ML20214L795
| ML20214L795 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1986 |
| From: | Jocelyn Craig NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20214L783 | List: |
| References | |
| REF-QA-99901047 99901047-86-02, 99901047-86-2, NUDOCS 8609100377 | |
| Download: ML20214L795 (25) | |
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ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON INSPECTION INSPECTION REPORT N0.: 99901047/86-02 DATE: June 21-26, 1986 ON-SITE H0tiRS: 240 CORRESPONDENCE ADDRESS:
Pacific Nuclear Systems, Incorporated Nuclear Packaging, Incorporated ATTN: Mr. David F. Jones Chairman / President 1010 South 336 Street Federal Way, Washington 98003 ORGANIZATIONAL CONTACT: Mr. Joe 011vadoti TELEPHONE NUMBER: (206) 874-2235 NUCLEAR INDUSTRY ACTIVITY: Designer and supplier of nuclear waste transpor-tation casks and handling equipment.
f ASSIGNED INSPECTOR: ,
) 8
- 4. W. Craig, Chief, Spe if,l Projects Inspection D te Section (SPIS), Vendor 'rogram Branch OTHER INSPECTOR (S - C. M. Abbate, SPIS; P. J. Prescott, SPIS; J. White, NRR R. L. ilimberg, SPIS; B. Clark, Consultant APPROVED BY: L % T J! rib dahn W. Craig, Chief, SPIS, Vdpdor Program Branch Date INSPECTION PASES AND SCOPE:
A. BASES: 10 CFR Part 71 and 10 CFR Part 21.
B. SCOPE: Review the nondestructive testing (NDT) activities performad on the two Model 125-B shipping casks. The casks will be used to transport nuclear waste from Three Mile Island Unit 2. Thc review included NDT records for visual inspection (VT) of welds, hydrostatic pressure tests, leak tests (LT), radiographic tests (RT), ultrasonic tests (UT), liquid penetrant tests (PT), and the gamna scan of the lead annulus.
PLANT SITE APPLICABILITY: Three Mile Island Unit 2.
8609100377 860902 PDR GA999 EMVNPI 99901047 PDR
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION N0.: 99901047/86-02 RESULTS: 6/21-26/86 PAGE 2 of 18 A. VIOLATIONS:
None.
B. NONCONFORMANCES:
Contrary to 10 CFR 71.119 and Section 3.3.2 of procedure number LT-26,
" Outer Cask Hydrostatic Pressure Test", Revision 0, dated November 6, 1985, LT-26 was not followed by Olympic Northwest Industries (0NI) in that pressure recording charts were not used during the outer cask hydrostatic pressure tests performed on both Model 125-B shipping casks. (86-02-01)
C. UNRESOLVED ITEMS:
None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (0 pen) Violation (86-01-01)
Contrary to Section 21.21 of 10 CFR Part 21, NUPAC has not developed and implemented appropriate procedures to provide for evaluating defects; or to assure that a director or responsible officer is informed if a basic component contains a defect or to notify the Commission when information is obtained which reasonably indicates a defect.
This area was not reviewed during this inspection.
- 2. (0 pen) Violation (86-01-02)
Contrary to Section 21.31 of 10 CFR Part 21, NUPAC issued purchase order (P0) 3104-IB, dated January 31, 1984, to (ONI) without specifying that the provisions of 10 CFR Part 21 wert applicable.
l l This area was not reviewed during this inspection.
- 3. (0 pen) Violation (86-01-03)
Contrary to paragraph 71.103 of Subpart H to 10 CFR Part 71, NUPAC failed to ensure that an adequate QA program was established and executed at a NUPAC subcontractor.
This area was not reviewed during this inspection.
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION NO.- 99901047/86-02 RESULTS: 6/21-26/86 PAGE 3 of 18
- 4. (Closed) Unresolved Item (86-01-04)
NDT documentation required by NRC C of C Number 9200 was not available in the Quality Record files for the Model 125-B casks. Applicable documentation for RT and PT conducted during fabrication was not reviewed.
Documentation for RT and PT performed during fabrication was reviewed during this inspection. The tests were performed in accordance with adequate procedures and performed by qualified personnel. This area is discussed in Sections E.3 and E.7. This item is considered closed.
- 5. (Closed) Unresolved Item (86-01-05)
RT, PT, VT, hydrostatic, UT, and LT are required by the Safety Analysis Report (SAR) prior to first use of the Model 125-B casks.
The results of these acceptance tests were not reviewed.
A review of the documentation of the results of the acceptance tests for the two Model 125-B casks determined that the procedures were adequate, the tests were performed by qualified personnel, and the results were acceptable. These items are discussed in Section E. This item is considered closed.
- 6. (Closed) Unresolved Item (86-01-06)
LT of the Model 125-B casks is required by C of C Number 9200.
The qualification records for the individual who performed the tests were not reviewed.
The records for the individual who performed the leak tests on the Model 125-B casks were reviewed during this inspection. The individual who performed the tests was found to be qualified as discussed in Section E.4. This item is considered closed.
E. INSPECTION FINDINGS AND OTHER COMMENTS:
- 1. Entrance and Exit Meetings An entrance meeting was conducted on June 21, 1986 at the PNSI/NUPAC office in Federal Vay, Washington. The purpose and scope of the inspection were discussed during this meeting. NUPAC is a subsidiary of PNSI and therefore, NUPAC utilizes the PNSI CAM. During the exit reeting conducted on June 26, 1986, the inspection findings and observations were discussed with NUPAC personnel.
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION 99901047/86-02 RESULTS: 6/21-26/86 PAGE 4 of 18 NO.-
- 2. Nondestructive Testing (NDT)
The NRC issued C of C Number 9200 which approved the design of the NUPAC Model 125-B shipping package (cask) on April 11, 1986. The NDT requirements applicable to this cask design are addressed in the C of C by reference to NUPAC drawings. These tests are also discussed in the Safety Evaluation Report (SER) for the Model 125-B casks.
Chapter .8 of the NUPAC SER for the Model 125-B Fuel Shipping Cask, Revision H, dated February 10, 1986, states that testing.is to be performed in accordance with the requirements delineated on NUPAC Drawing No. X-101-100, sheets 1 through 6, "NUPAC Model 125-B Shipping Cask, Revision H, dated February 10, 1986. Chapter 8 also provides specific steps for LT and additional requirements for shielding integrity tests. The SER states that NDT is to be performed in accordance with the ASME Code,Section III, Subsection NB. This subsection of the ASME Code requires that personnel performing NDT activities are to be qualified in accordance with the guidelines of ASNT SNT-TC-1A.
NDT records for the NDT tests performed on the Model 125-B casks were reviewed during this inspection and are discussed in Sections 3 through 9 below.
- 3. Radiographic Testing Note 12 of NUPAC Drawing No. X-101-100, Revision H, requires that radiographic testing (RT) be performed in accordance with ASME Code,Section III, Division 1, Subsection NB, Article NB-5000 and Section V, Article 2 for all longitudinal and circumferential seam welds of the outer containment vessel (OCV) inner and outer shells. RT is also required for the centrifugally cast tubes in the inner containment vessel (ICV). Subsection NB-5320 specifies the applicable radiographic acceptance standards. NB 5320 states, in part, that welds which are shown to have any discontinuities, such as any type of crack or zone of incomplete fusien or penetration, are unacceptable.
a) Outer Containment Vessel RT of the seam welds on the inner and outer shells of the OCV was performed on July 16-24, 1985, by an employee of the Nocter Corporation who was not a certified Level II exaniner in RT in accordance with the guidelines of ASNT SNT-TC-1A since he had not passed the color perception eye examination. All film
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 5 of 18 NO.: 99901047/86-02 reviewed by this Nooter employee was subsequently reviewed on July 22-24, 1985, by an employee of ONI who was a certified Level II examiner in RT per ANST SNT-TC-1A.
Nooter Corporation Welding Procedure Specification (WPS) number D-1626, Revision 0, dated May 15, 1985, and Nooter Drawing Number JN-D 68730, Revision 1, dated May 22, 1985, provide requirements for the seam welding of the inner and outer shells of the OCV. The inner shell is fabricated from one . inch thick type 304 stainless steel (SS) plate and the outer shell is fabricated from two-inch thick type 304 SS plate. Both shells consist of two sections. Each section is formed into a tube with a longitudinal weld and then the two sections are joined by a circumferential weld to achieve the 181-inch vessel length. The welds on the one-inch thick inner shell achieve 100% penetration by fusion. The welds on the two-inch thick outer shell are made by back welding a vee weld with shielded metal arc welding (SMAW) in two passes and submerged arc welding (SAW) in one pass. The root of the vee weld is backgouged to sound metal to achieve complete penetration of the vee weld. The remaining two-thirds of the wall thickness
[
is joined by SAW a U joint to complete the weld. The welding procedure on the outer shell is significant since a review of RT film should confirm that the incomplete penetration in the welds of the outer shell has been eliminated by backgouging.
This is discussed further below in the section c) Results.
Neither RT procedure nor radiographic technique sketches were available for review by the NRC inspectors. Radiographic reports were provided on Nooter Corporation form 108, June 1972 revision, and RT film review by Nooter and ONI were provided on Nooter form 109, June 1972 revision.
The RT of the longitudinal seam welds was performed with an
- X-Ray source on the outside of the shell and film on the inside diameter of the shell, b) Inner Containment Vessel l
Wisconsin Centrifugal Incorporated (WCI) RT procedure number l QCP-188, " Radiographic Procedure ASME Section VIII," Revision E, dated August 3,1984, was reviewed for applicability to the RT of the centrifugally cast tubes in the inner containment vessel of both casks. The procedure was written for ASME Code,Section VIII, and references penetrameter tables NB-5111-1 used l for the examination. Also, the procedure is in compliance with
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION NO.- 99901047/86-02 RESULTS: 6/21-26/86 PAGE 6 of 18 the ASME Code,Section III, Subsection NB-5000. The American Society for Testing and Materials (ASTM) Standard E-446 was used as a reference for class II casting imperfections.
PT of the centrifugally cast tubes in the ICV was performed on June 24 to July 27, 1985 by an employee of WCI who is a certified Level II examiner in RT in accordance with the guidelines of ASNT SNT-TC-1A.
c) Resul ts (1) The NRC inspectors reviewed 100% of the film covering RT of the longitudinal and circumferential welds on the inner and outer shells of the outer containment vessels on the Model 125-B casks. The 58 radiographs representing cask number 1 met the requirements of the ASME Code,Section III, NB-5300 and Section V, Article 2. The 29 radiographs representing the seam welds on the inner shell of cask number 2 also met these ASME Code requirements.
The 30 radiographs representing the seam welds on the outer shell of cask number 2 met the above ASME requirements except the two radiographs marked R1B-(1-4) seam, for stations 1-2 and 2-3. The NRC inspectors located an indication on the film which had not been identified by previous film reviewers. The indication was initially classified as incomplete penetration. The indication had a length of approximately 7/16-inches maximum, a width of approximately 1/16-inches maximum, and a depth estimated at 1/8-inch maximum. The indication was classified as lack of penetration because it was a straight line in the center of the weld and was estimated to be approximately 1/4 to 3/8-inches from the inside diameter of the cuter shell. The indication was determined to be in a location where hackgouging (as discussed above) failed to ensure complete penetration of the vee weld. Incomplete penetration is contrary to the requirements of the ASME Code.Section III, Subsection NB-5320 as stated above.
The identification of this weld indication which apparently did not comply with the requirements of C of C Number 9200 was discussed with NUPAC personnel. NUPAC requested that X-Ray, Inc. have another NDT examiner cualified as a level III in RT review the radiographs for stations 1-2 and 2-3 of the longitudinal weld cf cask 2. The X-Ray, Inc.
examiner stated that he believed that the indication was
l ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 7 of 18 NO.: 99901047/3 02 a slag inclusion. Slag with the dimensions specified above ~
would be acceptable and satisfy the requirements of C of C Number 9200.
Subsequent to the inspection, these radiographs for RIB-(1-4) seam 1-2 and 2-3 were computer enhanced and reviewed by three NDT Level III examiners serving as consultants to the NRC. The consensus of these examiners was that the indication was a slag inclusion in. the weld and acceptable under the ASME Code requirements specified in C of C Number 9200. A summary of this review is attached as an addendum to this report.
(2) WCI fabricated and performed RT for the seven centrifugally cast tubes in each cask. The NRC inspectors reviewed 20%
(180 radiographs) of the 840 radiographs covering RT of the seven centrifugally cast tubes in the ICV of each cask.
Based upon the radiographs reviewed and a review of the RT reports prepared by WCI, RT was performed in accordance with the written procedure, OCP-188, the ASME Code,Section V, and the results met the requirements of Subsection NB-5000 (3) Several weaknesses were identified during the review of RT records. These include data sheets documenting the review of radiographs which did not document the imperfections or artifacts present and the initial review of radiographs for the OCV which was performed by an individual who was not qualified to the standards specified in C of C Number 9200.
No items of nonconformance or unresolved items were identified i
in this area.
l
! 4. Fabrication Leak Verification 1
a) Procedure Review Sheet 1, NUPAC Drawing No. X-101-100, Revision H, General Note 19 specifies that the inner vessel and outer containment boundaries shall be 1 ak tested (LT) to demonstrate a leak rate l
not to exceed 1 x 10~9 atmospheric cubic centimeters per second (atm-cc/sec) per NUPAC leak verification procedure LT-21.
NUPAC procedures LT-21(a), " Inner Vessel Fabrication Verification Leak Test", and LT-21(b), " Outer Cask Fabrication Verification Leak Test", were approved for implementation on November 11, 1985. These procedures provided for the following tests to be i
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 8 of 18 NO.: 99901047/86-02 performed on each of the two packages constructed: 1) ICV -
Structural Integrity, Lid 0-Ring Seal Sealing Integrity, Rupture Disk Sealing Integrity, Vent Port Closure Bolt Sealing Integrity; and 2) OCV - Structural Integrity, Lid 0-Ring Seal Sealing Integrity, Rupture Disk Sealing Integrity, Vent Port Closure Bol t.
The tests were performed with consideration of guidelines provided in Regulatory Guide 7.4, " Leakage Tests on. Pack-ages for Shipment of Radioactive Materials", and ANSI N14.5-1977, "American National Standard for Leakage Tests on Packages for Shipment of Radioactive Materials." Since the specified acceptance criteria for all tests was 1 x 10-7 atm-cc/sec, the Helium Mass S which is sensitive to 5 x 10-gectrometric Envelope atm-cc/sec, was used. Method, Chicago Bridge and Iron (CB&I) performed the LT on the ICVs for each cask at their facility in Salt Lake City, Utah. These tests took place on November 13, 1985 and December 18, 1985.
NUPAC performed the LT on the OCVs for both casks at the ONI facility in Bremerton, Washington. These tests took place November 27, 1985 and December 17, 1985. NUPAC QA witnessed all leak tests performed on the two casks.
While NUPAC's LT-21 procedures identified the basic methodology for all helium leak tests performed, CB&I supplemented LT-21 with their own procedures, MST1P, " Helium Leak Testing Procedures-NUPAC Model 125-B Shipping ICV Assembly". This procedure was written in accordance with the test description in the SAR and was approved for use by NUPAC on October 31, 1985.
Both procedures detail equivalent techniques to perform leak testing. Further, while the test procedures LT-21(a) and (b) were reviewed and determined to be adequate, the inspector l
noted that the actual secuence followed during leak testing deviated from the procedure, but the procedure was not revised to reflect the actual test sequence.
b) Personnel Cualification During the NRC inspection conducted May 5-8, 1986, the qualifi-cations of the NUPAC employee who performed LT was identified as an unresolved item.
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION NO.- 99901047/86-02 RESULTS: 6/21-26/86 PAGE 9 of 18 10 CFR 71.119, " Control of special processes" requires that measures be established to assure that special processes such as NOT be controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements. NUPAC Procedure QP-14, " Quality Assurance Training" identifies criteria for the certification of personnel in areas pertaining to inspection, examination and testing.
Qualification pursuant to the ASME Code,Section III, Division I, Subsection NB, NB-5000 and Section V was a specific commitment in NUPAC's application relative to the Model 125-B cask for personnel performing liquid penetrant (PT), ultrasonic (UT),
and RT examination. This commitment directly references the qualification guidelines identified in SNT-TC-1A but does not apply to personnel performing LT.
c) Results The inspector reviewed the data associated with the tests and the results indicated that the acceptance criteria of 1 x 10-7 atm-cc/sec was achieved for all tests. In some instances the tests indicated leaking sufficient to require retesting. In these instances Supplier Disposition Requests (SDRs) were written to iMntify the problem and recommended the corrective action recessary. The inspector also reviewed the calibration data regarding the Mass Spectrometer Leak Detector (MSLO) used for the helium leak tests and verified that the MSLD was calibrated immediately before and after each test.
A review of the qualifications of the NUPAC employee who perform-ed the LT was performed including his training, experience, and abili ty. Interviews with the individual who performed and witnessed the tests and with his supervisor were conducted. The inspectors concluded that the individual was qualified and capable of performing LT and had an excellent working knowledge of LT based upon experience and training.
Based upon the material reviewed, the fabrication leak tests of all vessels used for the assembly of both Model 125-B shippirg casks were performed by qualified personnel and in Tes accordance with written procedures and requirements.results indicated t atm-cc/sec was achieved in all cases.
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 10 of 18 NO.: 99901047/86-02 No items of nonconformance or unresolved items were identified in this area.
- 5. Visual Examination a) Personnel Qualification General Note 9 on Ceneral Arrangement Drawing No. X-101-100, Revision H, requii's that all welds be visually inspected in accordance with Section 8.15.1, " Quality of Welds", of the American Welding Society (AWS) Structural Welding Code for Steel, DI.1-85. VT requirements are also contained in NUPAC's
" Procedure for Visual Inspection, Weldments and Adjacent Materials", VT-01, Revision 0, dated February 19, 1985. Visual inspection (VT) of welds consists of examination of the weld preparation, observation of in-process welding, and the exam-ination of the dimensional accuracy and quality of the final weld.
Section 3.1 of VT-01 requires that NUPAC assure that all person-nel performing VT are qualified and trained. Section 4.1 of VT-01 requires that all personnel conducting VT be certified to the requirements of Section IV of AWS QC-1, " Qualification and Certification of Welding Inspectors" or be approved specifically for VT by the Corporate Quality Director.
CB&I and ONI persotinel performed the VT of the welds on the two Model 125-B shipping casks. The shop travelers used during the fabricatien of the casks identify the steps in which VT was performed and include an area for the sign-off of the inspection indicating that the VT was performed and the results obtained.
Eight employees at CB&I were certified as CB&I Level II VT examiners and one employee was certified as a CB&I Level I VT examiner. The person at ONI performing VT was also qualified to be a VT examiner. The records for each of the VT examiners were reviewed with respect to eye examination results, training received in the area of VT, and experience in VT. The individuals performing VT were found to be qualified to the requirements outlined in NUPAC procedure VT-01.
l i
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 11 of 18 NO.: 99901047/86-02 b) Procedure Review Section 8.15.1 of AWS D1.1-85 sta'tes that welds shall be accept-able by visual inspection if various criteria are met. These criteria include no cracking, complete fusion and penetration, and undercut and underrun within acceptable dimensions. VT-01 provides the basic methods and requirements for visual examin-ation of weldments and adjacent materials. The procedure was reviewed and was adequate to perform an acceptable visual examination of welds and adjacent materials. The procedure outlines the responsibility and acceptance criteria to be used.
The procedure also identifies the two methods which can be used to perform VT and the steps to be followed during visual inspection.
Shop travelers used during the fabrication were reviewed with respect to VT. VT was performed and signed off by qualified examiners from CB&I and ONI. In addition, a NUPAC employee observed VT as well as other fabrication activities at CB&I and ONI.
This NUFAC employee was certified as an AWS Welding Inspector per the requirements of Section IV of AWS QC-1. NUPAC quality planners (shop travelers) were also reviewed during this inspection, and it was found that the NUPAC VT examiner had accepted, stamped, and dated the visual inspection performed on the welds.
No items of nonconformance or unresolved items were identified in this area.
- 6. Hydrostatic Pressure Tests e) Procedure Review Section 71.85(b) of 10 CFR Part 71 requires, in part, that the contair, ment system be tested at an internal pressure at least fifty percent higher than the maximum normal operating pressure.
Note 8 on NUPAC Drawing No. X-101-130, Revision B, dated Jur.e 21, 1985, " Assembly ICV NUPAC Model 125-8 Shipping Cask",
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 12 of 18 NO.: 99901047/86-02 requires that the inner vessel containment shall be subjected to an internal test pressure equal to 190 pounds per square inch (psi) and that testing be performed in accordance with the NUPAC fabrication verification pressure test procedure, LT-25. Note 8 on Drawing No. X-101-140, Revision A, dated June 25, 1985, " Assembly Cask NUPAC Model 125-B Shipping Cask,"
requires that the outer cask containment boundaries be subjected to an internal test pressure equal to 190 psi and that the testing be in accordance with the NUPAC fabrication verification pressure test procedure, LT-26.
The hydrostatic pressure test is performed by filling the cask with water and pressurizing it to 190 psi. The pressure is observed for ten minutes and the test is acceptable if the pressure drop does not exceed five psi over the ten minute test period.
CB&I performed the inner vessel containment hydrostatic pressure tests while ONI performed the outer vessel containment hydro-static pressure tests.
b) Inner Vessel Containment LT-25, " Inner Vessel Hydrostatic Pressure Test", Revision 0, dated November 6, 1985, and SHTP-1, " Shop Hydrostatic Test Procedure", Revision 1, dated August 8, 1985, were used to perform the ICV hydrostatic pressure tests on both Vodel 125-B Shipping Casks. LT-25 outlines the scope, referenced documents, technical requirements, test conditions, and acceptance criteria, but does not specify test media temperature or pressure gage requirements. SHTP-1 is a CB&I procedure which was used in additien to LT-25 to perform the ICV hydro-static pressure tests. SHTP-1 is a detailed procedure which defines the test step-by-step and includes safety consideraticns, test equipment layouts, test media temperature, and pressure gage requirements.
The equipment used during the test was calibrated prior to the tests. The two test result recording charts for the casks indicated _that the pressure was held at the required 190 psi for ten minutes with no drop in pressure.
l ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION NO.- 99901047/86-02 RESULTS: 6/21-26/86 PAGE 13 of 18 ,
1 l
c) Outer Vessel Containment LT-26, " Outer Cask Hydrostatic Pressure Test", Revision 0, dated November 6, 1985, was the procedure used by ONI to perform the outer vessel pressure tests and delineates the requirements for performing the hydrostatic pressure test on the outer vessel containment. The procedure includes the referenced documents, technical requirements, test conditions, and acceptance criteria, but temperature of test media and pressure gage calibration requirements were not specified.
Calibration data was reviewed and it was noted that the equipnent used during the tests was calibrated prior to use. Section 3.3.2 of LT-26 requires that recording charts be used, but no pressure recording charts were used during the outer vessel containment pressure tests.
The test results for these tests were transmitted from ONI to NUPAC by two letters dated November, 20, 1985 and December 11, 1985, stating that the tests were performed in accordance with LT-26 and that the results were acceptable. A NUPAC QA employee was present during the tests and NUPAC accepted the results.
Nonconformance 86-02-01 was identified in this area.
- 7. Liquid Penetrant Testing The requirements for liouid penetrant testing (PT) are contained in Note 10, NUPAC Drawing No. X-101-100, Sheet 1, Revision H, which specifies that welds identified en the drawings for the NUPAC Model 125-B casks are to be liauid penetrant inspected on rout and final pass in accordance with ASME Code,Section III, Division I, Subsection NB, Article NB-5000 and Section V, Article 6.
Additionally, the SER for these casks states that the drawings shall identify the weld joints to be nondestructively examined, the method used, and the code or standard for the examination procedure.
The NRC inspector reviewed the applicable PT procedures, personnel qualifications and test results for two vendors who performed PT on the Model 125-8 shipping package for NUPAC. CB&I Procedure PT SWI, and ONI Procedures QI 12.1 and QI 12.7 were reviewed.
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON 1
REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 14 of 18 NO.: 99901047/86-02 A representative sample of PT reports written by CB&I and ONI for the Model 125-B shipping package were reviewed. The documentation reviewed for the PT reports indicated that the PT results were satisfactory. Additionally, CB&I shop travelers were reviewed.
These travelers identified the steps during cask fabrication which specified PT examination and the individuals who performed the PT.
Based upon this review, PT was performed as specified in the travelers.
A sample of NDT travelers and NDT reports which were reviewed for PT were written in accordance with the applicable test procedures. It was also noted that the personnel records maintained by NUPAC on their sub-tier vendors for PT were current and found to be in accordance with the applicable procedures.
No items of nonconformance or unresolved items were identified in this area.
- 8. Gamma Scan The description of the Model 125-B cask contained in C of C Number 9200 includes the 3.88-inch thick lead annulus. The SER for the Model 125-B cask also discusses the lead shielding and corresponding radiation readings for the casks. Specifically, the radial shielding of the Model 125-B cask consists of 3.88-inches of lead sandwiched by a 2-inch outer cask steel cylinder and a 1-inch inner cask steel cylinder proceeded by a 1-inch steel inner vessel shell.
Section 8.0, " Acceptance Tests and Maintenance Program," of the SAR for the casks states that the lead shielding integrity shall be confirmed via gamma scanning. The SAR also discusses the method utilized tc derive maximum acceptable dose values. The acceptable values were determined by NUPAC based solely upon calculations; representative test blocks were not fabricated and used to determine acceptable gama scan readings. The acceptance values were based upon calculations which assumed up to a 10% Icss of shielding.
a) Procedure The gamma scan of the Model 125-B casks was performed for NUPAC by X-Ray, Inc. Purchase Order (P0) 3206-IT, dated July 30, 1985, contained the specifications for this test.
Included in the P0 were the requirements that the gamma scar.
be performed in accordance with NUPAC Procedure GS-001,
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 15 of 18 NO.: 99901047/86-02 Revision 4, that the scan be performed at Metalex Products, Ltd.,
and that the gamma scan be performed under the presence and direction of NUPAC QA personnel.
JUPAC Procedure GS-001, Revision 4, dated February 2, 1983, outlines the minimum requirements for gama scan of lead lined transportation casks. Addendum No. 1 to GS-001, Revision 4, dated September 9,1985, states that no reading indicating a loss of shielding in excess of 5% from the normal design lead thickness will be acceptable.
b) Results X-Ray, Inc. reports numbered 9255, dated October 2, 1985, and 9279, dated October 24, 1985, document the gama scan test results for cask 1 and 2. These reports state that the gamma scan was performed utilizing GS-001, Revision 4, Addendun No.1, and identify the source and survey instruments used. Charts of gama readings (grids as specified in GS-001) ware attached to the reports.
- During the gamma scan, readings which exceeded a 5% decrease in lead shield thickness values were identified and Quality Discrepancy Reports (QDRs) were written (QDR Nos. 243 and 263).
Since the readings did not exceed the 10% decrease in lead shield thickness acceptance values contained in the SAR, NUPAC deter-mined that the observed gamma readings were acceptable.
SDR No. 674 dated September 11, 1985 was also reviewed. This SDR identified a reduction in the lead annulus thickness frcm the value of 4.00 to 3.75-inches specified in NUPAC Orawing No.
X-101-120 to an actual value of approximately 3.482-inches to 3.62-inches on cask 1 and actual value of approximately 3.454-inches to 3.489-inches on cask 2. These values were the result of dimensional tolerances of the 2-inch and 1-inch shells and due to the 2-inch shell being 0.100-inch over gage. NUPAC determined that based upon the following items the casks were acceptable for use: (1) the minimum acceptable defect free lead thickness was 3.488-inches (based upon gamma scan acceptance criteria), and (2) the additional thickness of steel provides a !
lead equivalent shielding value. l The inspectors reviewed the radiation readings recorded on the grids during the gamma scan for each cask. No readings were identified which exceed the acceptance values contained in the SAR.
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON 1
REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 16 of 18 NO.: 99901047/86-02 No items of nonconformance or unresolved items were identified in this area.
- 9. Ultrasonic Examination NUPAC Drawing No. X-101-100, sheet 1, Revision F, Note 11 states that ultrasonic inspection (UT) shall be performed on indicated welds and fcrgings in accordance with ASME Code,Section III, Division 1, Subsection NB, Article NB-5000 and Section V, Article 5. During this inspection the inspectors reviewed the applicable NUPAC drawings to identify the welds and forgings which required UT. Additionally, the qualifications of the personnel who performed the UT, the test procedures used and the test results were reviewed.
Gulf Coast Machine and Supply Company (Gulfco) performed UT on various forgings used in the Model 125-B casks, including cask lid (Gulfco Report No. UT-3212), cask base (Gulfco Report No. UT-3219), and outer cask collar (Gulfco Report No. 3218 and 3221). The UT reports from Gulfco certified that personnel performing UT examinations had been qualified to SNT-TC-1A and that the forgings identified on the UT reports had been inspected and found acceptable. Additionally, the Gulfco UT procedure UT-388 was reviewed to determine whether or not the procedures were adequate. ASME Code Section V, Article 5, Ultrasonic Examination General Requirements was the basis for the procedural review.
Eased upon the UT documents reviewed, Gulfco UT activities were performed by qualified personnel utilizing adeouate procedures, and the UT test results were acceptable. However, the UT data generated durirg the tests (transducer recordings) was not available to be reviewed.
CB&I performed UT on welds made during Model 125-8 cask assembly.
CB&I shop travelers identify the operations / steps performed during assembly of the casks. These travelers were audited to determine whether UT had been performed on the appropriate welds and which individuals had perforried the UT. CB&I UT reports and CB&I UT procedure UT-1-PSX were also reviewed.
Based upon an audit of CB&I travelers and CB&I Record Drawings i and NUPAC Drawing No X-101-100, Revision H, UT was performed upon the appropriate welds. Further, based upon a review of CB&I UT examination procedures. UT reports and CB&I NDT personnel aualification records, UT testing was performed by qualified personnel utilizing adeouate procedures. While the UT test results were acceptable, CB&I UT reports were not l
l
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 17 of 18 N0.: 99901047/86-02 completely filled out and the data generated during the UT tests (transducer recordings) was not available for review.
UT activities at CB&I were also reviewed by NUPAC personnel during cask fabrication.
NUPAC QA Instructions require a NUPAC inspector to verify certain activities at vendors performing work for NUPAC. For example. 0A Instruction IT-56, Body Weldment, ICV requires a NUPAC inspector to verify activities such as UT of welds and identification of welds to ensure that testing is performed in accordance with requirements of the C of C. IT-56 was performed by a NUPAC inspector during fabrication of both Model 125-B casks.
No items of nonconformance or unresolved items were identified in this area.
F. PERSONS CONTACTED:
- C. Temus, Director of Regulatory Affairs, NUPAC
- J. R. Olivadoti, QA Manager, NUPAC
- G. R. Hayes, EG&G Quality Engineer, EG&G Idaho, Inc.
K. Hanna, QC Engineer, NUPAC D. Schmoker, Vice President of Engineering, NL' PAC
- Attended Exit Meeting
ORGANIZATION: NUCLEAR PACKAGING INCORPORATED FEDERAL WAY, WASHINGTON REPORT INSPECTION RESULTS: 6/21-26/86 PAGE 18 of 18 NO. L 99901047/86-02 Addendum to Inspection Report No. 99901047/86-02 Subsequent to the NRC inspection conducted June 21-26, 1986, at the NUPAC facility in Federal Way, Washington, information concerning the indication on the radiographs classified as incomplete penetration was reviewed. The NRC inspectors had located an indication on film marked R1B-(1-4), film 2-3 which they interpreted to be incomplete or lack of penetration.
Incomplete penetration does not meet the requirements of the ASME Code,Section III, Subsection NB, Article NS-5320 which specifies that incomplete penetration is unacceptable. The linear length of the indication was approximately 7/16 or 0.438-inches. Article NB-5320 (b)(2) specifies that any elongated indication which has a length greater than 1/3 t is a discontinuity that is unacceptable.
The outer shell of the outer cask longitudinal seam weld has a thickness of 2 1/8-inches. Since t is the thickness of the thinner portion of the weld,1/3 t equals 1/3 of 2 1/8-inches which equals 0.708-inches. Therefore, the 0.438-inch elongated indication is acceptable under NB-5320(b)(2) if the indication was determined to be a slag inclusion.
On July 15, 1986, Messrs. Sam Wenk of Port St. Lucie, Florida and Ed Martindale of EMAR Enterprises who are certified to be qualified to a NDT Level III in RT in accordance with the guidelines of ASNT SNT-TC-1A, reviewed the RT film marked RIB-(1-4) seam, Film # 2-3. The NRC inspectors who performed the inspection were also present during this review and discussion of the indication and additional new information provided by a computer enchancment of the radiograph.
In addition to the initial 0.438-inch indication, a second 0.125 inch indication was identified approximately 0.250-inches from the initial indication toward station number 3.
The review concluded that the indications exhibited width without sharpness
% each end, and even density across the indication which suggests volume.
These characteristics of the indications and the location of the indications suggest volumetric slag inclusions. The consensus of the three RT Level III interpreters, and the NRC inspectors was that the 0.438-inch and 0.125-inch long linear indications are cl6ssified as slag which are acceptable to the i
recuiremer.ts of the ASME Code,Section III, Subsection NB, Article NB-5320.
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