ANSI N 45.2.2-197?

4.1. The requirements for packing, handling, storage and shipping are divided into

- four levels with respect to protective measures to prevent damage, deterioration or contamination, viz. level A thrcugh D.

The following levels apply to RPV componants and items :

Level C : Protection required from exposure to environment, airborne contaminants (e.g. rain, snow, dust, dir% salt spray,, fumer ) , g-forces and physical damage. Protection from vapor and condensation is relatively not so important.

I,evel D : These components / items are less sensitive to the environment than

. level C. These components / items require protection against the elements, airborne contaminants, and physical damage.

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4.2. Storage level D is applicable to

a. Reactor Pressure Vessel. ,

b. Reactor Pressure Vessel Head.

Scorage Level C is applicable to the small parts, such as :

a. Otuds, nuts, washers.

b. Metal 0-ring =.

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c. Gasket retaining clipe, rings, pins' and drive pin tools. ,

d. Thermal sleeves.

e. Seal surface protector.

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RSV zware Apparatenbouw b.v. Quality Procedure no.: 9.15.02 (E)

Rotterdem Heavy Equioment I

f. Stud protector caps and protector cap mandrel.

g. Stud guide caps, i

h. Covers for access holes in skirt ring. ,

1. Stud elongation measuring rods, and dial depth gauges. -

j. Stud handling tool and nut runner assembly.

k. Calibration blocks.

5. Environmental conditions for storage

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5.1. k vel C - components / items shall be stored within a fire resistant, J weathertight and nell ventilated building or equivalent enclosure.

Precautions shall be taken against vandalism.  ;

This area shall be sit'tated and constructed so that it will not be subject to flooding: the floor shall be paved or equal and well drained.

5.2. uvel o - componentVitems may be stored outdoors in an area marked and designated for storage, which is well drained, preferably gravel covered or paved and reasonably res:ve.1 from the actual construction area and traffic

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so that, possibility of das.tge from construction equipment is minimized.

Comwr. ant / items shall be s pred on cribbing or equivalent to allow for air circulation and to avoid trapping water.

5.3. Level D - components / items may be stored in level C - locations, however not vice versa.

5.4. Access to storage areas shall be contrclied and limited only to personnel designated by the reponsible organization. Areas near stored components and items shall be cleancd as required to avoid the accumulation of trash, discarded packing materials and other detrimental soil.

The use or storage of food, drinks and salt tablet dispensers shall not per-mitted near stored components / items.

Measure shall be taken to prevent the entrance of rodents and other animals into indoor storage areas or equipment to minimize possible contaminsation and mechenical damage to stored material.

6. Storage methods 6.1. All components / items shall be stored in such a manner'as to permit ready access for inspection or maintenance without excessive handling, to minimize risk of danage.

6.2. All components / items shall be plainly marked so that they are easily identified without ex assive handling or unnecessary opening of crates and boxes.

6.3. Weatharproof covering, when used for outdoor storage, shall be flame -

resistant type of sheeting or tarpaulins. They shall be placed so as to provide drainage and to insure air circulation to minimize condensation. They shall be l

tied down to prevent moisture frca entering laps and to protect the coverings l from wind damage.

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1 P ga 4 cf 4 RSV zware Apparatenbouw b.v. Quality Procedure no.: 9.15.04 (E)

Rotterdam Heavy Eqwpment p

7. Control of components / items in stort.ge 7.1. Inspections shall be performed and documented on a periodic basis to assure that the integrity of components / items and its container is being maintained. .

Deficipncies noted shall be corrected and documented.

• Characteristics verified during inspection shall include the following :

a. Ideatification and marking.

b. Protective covers and seals.

c. Coatings and preservatives, if applicable.

d. Desiccants and inert gas blankets, if applicable.

e '. physical damage.

f. cleanlyness.

7.2. Items in storage shall have all covers, caps, plugs or other closures intact.

Cove a removed for internal access at any time for any reason shall be immediat ly replaced and resealed after completion of the purpcse of removal.

7.3. The required surfacu preparation, cleaning, preserving and packaging status is given in detail for a certain component / item in the applicable RSV-A procedure specification.

7.4. Items pressurized with inert gas shall be monitored at such a frequency as to insure that the gas pressure is maintained during storage. Desiccant humidity indicators shall also be monitored and desiccants shall be changed or reprocessed when specified.

7.5. In the event of fire should accur in the storage area at any time, each item known to have been heated to an ambient temperature of over 65 C or subjected to smoke contamination shall be thoroughlyexamined and verified to be in confermance with specified requirements.

8. Franquency of inspection 8.1. Inspection in accordance with par. 7.1. shall be based for Reactor Pressure Vessel and for Reactor Pressure Vessel Head on a weekly basis.

8.2. Inspection in accordance with par. 7.1. shall be based for the internal surfaces of reactor pressure vessel and for reactor pressure vessel head (viz surfaces under a cover) on a half annual basis. . I 8.3. Inspection in accordance with par. 7.1. shall be based for "small parts" as per .

par. 4.2. in the status "as packed" on a half annual basis.In case a damage of boxes is ooserved, these bcmes shisll be opened and the items unpacked and )

inspected for damage. 1 i

8.4. Inspection in accordance with par. 7.1. shall be based for "small parts" as per par. 4.2. in the status " unpacked", as an at random sample of 10 % of the boxes on a two annual basis.

j 9. Reportage l

Written storage records chall be prepared that include such pertinent information as storage location, inspection results and protection.

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