Information Notice 2000-11, Licensee Responsibility for Quality Assurance Oversight of Contractor Activities Regarding Fabrication and Use of Spent Fuel Storage Cask Systems
| ML003734271 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/2000 |
| From: | Brach E, Marsh L NRC/NMSS/SFPO, Operational Experience and Non-Power Reactors Branch |
| To: | |
| Poslusny C NMSS/SFPO (301) 415-1341 | |
| References | |
| IN-00-011 | |
| Download: ML003734271 (6) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
OFFICE ON NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
August 7, 2000
NRC INFORMATION NOTICE 2000-11:
LICENSEE RESPONSIBILITY FOR QUALITY
ASSURANCE OVERSIGHT OF CONTRACTOR
ACTIVITIES REGARDING FABRICATION AND USE
OF SPENT FUEL STORAGE CASK SYSTEMS
Addressees
All U.S. Nuclear Regulatory Commission (NRC) 10 CFR Part 50 and Part 72 licensees, and
Part 72 Certificate of Compliance holders.
Purpose
The NRC is issuing this information notice (IN) to remind general and site specific licensees of
their responsibilities to assure that the quality assurance requirements of Part 72, Subpart G, to
Title 10 of the U.S. Code of Federal Regulations (CFR) have been met before a dry cask
storage system is placed in service at their nuclear power plants. The regulations require that
nuclear power plant licensees assume full responsibility for the overall safety and operational
use of the dry cask storage system at their sites. The nuclear power plant licensee is also
responsible for assuring that the fabrication and preparation for use of the dry cask storage
system, and the contractors activities associated with the dry cask storage system, conform
with NRC regulations, the Certificate of Compliance (CoC), and the license conditions for the
nuclear power plant. This IN discusses a number of examples of inadequate implementation of
quality assurance (QA) programs identified in recent NRC inspections. It is expected that
recipients will review the information for applicability to their facilities and consider actions, as
appropriate, to avoid similar problems. However, suggestions contained in this IN are not new
NRC requirements; therefore, no specific action nor written response is required.
Description of Circumstances
During an inspection in 1999, NRC staff identified cracks in the front opening of fabricated
horizontal spent fuel storage modules that could have affected their structural integrity. The
NRC further learned that the applicants contractor and subcontractor had accepted these
cracks without documenting them in either nonconformance reports (NCRs) or process
deficiency reports. As a result, about 29 storage modules were found to have similar cracks. It
was determined that the acceptance of this nonconforming condition was based on the
contractors reliance on inapplicable acceptance criteria, inadequate worker training, and a lack
of understanding of the role of the NCR process. This could have been avoided if the applicant
had been more actively and effectively involved in overseeing its contractors quality assurance
activities.
Problems in the implementation of the program by the applicants contractor and subcontractor, occurred in part because of the lack of effective oversight. The identified deficiencies were
corrected prior to the issuance of the Part 72 license.
During another inspection in 1999, the NRC reviewed the implementation of the licensees QA
program with respect to the fabrication of spent fuel storage casks. The licensee had
contracted with a vendor for the delivery of pressurized water reactor (PWR) fuel baskets for
use at the Independent Spent Fuel Storage Facility. The licensee had established a QA
program that was found to meet regulatory requirements. However, inspectors found instances
of inadequate oversight of contractor and subcontractor activities. Specifically, the inspection
team identified a number of examples of violations of 10 CFR 72.154, Control of purchased
material, equipment, and services.
In one example, the NRC determined that the licensee did not effectively oversee the design
control process when changes were made to the coating application process for the storage
cask fuel basket internals. A number of design drawings required that the fuel basket
protective coating be applied according to the manufacturers specifications. This included
spray application of coating followed by high temperature curing. The vendor instructed its
contractor to brush-apply coatings to basket internal areas not adequately covered by the spray
process, but the vendor failed to complete a design change/request notice to support and justify
this change as required by its procedure. After being informed of this issue, the vendor initiated
a corrective action report to resolve the matter.
Other examples of inadequate oversight of contractors activities were identified by the
inspection in the areas of design development, material procurement, fabrication and assembly, and test and inspection. Specifically, the contractors fabrication procedure contained
conflicting requirements for fabrication quality assurance. In addition, the contractor did not
have a procedure in place for controlling access to its small parts storage area, personnel were
not adequately controlling ink stamps used for documenting work acceptance on fabrication
travelers, and personnel had performed dimensional acceptance measurements using
uncalibrated measurement and test equipment.
Discussion:
Section 140, of 10 CFR Part 72, states that, the certificate holder and applicant for a CoC are
responsible for the quality assurance requirements as they apply to the design, fabrication, and
testing of a spent fuel storage cask. However, the regulation also clearly states that, the
licensee and the certificate holder are also simultaneously responsible for these quality
assurance requirements through the oversight of contractors and subcontractors. The
regulation also recognizes that there are circumstances when licensees delegate to others, such as contractors, agents, or consultants, the work of establishing and executing the quality
assurance program, but that the licensee shall retain responsibility for the program. The
problems and deficiencies discussed above could have been avoided had each
applicant/licensee ensured that both contractor and subcontractor organizations understood
and effectively implemented a QA program in accordance with 10 CFR Part 72. Oversight by
an applicant/licensee should be based on direct knowledge of specific implementation of a QA
program, independent evaluation of program findings, and trending of defects and problems. If a design or fabrication problem occurs with a spent fuel storage cask the ultimate
responsibility for assuring the quality of the cask still remains with the cask user, the licensee.
This information notice requires no specific action nor written response. If you have any
questions about the information in this notice, please contact the technical contact listed below
or the appropriate regional office.
/RA/M. Wayne Hodges
/RA/
For
E. William Brach, Director
Ledyard B. Marsh, Chief
Spent Fuel Project Office
Events Assessment, Generic Communications,
Office of Nuclear Material Safety
and Non-Power Reactors Branch
and Safeguards
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Technical Contacts: Chet Poslusny, NMSS
301-415-1341 E-mail: cxp1@nrc.gov
Charles Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachments:
1. List of Recently Issued NMSS Information Notices
2. List of Recently Issued NRR Information Notices If a design or fabrication problem occurs with a spent fuel storage cask the ultimate
responsibility for assuring the quality of the cask still remains with the cask user, the licensee.
This information notice requires no specific action nor written response. If you have any
questions about the information in this notice, please contact the technical contact listed below
or the appropriate regional office.
/RA/M. Wayne Hodges
/RA/
For
E. William Brach, Director
Ledyard B. Marsh, Chief
Spent Fuel Project Office
Events Assessment, Generic Communications,
Office of Nuclear Material Safety
and Non-Power Reactors Branch
and Safeguards
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
Technical Contacts: Chet Poslusny, NMSS
301-415-1341 E-mail: cxp1@nrc.gov
Charles Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachments:
1. List of Recently Issued NMSS Information Notices
2. List of Recently Issued NRR Information Notices
C:\\Infonotice2.wpd
Template NRR-052
ADAMS accession No. ML003734271
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DATE:
3/31/00
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4/05/00
07/24/00
07/26/00
OFC:
SFPO
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OFFICIAL RECORD COPY
Attachment 1 LIST OF RECENTLY ISSUED
NMSS INFORMATION NOTICES
_____________________________________________________________________________________
Information
Date of
Notice No.
Subject
Issuance
Issued to
_____________________________________________________________________________________
2000-10
Recent Events Resulting in
Extremity Exposures
Exceeding Regulatory Limits
7/18/2000
All material licensees who
prepare or use unsealed
radioactive materials, radio
pharmaceuticals, or sealed
sources for medical use or for
research and development
2000-07
National Institute for
Occupational Safety and
Health Respirator User Notice:
Special Precautions for Using
Certain Self-Contained
Breathing Apparatus Air
Cylinders
4/10/2000
All holders of operating licenses
for nuclear power reactors, non- power reactors, and all fuel cycle
and material licensees required to
have an NRC approved
2000-05
Recent Medical
Misadministrations Resulting
from Inattention to Detail
3/06/2000
All medical licensees
2000-04
1999 Enforcement Sanctions
for Deliberate Violations of
NRC Employee Protection
Requirements
2/25/2000
All U.S. Nuclear Regulatory
Commission licensees
2000-03 High-Efficiency Particulate Air
Filter Exceeds Mass Limit
Before Reaching Expected
Differential Pressure
2/22/2000
All NRC licensed fuel-cycled
conversion, enrichment, and
fabrication facilities
2000-02
Failure of Criticality Safety
Control to Prevent Uranium
Dioxide (UO2) Powder
Accumulation
2/22/2000
All NRC licensed fuel-cycled
conversion, enrichment, and
fabrication facilities
99-33
Management of Wastes
Contaminated With
Radioactive Materials
12/28/99
All medical licensees
99-32
The Effect of the Year 2000
Issues on Medical Licensees
12/17/99
All NRC medical licensees
99-31
Operational Controls to Guard
Against Inadvertent Nuclear
Critically
11/17/99
All NRC licensed fuel cycle
conversion, enrichment and
fabrication facilities
____________________________________________________________________________________
OL = Operating License
CP = Construction Permit
Attachment 2 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
_____________________________________________________________________________________
Information
Date of
Notice No.
Subject
Issuance
Issued to
________________________________________________________________________________
2000-10
Recent Events Resulting in
Extremity Exposures
Exceeding Regulatory Limits
7/18/2000
All material licensees who
prepare or use unsealed
radioactive materials, radio
pharmaceuticals, or sealed
sources for medical use or for
research and development
95-03, Supp 2
Loss of Reactor Coolant
Inventory and Potential Loss of
Emergency Mitigation
Functions While in a Shutdown
Condition
7/03/2000
All holders of OL for nuclear
power reactors except those who
have ceased operations and have
certified that fuel has been
permanently removed from the
reactor vessel
2000-09
Steam Generator Tube Failure
at Indian Point Unit 2
6/28/2000
All holders of OL for nuclear
power reactors, except those who
have permanently ceased
operations and have certified that
fuel has been permanently
removed from the reactor vessel
2000-08
Inadequate Assessment of the
Effect of Differential
Temperatures on Safety-
Related Pumps
5/15/2000
All holders of operating licensees
for nuclear power reactors
2000-07
National Institute for
Occupational Safety and
Health Respirator User Notice:
Special Precautions for Using
Certain Self-Contained
Breathing Apparatus Air
Cylinders
4/10/2000
All holders of operating licenses
for nuclear power reactors, non- power reactors, and all fuel cycle
and material licensees required to
have an NRC-approved
2000-06
Offsite Power Voltage
Inadequacies
3/22/2000
All holders of operating licenses
for nuclear power reactors, except those who have
permanently ceased operations
and have certified that fuel has
been permanently removed from
the reactor