ML110680554

IR 05000286-10-010, on 11/29/10 - 02/17/11, Entergy Nuclear Operations, Inc., Holtec Manufacturing Division, Turtle Creek, PA, Inspection Report

ML110680554
Person / Time
Site:	Indian Point
Issue date:	03/09/2011
From:	Division of Nuclear Materials Safety I
To:	Entergy Nuclear Operations
References
IR-10-010
Download: ML110680554 (6)

See also: IR 05000286/2010010

Text

lnspection No.

Docket No.

License No.

Licensee:

Facility:

Location:

Inspection Dates:

Inspector:

Approved By:

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

INSPECTION REPORT

05000286/201 001 0

05000286

DPR-64

Entergy Nuclear Operations Inc.

Holtec Manufacturing Division

Turtle Creek, PA

November 29 - December 2,2010,

FebruaryT -10,17,2011

John Nicholson

Health Physicist

Decommissioning Branch

Division of Nuclear Materials Safety

Rob Temps

Senior Safety Inspector

Rules, Inspections, & Operations Branch

Division of Spent Fuel Storage and Transportation

Judith A. Joustra, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

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EXECUTIVE SUMMARY

lR 050002861201001Q; 1112912010 - 1 21212010, 02107 - 1 0, and 17 , 2011 ; Indian Point Energy

Center (IPEC); Oversight of factory testing and inspection 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 factory testing of the Unit 3 STC

at HMD. A license amendment request (M1091940177) for the STC under 10 CFR Part 50 was

submitted by Entergy Nuclear Operatons, Inc. (the licensee) to the NRC on July 8, 2009. At the

time of this inspection, the NRC was in the process of drafting a second request for additional

information (RAl) to the licensee regarding the amendment request for the STC. The review of

that request is ongoing. This STC will be used for the wet transfer of spent fuel assemblies from

the IPEC Unit 3 spent fuel pool (SFP) to the IPEC Unit 2 SFP.

The inspector reviewed equipment performance, program controls, and documentation. Specific

inspection areas included the testing of STC components, observing STC component inspection

on the floor of the manufacturing facility, a review of the non-conformance reports to date, a

review of the licensee's quality assurance program, and interviews with both the licensee and

Holtec personnel performing the testing and inspection of the components.

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

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REPORT DETAILS

1.0 Review of Fabrication Documentation

a.

Inspection Scope (1P60852)

The inspection included a limited review of the licensee's oversight of the HMD

fabrication of the IPEC STC since the previous inspection at HMD conducted in April

2Q10. The inspector performed an onsite review of the HMD's Technical Specification

requirements for implementing procedures controlling fabrication to assure that HMD's

Technical Specification requirements were incorporated.

b.

Observations and Findinqs

IPEC has a written contract with URS Washington Division (URS), an engineering and

technical services provider company, to provide oversight of onsite quality assurance 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 component documentation to confirm that hold

points had been inspected as required. Weekly verbal communication occurs between

URS and the IPEC Project Manager. The inspector reviewed the purchase agreement

specifications developed by the licensee and provided to HMD. The purchase

agreement states that all drawings for fabrication must be approved by the licensee prior

to the start of fabrication. lt also states that non-conformance reports (NCRs) considered

as design changes require the licensee's approval, although the contractor may proceed

at its own risk prior to IPEC's acceptance. The contractor must request and obtain

written approval of the licensee prior to shipment of the component.

While reviewing NCRs associated with the STC, the inspector noticed that NCR 09121-1,

Rev. 3, involved a design change to the STC shellthickness lrom718" to 3/4". This

design change was dispositioned without the licensee's approval or review of the

analysis performed by Holtec. Licensee personnel stated that they were not notified of

the significance of this NCR by Holtec and at the time of the inspection had not yet

performed the proper analysis of the design change as required by the Entergy Quality

Assurance Manual. The NCR form used by Holtec did not differentiate between rework

and repair. In general, rework is the act of reprocessing non-complying components,

through the use of original or equivalent processing, in a manner that assures full

compliance of the component with applicable drawings or specifications. In contrast,

repair is generally the act of restoring the functional capability of a defective component

in a manner that precludes compliance of the component with applicable drawings or

specifications. Usually rework does not require customer approval, while most repair

work does.

The IPEC Assistant Project Manager stated to the inspector that an Entergy Corrective

Action Request (CAR) LO-CAR-2010-00098 was sent to Holtec on December 2Q,2010

for their follow up. The follow-up response to the CAR from Holtec had not been

received by the licensee prior to the end of this inspection.

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c.

Conclusions

The inspectors determined that the licensee representatives on site at HMD including the

URS Washington Division personnel, and IPEC project management personnel, did not

appear to be as familiar as they should have been with how design changes should be

handled per the contractural agreement between the licensee and HMD and the Entergy

Quality Assurance Manual. As of February 7,2011, the licensee drafted new language

for the contract with Holtec, and Holtec modified the NCR form they use to include a

designation for repair. The Entergy Quality Assurance Program Manual requires that

supplier evaluations be performed any time prior to placing the component in service. At

the conclusion of this inspection, the STC was still being fabricated by Holtec, had not

been licensed by the NRC, and had not been shipped to or used by the licensee. A

timely review of the design change was not performed by the licensee. However since

the STC had not been placed into service, no findings of significance were identified.

2.0

Factory testing and Fit up of STC Components

a.

lnspection Scope

The testing and inspection of the various STC components on the HMD factory floor was

observed. The inspector also reviewed documentation of factory testing of various

components that had occurred prior to the inspection.

b.

Observations and Findinqs

IPEC personnel prepared a spreadsheet that included each component of the STC and

what actions where to be performed for that component. Actions included visual

inspection for component integrity, testing of the selected component with other

components, and functionality of the component. IPEC personnel performed an

extensive review of the various components and identified numerous action items for

follow up by HMD. In addition load test results of the STC lifting trunnions and the lid

lifting devices were reviewed. Open items were noted by the IPEC project managers as

well as spare parts to be provided with the STC. Additional visits to Holtec by the

licensee will be necessary to resolve the remaining open items.

c.

Conclusions

The licensee demonstrated adequate oversight of HMD during the testing and inspection

of STC components. A detailed spreadsheet of components, test results, and follow up

items was developed. No findings of significance were identified.

Exit Meeting Summary

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

inspector presented the inspection results in a conference call with Joe DeFrancesco, Project

Manager for IPEC, and other licensee personnel at the conclusion of this inspection on

February 17,2011.

ATTACHMENT: SUPPLEMENTAL INFORMATION

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SU PPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Glenn Bello, Quality Assurance Auditor, Entergy

"Joe DeFrancesco, Project Manager, Entergy

Suzanne Leblang, Fleet Dry Fuels Coordinator, Entergy

• Rich Miller, Assistant Project Manager, Entergy

• Joseph Pennington, Supervisor Supplier Quality Assurance

Peter Probst, Quality Assurance Auditor, URS Washington Division

Steve Triditi, Mechanic, Entergy

Carl Weber, Mechanic, Entergy

• Denotes attendance at exit telephone call

60852

INSPECTION PROCEDURES USED

ISFSI Component Fabrication by Outside Fabricators

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on the list does

not imply the NRC inspector reviewed the documents in their entirety but rather that selected

sections or portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document, or any part

of it, unless this is stated in the body of the inspection report.

Load Test Procedure for the Shielded Transfer Canister, HPP-1775'8, Rev. 3

Non-Conformance Reports for Shielded Transfer Canister Project

Procurement Specification for Elastomeric Seals for Modified lP-2 HI-TRAC 100D Lid

Entergy CAR LO-CAR-2O10-00087, dated 1110412Q10

Entergy CAR LO-CAR-2O1 0-00098, dated 121101201 1

Entergy Quality Assurance Program Manual, Rev. 21, dated 121141201Q

Vendor Non-Conformance Report #189, dated 1111112010

STC Leak test Procedure, HPP-1775-4, Rev.0, dated 11108/2010

Hydrostatic Pressure Test Procedure for STC, HPP-1775-7, Rev. 0, dated 1012912010

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ADAMS

CAR

CFR

DNMS

HMD

IPEC

ISFSI

NCR

NRC

QA

RAI

STC

URS

ACRONYMS

Agency wide Documents Access and Management System

Corrective Action Request

Code of Federal Regulations

Division of Nuclear Materials Safety

Holtec Manufacturing Division

Indian Point Energy Center

Independent Spent Fuel Storage Installation

Non-Conformance Report

Nuclear Regulatory Commission

Quality Assurance

Request for Additional Information

Shielded Transfer Canister

URS Washington Division

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