ML20138P151
| ML20138P151 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1985 |
| From: | Cilimberg R, Jocelyn Craig NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20138P133 | List: |
| References | |
| REF-QA-99900251 NUDOCS 8512240328 | |
| Download: ML20138P151 (28) | |
Text
{{#Wiki_filter:_ _. _ _ _ l l ORGANI.7.ATION: JOSEPH OAT CORPORTION CAMDEN, NEW JERSEY REPORT' INSPECTION INSPECTION NO.: 99900251/85-01 DATE(S): 9/23-27/85 ON-SITE HOURS: 154 CORRESPONDENCE ADDRESS: Joseph Oat Corporation ~ ATTN: Mr. John Benckert Quality Control Manager 2500 Broadway Camden, New Jersey 08104 ORGANIZATIONAL CONTACT: Mr. John Benckert, QC Manager TELEPHONE NUMBER: (609) 541-2900 PRINCIPAL PRODUCT: Nuclear Heat Exchangers, Fuel Storage Racks, Defueling Canisters. NUCLEAR _ INDUSTRY ACTI iTY: Approximately 75% of Jo$eph Oat Corporation's activity is devoted tt, the commercial nuclear in'dustry. ' ASSIGNED INSPECTOR: -
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R. L. Cilimberg, Sppial Projects Inspection Date Section (SPIS) 1 OTHERINSPECTOR(S): C. Abbate, SPIS J. Thomas, TMI Program Office B Brown, EG&G I F.. F m tis, IS APPROVED BY: d / e a5 Jc hn W. Craig, Chief, SPlh Vendor Program Branch ae INSPECTION CASES AND SCOPE: A. BASES: 10 CFR Part 21 and 10 CFR Fart 50, Appendix B. B. SCOPE: Verify the implementation of the Joseph Oat QA program and
- compliance with the requirements of 10 CFR Part 21 during the fabrication i of defueling canisters for TM1-2. These QA requirements and the appli-
- cability of 10 CFR Part 21 were specified in Bechtel purchase order TC-022111, Rev. O dated August 7, 1985, and Bechtel Technical Specification 15737-2-N-101A(0), Rev. 2 dated June 18, 1985.
PLANT SITE APPLICABILITY: TMI-2 (50-320) l I- y '~ f e51224032s e*s12M,. m r g g*
i : I o ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.: 99900251/85-01 RESULTS: PAGE 2 of 16 l i A.- VIOLATIONS: Contrary to Sections 21.21(a)(1) and (2) of 10 CFR Part 21 Joseph Oat l procedure SP-1522, " Procedure for Reporting Defects and Non-Compliances," i
.is not appropriate in that it (a) fails to adequately address a procedure to be followed by Joseph Oat. personnel in informing the licensee or purchaser of a deviation in order that it may be evaluated, and (b) fails to address informing a directnr or responsible officer of deviations on failures of conditions reportable to the NRC, Oat purchasers and/or
. licensees for equipment / services previously supplied by Joseph Oat.
This is a Severity Level IV violation (Supplement VII). . B. NONCONFORMANCES:
- 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Section 4.2.2 of the Oat Quality Assurance Manual (QAM),
Revision 8, dated June 26, 1985, lifting lugs were installed and removed on canister 2476Al without a description in the traveler of the operation steps for the lifting lugs.
- 2. Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Section 4.2.2 of the Oat QAM, the shell of canister 2476A2 was formed with a steel bar and a hammer to achieve a concentric fit-up between the shell and the lower. head without a description in the traveler for this operation step in the manufacturing process.
- 3. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 4.3.3.1 of Bechtel Technical Specification 15737-2-M-101A, Revision 2, dated June 19, 1985, Turco Dy-Check Remover No. 3 was being used for cleaning canister parts and welds before obtaining Bechtel's approval for the procedure which permits the use of this cleaner.
- 4. Contrary to Criterion XVI of Appendix B to 10 CFR 50, Special
- Condition' 19 to Bechtel Purchase' Order TC-022111, and Section 9.1 of tae Oat QAM, a condition adverse to quality existed in that conflicting documentation left the status.of the recombiner elements in the canister lower heads indeterminate and no action had been taken to identify and correct the apparent nonconformity.
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ORGANIZATION: JOSEPH OAT CORPORATION j CAM 0EN, NEW JERSEY 1 l REPORT INSPECTION j NO.:- 99900251/85-01 RESULTS: PAGE 3 of 16 i l C. UNRESOLVED ITEMS:
- 1. The chemical reaction of the concrete resin with water during refueling requires evaluation relative to the impact on TMI-2 defueling activities and subsequent transportation safety implications. -This item is discussed in E.1 below.
- 2. .The quality of the catalyst in 'the lower heads supplied by NES is an unresolved item based on indications of overheating, weight discrepancies, and absence of receipt inspection criteria as discussed in E.2 below.
- 3. Missing radiographs for a number of the longitudinal welds on the canister shells is an unresolved item. This item is discussed in E.10 below.
- 4. The method of pouring the concrete resin into the canister 3s,embly is an unresolved item. The present procedure does not adequately address whether continuous pouring is required. The present method of intermittent pouring may have an effect on the overall curing and behavior of this material. This item is discussed in E.11 below.
- 5. The applicability of Joseph Oat invoking the provisions of 10 CFR 21 upon Air-Oil Systems Incorporated, Purchase Order 19515, is an unresolved item. This item is discussed further in E.3 below.
D. STATUS OF PREVIOUS INSPECTION FINDINGS: Not applicable. E. OTHER FINDINGS AND COMMENTS:
- 1. Durability cf Concrete Resin - Cleaning of excess concrete resin from the surfaces of the canister was observed approximately 24 hours after the concrete resin was poured into the void between -
the boral shroud and the shell of fuel canister 2476A1. This cleaning was performed by wiping the excess concrete resin with a water-dampened cloth as required by section 5.1 of procedure QC-2476-82 dated August 1, 1985. The inspectors observed that
'the concrete resin was easily removed. This raised questions M
o ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.: -99900251/85-01 RESULTS: PAGE 4 of 16 concerning potential deterioration of the concrete resin when the canister is immersed in the water in the TMI-2 reactor and during subsequent long term storage. A sample of concrete resin (which had been poured approximately 24 hours previously) was placed in a cup of water and observed to interact with the water and weaken within one hour. There were no specifications for curing and installation of the resin, and the suitability of the concrete resin in fuel canisters when exposed to water without meeting the , curing recommendations of the resin manufacturer have not been reviewed. Unresolved item number C.1 was identified in this area.
- 2. Inspection of Recombiner Catalyst in Lower Heads ,
The NRC inspectors noted that the recombiner elements had been installed in 30 of the fuel canister lower heads. These elements were installed by NES Manufacturing prior to shipment to Joseph Oat. Bechtel specification 15737-2-M-101A requires that the recombiner elements be handled in clean work areas with gloved hands and that care be exercised to protect the recombiners from contamination during canister fabrication. However, the Bechtel specification gives no indication of what foreign materials pose a threat of catalyst contamination.
.The inspectors verified that the recombiners were adequately protected from contamination by dirt or debris from the shop environment at Oat and that Oat had provided adequate procedural controls during fabri-cation to assure the cleanliness as specified in the Bechtel specifi-cation. The inspectors selected four canister lower heads from stock and inspected the installed recombir.ers, four of which tre welded Sto each head. The wire screens covering the catalyst pellets in all four /
of the elements in one head were contaminated with cloth fibers. Further review, determined that the shop traveller used as the basic ' canister fabrication procedure contained requirements to clean the inside of the head prior to its installation. The Quality Control Manager at Oat indicated that th'it, would be done with a vacuum cleaner. Visual examination of the recombiner elements in one of the heads revealed that the wire screen covering the elements exhibited a high degree of discoloration probably the result of welding the screens to the recombiner element. The catalyst pellets beneath the discolored area of the screen aleo appeared to be discolored. The pellets in this area, which comprised 40% to 50% of the pellets in each element, were much lighter in color. Dat had performed a visual I I i l
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O 4 ORGANIZATION: JOSEPH OAT CORPORATION
. CAMDEN, NEW JERSEY REPORT INSPECTION NO.: 99900251/85-01 RESULTS: PAGE 5 of 16 inspection _of the.recombiner elements for shipping damage upon receipt, and relied upon a letter from Bechtel certifying that the elements installed by NES met the design specifications. The inspectors questioned whether the heat of welding, which had been performed by NES Manufacturing may have damaged the silicon coating on the catalyst pellets in these elements and impaired their operability. Oat did not detect the discoloration and had not inspected for this characteristic since Bechtel had not provided any information or specifications on what the characteristics of-the catalyst should be.
Based on the observed discoloration of catalyst pellets and lack of inspection criteria and the catalyst weight problems discussed below the quality of the catalyst is in question. Unresolved item number C.2 was identified in this area.
- 3. Procurement Document Control The inspectors reviewed purchase documents issued by Joseph Oat for procurement of material for fuel canister fabri' cation. Joseph Oat is in the process of fabricating 30 fJel Canisters (A-1 through A-30) using material supplied by Bechtel. This material was shipped from NES Manufacturing's facility in Greensboro, NC, to Oat. In addition, Oat has been contracted to fabricate approximately 30 additional fuel canisters (A-31 through A-60) using Oat procured material. The inspectors verified that an acceptable Bill of Material (BOM) had been prepared by Oat from the Bechtel purchase order, technical specification, and drawings.
The BOM had been prepared in accordance with and met the requirements
- of the Oat Quality Assurance Manual (QAM). The BOM was applicable to fuel canisters A-1 through A-60, however, it served as the o reference for generation of material procurement documents for only the second 30 canisters. Some, but not all, purchase orders have been issued by Oat for material'for canisters A-31 thru A-60. The -
inspectors examined several of those purchase orders to determine whether Oat had incorporated the appropriate regulatory, technical, and QA program requirements. Bechtel specified that the requirements of 10 CFR 50 Appendix B and ANSI N45.2 were to be met by Joseph Oat as described in Technical Specification 15737-2-M-101A(Q) for the defueling canisters. The requirements for Certified Material Test Reports (CMTR) in the Technical Specification were subsequently clarified and relaxed in a letter from the buyer' dated August 12, 1985. For the P0s reviewed, in all cases where Bechtel specified l l l
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~ ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY i
REPORT INSPECTION l
.NO.: 99900251/85-01 RESULTS: PAGE 6 of 16 that a CMTR was required, the Joseph Oat purchase order also specified that a CMTR be provided and invoked the quality assurance requirement of 10 CFR-50 Appendix B and ANSI N45.2 on the subtier supplier. The inspectors verified that these purchase orders were issued only to vendors currently on the' Active Qualified Supplier List or were issued contingent upon Oat completing a vendor audit and placing the vendor on the Active Qualified Supplier List. Oat
.did not invoke the requirements of 10 CFR 50 Appendix B and ANSI N45.2 upon suppliers for material not requiring a CMTR (determined by Bechtel) but did specify that the subtier vendor provide a Certificate of Compliance certifying that the material was supplied in accordance with the purchase order and the applicable drawings -
and references. This met the requirement of the QAM since these vendors hold Quality Systems Certificates issued by ASME or other equivalent certificates. , Bechtel Technical Specification 15737-2-M-101A(Q) also required that the reporting requirements of 10 CFR 21 were to be met by Joseph Oat. The inspectors found that Oat had not invoked the requirements of 10 CFR 21, " Reporting of Defects and Noncompliance," on Air-Oil Systems, Incorporated (purchase order 19515). This purchase order was for four quick-disconnect fittings, two of which were considered commercial grade and not subject to the provisions of 10 CFR 21. However, the two remaining catalog items were modified by Air-Oil Systems thus removing their exemption from 10 CFR 21. Unresolved item number C.5 was identified in this area. 10 CFR Part 21
- 4.
Joseph Oat Standard Procedure SP-1522, " Procedure for Reporting Defects and Non-Compliances," dated January 15, 1979, was reviewed by the NRC inspector and found not to be in compliance with 10 CFR 21. The NRC inspector determined that the procedure, SP-1522, was inadequate in that it did not contain appropriate procedures to assure that a dire'ctor or responsible officer of the ' Joseph Oat Corporation is informed of deviations or failures as required by 10 CFR 21.21(a)(2). In addition SP-1522 failed to adequately address measures to make necessary notifications, by Joseph Oat personnel, of licensees or purchasers of deviations or failures in basic components supplied them in order that such deviations may be evaluated. SP-1522 is a general statement of policy rather than a procedure to implement such a policy. Violation A.1 was identified-in this area.
ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.: 99900251/85-01 RESULTS: PAGE 7 of 16 Interviews with the Quality Control Manager and Vice President of Engineering indicated that Oat has never made a Part 21 report, nor , were they aware of any instance where material or services furnished by them was the subject of a Part 21 report issued by either an Oat customer or a licensee. The inspector also verified that the posting requirements of 10 CFR 21 were satisfied both in the Manufacturing and Engineering work areas. Posting included 10 CFR 21 and Section 206 of the Energy Reorganization Act of 1974.
- 5. Lifting Lugs The NRC inspectors observed that two stainless steel plates containing holes (lifting lugs) for chain hooks were welded on opposite sides of the outer surface of canister shell 2476Al to facilitate handling of the canister. After pouring the resin was completed the lifting lugs were removed. Traveler ho. 2476Al did not contain an operation description for installation or removal of the lifting lugs. Oat personnel stated that a procedure had been written to cover removal of temporary fixtures but this procedure had not been approved by Bechtel and had not been referenced in the traveler. Bechtel required that Oat adhere to the General Welding
-Requirements (G300), Revision 6, dated March 20, 1981, which is attachment 3 to Bechtel Specification 15737-2-M-101A. Section 11.1.2 of attachment 3 requires that Oat not fabricate until a weld table or map has been reviewed by Bechtel. Bechtel had not approved a weld map to cover Oat's welding of the lifting lugs on the canister shells. Nonconformance B.1 was identified in this area.
6 .- Audits The inspectors reviewed Joseph Oat's internal QA audit program. The Oat QAh requires that the General Manager have the Quality Control Department audited once 'during each twelve 'nonth period
- and that the Quality Control Manager have all other portions of the QA program audited once each twelve mor.ths. The Quality Control Manager had prepared a schedule of audits providing for the require-ments of one section of the QAM to be audited each month in such a manner that all of the twelve sections were audited once per year.
These monthly audits were all performed by the lead auditor who currently is the Quality Control Manager. While this individual does have responsibility in many of the areas being audited, a comprehensive audit of all areas of the QAM is performed by the General Manager annually.
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ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.: 99900251/85-01 RESULTS:. PAGE 8 of 16 The General Manager did not have direct responsibility in the audited areas which meets the requirements of ANSI N45.2. The audits were performed using written checklists that provided space for the auditor to write descriptive consnents on deficient areas. Audit reports were reviewed by management and documentation was provided of ' deficient areas and corrective actions taken. Corrective actions were documented, reviewed and approved by the auditor who had identified the deficiency and were subsequently reviewed by management. -
.The NRC . inspectors reviewed Joseph Oat's program for qualification of suppliers which' requires audits to be documented on a checklist .
which indicate the attributes of the supplier's QA program and the acceptability of the areas reviewed. One supplier qualification audit was reviewed. The inspectors concluded that Joseph Oat's audit program met the requirement of the QAM.
- 7. Canister Cleanliness Canister shells were stored indoors at the Oat facility under clear plastic sheets with rebber end caps on the empty shells. Cleaning operations are described on the traveler used during fabrication and Job Procedure No. JP-2476-1 is referenced.for all cleaning.
This Oat procedure outlines the requirements for in-process and final cleaning of the fuel canisters and specifies permissible cleaning agt..+s, mechanical cleaning limitations, and cleaning
- provisions o r top head weldment assembly, vessel assembly, and cement pouring. However, the inspectors observed that weld wire was cleaned in a plastic container which did not identify the solvent.
- . The NRC inspectors questioned whether the solvent could dissolve the i plastic and coat the weld wire thus affecting the quality of the welds. Oat personnel were unable to evaluate the effect of the ~
plastic containers on the welding operation and the plastic containers were promptly replaced with metal containers. The NRC inspectors determined that Turco Dy-Check Remover No. 3 was being used extensively for cleaning canister shells, weld wire, welds, and other stainless steel parts. This cleaner is not listed on the Bechtel approved cleaning procedure JP-2476-1 and therefore should not be used for cleaning canisters. Revision 2 of procedure JP-2476-2 includes this cleaner, but revision 2 has not been I n1 _
m - ~- =~ L : ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY-REPORT- INSPECTION ! NO.: 99900251/85-01 RESULTS: PAGE 9 of 16 l approved by Bechtel. The NRC inspectors note that the cleaner.is approved by Bechtel for removing dye penetrant used to perform inspections of the canisters. Nonconformance B.3 was identified in this area. The NRC inspectors. observed that tap water was used to remove the excess concrete resin discussed in item 1 above, but the operator immediately switched to deionized water when questioned by the inspector. The QC Manager comitted to revise QC-2476-82 to require deionized water. I 8'. Control of Special Processes The NRC inspectors reviewed the Oat QAM and 12 Oat procedures to determine whether special processes were being conducted by qualified personnel using qualified procedures and equipment. A review of two travelers relating to fabrication of two fuel canisters revealed that all individual operations were properly initialed and dated. In addition, the hold points for witnessing by the Bechtel site inspector were signed or initialed and dated.
'The traveler package contained a weld and heat sketch and record sheet which identified bill of material item numbers,-heat numbers, weld numbers, welding procedure specification numbers, welder stamp, and filler metal heat numbers. Operation descriptions in the travelar described fabrication steps and identified the approved drawings which contairied weld notes and joint details.
.While observing the fit-up (Operation Number 20) for welding the lower head to the shell of canister 2476A2, the NRC inspectors observed that the shell had been distorted by thermal stresses which had been initiated by welding the impact plate to the shell
-(OperationNumber16). The Oat welder achieved a concentric fit-up between the shell and the lower head by " tapping" the shell with a steel bar and a hamer. The Oat QAM, Section 4.2.2, requires that '
each operation be described on tihe shop traveler. -The " tapping" forming (Operationoperating)was not covered Number on Traveler byNonconformance 2476A2. an approved procedure B.2 was identified ire this area.
- 9. Training / Qualification -
The NRC inspectors reviewed applicable sections of the QAM, and
. training records from 1983 to the present for 16 employees (8-manufacturing, 2-purchasing, 2-engineering, 3-QA/QC,1-General Manager) to determine whether personnel performing and verifying
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. .,, ORGANIZATION: JOSEPH DAT CORPORATION CAMifdN, NEW JERSEY RE' PORT INSPECTION N0.7 99900251/85-01 RESULTS: PAGE 10 of 16 activities affecting quality had received the necessary training and qualifications. Qualification records were evaluated for these personnel and it was. determined that they met the requirenants of -
. Section 12 of the QAM for Indoctrination and Training. Training was given in various. disciplines of the QAM and quality procedures. QA
. inspectors performing inspections, examinations a6d tests were required to. pass -a written examination and were c ' ertified as Level I,
,- II, or III. Oat procedures were found to be in compliance with the
. guidelines of SNT-TC-1A.
Qualification records for three 9 elders who are scheduled to work on the defueling canisters were, reviewed. All welders were qualified to weld using procedures MPS-8303 "GTAW" and WPS-4304 SMAW. The qualifications were signed off by the welding engineer and the QC Manager. A current qualification Maintenance Chart is
- maintained and a file documenting that each welder had welded using.
a process to maintain' their qualification in accordance with Section IX of the ASME Code is~ located in the QC Manager's office. A-review of three Proced:.re Qualification R? cords (PQR) for WPS-8303 and three PQR for WPS-4303 ar.d six tect reports indicated'that all testing had been performed as ' required in accordance with Section IX of the ASME t Code. The disposition of. welding filler metal and electrodes appeared to be in compliar.ce with Section 5.1.5 throbgh 5.1.9 of the QAM.
- 10. Nondestructive . Examination 4e Nondestructive examinaticn (NDE) of the TMI 2 defueling canister
~is to be performed in accordance with the requirements in the 1983 edition of the ASME Code Section VIII, Subsection UW (lethal),
paragraphs UW-50, UW-51, and UW-53 a's required by Bechtel Specification 15737-2-M-101A(Q). The HRC inspectors determined that Oat has three certified NDE examiners currently participating in canister NDE examinations. John Benckert, QC Manager, is c6rtified Level III in radiographic -
. (RT), penetrant (PT),'and visual (VT) methods; Charles Leonard, Assistant QC Manager, is certified Level II in RT, PT, and VT; s.and William Badaili is certified Level II in PT and VT. The Oat procedarss for qualification and certification of NDE personnel, as well as the individual training and certification records including eye examination results for the above NDE examiners were found to be in compliance with the guidelines of SNT-TC-1A.
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f, q ORGANIZATION:' JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.: 99900251/85-01 RESULTS: PAGE 11 of 16 All radiography is currently being performed under subcontract by Eastern Testing and Inspection, Inc. (ETI) of Pennsauken, NJ, with radiograph . interpretation and final acceptance by Cat Level II and III examiners. The ETI procedures for qualification and certification of NDE personnel, including individual training;and certification records with current eye examination results were reviewed by the
' NRC inspectors and found to be in compliance with the guidelines of SNT-TC-1A.
The NRC inspectors reviewed Oat procedures QC-2476-20 Radiographic Examination of Welds, Revision 1, dated August 12, 1985; QC-2476-10, Liquid Penetrant Examination of Welds, Revision 0,. dated July 25, 1985; QC-2476-60, Visual Examination of Welds, Revision 1, dated August 12,1985; SP-1579, Requirements for Qualification and Certification of NDE Personnel (J. Oat), Revision 4, dated September 1, 1983; and CP-101, Procedures for Qualification and Certification of NDE Personnel (ETI), Revision 3, dated June 1, 1981- All of these procedures were determined to meet the applicable ASME code requirements. The NRC inspectors reviewed Oat procedure OC-2476-70, Ultrasonic Inspection for Circumferential Pipe Weldments per ASME Section VIII
- and V. \This procedure is not on the List of Approved Procedures and, therefore, should not be used for canister inspection. This procedure can be confusing to the examiners in that paragraph 3.4.3 states that " Instrument settings during calibration shall not be changed during actual test." This is contradictory to paragraphs 4.1.1, 4.2.1, 4.2.2, and ASME code requirements (Section V, Article 5 paragraphs T-546-2.2.2, T-546-2.2.3, and T-546-2.2.4) which state that "Secnning shall be performed at a gain setting at least two times the primary reference level." Procedure QC-2476-70, paragraphs 4.2.1 and 4.2.2 for angle beam examinations, also states that the search units shall be manipulated so that sound passes through the required volume of weld and adjacent base metal. These paragraphs are incomplete unless they are e'xpanded to include the ASME Section V, -
Article 5 requirements of paragraph T-524.1 which states that each pass of the search unft shall overlap a minimum of 10% of the transducer dimension perpendicular to the direction of the scan, and paragraph T-524.2 which requires that the rate of search unit move-ment for examination shall not exceed six inches /second unless calibration is verified at scanning speed. k v% n .- - . , , , , . , - - , - . - - , , , .n,-.. . . ,.- - , , - - , - - - - - - - . - , , , - - - , -
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; ORGANIZATION: -JOSEPH OAT CCRPORATION CAMDEN, NEW JERSEY REPORT c; INSPECTION i
NO.: -99900251/85-01 RESULTS: PAGE 12 of 16 The NRC inspectors reviewed the radiographs, technique sheets, and-
.' inspection report for-the head to canister weld on cant iter No.
2476A-1 which was the only weld of this type that had been tradiographed by Oat at the time of this inspection.- No; rejectable indications were'noted during review of the radiographs'and-inspection reports and the radiographic technique, quality, and densities were determined by the NRC inspectors to meet thc' ASME code requirements. , , , ;The NRC inspectors reviewed radiographs and inspection reports for the longitudinal welds on the canister shells'that were supplied to Oat by NES. The, radiographs had been. supplied initially by Armco Steel, Wildweed, Florida. Review of these radiographs by the NRC inspectors did not-identify any indications on the~ radio-graphs that were differs t than those reported by Armco'and the
- quality of the radiograpWs was determined to meet the applicable requirements of the ASME code.
Theridentification nunbers of the shells for which radiographs and
. inspection reports,were' reviewed are as follows:
95P1 95P2 , 24P1 24P2 109P1 109P2 129P1 129P2 137P1 137P2 v 120P1 120P2 130P1 130P2 89P1 89P2 .
> 44P1 44P2 .
110P1 110P2 l 117P1 117P2 127P1 127P2 124P1 '
-124P2 126P1 126P2 92P1 92P2 Th'e NRC inspectors' observed the dye penetrant examination (PT) o.f impact plate to shroud welds on canister numbers 2476-A2 and 2476-A3
. y* and the-PT of the lower head.to canister root pass weld on canister number 2476A2 and concluded that the techniques, materials, and 1
- documentation for the examinations were in conformance with approved procedure's and the inspection personnel (Level II) and materials were cert,ified.
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o ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTIO,1 NO.: i99900251/85-01 RESULTS: PAGE 13 of 16 During the-inspection, the NRC inspectors were. informed by Oat that
- Bechtel had advised Oat that.some radiographs were missing for the longitudinal welds on the canister shells before the shells were shipped to Oat from NES. During Oat's inspection of packing lists provided by NES, Oat determined that 40 welds had one view missing and one weld had no radiograph. Dat issued Deviation Notice number 2956 dated September 24, 1985 per Oat QAM section 3.2.6. The NRC inspectors determined that Oat's action was acceptable in that missing radiographs will be replaced. -
Unresolved item number C.3 was identified in this area.
- 11. Concrete Resin Pouring The NRC inspector witnessed the concrete resin pour for fuel canister assembly No. 1. Oat Procedure QC-2476-82, dated
-August 1, 1985, describes this activity.
This low density (62.5. pounds / cubic foot) light-weight concrete consists of a mixture of 60% refractory cement,11% glass bubbles and 29% demineralized water, by weight, which fills the cavity between the ~ square inner boral shroud and the circular outer shell of the canister assembly thus'providing continuous lateral support to both' components. This distributed loading function is intended to minimize instantaneous displacements in the overall shape of the boral shroud during all postulated accident conditions to successfully
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meet the criticality criteria. The inspector observed the Joseph Oat technician preparing the concrete which was supplied by the Advanced Ceramics Division of , Babcock & Wilcox (B&W). This materL1 consisted of 148 boxes of pre-measured LICON ultralight concrete certified by B&W in a Certificate of Compliance, dated April 9,1985, as meeting the
. design specification. It could'not be determined by Oat personnel, or_ the NRC inspector whether the pre-mix furnished by B&W contained the proper proportions (60/11 pdrcent by weight) of refractory cement and glass bubbles. The quality of the mix is questionable in light of the observation that the resin loses structural properties when allowed to react with water as discussed in E.1 above.
.As the placing of the concrete continued, the NRC inspectors noticed that the Oat procedure did not clearly address the method of pouring
-the resin, i.e., continuous or intermittent. It is uncertain
-whether this potential lack of bonding of the resin may have any affect on the structural analysis which was performed to substantiate the structural integrity of the fuel canister.
Unresolved item number C.4 was identified in this area.
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ORGANIZATION: JOSEPH OAT CORPORATION CAMDEN, NEW JERSEY REPORT INSPECTION NO.:. 99900251/85-01 RESULTS: PAGE 14 of 16
- 12. Calibration of Measuring and Test Equipment Section 6 of the Oat QAM, " Tool, Gauge, and Equipment Control," and calibration records (Gauge Control Records and Calibration Cards) for several different pressure' gauges, micrometers, vernier calipers and
' densitometer were reviewed. _ - All tools, gauges and equipment are identified with a unique number and recorded on a Master Tool List, with the exception of tapes, rules and scales which are calibrated only'if so specified by contract. A " periodic check"
. as defined in Section 6.1.3, of the Oat procedure, is also performed each time an instrument is used to ensure its continued ' accuracy.
All instruments observed during the inspection possessed
.a calibration " sticker" which. contained the date calibrated, next ! calibration due date, device identification number and the individual performing the . calibration.
Several instruments, used primarily for receipt inspection of canister shells, were reviewed for compliance. These instruments were a 0-1 inch tube wall micrometer (No. J-20) and a.0-24 inch vernier 7 caliper (No. K-7). In addition calibration data for an X-rite Model 301 densitometer, used in conjunction with the reading cnd interpre-tation of radiographs, was'also reviewed and found to be satisfactory. As an. extra precaution, the Oat inspector calibrated item No. J-20 at 0,-25', 50, 75, and 100 percent of range, with item No. K-7 calibrated at 0, 25, and 50 percent. This additional step ensures calibration is also maintained between intervals. All calibration activities, reviewed by the NRC inspector, were performed by the Quality Control LManager or his assistant.
- 13. Control of Purchased Material No material purchased by Oat had been received at the time of the
; inspection. Material at Oat was provided by Bechtel and shipped from NES Manufacturing to Oat. The inspectors verified that the material had been receipt inspec'ted and entered into Oat's material control program. As material was received, the material receiving ';. report (MRR) was filled out listing the items received, heat numbers when applicable, whether proper documentation was received, and .
whether there was apparent. shipping damage. As subsequent receipt inspections, such as dimensional checks, were performed, the MRR was annotated showing the area to be inspected was completed. However, the specific items checked were not identified on the MRR. The receipt inspections being performed and the completed documentation relating to the receipt inspections met the requirements of the QAM. e i
. - . , - - . , . - , . . . . . . . - - , ,,,~n -
J i i l l
~ ORGANIZATION: JOSEPH OAT CORPORATION
-CAMDEN, NEW JERSEY ;
REPORT INSPECTION NO.: '99900251/85 RESULTS: PAGE 15 of 16 Activities performed and observed by the NRC inspectors during receipt inspection of the canister shells shipped from NES by Bechtel included a dimensional check of the shell (0D, ID, straightness and length), in addition to a visual examination
- for cracks and damage as required by Oat Procedure SP-1532, Revision 0, dated October 10,'1979. Dat personnel observed that shells furnished by Bechtel from NES did not possess the weld preparation necessary for full penetration welding of the lower head and bulkhead components to the fuel canister shells. Oat arranged for a local contractor to machine a J-bevel in the end of the shells to facilitate fit-up for welding the lower heads to the shells. .
During receipt inspection of the boral shrouds, the NRC inspectors determined that a wall thickness inspection was not performed by Oat as required by Section 3.2.3 of the Oat QAM. The failure to identify specific characteristics inspected was identified as a weakness in Oat's receipt inspection activities. During the NRC inspection the Oat QC inspector inspected the dimensions of shrouds in addition to committing to incorporating complete dimensional measurements of all shrouds in future inspections. The receipt inspection activities performed on the shrouds did not follow a prescribed checklist of items to be verified, but rather an.overall check of dimensions in accordance with manufacturing drawings. The consistency of measurements is questionable when measurements to be checked and acceptable tolerances are not specifically prescribed. Further, the blue-line drawings used as a basis for dimensional check during receipt inspection were poor quality reproductions. l l The inspectors reviewed a random sampling of CMTRs and Certificate of Compliances for material supp' lied by Bechtel.. During this review, th(. inspectors noted that Bechtel had supplied a letter as a Certificate of Compliance indicating that the canister lower heads and recombiner catalyst met all design specifications. The canister lower heads had been formed by a subcontractor to NES Manufacturing and the catalytic recombiner elements had been installed by NES Manufacturing. Bechtel then supplied these units to Oat with a Bechtel Certificate of Compliance. However, the inspector found in the documentation package a Suppliers Deviation Disposition Request (SDDR) issued by NES Manufacturing to Bechtel indicating that when the recombiner catalyst was weighed and l l. t r -
,-- . . . _ . , _ _ _ - _ , , , _ _ . . ~ . . . . _ . __m- , __ _
s ORGANIZATION: JOSEPH OAT CORPORATION
- CAMDEN, NEW JERSEY REPORT' INSPECTION NO.: 99900251/85-01 RESULTS: PAGE 16 of 16 bagged from bulk supply individual inspection verification of weights was not performed. There had been no indication of resolution of the potential discrepancy on the weights of catalyst actually installed -
in the elements. The NRC inspectors found that Oat had not evaluated this SDDR which appears to be in conflict with the Certificate of Compliance on the recombiner elements. Bechtel issued the Certificate of Compliance without determining whether NES had corrected the discrepancy on the weights of the catalyst actually installed in the lower heads. Nonconformance B.4 was identified in this area.
- 14. Material-Identification and Control The NRC inspectors reviewed the procedures and the functioning of the material control system. Material markings, identifying each component by job, item and heat number, were found etched into the material. Transfer of markings prior to cutting each piece was not verified since Joseph Oat's contract primarily calls for canister assembly. Nonconforming canister shells were prope'rly segregated from production material and all observed to possess a " Hold" tag. ,
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