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
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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.