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Information Notice No. 95-29: Oversight of Design and Fabrication Activities for Metal Components Used in Spent Fuel Dry Storage Systems
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C. 20555-0001 June 7, 1995 NRC INFORMATION NOTICE 95-29: OVERSIGHT OF DESIGN AND FABRICATION ACTIVITIES FOR METAL COMPONENTS USED IN SPENT FUEL DRY STORAGE SYSTEMS Addressees All holders of operating licenses or construction permits for nuclear power reactors. Independent spent fuel storage installation designers and fabricators. Purpose The U.S. Nuclear Regulatory Commission is issuing this information notice to alert addressees to observed shortcomings in oversight of design and fabrication activities for metal components used in spent fuel dry storage systems. 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 information notice are not NRC requirements; therefore, no specific action or written response is required. Description of Circumstances As part of an application for an independent spent fuel storage installation license or spent fuel dry storage system certificate of compliance, the applicant provides quality assurance commitments to NRC pursuant to the requirements of Part 72, Subpart G, of Title 10 of the Code of Federal Regulations. The holder of a general license under 10 CFR Part 72, Subpart K, must implement the quality assurance program approved by NRC under its 10 CFR Part 50 license for activities under the general license. NRC performs inspections of licensees and certificate of compliance holders to verify adequate implementation of these regulatory requirements. NRC has been conducting quality assurance inspections of designers and fabricators of metal components for dry storage systems since 1991. Metal components of dry storage systems are normally fabricated at vendor facilities located offsite from a power reactor licensee. These components include items (e.g., storage canister, storage basket, and onsite transfer cask) that are not part of the concrete installation structures. Inspections have been conducted at design facilities, fabrication facilities and reactor licensee sites to review specific dry storage system quality requirements and their implementation. A total of six NRC inspection reports have been issued to date: specifically, Inspection Report Nos. 722501/91-02, 721007/92-01, 721004/93-07, 72-1007/94-207, 72-0010/94-210, and 72-0010/94-212. The results 9506050138 . IN 95-29 June 7, 1995 Page 2 of 3 of these inspections are relevant to licensees and certificate holders who are currently, or are planning to be, involved in design, fabrication or oversight activities associated with dry storage systems. In five of the six inspections, NRC identified shortcomings in the implementation of quality assurance commitments. The most frequent inspection findings are categorized in Attachment 1, "Inspection Findings for Design and Fabrication Activities of Metal Components Used in Spent Fuel Dry Storage Systems." Discussion NRC inspects the implementation of licensee and certificate holder quality assurance programs to verify the quality of metal components used in dry storage systems. In order to ascertain compliance with safety analysis report commitments, the inspection teams review design and fabrication records, weldment radiographs, licensee oversight of vendor activities, fabrication processes, nondestructive examination activities, and personnel qualifications. As shown in Attachment 1, the majority of inspection findings were in the areas of document control, quality assurance records, and control of purchased material, equipment and services. These inspection results present a number of findings which individually may not be of high safety significance. However, when the inspection team identifies many occurrences of the same type of finding, or many findings in a variety of areas, the overall assurance of quality is undermined. On several occasions, the quality of safety-related hardware was indeterminate at the conclusion of the inspection. Only after extensive searches for missing quality records, physical reexamination or testing were the issues resolved. The time required to resolve these inspection findings has resulted in significant delays in schedules to reactor facility licensees and certificate holders. Related Generic Communications IN 95-28, "Emplacement of Support Pads for Spent Fuel Dry Storage Installations at Reactor Sites." . IN 95-29 June 7, 1995 Page 3 of 3 This information notice requires no specific action or written response. If you have any questions about the information in this notice, please contact one of the technical contacts listed below. /s/'d by BKGrimes /s/'d by DACool Brian K. Grimes, Director Donald A. Cool, Director Division of Project Support Division of Industrial and Office of Nuclear Medical Nuclear Safety Reactor Regulation Office of Nuclear Material Safety and Safeguards Technical contacts: Stephen C. O'Connor, NMSS (301) 415-7878 Stephen S. Koenick, NRR (301) 415-2841 Attachments: 1. Inspection Findings for Design and Fabrication Activities of Metal Components Used in Spent Fuel Dry Storage Systems . Attachment 1 IN 95-29 June 7, 1995 Page 1 of 1 INSPECTION FINDINGS FOR DESIGN AND FABRICATION ACTIVITIES OF METAL COMPONENTS USED IN SPENT FUEL DRY STORAGE SYSTEMS Quality Assurance (QA) Program Section.No. of Inspection Findings.Document Control Maintenance of QA Records Control of Purchased Material, Equipment, and Services Control of Measuring and Test Equipment Instructions, Procedures, and Drawings Inspection (Fabrication Hold Points and Quality Control) Nonconforming Materials, Parts, or Components.20 19 18 16 14 12 11 Description of QA Program Findings: . Document control deficiencies can be summarized generally as outdated revisions of procedures, instructions and drawings located where they may be used inadvertently by personnel, or missing authorization signatures, dates or approval stamps. . Maintenance of QA records deficiencies can be summarized generally as inadequacies in maintaining sufficient documented evidence of welder qualifications, dimensional checks, certified material test reports, or records of weld repairs. . Control of purchased material, equipment, and services deficiencies can be summarized generally as use of contractors or suppliers not on an approved vendor list, missed periodic audits of contractors or suppliers on an approved vendor list, or inadequate examination of products on delivery. . Control of measuring and test equipment deficiencies can be summarized generally as use of inappropriate or uncalibrated equipment in fabrication, test or operation activities. . Deficiencies in instructions, procedures and drawings can be summarized generally as performing activities affecting quality that are not in accordance with approved documented guidelines. . Inspection deficiencies can be summarized generally as fabrication hold points not witnessed and approved by authorized personnel, or unqualified quality control inspection personnel. . Nonconforming materials, parts or components deficiencies can be summarized generally as nonconforming items not identified as such to prevent inadvertent use, or not tracked and documented properly to maintain a complete history of materials used in fabrication.
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