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=Text=
=Text=
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION REGION I INSPECTION REPORT
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION


Inspection No. 05000286/2010008  
==REGION I==
INSPECTION REPORT Inspection N /2010008 Docket N License N DPR-64 Licensee:  Entergy Nuclear Operations, Inc.


Docket No. 05000286
Facility: Holtec Manufacturing Division Location: Turtle Creek, Pennsylvania 15145 Inspection Dates: April 20 - 21, 2010 Inspector: John Nicholson Health Physicist Decommissioning Branch Division of Nuclear Materials Safety Clyde Morell Safety Inspector Spent Fuel Storage and Transportation Nuclear Materials Safety and Safeguards Approved By: Judith A. Joustra, Chief Decommissioning Branch Division of Nuclear Materials Safety
 
License No. DPR-64
 
Licensee: Entergy Nuclear Operations, In Facility: Holtec Manufacturing Division  
 
Location: Turtle Creek, Pennsylvania 15145  
 
Inspection Dates: April 20 - 21, 2010  
 
Inspector: John Nicholson Health Physicist Decommissioning Branch Division of Nuclear Materials Safety  
 
Clyde Morell Safety Inspector Spent Fuel Storage and Transportation Nuclear Materials Safety and Safeguards Approved By: Judith A. Joustra, Chief Decommissioning Branch Division of Nuclear Materials Safety  
 
ii


=EXECUTIVE SUMMARY=
=EXECUTIVE SUMMARY=
IR 05000286/2010008; 04/20/2010 - 04/21/2010; Indian Point Energy Center (IPEC); Oversight of fabrication of IPEC Unit 3 shielded transfer cask (STC) at the Holtec Manufacturing Division (HMD)facility in Turtle Creek, Pennsylvania.
IR 05000286/2010008; 04/20/2010 - 04/21/2010; Indian Point Energy Center (IPEC); Oversight of fabrication of IPEC Unit 3 shielded transfer cask (STC) at the Holtec Manufacturing Division (HMD)facility in Turtle Creek, Pennsylvania.


This report covers an announced on-site inspection conducted by an NRC Region I inspector and an inspector from the NRC Nuclear Materials Safety and Safeguards Division, Spent Fuel Storage and Transportation Branch, of IPEC's oversight of the manufacturing process of the Unit 3 STC at HMD. A license amendment request for the STC under 10 CFR Part 50 was submitted by Entergy to the NRC on July 8, 2009. The NRC sent a request for additional information (RAI) to Entergy regarding the amendment request for the STC. The review of that request is ongoing. This STC will be used for the transfer of spent fuel assemblies from the IPEC Unit 3 spent fuel pool (SFP) to the IPEC Unit 2 SFP. At the time of the inspection, fabrication of the STC was put on hold for approximately three months while Entergy completes its response to the RAI.
This report covers an announced on-site inspection conducted by an NRC Region I inspector and an inspector from the NRC Nuclear Materials Safety and Safeguards Division, Spent Fuel Storage and Transportation Branch, of IPECs oversight of the manufacturing process of the Unit 3 STC at HMD. A license amendment request for the STC under 10 CFR Part 50 was submitted by Entergy to the NRC on July 8, 2009. The NRC sent a request for additional information (RAI) to Entergy regarding the amendment request for the STC. The review of that request is ongoing. This STC will be used for the transfer of spent fuel assemblies from the IPEC Unit 3 spent fuel pool (SFP) to the IPEC Unit 2 SFP. At the time of the inspection, fabrication of the STC was put on hold for approximately three months while Entergy completes its response to the RAI.


The inspector reviewed equipment performance; program controls and documentation; and personnel qualifications and performance. Specific inspection areas included the welding and non-destructive examination of the STC completed to date.
The inspector reviewed equipment performance; program controls and documentation; and personnel qualifications and performance. Specific inspection areas included the welding and non-destructive examination of the STC completed to date.
Line 47: Line 34:
Within the scope of this inspection, no violations of NRC requirements were identified.
Within the scope of this inspection, no violations of NRC requirements were identified.


1
ii


=REPORT DETAILS=
=REPORT DETAILS=


1.0 Welding and Nondestructive Testing
1.0 Welding and Nondestructive Testing


====a. Inspection Scope====
====a. Inspection Scope====
(IP60852)
(IP60852)
The inspection included a limited review of IPEC's oversight of the HMD qualification  
The inspection included a limited review of IPECs oversight of the HMD qualification and certification programs for welding and nondestructive examination (NDE) personnel, and the HMD programs and procedures for controlling special processes such as welding, and NDE associated with the fabrication of the IPEC Shielded Transfer Cask by Holtec. The inspector performed an onsite review of the HMDs Technical Specification requirements for implementing procedures controlling welding fabrication, and NDE inspection processes against the HMD quality assurance (QA) implementing procedures to assure that HMDs Technical Specification requirements were incorporated.
 
and certification programs for welding and nondestructive examination (NDE) personnel, and the HMD programs and procedures for controlling special processes such as  
 
welding, and NDE associated with the fabrication of the IPEC Shielded Transfer Cask by  
 
Holtec. The inspector performed an onsite review of the HMD's Technical Specification  
 
requirements for implementing procedures controlling welding fabrication, and NDE  
 
inspection processes against the HMD quality assurance (QA) implementing procedures  
 
to assure that HMD's Technical Specification requirements were incorporated.


====b. Observations and Findings====
====b. Observations and Findings====
IPEC utilizes the Nuclear Procurement Issues Committee (NUPIC) process to place  
IPEC utilizes the Nuclear Procurement Issues Committee (NUPIC) process to place Holtec on its approved vendor list. The last NUPIC audit of Holtec was conducted October 20 through November 8, 2008. The NUPIC audit team spent a week at the Holtec corporate office and a week at the HMD facility. IPEC has a contract with URS Washington Division (URS) to serve as onsite quality assurance oversight for the fabrication of the STC at HMD. The URS contractor is required to witness hold points during the fabrication process. The inspector reviewed several hold points and noted that URS staff signed off on the hold points. Weekly communication occurs between URS and the IPEC Project Manager. The inspector reviewed the purchase agreement specifications developed by IPEC and provided to HMD. The agreement states that all drawings for fabrication must be approved by IPEC prior to the start of fabrication.
 
Holtec on its approved vendor list. The last NUPIC audit of Holtec was conducted  
 
October 20 through November 8, 2008. The NUPIC audit team spent a week at the  
 
Holtec corporate office and a week at the HMD facility. IPEC has a contract with URS  
 
Washington Division (URS) to serve as onsite quality assurance oversight for the  
 
fabrication of the STC at HMD. The URS contractor is required to witness hold points  
 
during the fabrication process. The inspector reviewed several hold points and noted  
 
that URS staff signed off on the hold points. Weekly communication occurs between  
 
URS and the IPEC Project Manager. The inspector reviewed the purchase agreement  
 
specifications developed by IPEC and provided to HMD. The agreement states that all drawings for fabrication must be approved by IPEC prior to the start of fabrication.
 
At the time of the inspection, the STC circumference weld was complete. The top flange
 
was welded on but not the bottom flange. The stainless steel overlay on the inside was
 
in process. The basket plate subassemblies had been fabricated, but the basket was
 
not assembled.
 
The inspector reviewed HMD personnel NDE certification records to ascertain that they
 
were certified in accordance with American Society for Nondestructive Testing (ASNT)
 
ASNT-TC-1a -1992 editions, and the quality assurance (QA) HMD implementing
 
procedure HQP-9.1, revision 11, Written Practice Qualification of NDE Personnel.
 
The inspector compared the HMD implementing procedure HQP-9.1, revision 11 to the
 
Recommended Practice No. ASNT-TC-1a -1992 requirements for qualification and
 
certification of nondestructive testing (NDT) personnel. The inspector found the HMD
 
procedures to be compliant.
 
HMD has out sourced the management of the NDE program qualification and
 
certification of HMD NDE personnel, the review and approval of HMD NDE procedures, and HMD Level III activities via a purchase agreement with System One. The inspector verified that HMD had imposed via the purchase agreement the requirement for System One to implement the HMD QA program and implementing procedures when providing NDT services
. A formal letter delegating these activities or a letter of appointment to System One was not available during this inspection. The inspector brought this to the attention of the Holtec QA Manager and immediate action was taken by drafting a letter
 
before the end of the inspection.
 
The inspector reviewed System One NDE personnel qualification records for two
 
personnel who performed NDT Level III activities to determine if they were qualified and
 
certified in accordance with HMD HCP-9-1. The inspector found them to be compliant.
 
ANST TC-1a requires annual eye examinations (requirement for near vision) for NDT Level III certifications. The inspector reviewed the results of eye examinations
 
performed for one HMD NDT employee as well as two System One NDT subcontractors with NDT Level III certifications, and determined that the annual eye exams, as required
 
by ASNT-TC-1a, were in compliance.
 
In addition, the inspector reviewed the HMD implementing procedure HQP-9.4, Revision 7, "Qualification and Performance of Welding Activities". HMD HQP-9.4, Paragraph 5.5
 
- Welding Engineer states in part: "The Quality Assurance Manager, Quality Manager, or the Inspection Supervisor may perform the duties of the Weld Engineer". This implies that all parties identified are qualified as a Weld Engineer. HMD HQP-9.4, Paragraph 6.2.4 states in part: "Holtec Manufacturing Division became an operational division of Holtec in 2006. Prior to this, the company was known as
 
U.S. Tool & Die (UST&D) (under different ownership until 2004 when it became a
 
subsidiary of Holtec) all weld procedures (and procedure qualification records)
 
developed and qualified under the UST&D QA Program are acceptable for use under Holtec's QA program. ASME Section IX, QW-201 states that: "-each manufacturer or
 
contractor is responsible for the qualifying of WPSs PQRs and Welder Qualifications."
 
Also ASME Section IX, QW-201.1 states in part: "When a manufacturer contactor or part
 
of a manufacturer or contractor is acquired by a new owner(s), the procedure
 
qualification records (PQRs) and welding procedures specifications (WPSs) may be
 
used by the new owners without requalification, provided all of the following are met:
 
a. the new owner takes responsibility for the WPSs and PQRs b. the WPS's reflect the name of the new owner(s)c. the Quality Control System/Quality Assur ance Program reflects the source of the PQRs as being from the former manufacturer" The inspector determined that item "a" above, of the Code had not adequately been
 
documented on the basis that all the approval signatures were UST&D employees and
 
the PQR and WPS issue dates were prior to the date of the Holtec acquisition date of
 
2006. PQRs and WPSs indicating a review and approval signature by a responsible
 
HMD official after the 2006 acquisition of UST&D by HMD were not available. The
 
Holtec Corporate QA Manager concurred that each of the old UST&D PQRs and WPSs
 
should contain a Holtec review and approval signature. On this basis, Holtec Corporate
 
issued a corrective action (CPV788 dated 4/4/10) for documenting and tracking the
 
evaluation of planned actions.
 
The inspector also reviewed other PQR's and WP's for compliance to items "b" and "c" above of the Code and determined that requirements had been met.


10 CFR Part 71.111 requires, in part, that the instructions, procedures, and drawings
At the time of the inspection, the STC circumference weld was complete. The top flange was welded on but not the bottom flange. The stainless steel overlay on the inside was in process. The basket plate subassemblies had been fabricated, but the basket was not assembled.


must include appropriate quantitative or qualitative acceptance criteria for determining
The inspector reviewed HMD personnel NDE certification records to ascertain that they were certified in accordance with American Society for Nondestructive Testing (ASNT)
ASNT-TC-1a -1992 editions, and the quality assurance (QA) HMD implementing procedure HQP-9.1, revision 11, Written Practice Qualification of NDE Personnel.


that important activities have been satisfactorily accomplished.
The inspector compared the HMD implementing procedure HQP-9.1, revision 11 to the Recommended Practice No. ASNT-TC-1a -1992 requirements for qualification and certification of nondestructive testing (NDT) personnel. The inspector found the HMD procedures to be compliant.


The inspector reviewed the traveler for fabrication weld 1.1 referenced on Holtec Drawing 6988, Revision 0 and verified that the traveler provided adequate controls for
HMD has out sourced the management of the NDE program qualification and certification of HMD NDE personnel, the review and approval of HMD NDE procedures, and HMD Level III activities via a purchase agreement with System One. The inspector verified that HMD had imposed via the purchase agreement the requirement for System One to implement the HMD QA program and implementing procedures when providing NDT services. A formal letter delegating these activities or a letter of appointment to System One was not available during this inspection. The inspector brought this to the attention of the Holtec QA Manager and immediate action was taken by drafting a letter before the end of the inspection.


the following welding and NDE processes:  WPS-247 andWPS-93B  RT-09121-1 and RT-09121-4 The inspector determined that the welding and NDE processes were in accordance with the HMD process control.
The inspector reviewed System One NDE personnel qualification records for two personnel who performed NDT Level III activities to determine if they were qualified and certified in accordance with HMD HCP-9-1. The inspector found them to be compliant.


The inspector reviewed several WPS's and determined that they met the requirements of ASME Section IX, QW-250 - Welding Variables. The inspector also reviewed several
ANST TC-1a requires annual eye examinations (requirement for near vision) for NDT Level III certifications. The inspector reviewed the results of eye examinations performed for one HMD NDT employee as well as two System One NDT subcontractors with NDT Level III certifications, and determined that the annual eye exams, as required by ASNT-TC-1a, were in compliance.


NDE RT inspection reports and determined that they met the requirements of ASME
In addition, the inspector reviewed the HMD implementing procedure HQP-9.4, Revision 7, Qualification and Performance of Welding Activities. HMD HQP-9.4, Paragraph 5.5
- Welding Engineer states in part: The Quality Assurance Manager, Quality Manager, or the Inspection Supervisor may perform the duties of the Weld Engineer. This implies that all parties identified are qualified as a Weld Engineer.


Section V.
HMD HQP-9.4, Paragraph 6.2.4 states in part: Holtec Manufacturing Division became an operational division of Holtec in 2006. Prior to this, the company was known as U.S. Tool & Die (UST&D) (under different ownership until 2004 when it became a subsidiary of Holtec) all weld procedures (and procedure qualification records)developed and qualified under the UST&D QA Program are acceptable for use under Holtecs QA program. ASME Section IX, QW-201 states that: each manufacturer or contractor is responsible for the qualifying of WPSs PQRs and Welder Qualifications.


The inspector interviewed the HMD welding engineer to determine what systems were being used to control fabrication welding with regards to the following: a. Welding production drawing and changes b. Determining the correct WPS for fabrication use c. Assigning of qualified welders d. Tracking welder qualifications e. Issuance of welding materials and tracking usage.
Also ASME Section IX, QW-201.1 states in part: When a manufacturer contactor or part of a manufacturer or contractor is acquired by a new owner(s), the procedure qualification records (PQRs) and welding procedures specifications (WPSs) may be used by the new owners without requalification, provided all of the following are met:
a. the new owner takes responsibility for the WPSs and PQRs b. the WPSs reflect the name of the new owner(s)c. the Quality Control System/Quality Assurance Program reflects the source of the PQRs as being from the former manufacturer The inspector determined that item a above, of the Code had not adequately been documented on the basis that all the approval signatures were UST&D employees and the PQR and WPS issue dates were prior to the date of the Holtec acquisition date of 2006. PQRs and WPSs indicating a review and approval signature by a responsible HMD official after the 2006 acquisition of UST&D by HMD were not available. The Holtec Corporate QA Manager concurred that each of the old UST&D PQRs and WPSs should contain a Holtec review and approval signature. On this basis, Holtec Corporate issued a corrective action (CPV788 dated 4/4/10) for documenting and tracking the evaluation of planned actions.


The HMD welding engineer stated that HMD uses a computer-based production routing system to control these items. Because of the HMD self-imposed stop work and the
The inspector also reviewed other PQRs and WPs for compliance to items b and c above of the Code and determined that requirements had been met.


limited amount of completed fabrication the inspector performed a limited review of
10 CFR Part 71.111 requires, in part, that the instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.


welding related fabrication travelers and was able verify that the requirements of the  
The inspector reviewed the traveler for fabrication weld 1.1 referenced on Holtec Drawing 6988, Revision 0 and verified that the traveler provided adequate controls for the following welding and NDE processes:
WPS-247 andWPS-93B RT-09121-1 and RT-09121-4 The inspector determined that the welding and NDE processes were in accordance with the HMD process control.


associated procedures were being maintained.
The inspector reviewed several WPSs and determined that they met the requirements of ASME Section IX, QW-250 - Welding Variables. The inspector also reviewed several NDE RT inspection reports and determined that they met the requirements of ASME Section V.


The inspector also reviewed the completed radiograph (RT) report for Holtec drawing No. 6988 rev. 0, fabrication weld1.2, RT of weld, and verified that the RT process was
The inspector interviewed the HMD welding engineer to determine what systems were being used to control fabrication welding with regards to the following:
a. Welding production drawing and changes b. Determining the correct WPS for fabrication use c. Assigning of qualified welders d. Tracking welder qualifications e. Issuance of welding materials and tracking usage.


documented in accordance with the requirements of ASME Section V.
The HMD welding engineer stated that HMD uses a computer-based production routing system to control these items. Because of the HMD self-imposed stop work and the limited amount of completed fabrication the inspector performed a limited review of welding related fabrication travelers and was able verify that the requirements of the associated procedures were being maintained.


In addition, the inspector reviewed the WPS variables identified in the respective WPS against the WPS variables identified in ASME Section IX, Paragraphs QW-250 through QW-256 to verify compliance with ASME Section IX. The WPSs were found to be compliant with the ASME Section IX Welding Code as an acceptable WPS for the HMD
The inspector also reviewed the completed radiograph (RT) report for Holtec drawing No. 6988 rev. 0, fabrication weld1.2, RT of weld, and verified that the RT process was documented in accordance with the requirements of ASME Section V.


identified process.
In addition, the inspector reviewed the WPS variables identified in the respective WPS against the WPS variables identified in ASME Section IX, Paragraphs QW-250 through QW-256 to verify compliance with ASME Section IX. The WPSs were found to be compliant with the ASME Section IX Welding Code as an acceptable WPS for the HMD identified process.


====c. Conclusions====
====c. Conclusions====
IPEC demonstrated adequate oversight of HMD to fabricate the STC. Welding and NDE  
IPEC demonstrated adequate oversight of HMD to fabricate the STC. Welding and NDE activities were performed by HMD in accordance with approved procedures. Personnel were qualified to perform their assigned functions. No findings of significance were identified.
 
activities were performed by HMD in accordance with approved procedures. Personnel  
 
were qualified to perform their assigned functions. No findings of significance were  
 
identified.


===Exit Meeting Summary===
===Exit Meeting Summary===


The inspector presented the inspection results to Joe DeFrancesco, Project Manager for IPEC  
The inspector presented the inspection results to Joe DeFrancesco, Project Manager for IPEC and other Holtec corporate and HMD personnel at the conclusion of this inspection on April 21, 2010. The inspector confirmed that proprietary information was not provided or examined during the inspection.
 
and other Holtec corporate and HMD personnel at the conclusion of this inspection on  
 
April 21, 2010. The inspector confirmed that proprietary information was not provided or  
 
examined during the inspection.


ATTACHMENT:  
ATTACHMENT:  
Line 231: Line 98:


SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED  
PARTIAL LIST OF PERSONS CONTACTED
*Kevin Cuthill, Holtec International Corporate  
*Kevin Cuthill, Holtec International Corporate
*Robert Czarnecki, Senior Product Line Manager HMD  
*Robert Czarnecki, Senior Product Line Manager HMD
*Joe Defrancesco, Project Manager, Entergy Indian Point Energy Center  
*Joe Defrancesco, Project Manager, Entergy Indian Point Energy Center
*Alan Hickman, Manufacturing Support Supply Chain Manager Holtec International Corporate  
*Alan Hickman, Manufacturing Support Supply Chain Manager Holtec International Corporate
*Joe Lasko, QC Engineer HMD  
*Joe Lasko, QC Engineer HMD
*John Menhart, Senior Manufacturing Engineer/Welding Engineer, HMD  
*John Menhart, Senior Manufacturing Engineer/Welding Engineer, HMD
*Gregory Miller, Quality Assurance Manager HMD
*Gregory Miller, Quality Assurance Manager HMD
Peter Probst, Quality Assurance, URS Washington Division  
Peter Probst, Quality Assurance, URS Washington Division
*Mark Soler, Quality Assurance Manager Holtec International Corporate  
*Mark Soler, Quality Assurance Manager Holtec International Corporate
* denotes attendance at exit meeting  
* denotes attendance at exit meeting
 
INSPECTION PROCEDURES USED
INSPECTION PROCEDURES USED
60852 ISFSI Component Fabrication by Outside Fabricators  
60852 ISFSI Component Fabrication by Outside Fabricators
 
ITEMS OPEN, CLOSED, AND DISCUSSED
ITEMS OPEN, CLOSED, AND DISCUSSED
None
None
Line 258: Line 123:
QCP: 10.5 H, Rev. 15, Visual Weld Examination for Holtec Product Lines
QCP: 10.5 H, Rev. 15, Visual Weld Examination for Holtec Product Lines
QCP 10.7, Rev. 5, Control of Welding and Removal of Temporary Attachments
QCP 10.7, Rev. 5, Control of Welding and Removal of Temporary Attachments
QCP: 10.8, Rev. 6, Repair of Material  
QCP: 10.8, Rev. 6, Repair of Material
 
LIST OF ACRONYMS USED
LIST OF ACRONYMS USED
ADAMS Agency wide Documents and Management System AMSE  American Society of Mechanical Engineers
ADAMS Agency wide Documents and Management System
AMSE  American Society of Mechanical Engineers
ASNT  American Society for Nondestructive Testing
ASNT  American Society for Nondestructive Testing
CFR Code of Federal Regulations
CFR   Code of Federal Regulations
HMD Holtec Manufacturing Division
HMD   Holtec Manufacturing Division
IPEC  Indian Point Energy Center
IPEC  Indian Point Energy Center
NDE non destructive examination
NDE   non destructive examination
NDT non destructive testing
NDT   non destructive testing
NUPIC Nuclear Procurement Issues Committee
NUPIC Nuclear Procurement Issues Committee
PQR procedure qualification records
PQR   procedure qualification records
QA quality assurance
QA   quality assurance
RAI request for additional information
RAI   request for additional information
RT radiograph
RT   radiograph
SFP spent fuel pool
SFP   spent fuel pool
STC shielded transfer cask
STC   shielded transfer cask
URS URS Washington Division
URS   URS Washington Division
UST&D U.S. Tool & Die
UST&D U.S. Tool & Die
WPS Welding Procedure Specifications
WPS   Welding Procedure Specifications
}}
}}

Revision as of 17:54, 13 November 2019

IR 05000286-10-008; 04/20/2010 04/21/2010; Indian Point Energy Center (Ipec); Oversight of Fabrication of IPEC Unit 3 Shielded Transfer Cask (Stc) at the Holtec Manufacturing Division (Hmd) Facility in Turtle Creek, Pennsylvania
ML101410062
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 05/20/2010
From: Morell C, Jackie Nicholson
NRC/NMSS/SFST/LID/RIOB, Decommissioning Branch I
To:
Entergy Nuclear Operations
References
IR-10-008
Download: ML101410062 (8)
v • d • e


Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

INSPECTION REPORT Inspection N /2010008 Docket N License N DPR-64 Licensee: Entergy Nuclear Operations, Inc.

Facility: Holtec Manufacturing Division Location: Turtle Creek, Pennsylvania 15145 Inspection Dates: April 20 - 21, 2010 Inspector: John Nicholson Health Physicist Decommissioning Branch Division of Nuclear Materials Safety Clyde Morell Safety Inspector Spent Fuel Storage and Transportation Nuclear Materials Safety and Safeguards Approved By: Judith A. Joustra, Chief Decommissioning Branch Division of Nuclear Materials Safety

EXECUTIVE SUMMARY

IR 05000286/2010008; 04/20/2010 - 04/21/2010; Indian Point Energy Center (IPEC); Oversight of fabrication of IPEC Unit 3 shielded transfer cask (STC) at the Holtec Manufacturing Division (HMD)facility in Turtle Creek, Pennsylvania.

This report covers an announced on-site inspection conducted by an NRC Region I inspector and an inspector from the NRC Nuclear Materials Safety and Safeguards Division, Spent Fuel Storage and Transportation Branch, of IPECs oversight of the manufacturing process of the Unit 3 STC at HMD. A license amendment request for the STC under 10 CFR Part 50 was submitted by Entergy to the NRC on July 8, 2009. The NRC sent a request for additional information (RAI) to Entergy regarding the amendment request for the STC. The review of that request is ongoing. This STC will be used for the transfer of spent fuel assemblies from the IPEC Unit 3 spent fuel pool (SFP) to the IPEC Unit 2 SFP. At the time of the inspection, fabrication of the STC was put on hold for approximately three months while Entergy completes its response to the RAI.

The inspector reviewed equipment performance; program controls and documentation; and personnel qualifications and performance. Specific inspection areas included the welding and non-destructive examination of the STC completed to date.

Within the scope of this inspection, no violations of NRC requirements were identified.

ii

REPORT DETAILS

1.0 Welding and Nondestructive Testing

a. Inspection Scope

(IP60852)

The inspection included a limited review of IPECs oversight of the HMD qualification and certification programs for welding and nondestructive examination (NDE) personnel, and the HMD programs and procedures for controlling special processes such as welding, and NDE associated with the fabrication of the IPEC Shielded Transfer Cask by Holtec. The inspector performed an onsite review of the HMDs Technical Specification requirements for implementing procedures controlling welding fabrication, and NDE inspection processes against the HMD quality assurance (QA) implementing procedures to assure that HMDs Technical Specification requirements were incorporated.

b. Observations and Findings

IPEC utilizes the Nuclear Procurement Issues Committee (NUPIC) process to place Holtec on its approved vendor list. The last NUPIC audit of Holtec was conducted October 20 through November 8, 2008. The NUPIC audit team spent a week at the Holtec corporate office and a week at the HMD facility. IPEC has a contract with URS Washington Division (URS) to serve as onsite quality assurance oversight for the fabrication of the STC at HMD. The URS contractor is required to witness hold points during the fabrication process. The inspector reviewed several hold points and noted that URS staff signed off on the hold points. Weekly communication occurs between URS and the IPEC Project Manager. The inspector reviewed the purchase agreement specifications developed by IPEC and provided to HMD. The agreement states that all drawings for fabrication must be approved by IPEC prior to the start of fabrication.

At the time of the inspection, the STC circumference weld was complete. The top flange was welded on but not the bottom flange. The stainless steel overlay on the inside was in process. The basket plate subassemblies had been fabricated, but the basket was not assembled.

The inspector reviewed HMD personnel NDE certification records to ascertain that they were certified in accordance with American Society for Nondestructive Testing (ASNT)

ASNT-TC-1a -1992 editions, and the quality assurance (QA) HMD implementing procedure HQP-9.1, revision 11, Written Practice Qualification of NDE Personnel.

The inspector compared the HMD implementing procedure HQP-9.1, revision 11 to the Recommended Practice No. ASNT-TC-1a -1992 requirements for qualification and certification of nondestructive testing (NDT) personnel. The inspector found the HMD procedures to be compliant.

HMD has out sourced the management of the NDE program qualification and certification of HMD NDE personnel, the review and approval of HMD NDE procedures, and HMD Level III activities via a purchase agreement with System One. The inspector verified that HMD had imposed via the purchase agreement the requirement for System One to implement the HMD QA program and implementing procedures when providing NDT services. A formal letter delegating these activities or a letter of appointment to System One was not available during this inspection. The inspector brought this to the attention of the Holtec QA Manager and immediate action was taken by drafting a letter before the end of the inspection.

The inspector reviewed System One NDE personnel qualification records for two personnel who performed NDT Level III activities to determine if they were qualified and certified in accordance with HMD HCP-9-1. The inspector found them to be compliant.

ANST TC-1a requires annual eye examinations (requirement for near vision) for NDT Level III certifications. The inspector reviewed the results of eye examinations performed for one HMD NDT employee as well as two System One NDT subcontractors with NDT Level III certifications, and determined that the annual eye exams, as required by ASNT-TC-1a, were in compliance.

In addition, the inspector reviewed the HMD implementing procedure HQP-9.4, Revision 7, Qualification and Performance of Welding Activities. HMD HQP-9.4, Paragraph 5.5

- Welding Engineer states in part: The Quality Assurance Manager, Quality Manager, or the Inspection Supervisor may perform the duties of the Weld Engineer. This implies that all parties identified are qualified as a Weld Engineer.

HMD HQP-9.4, Paragraph 6.2.4 states in part: Holtec Manufacturing Division became an operational division of Holtec in 2006. Prior to this, the company was known as U.S. Tool & Die (UST&D) (under different ownership until 2004 when it became a subsidiary of Holtec) all weld procedures (and procedure qualification records)developed and qualified under the UST&D QA Program are acceptable for use under Holtecs QA program. ASME Section IX, QW-201 states that: each manufacturer or contractor is responsible for the qualifying of WPSs PQRs and Welder Qualifications.

Also ASME Section IX, QW-201.1 states in part: When a manufacturer contactor or part of a manufacturer or contractor is acquired by a new owner(s), the procedure qualification records (PQRs) and welding procedures specifications (WPSs) may be used by the new owners without requalification, provided all of the following are met:

a. the new owner takes responsibility for the WPSs and PQRs b. the WPSs reflect the name of the new owner(s)c. the Quality Control System/Quality Assurance Program reflects the source of the PQRs as being from the former manufacturer The inspector determined that item a above, of the Code had not adequately been documented on the basis that all the approval signatures were UST&D employees and the PQR and WPS issue dates were prior to the date of the Holtec acquisition date of 2006. PQRs and WPSs indicating a review and approval signature by a responsible HMD official after the 2006 acquisition of UST&D by HMD were not available. The Holtec Corporate QA Manager concurred that each of the old UST&D PQRs and WPSs should contain a Holtec review and approval signature. On this basis, Holtec Corporate issued a corrective action (CPV788 dated 4/4/10) for documenting and tracking the evaluation of planned actions.

The inspector also reviewed other PQRs and WPs for compliance to items b and c above of the Code and determined that requirements had been met.

10 CFR Part 71.111 requires, in part, that the instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

The inspector reviewed the traveler for fabrication weld 1.1 referenced on Holtec Drawing 6988, Revision 0 and verified that the traveler provided adequate controls for the following welding and NDE processes:

WPS-247 andWPS-93B RT-09121-1 and RT-09121-4 The inspector determined that the welding and NDE processes were in accordance with the HMD process control.

The inspector reviewed several WPSs and determined that they met the requirements of ASME Section IX, QW-250 - Welding Variables. The inspector also reviewed several NDE RT inspection reports and determined that they met the requirements of ASME Section V.

The inspector interviewed the HMD welding engineer to determine what systems were being used to control fabrication welding with regards to the following:

a. Welding production drawing and changes b. Determining the correct WPS for fabrication use c. Assigning of qualified welders d. Tracking welder qualifications e. Issuance of welding materials and tracking usage.

The HMD welding engineer stated that HMD uses a computer-based production routing system to control these items. Because of the HMD self-imposed stop work and the limited amount of completed fabrication the inspector performed a limited review of welding related fabrication travelers and was able verify that the requirements of the associated procedures were being maintained.

The inspector also reviewed the completed radiograph (RT) report for Holtec drawing No. 6988 rev. 0, fabrication weld1.2, RT of weld, and verified that the RT process was documented in accordance with the requirements of ASME Section V.

In addition, the inspector reviewed the WPS variables identified in the respective WPS against the WPS variables identified in ASME Section IX, Paragraphs QW-250 through QW-256 to verify compliance with ASME Section IX. The WPSs were found to be compliant with the ASME Section IX Welding Code as an acceptable WPS for the HMD identified process.

c. Conclusions

IPEC demonstrated adequate oversight of HMD to fabricate the STC. Welding and NDE activities were performed by HMD in accordance with approved procedures. Personnel were qualified to perform their assigned functions. No findings of significance were identified.

Exit Meeting Summary

The inspector presented the inspection results to Joe DeFrancesco, Project Manager for IPEC and other Holtec corporate and HMD personnel at the conclusion of this inspection on April 21, 2010. The inspector confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

  • Kevin Cuthill, Holtec International Corporate
  • Robert Czarnecki, Senior Product Line Manager HMD
  • Joe Defrancesco, Project Manager, Entergy Indian Point Energy Center
  • Alan Hickman, Manufacturing Support Supply Chain Manager Holtec International Corporate
  • Joe Lasko, QC Engineer HMD
  • John Menhart, Senior Manufacturing Engineer/Welding Engineer, HMD
  • Gregory Miller, Quality Assurance Manager HMD

Peter Probst, Quality Assurance, URS Washington Division

  • Mark Soler, Quality Assurance Manager Holtec International Corporate
  • denotes attendance at exit meeting

INSPECTION PROCEDURES USED

60852 ISFSI Component Fabrication by Outside Fabricators

ITEMS OPEN, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

HMD Procedures:

HQP-9.1, Rev. 11, Written Practice Qualification of NDE Personnel

HQP-9.2, Rev. 6, Welder Qualification Requirements

HQP-9.4, Rev. 7, Qualification and Performance of Welding Activities

QCP: 9.2A, Rev. 8, Control and Issuance of SMAW and SAW Weld Filler Metal and Flux

QCP: 9.6, Rev.15, Liquid Penetration Examination (Water Washable)

QCP: 9.7, Rev. 8, Magnetic Particle Examination (Dry Particle Method)

QCP: 10.5 H, Rev. 15, Visual Weld Examination for Holtec Product Lines

QCP 10.7, Rev. 5, Control of Welding and Removal of Temporary Attachments

QCP: 10.8, Rev. 6, Repair of Material

LIST OF ACRONYMS USED

ADAMS Agency wide Documents and Management System

AMSE American Society of Mechanical Engineers

ASNT American Society for Nondestructive Testing

CFR Code of Federal Regulations

HMD Holtec Manufacturing Division

IPEC Indian Point Energy Center

NDE non destructive examination

NDT non destructive testing

NUPIC Nuclear Procurement Issues Committee

PQR procedure qualification records

QA quality assurance

RAI request for additional information

RT radiograph

SFP spent fuel pool

STC shielded transfer cask

URS URS Washington Division

UST&D U.S. Tool & Die

WPS Welding Procedure Specifications

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