ML20211G953
| ML20211G953 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/1986 |
| From: | Abbate G, Jocelyn Craig NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20211G921 | List: |
| References | |
| REF-QA-99900768 NUDOCS 8611040340 | |
| Download: ML20211G953 (13) | |
Text
{{#Wiki_filter:* ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORT INSPECTION INSPECTION N0.: 99900768/86-01 DATE: 9/8-10/86 ON-SITE HOURS: 48 CORRESPONDENCE ADDRESS: Westinghouse Hittman Nuclear, Inc. ATTN: Mr. Bruce Rowe Quality Assurance Manager 9151 Rumsey Road Columbia, Maryland 21045 ORGANIZATIONAL CONTACT: Mr. Bruce Rowe TELEPHONE NUMBER: (301) 964-5000 NUCLEAR INDUSTRY ACTIVITY: Westinghouse Hittman Nuclear, Inc. is a Certificate of Compliance (C of C) holder for a number of transportation packages (casks) and provides services for the shipping of radioactive material. A , s- ~ r ASSIGNED INSPECTOR: , C' o C/.lM.Abbate,SecialProjects1ns@ction Date' Section (SPIS OTHER INSPECTOR (S : . P. McIntyre, SPIS APPROVED BY: 6k t 464n W. Craig, Chief, SPIS, Vbddor Progran Branch Date' INSPECTION BASES AND SCOPE:
- A. BASES
- 10 CFR Part 71,10 CFR Part 21.
l B. SCOPE: Review Westinghouse Hittman Nuclear, Inc. (Hittman) activities related to 10 CFR Part 71 and 10 CFR Part 21 with respect to transpor-tation casks, follow-up on previous inspection findings. I PLANT SITE APPLICABILITY: Nuclear power facilities who are registered users of the casks for which Hittman is the C of C holder. l 8611040340 861030 PDR QA999 EMVWHIT 99900768 PDR
ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORf INSPECTION RESULTS: PAGE 2 of 8 NO.: 99900768/86-01 A. VIOLATIONS:
- 1. Contrary to Section 21.31 of 10 CFR Part 21, Westinghouse Hittman Nuclear, Inc. (Hittman) issued Purchase Orders (P0) for basic ccmponents, N43369, dated April 22, 1986 and N43888, dated July 22, 1986, to the George P. Thomas Rubber Company for replacement gaskets and N43492, dated May 22, 1986, to the Alleghany-York Corporation for replacement 0-rings, without specifying that the provisions of 10 CFR Part 21 were applicable.
This is a Severity Level V violation (Supplement VII).
- 2. Contrary to paragraph 71.133 of Subpart H to 10 CFR Part 71 and Sections 16.1.3 and 16.2.15 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1, 1985, the Corrective Action Log indicated that sevefal responses to Corrective Action Memos (CAM) from the Action Designees had not been received for items identified in 1985, several CAMS from 1984 and 1985 remain open and the last documented review of the CAM system by the QA Manager was performed on April 19, 1985.
This is a Severity Level V violation (Supplement V).
- 3. Contrary to paragraph 71.137 of Subpart H to 10 CFR Part 71 and Sections 18.1.7 and 18.2.4 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1, 1985, audits scheduled to be performed in July and August,1986, have not been conducted and the corrective acticns for deficient areas identified in the 1985 Internal Audit have not been re-audited l to verify implementation.
l This is a Severity Level V violation (Supplement V). I
- 4. Contrary to paragraph 71.137 of Subpart H to 10 CFR Part 71 and Section 18.2.12 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 3, 1985,
! three deficiencies identified in audit number 36-09 were not l documented on a CAM as required. This is a Severity Level V violation (Supplement V). 1 l B. NONCONFORMANCES: None.
ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORT INSPECTION PAGE 3 of 8 NO.: 99900768/86-01 RESULTS: C. UNRESOLVED ITEMS: None. D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (Closed) Violation 82-01-01:
Contrary to paragraph 21.21(a) of 10 CFR Part 21, procedures had not been adopted to provide for: (1) evaluating deviations or informing the licensee or purchaser; and (2) assuring that a director or responsible officer was informed if the supplied component (a) failed to comply or (b) contained a defect. During this inspection, the NRC inspector reviewed Procedure HNDC-C-015, Revision 1, dated February 2,1983, " Reporting of Defects and Noncompliances." The procedure outlines the requirements, responsi-bilities, and steps to be taken when a defect or noncompliance is identified. The procedure references Westinghouse Advanced Energy. Systems Division (WAESD) Procedure DP-906, " Identification and Reporting of Nuclear Safety Related Noncompliances and Deficiencies." Revision 1, dated February 13, 1984, of DP-906 was also reviewed. This procedure provides an interface with the provisions of HNDC-C-015 to ensure that potentially reportable items are reviewed by the WAESD General Manager. Additionally, evaluations performed by Hittman's Operation Review Committee (0RC) of potentially reportable conditions were examined. Based upor, this review, this item is considered closed.
- 2. (Closed) Violation 82-01-02: ,
Contrary to paragraph 21.51(b) of 10 CFR Part 21, records were not prepared with respect to failures (in February through June 1981 testing) of Flextron Urethane 66-11 foam to meet the energy absorption characteristics described in the NRC approved Safety l Analysis Report (page 71) for the HN-200 cask. During an investigation conducted on January 28, 29; February 1-3, 16-19; March 1-5, 10, 1982, Report No. 99900768/82-02, the investi- ' gator concluded that the foan in the HN-200 impact skirts met the specifications presented in the Safety Analysis Report. This item is considered closed. 1
~ ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORT INSPECTION RESULTS: PAGE 4 of 8 N0.: 99900768/86-01 E. INSPECTION FINDINGS AND OTHER COMMENTS:
- 1. Entrance and Exit Meetings An entrance meeting was conducted on September 8,1986 at the Westinghouse Hittman Nuclear, Inc. (Hittman) office in Columbia, Maryland. The purpose and the scope of the inspection were discussed during this meeting. Hittman is a subsidiary of the Westinghouse Electric Corporation. Hittman utilizes two Quality Assurance (QA) programs. C-100, is the QA program for the engineering, design, procurement, fabrication and initial testing of radwaste shipping packages, and C-200 is the QA program for the use of radwaste shipping packages. Both programs have been reviewed and approved by the NRC and encompass the criteria of 10 CFR Part 71, Subpart H. Cask designs are authorized for use through the Certificate of Compliance (C of C) issued by the NRC.
Hittman is the C of C holder.for several cask designs. During the exit meeting conducted on September 10, 1986, the inspection findings and observations were discussed with Hittman personnel.
- 2. Maintenance and Repairs Hittman repairs and performs periodic maintenance on transportation casks. These activities are governed by Procedure HNDC-0-001, " Cask Maintenance and Repair," Revision 1, dated January 4,1983.
During the inspectior., the inspector examined the Rcutine Scheduled Maintenance Log for 1986. Routir:e Scheduled Maintenance consists of changing gaskets and 0-rings, leak testing and other maintenance as specified in the C of C and by Hittman. The log was divided to assure that each cask received routine scheduled maintenance at least once every four months. . The log included the log number, package identi-fication number, dates of maintenance, where the maintenance was performed, who performed the maintenance, the tag numbers of the replacement material which was used, a sumary of the work performed and a summary of the package condition. During the routine inspections, form HNDC-Q-005-A, dated March 1982, is used. This form is a checklist of items to be inspected and includes items such as gaskets, nuts, bolts, and paint. After being completed, the forms are kept in a file which comprises the routine inspection history of the casks for that year.
ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORT INSPECTION N0.: 999007E8/Bf-01 RESULTS: PAGE 5 of 8 When an item needs repair, a Corrective Action Pemo (CAM) is written. The CAM describes the condition and the recommended action to be performed by the action designee. Replacement parts are identified in the storeroom by a green tag. Only green-tagged items may be used for maintenance activities. When the part is used in repair or replacement activities, the tag number and package on which it is being used are recorded on the Cask Materials Log Sheet, form 10. The inspector reviewed individual files for three transportation packages and found that the information in the files regarding maintenance corresponded to the information on the Routine Scheduled Maintenance Log and packages were receiving routine inspections and maintenance at least every four months. The inspector also noted that the replacement parts in the storeroom were green-tagged and that the Cask Materials Log. Sheet was being utilized and was up to date. Purchase Orders (PO) N43369, dated April 21, 1986, N43492, dated May 12, 1986, and N43888, dated July 22, 1986, were reviewed. These P0s were for replacement gaskets and 0-rings. During the review it was noted that these P0s for basic componants.were written without specifying that the provisions of 10 CFR Part 21 were applicable. Violation 86-01-01 was identified in this area. Four P0s for replacement studs, nuts, bolts, and washers were also examined. All but one P0 required a C of C from the supplier. P0 36330, dated December 2, 1980, did not require a C of C from the supplier, but Hittman sent samples to an outside company to perform chemical analysis on the material to assure that it met the specifi-I cations. In one case, one sample failed to meet the specifications and the lot from which this sample was obtained was rejected by Hittman.
- 3. Corrective Action Memo System The Corrective Action Memo (CAM) System implemented by Hittman is outlined in Section 16 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1, 1985.
This section outlines the requirements, responsibilities, and procedure to be followed when a deficiency is identified. The Corrective Action Log was reviewed. This log lists the CAM identification number, when a response was received from the action designee, and when the CAM was closed out. During the review it was noted that no responses had been received for five items in 1985 and
ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORT INSPECTION NO.: 99900768/86-01 RESULTS: PAGE 6 of 8 that six items from 1984 and 1985 remain open. Additionally, Section 16 of C-200, requires that the OA Manager regularly review the CAM system to assure follow-up action is being taken. The inspector examined the CAM Review Sheet and noted that the last documer.ted review of the CAM System by the QA Manager had been performed on April 19, 1985. Violation 86-01-02 was identified in this area. The inspector also reviewed CAM 86-05, dated April 22, 1986. The deadline for the response by the action designee was May 20, 1986, however, the response was not received until July 1,1986. Although the response had been completed, it was not completed in a timely manner nor had the information been recorded in the CAM log.
- 4. Audits Section 18 of the Hittman QA Manual, " Audits," as well as internal and external audits performed by Hittman in 1985 and 1986 were reviewed. The inspector also reviewed the 1984 and 1985 annual audit of Westinghouse Hittman by the Westinghouse Technical Services Division (WTSD).
Internal The 1985 and 1986 Internal Audit Schedules were reviewed during the inspection. The schedule lists the areas to be audited and the sta M of the audits (response to findings received, follow-up action, item closed out). The eighteen criteria of 10 CFR Part 71 Subpart H are covered in audits performed by Hittman, Westinghouse Advanced Enert:y Systems Division (WAESD) or customers. It was noted that corrective actions for 1985 Internal Audit findings had not been re-audited te verify implementation and the 1986 Internal Audit Schedule did not reflect current activities in that the audits scheduled to be per-formed in July and August, 1986, have not been conducted. The inspector also reviewed several internal audit reports from 1985 and 1986; 85-03, 85-05, 85-07, 85-09, 85-10, 85-11, 86-04, and 86-09 were examined to determine if Hittman is performing audits in accordance with the requirements of Section 18. Some of the audit reports had not been written and issued in a timely manner. Audit 85-10 which inspected several different sections of the Hittman QA manual was performed in October 1985, with four deficiencies identified, however, the audit report was
ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, PARYLAND REPORT INSPECTION N0.: 99900768/86-01 RESULTS: PAGE 7 of 8 not officially distributed until April of 1986. Audit 85-11 was performed in November 1985, the audit report was issued January 1986. Audit 86-09 was conducted in July 1986, with a draft report written. The report had not been officially issued at the time of the NRC inspection. In addition, the three audit findings listed in the report had not been documented on a CAM as required by Section 18 of the QA manual. Violations 86-01-03 and 86-01-04 were identified in this area. External The inspector reviewed the Hittman Evaluated Suppliers List to determine which vendors are required to be audited by Hittman. The list consisted of five vendors including Riteway Machine and Specialty Company (Riteway) and Nuclear Packaging, Inc. (NUPAC), manufacturers of transportati.on casks for Hittman. Although no 0A requirement exists, it was noted that no external audit schedule for 1986 had been developed, and one vendor on the Evaluated Suppliers List had not been audited in 1985. The audits of the two cask suppliers reviewed by the NRC inspector were conducted with appropriate checklists and met the require-ments of Section 18 of the QA manual. No violations were identified during this part of the inspectiun.
- 5. Procurement The NRC inspector reviewed the Hittman process for the procurement of safety related Radwaste Shipping Packages. Section 4 of the Hittman QA Manual, " Procurement Document Control," delineates the sequence of actions to be accomplished for the preparation, review, approval and control of procurement documents used for the purchase of items and services for Hittman packages.
Section 4 states that the purchase requisition shall include such information as:
'1. statement of work to be performed by the supplier,
- 2. technical requirements,
- 3. 0A requirements of 10 CFR Part 71 Subpart H, as appropriate, 7
~
ORGANIZATION: WESTINGHOUSE HITTMAN NUCLEAR, INC. COLUMBIA, MARYLAND REPORT INSPECTION N0.: 99900768/86-01 RESULTS: PAGE 8 of 8
- 4. documentation (such as drawings, specifications, procedures, material certifications),
- 5. requirement for access to supplier facilities,
- 6. extending applicable requirements to subtier vendors when necessary.
The inspector reviewed the Hittman procurement documents concerning Riteway for the fabrication of an HN-100 series 3 cask, and NUPAC for the fabrication of an HN-500 cask. These documents included the P0s and the Cask Fabrication Specifications (SPEC). These SPECS were referenced on the P0. The SPECS set forth the technical and QA requirements to be placed on the supplier fabricating the cask. The technical requirements include performance, materials, fabri-cation, welding, and nondestructive testing procedures, while the QA requirements include 10 CFR Part 71 Subpart H,10 CFR Part 21, buyers surveillance, audits, and C of Cs.
~
The inspector also audited the Final Data Package from the supplier to assure that requirements set forth in the P0 and the SPEC had been included. The Data Package included documentation such as the C of C, weld certifications, material test reports, NDE reports, gamma scan and UT examination reports, final paint inspection reports, and appropriate travelers. All procurement documents reviewed met the Hittman QA and procedural requirements and included the necessary documentation. Data Packages reviewed from Riteway and NUPAC included information that was stipulated in the P0 and the SPEC. No violations were identified during this part of the inspection. F. PERSONS CONTACTED: l *B. Rowe, QA Manager I
*J. Pawlik, Administrative Services Manager T. Johnson, President
*S. McKew, Transportation and Maintenance Manager f
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