A TRANSNUCLEAR, INC. US Unsubstantiated

A
AREVA
TRANSNUCLEAR, INC.
E-28731
Report to the US Nuclear Regulatory Commission (USNRC)
UnsubstantiatedCertified MaterialTest Reports
Hwa Shin Bolt Industrial Co., Ltd.
October30, 2009
PURPOSE OF REPORT
Pursuant to the requirements of 10 CFR 21, Transnuclear, Inc. is providing the enclosed thirty day written
report as provided for in 10 CFR 21.21 (d)(3)(ii).
On October 1, 2009, the President and Chief Executive Officer of Transnuclear, Inc. provided phone and
follow-up written notification to the NRC Operations Center of a potential deviation and failure to comply
associated with unsubstantiated certified material test reports (CMTRs) for certain small parts utilized in
products fabricated in accordance with the requirements of 10 CFR 72.
Information required to be reported by 10 CFR 21.21 is provided as follows:
10 CFR 21.21(d) (4) (i)
Name and address of the individual informing the commission
Tara J. Neider
President and Chief Executive Officer
Transnuclear, Inc.
7135 Minstrel Way, Suite 102
Columbia, MD 21045
10 CFR 21.21(d) (4) (ii)
Identification of the facility and the basic component supplied to such facility
This information is presented in the section of this report titled "Extent of Impact and Current Status."
10 CFR 21.21(d) (4) (iii)
Identification of the firm supplying the basic component which fails to comply or contains a defect
Transnuclear Inc., 7135 Minstrel Way, Suite 300, Columbia, MD 21045
The NRC 10 CFR 72 Certificate Holder and supplier of the Dry Shielded Canisters discussed in this
report.
Hitachi Zosen (HZ) Corporation, Ariake Works, Nagasu-Machi, Tamana-Gun, Kumamoto-Pref, Japan
The Transnuclear sub-contractor responsible for material procurement and fabrication of Dry Shielded
Canisters (DSCs) and Transfer Cask discussed in this report.
10 CFR 21.21(d) (4) (iv)
Nature of the defect or failure to comply and the safety hazard which is created or could be created
Transnuclear has conducted the necessary evaluations and review and determined that the defect or failure
to comply discussed in this report does not and cannot result in loss of safety function such that a
substantial safety hazard could be created. Information supporting this statement is presented in the
sections of this report titled "Engineering Evaluations and Significant Safety Hazard Determination" and "List
of Impacted Items."
10 CFR 21.21(d) (4) (v)
The date on which the information of such defect or failure to comply was obtained
This information is presented in the section of this report titled "Issue Chronology."
10 CFR 21.21(d) (4) (vi)
In the case of a basic component which contains a defect or fails to comply, the number and location of
these components in use at, supplied for, beingq supplied for, or may be supplied for...
This information is presented in the section of this report titled "Extent of Impact and Current Status."
10 CFR 21.21(d) (4) (vii)
The corrective action which has been, is being, or will be taken: the names of the individual or organization
responsible for the action: and the time that has been or will be taken to complete the action
This information is presented in the section of this report titled "Corrective Action That Has Been / Is Being I
Or Will Be Taken."
10 CFR 21.21(d) (4) (viii)
Any advice relative to the defect or failure to comply about the facility, activity, or basic component that has
been, is beingq taken, or will be .qiven to purchasers or licensees
Transnuclear has notified all users (licensees) of the Dry Shielded Canisters subject to this report of the
defect or failure to comply discussed within this report. Additionally, Transnuclear has notified other
suppliers utilized by Transnuclear for the fabrication of products required to meet the requirements of 10
CFR 72 of the condition discussed in this report and confirmed that these TN subcontractors have not
procured materials and items from the source of supply discussed herein.
This report is provided to the USNRC by Transnuclear on October 30, 2009:
Tara J. Neider
President nd (ChiefExecutive Officer
Transnuclear, Inc.
7135 Minstrel Way, Suite 300
Columbia, MD 2104
E-28731
Page 2 of 24
Executive Summary
BACKGROUND
Transnuclear Inc. (TN), utilizes Hitachi Zosen (HZ) Corporation, Ariake Works in Nagasu, Japan, as a
fabricator of Dry Shielded Canisters (DSC's) for supply by TN to multiple 10 CFR 50 licensees for the dry
storage of spent nuclear fuel assemblies under the provision of 10 CFR 72. In general, DSC's consist of
an outer stainless steel shell (canister assembly) with a welded lid that serves as the confinement
boundary for the radioactive materials being stored. Internally, a DSC utilizes a welded stainless steel
frame (basket) to position and hold the spent nuclear fuel elements along with any necessary neutron
poison material. The basket has shaped segmented "rail" assemblies that are bolted to this frame to
shape the basket into a cylindrical form that is designed to fit inside the canister assembly. The fabrication
process generally requires the use of materials procured from multiple suppliers and includes products
and items such as stainless steel plate and forgings (dependent upon the design) for the canister, basket
and rails along with nuts, bolts, studs and screws that are used to attach the rail assembly to the basket
and form the basket assembly.
IDENTIFICATION AND REPORTING OF UNSUBSTANTIATED CERTIFIED MATERIAL TEST REPORTS
In August 2009, a Quality Assurance (QA) representative from Progress Energy (PGN) was at the HZ,
Ariake Works for the purposes of conducting oversight of TN and HZ controls for fabrication of DSCs
intended for use at the PGN Brunswick Nuclear Plant (these DSCs are still in fabrication and have yet to
be delivered for use).
On September 9, 2009, TN was informed by PGN that two panhead screws had been removed from the
HZ shop by the PGN QA Representative and that PGN had subjected them to testing at the PGN Harris
Energy & Environmental Center. The PGN report of this testing indicated that the material of composition
for these screws appeared to be something other than what was represented in the Certified Material
Test Report (CMTR) provided to HZ by the Hwa Shin Bolt Industrial Company of Busan, South Korea.
Specifically, the HZ purchase order required that panhead screws meet the requirements of ASME
SA193, Grade B8 (or equivalent) and that a Certified Material Test Report must be provided to
substantiate satisfaction of this requirement.
Figure 1: Panhead Screw Installed in DSC
On September 10, 2009, TN provided HZ with the information received from PGN and requested that HZ
assess the concern raised and to provide TN with any actions necessary to address the identified
concern. TN also notified PGN of this communication with HZ on the same day.
E-28731
Page 3 of 24
On September 18, 2009, HZ provided TN with a copy of a letter that they had received from Hwa Shin
Bolt Industrial Company (the supplier of the panhead screws for the PGN - Brunswick project) that stated
that the panhead screws provided were not manufactured from the material that had been certified to in
the CMTR. Upon receipt of this information, TN requested that HZ initiate an internal Corrective Action
Report and identify all material procured by HZ from Hwa Shin. Additionally, on September 18, 2009, TN
notified PGN of the information received from HZ and that HZ had been requested by TN to initiate a
Corrective Action Report to establish the extent of condition.
During the week of September 19, 2009, HZ initiated its review of procurement history with Hwa Shin Bolt
Industrial Company. On September 22, 2009 HZ also visited the Hwa Shin facility in Busan, South Korea.
As a result of the trip to Hwa Shin, HZ determined that documentation provided by Hwa Shin to
substantiate the material provided was suspect. This determination was provided by HZ to the TN
representative at HZ who then passed this information to TN personnel in the Columbia, MD offices on
September 25, 2009.
On September 24, 2009, TN issued Supplier Finding Report (SFR) No. 2009-058 to HZ for the purposes
of requesting corrective action for the condition identified with the panhead screws and to also identify the
extent of the condition (all material procured from Hwa Shin). TN also initiated an internal Corrective
Action Report (CAR) No. 2009-086 to start the internal review processes for determining if the condition
was potentially reportable under the provisions of 10 CFR 21. At this time, TN also initiated discussions
with NRC staff from the Division of Spent Fuel Storage and Transportation to notify them of the identified
condition and discuss reportability requirements. These discussions were held on September 24 and 25,
2009 with information associated with the condition being provided by email. At this point, TN understood
that the condition did impact DSCs that were being fabricated for PGN - Brunswick and that none of
these DSCs had been delivered for use. The extent of condition determination on the part of HZ for
projects other than PGN - Brunswick was still being developed.
On October 1, 2009, a TN management representative visited the HZ facility in Japan to review corrective
actions being taken or planned and the status of the extent of condition determination. The initial HZ
extent of condition review was provided to TN at that time and based on a review of the information it was
determined that Hwa Shin had provided items that had been utilized in multiple projects and included a
large number of DSCs and one Transfer Cask that had been provided by TN to several NRC licensees.
This information was provided to senior management at the TN Columbia offices and on October 1st,
2009, the TN President and CEO provided verbal notification to the NRC Operations Center of the
potential for a reportable condition under the requirements of 10 CFR 21. This verbal notification was also
followed-up with a written confirmation of the phone call. As part of this notification to the NRC, TN stated
that "Transnuclear is in the process of performing a 10 CFR 21 but does not believe that the issue has
safety significance. TN is reporting this issue because Hwa Shin may have supplied parts to others that
may have safety significance."
Between the notification to the NRC on October 1, 2009 and the date of this report, TN has conducted
reviews and evaluations of technical and licensing requirements for the DSC models and Transfer Cask
impacted by this condition, worked with HZ to develop and institute a testing program in order to obtain
additional information on the material properties of the items supplied by Hwa Shin, and initiated or
implemented other corrective actions determined necessary to address the potential for impact on safety
as a result of this event.
Although many of the planned corrective actions are incomplete at this time, and TN and its subcontractor
HZ have yet to complete the root cause(s) determination such that appropriate preventative actions can
be identified and implemented, TN has been able to conclude that:
1.
Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into loaded
DSC Models 61 BT and 32PT do not and cannot create a condition that results in a loss of safety
function such that a Substantial Safety Hazard could be created. TN has made this conclusion
E-28731
Page 4 of 24
based on a review of design calculations, testing of available Hwa Shin materials and review of
licensing documents.
2.
Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into Transfer
Cask Model OS-197H delivered to Constellation - Ginna Nuclear Power Plant will be replaced
by TN prior to first use. As such, the condition does not create a condition that results in a loss
of safety function such that a Substantial Safety Hazard is created. Replacement of these parts
will be controlled under the TN NRC approved Quality Assurance Program. Constellation.
approval of the replacement plan will be obtained before implementation.
3.
Items provided by Hwa Shin Bolt Industrial Company to HZ that have not been incorporated by
fabrication activities into a DSC will be replaced with items procured from a different HZ audited
and approved source. Disposal of these items will be controlled under the TN approved HZ
Quality Assurance Program.
4.
Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into a DSC by
fabrication activities will be replaced and disposed of if replacement of the items does not raise
the potential of damage to the DSC. Replacement of these items will be controlled under the TN
approved HZ Quality Assurance Program and/or the TN NRC approved Quality Assurance
Program. Necessary approvals will also be obtained from the NRC 10 CFR 50 licensee prior to
implementing the replacement plan.
5.
Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into a DSC
and cannot be removed due to concerns with damaging the DSC will not be removed. Approval
and justification for use for the items not removed will be provided to HZ by TN as required by
the TN NRC approved Quality Assurance Program. In addition, TN will provide the documented
justification for not removing these items from each DSC to each affected NRC 10 CFR 50
licensee for its approval prior to implementing the disposition and recertification of the DSC to
the conditions of the applicable 10 CFR 72 NRC Certificate of Compliance. This applies to DSCs
that have been delivered (both loaded and not loaded) and DSCs that are still at the HZ facility in
Japan.
E-28731
Page 5 of 24
Extent of Impact and Current Status
EXTENT OF IMPACT
Dry Shielded Canisters
HZ performed an extent of condition review as required by TN SFR 2009-058 and HZ CAR No. C-09-C-12.
From this review, HZ provided the following table detailing all projects undertaken for TN with identification
of those projects for which HZ had procured items from the Hwa Shin Bolt Industrial Company.
Note: 61 BT-M is HZ's internal type designation for the TN Model 61 BT DSC (for Short Damaged Fuel)
Attaho0ment
I
774520010,0.DS~sa8760164
001000
NO.16F2311W.29.20o
Status ofAllTNProjects related to HWASHINBOLTMaturials(Reference TNSFR No.2009-058,
HZCARNo.C-00-C-12)
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Table 1: Extent of Condition for DSCs fabricated by Hitachi Zosen
E-28731
Page 6 of 24
OS 197 Transfer Cask
The materials provided to HZ by Hwa Shin also included items incorporated into one transfer cask that
was delivered to Ginna. TN has confirmed that this Transfer Cask has not been put into service by
Constellation Energy. These parts will be replaced.
HZ
TN
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Type
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49
Table 2: Extent of Condition for Transfer Casks fabricated by Hitachi Zosen
CURRENT STATUS
Dry Shielded Canisters and Transfer Cask
The items in question affect a total of 59 DSCs that are either still at the HZ facility in Japan, have been
delivered for use but not put into service or have been put into service by a 10 CFR 50 licensee in the
United States. Of the 59 DSCs with Hwa Shin items, 39 have been delivered with 17 of these having
been loaded and placed in the NUHOMS Horizontal Storage Modules (HSM) and the remainder (22) in
storage waiting to be loaded. The one Transfer Cask with Hwa Shin parts has been shipped to its US
licensee but has not been put into service.
Exelon
Oyster Creek
Exelon
Oyster Creek
DOM-
Millstone
1004
1004
1004
61 BT
DSC
61BT
DSC
32PT
DSC
1098
10982
11066
161F231
16F018
16F306
009
010
OCG61 B-009-C
YES
OCG61B-010-C
YES
011
OCG61B-011-C
012
OCG61B-012-C
013
014
015
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
OCG61B-013-C
YES
YES
YES
OCG61B-014-C
OCG611B-015-C
YES
YES
YES
YES
YES
YES
016
OCG611B-016-C
YES
YES
YES
017
OCG61B-017-C
YES
YES
NO
On Site
018
OCG61B-018-C
YES
YES
NO
On Site
YES
YES
YES
YES
YES
YES
YES
YES
NO
On Site
YES
YES
NO
On Site
YES
YES
NO
On Site
HZ01 0
HZ011
HZ012
HZ013
HZ014
MPS32PT-S100A-HZ010
MPS32PT-S1 00A-HZ011
MPS32PT-S100A-HZ012
MPS32PT-S100A-HZ013
MPS32PT-S100A-HZ014
E-28731
Page 7 of 24
bS32P -S1
HZ01 5
HZ016
HZ017
HZ018
PPLSusquehanna
PPLSusquehanna
NPPD-
61BT
DSC
1004
1004
61BT
DSC
61B
1004
10963
10964
11203
16F312
16F311
___
1004
61BT
DSC
10983
___
16F312
1004
61BT
DSC
10965
16F317
11171
16F312
I
I
32PT
DSC
11202
16F313 1
NO
NO
NO
NO
NO
NO
Fabrication
Complete
Fabrication
Complete
Fabrication
Complete
YES
YES
YES
YES
027
SSE61 B-027-A
YES
YES
YES
028
029
SSE61B-028-A
SSE61B-029-A
YES
YES
YES
YES
NO
YES
030
SSE61 B-030-A
YES
YES
YES
031
SSE61B-031-A
YES
YES
NO
On Site
032
SSE61 B-032-A
YES
YES
NO
On Site
033
SSE61B-033-A
YES
YES
YES
034
SSE61 B-034-A
YES
YES
YES
001
CNS61B-001-A
YES
YES
NO
On Site
002
CNS61 B-002-A
YES
YES
NO
On Site
003
CNS61 B-003-A
YES
YES
NO
004
NO
Y
YES
NO
YSO
YES
NO
005
CNS61B-004-A
B0
CNS61 B-005-A
NO
On Site
Fabrication'
on Hold
i
On Site
006
CNS61B-006-A
YES
YES
NO
On Site
007
CNS61 B-007-A
YES
YES
NO
On Site
008
CNS61 B-008-A
YES
YES
NO
On Site
019
OCG61B-019-C
YES
YES
NO
On Site
020
021
OCG61B-020-C
OCG61B-021-C
YES
YES
YES
YES
NO
On Site
NO
On Site
022
OCG61 B-022-C
Not Yet
Assigned
Not Yet
Assigned
Not Yet
Assigned
Not Yet
Assigned
Not Yet
Assigned
Not Yet
Assigned
Not Yet
Assigned
Not Yet
Assigned
REG32PT-S125A-16-001
YES
YES
NO
On Site
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
---
YES
YES
NO
On Site
NO
NO
On Site
036
002
004
1004
NO
YES
003
ConstellationGinna
NO
YES
001
61BTH
DSC
NO
On Site
SSE61 B-026-A
038
1004
NO
SSE61B-025-A
037
ProgressBrunswick
YES
026
035
PPLSusquehanna
YES
025
DSC
Cooper
ExelonOyster Creek
16F308
A-HZ015
MPS32PT-S100.. A-HZ016
MPS32PT-S100I
A-HZ017
MPS32PT-S100A-HZ018
001
002
1 REG32PT-S125A-16-002
__ES
YES
-YES
YES
]
On Site
E-28731
Page 8 of 24
k.saus
003
004
005
006
007
008
009
010
ConstellationGinna
1004
OS197H
Transfer
Cask
1 9
11203
16F314
OS197H7
A-i16-003
REG32PT-S125A-16-004
REG32PT-S125A-16-005
REG32PT-S125A-16-006
REG32PT-S125A-16-007
REG32PT-S125A-16-008
REG32PT-Si25A-1 6-009
REG32PT-S125A-1 6-010
NO
NO
NO
NO
---
NO
NO
---
NO
NO
---
NO
NO
---
NO
NO
---
NO
NO
NO
NO
OS197H-7
YES
YES
1r
NO
On Site
E-28731
Page 9 of 24
Engineering Evaluations and Significant Safety Hazards
Determination
ENGINEERING EVALUATIONS
Justification for Continued Operations
In order to support operability determinations on the part of licensee with loaded DSCs subject to the
condition described in this report, TN provided the following information:
Transnuclear Memo E-28630, dated 10/09/09, Justificationfor Continued Operabilityfor Loaded
NUHOMS 32PT DSCs Serial Numbers MPS32PT-S100-A-HZ010 and -HZ01 I at Dominion Nuclear
Connecticut's Millstone Power Station
Transnuclear Memo E-28634, dated 10/08/09, Justificationfor Continued Operabilityfor Loaded
NUHOMS 61BT DSCs at PPL Electric Steam Utilities Corp's Susquehanna Steam and Electric Station
Transnuclear Memo E-28726, dated 10/29/09, Justificationfor Continued Operabilityfor Loaded
NUHOMS 61BT DSCs Serial Numbers OCG-61B-009-Cthru -016-C at Exelon's Oyster Creek Generating
Station
These memos concluded that that the subject DSCs remain capable of performing the design functions of
confinement, heat removal, shielding and criticality control associated with the safe storage of spent
nuclear fuel.
Significant Safety Hazard Determination
(The following is an attachment to TN CAR 2009-086 and is being provided in its entirety)
Attachment to CAR 2009-086
October 30, 2009
Substantial Safety Hazard Determination
The subject corrective action report resulted from the identification that small screws supplied to one of
Transnuclear's canister fabricators, Hitachi Zosen, by Hwa Shin Bolt Industries is suspected of being a different
material than that specified and certified. Hwa Shin supplied studs, screws, nut and washers. In addition, they
provided material for the test port plugs, tool sockets and alignment legs. Until determined otherwise, all materials
supplied by Hwa Shin are being treated as indeterminate by Hitachi Zosen and Transnuclear.
The following NUHOMS® DSCs are affected by this situation: 32PT, 61BT, and 61BTH Type 2. Plants that are
affected are Exelon/Oyster Creek, Dominion/Millstone, PPL/Susquehanna, NPPD/Cooper, Progress
Energy/Brunswick, and Constellation/Ginna. In addition, the Transfer Cask, 0S197H-7 purchased by Nine Mile
Point and delivered to Ginna is also affected by this CAR. DSCs affected range from some with loaded fuel to some
in varying stage of fabrication.
The parts which are affected by Hwa Shin for the canisters loaded with fuel are described in detail and listed in the
reference [1].
Hitachi Zosen is performing material testing (chemistry and hardness) on materials from Hwa Shin that were in
Hitachi Zosen's inventory, waiting to be used for the DSCs or Hwa Shin materials left over from previously
fabricated DSCs. Hitachi Zosen provided TN with the test results and based on this information TN has concluded
that all materials exhibit the chemistry of 300 series stainless steel except for lock washers which exhibit the
chemistry of 200 series stainless steel. The vent (test) port plug and the weld studs exhibit hardness characteristic of
E-28731
Page 10 of 24
annealed material; washers, screws, and nuts exhibit hardness characteristic of cold-worked materials. All materials
were tested in accordance with Hitachi-Zosen Material Verification Procedure MVP-01, Rev 2.
Based on these test data, Hwa Shin did not supply grossly deficient material from a technical point of view. That is,
the alternate materials provided are austenitic stainless steels with corrosion resistance and strength similar to that of
the specified material. It is reasonable to assume that materials already installed in the DSCs are also stainless steel.
If materials were not stainless steel, indication of this difference in material would most likely have been identified
during fabrication process as a result of visual inspection, weldability issues, corrosion, liquid penetration
examination, etc.
An evaluation was performed on the parts supplied by Hwa Shin [1]. A summary of the evaluation is provided
below:
A. The failure of the parts will not affect the public health and safety.
B. The basket rail weld studs, nuts, screws, and washers are used to hold the basket together during
fabrication. Once the basket is assembled and installed in the DSC these parts are not required. No credit
was taken for them in the normal, off-normal and accident loading conditions.
C. As long as the materials are any grade of austenitic stainless steel the parts will perform as well as the
originally specified material, and it will not affect the safety function of the DSC.
D. The test port plugs are used to seal the test port in the outer top cover plate and are not part of the
confinement boundary, and substitution of an alternate austenitic stainless steel would not affect its
function. This part is subject to visual and liquid penetration examinations following welding.
E. The shoulder screw is used to assemble the spacer disk to the top shield plug. The spacer disk's function is
to minimize the gap between the top shield plug and the basket. After installation, the spacer disk will
perform its function as it will be captured between the basket and the top shield plug and the function of the
shoulder screw is not required.
In consideration of items A - E cited above, Transnuclear determines that this condition does not and cannot result
in the loss of safety function such that a Substantial Safety Hazard is created.
References:
1.
CAR 2009-086, Condition Evaluation
Prepared By$t
,
1
F
Reviewed By:
Approved
.
•
1
.,x•
L.
P. Shih, Director of Engineering and Licensing
J. Bondre, VP of Engineering
R. Grubb, Chief Operating Officer
E-28731
Page 11 of 24
List of Impacted Items
IMPACTED ITEMS
Listing of Items Supplied by Hwa Shin
This section of the report contains a listing of the items that are affected for each type of DSC and the
Transfer Cask. The applicable drawings are also listed in the table with the part (item) number and original
material that was specified in the system design.
NUHOMS® 32PT DSC
Hex Nut, TN item 49 (HZ item 349), Quality Category A, material ASTM F594 Group 1, shown on
drawings 11064-30-3 and NUH32PT-2003.
NUHOMS® 61BT DSC
HZ Item Number
TN Item Number
46P
46R
46S
60
Reference: Transnuclear
Description
Quality
Category
46P
Weld stud
46R
Flat washer
46S
Hex nut
60
Vent (test) port plug
drawings 10961-30-2 & 1098-30-2
Additional parts for damaged fuel option (61 BT)
HZ Item Number
TN Item
Description
Number
79D
79D
Top Cap, Tool Socket
80E
80E
Bottom Cap, Tool Socket
83
83
Shoulder Screw
84
84
Machine Screw
Reference: Transnuclear drawings 1098-30-27
A
A
A
A
Quality
Category
A
NITS
C
NITS
Mtra pcfe
Material Specified
SA 479 type 304
304 SST
304 SST
SA 479 type 304
Material Specified
SA 479 type 304
304 SST
AISI 304 or 316
SST
NUHOMS® 61BTH Type 2 DSC
HZ Item
SNumber
215A/B
216
217A/B
219
014
231
231A
218
602J
TN Drawing-Item Number
NUH61 BTH-4002-15
NUH61BTH-4002-16
NUH61BTH-4002-17
NUH61BTH-4002-19
NUH61BTH-4000-14
NUH61BTH-4002-31
NUH61BTH-4002
(DWG Note 29)
NUH61BTH-4002-18
NUH61 BTH-4006-2J
Description
ult
Quality
Material Specified
Stud
Hex Nut
Flat Washer
Oval Washer
Test Port plug
Panhead Screw
Hex Nut
A
C
C
NITS
A
A
A
SA 479 type 304
SST
SST
SST
SA 479 type 304
SA 193 B8
SST
Lock washer
Alignment Leg
NITS
A
SST
SA 479 type 304
E-28731
Page 12 of 24
NUHOMS® OS197H Transfer Cask
HZ Item
TN Drawing-Item Number
410
325
327
314
Quality
Description
Number
Material Specified
Category
NUH-06-8021-10
NUH-06-8003-25
NUH-06-8003-27
NUH-06-8003-14
Hex Bolt
Washer
Washer
Cap Screw
B
NITS
NITS
NITS
SA 193 B7
ASTM F436
ASTM F436
17m4 SS Sy
=
90ksi
Table 4: List of Affected Parts
Pictures or Graphic of Impacted Items
Some of the items that are affected and installed are accessible and can be removed. Several of the DSCs
in various stages of fabrication at HZ have these parts installed. Where possible pictures were taken of the
part to show what the part looks like and generally where it is located.
FIGURE 2: 32PT Hex Nut (Item 49)
Top Shield
Plug Modified
Canister
Shell
Top Spacer
Shoulder Screw
-
Fuel
Compartment
Extension
Fuel Basket
Figure 3: 61 BT (for Short Damaged Fuel) Shoulder Screw (Item 83)
E-28731
Page 13 of 24
Figure 4: 61 BT Weld Stud (Item 46P), Flat Washer (Item 46R), and Hex Nut (Item 46S)
Figure 5: 61 BT Vent (Test) Port Plug (Item 60), and 61 BTH Test (Vent) Port Plug (Item 14)
Figures 6 & 7: 61BTH Stud (TN Item 15 / HZ Item 215A/B) (61BT Stud is Similar)
E-28731
Page 14 of 24
Figure 8: 61BTH Weld Stud (Item 15), Flat Washer (Item 17), Oval Washer (Item 19) and Hex Nut (Item 16)
Figure 9: 61BTH Panhead Screw (Item 31)
Figure 10: 61BTH Hex Nut (DWG Note 29)
Figure 11: 61 BTH Alignment Leg for Top Grid Assembly (TN Item 2J / HZ Item 602J)
E-28731
Page 15 of 24
MATERIAL CONTROL
Control of Non-Conforming Items
HZ has collected all Hwa Shin items that remained unused, has placed the unused items in a controlled
area away from the area where fabrication is being performed and has tagged the items to prevent further
use. These items are under the control of the HZ nonconformance system until dispositioned.
Figures 12 & 13: Hwa Shin Items- Tagged with NCR and in Segregated Storage
E-28731
Page 16 of 24
ISSUE CHRONOLOGY
The following provides the sequence of events starting at the point TN became aware of the potential
issue with material supplied to HZ by Hwa Shin and to the point of TN's notification to the NRC
Operations Center (10/1/09) of a condition that may be reportable under the provisions of 10 CFR 21.
09/09/09
TN received information from Progress Energy (PGN) that analysis of two panhead
screws (item 31, TN Drawing NUH61 BTH-4002; Sheet 1 of 8, Part List; and Sheet 3 of 8,
Detail 1) indicated that the material of composition may not be as required by ASME
SA193 B8. The panhead screws were obtained by PGN oversight personnel at the
Hitachi Zosen facility during the assembly of the initial 61BTH DSCs for PGN Brunswick
Station / TN Project No. 11171. No DSCs have been delivered under this order by TN to
PGN at this time
09/10/09
TN notified Hitachi Zosen of the information provided by Progress Energy and requested
a Hitachi Zosen evaluation and response
09/18/09
Hitachi Zosen notified TN of the results of their follow-up discussions with Hwa Shin Bolt
Industrial Company. Hwa Shin states by letter to HZ that the material they supplied was
not the material that they certified
9/18/09
TN notified Progress Energy of the HZ evaluation. Copies of the Hwa Shin Bolt Industrial
Company letter and material specification requirements provided
09/23/09
Discussions held between TN and HZ on actions being planned by HZ in response to the
Hwa Shin letter of 9/17/09
09/23/09
HZ visit to Hwa Shin to discuss the letter provided to HZ by Hwa Shin on 9/17/09
09/24/09
Supplier Finding Report (SFR-2009-058) issued to request HZ to provide extent of
condition and corrective action for materials supplied to by Hwa Shin Bolt Industrial
Company
09/24/09
TN initiated CAR 2009-086 (Level 1) in order to obtain a reportability determination. TN
Procedures TIP 7.13, 16.1 and 15.1 provide procedural instructions to determine 10 CFR
21 reporting
09/24/09
TN initiated and held a telecon with the Director and several staff of the USNRC Division
of Spent Fuel Storage and Transportation to discuss the identified condition and potential
reportability under 10 CFR 21. TN participants in this phone call were President, Chief
Operating Officer and Director, Corporate Quality Assurance
09/25/09
The TN oversight representative at HZ provided TN Columbia with a summary of the
results of the HZ visit to Hwa Shin. The HZ visit confirmed that the CMTR provided by
Hwa Shin was false and that this condition applied to all small parts provided by Hwa
Shin. HZ indicated that larger parts did have CMTR traceability
09/25/09
A phone call was initiated by NRC Director, Division of Spent Fuel Storage and
Transportation and the TN Chief Operations Officer. NRC requested and TN provided a
copy of the Hitachi Zosen purchase order to Hwa Shin for the panhead screws
E-28731
Page 17 of 24
10/01/09
A meeting was held between HZ and TN personnel at the HZ facilities in Japan. The
purpose of the meeting was to understand the HZ status with respect to corrective
actions associated with Hwa Shin and determine if HZ had completed its determination of
the extent of condition with respect to the procurement of materials and items from Hwa
Shin
10/01/09
10/1/09 - email / TN personnel at HZ notify senior management at TN Columbia offices
that the HZ extent of condition for parts procured by HZ from Hwa Shin extend beyond
the Progress Energy Project and include DSCs delivered
10/01/09
HZ issues Nonconformance Reports for all Hwa Shin Parts and segregates the parts.
NCR's were also initiated for each HZ job with DSCs or other components that contain
suspect parts (both shipped or at HZ)
10/01/09
TN determined that the condition is potentially reportable under the provisions of 10 CFR
21.21 and the NRC Operations Center is notified via telephone call by T. Neider. Followup email is provided to the NRC to confirm the call
E-28731
Page 18 of 24
Corrective Action That Has Been / is Being / or Will Be Taken
Transnuclear Actions
The following TN corrective action plan details known corrective actions that have been, are being or
planned to be taken as a result of the condition discussed in this report. TN expects that this corrective
action plan will to be modified as more information is developed. These actions are current as of the date
of this report and are being controlled and tracked under TN CAR 2009-086.
Transnuclear Corrective Action Plan
Action
Due Date
Comments
Responsible
Organization
or Position
COO
9/10/09
Complete
1
Brief all TN staff on the Hwa Shin issue
2
Initiate SFR to request Hitachi Zosen Corrective
Action and Extent of Condition for Hwa Shin
items
Initiate CAR to ensure 10 CFR 21 reportability
considerations are addressed and obtain any
necessary internal corrective actions
Notify NRC Operations Center of the potential
for a reportable condition under 10 CFR 21
QA
9/24/09
See Note 1
Complete
QA
9/24/09
See Note 2
Complete
President &
CEO
10-1-09
See Note 3
Complete
Notify all impacted customers of the Hwa Shin
issue and support operability determinations as
requested.
Notify the TN Users Group of the Hwa Shin
issue.
Sr. Mgmt.
10/14/09
See Note 4
Complete
Management
10/15/09
See Note 5
Completed
7
Complete substantial safety hazards
determination.
COo
10/30/09
See Note 6
Complete
8
Provide written report to NRC as required by 10
CFR 21.21 (d) (3)(ii). Report to be transmitted as
required by 10 CFR 21.5
Provide User Group with the report provided to
the NRC
President &
CEO
10/30/09
See Notes 7 & 8
Complete
Management
10/30/09
Complete
10
Provide written notification to all current TN
fabricators regarding the Hwa Shin issue.
QA
10/7/09
See Note 20
Complete
11
Perform oversight of the second visit to Hwa
Shin by HZ.
QA
10/7/09
See Note 9
Complete
12
Request all current major TN fabricators provide
written descriptions of procedural controls
utilized for the detection of Counterfeit and
QA
10/20/09
See Note 10
Complete
3
4
5
6
9
See Note 11
E-28731
Page 19 of 24
Transnuclear Corrective Action Plan
#
Action
Responsible
Organization
or Position
Due Date
Comments
Fraudulent Items (C/Fl)
13
Determine if Hwa Shin was utilized by other
fabricators of TN equipment.
QA
12/3/09
Working
14
Perform oversight of HZ audit to qualify a new
supplier to replace Hwa Shin
QA
10/23/09
See Note 12
Complete
15
Review TN fabricator controls for Counterfeit
and Fraudulent Items (C/Fl).
QA
11/30/09
QA
11/19/09
Not Started as of
10/28/09
QA
11/19/09
Not Started as of
10/28/09
Engineering
12/8/09
Not Started as of
10/28/09
QA
12/04/09
Not Started as of
10/28/09
QA
12/18/09
Not Started as of
10/28/09
16
17
Determine if any corrective action is needed
Develop language to be inserted into TN
procurement specification requiring supplier to
provide TN with material sample (at TN's
discretion) for testing to determine acceptability
of material supplied. Obtain internal agreement
on the language
Develop language to be inserted into TN
procurement specification (fabricators of major
equipment) requiring supplier to institute a
random screening program for material suppliers
for the purpose of periodically substantiating
material certifications provided. Use of tools
such as XRF analyzers or qualified laboratories
should be provided as an option.
See Note 13
Waiting on
responses from
fabricators
The requirement should include language
requiring the supplier to submit the random
testing program to TN for its review and
approval.
18
19
20
Obtain internal agreement on the language
Identify specifications and schedule for
implementing revised TN Procurement
Specification language for C/Fl controls
Review TN procurement controls against
information provided in NRC GL 82-02 and other
generic communications provided by the NRC to
determine if the procurement controls
encompass appropriate provisions for requiring
TN suppliers to take actions to preclude the
entry of fraudulent and substandard materials
into the supply chain. As determined necessary,
identify any additional corrective actions based
on the results of this review.
Review TN supplier oversight controls against
information provided in NRC GL 82-02 and other
generic communications provided by the NRC to
determine if the controls provide for appropriate
E-28731
Page 20 of 24
Transnuclear Corrective Action Plan
#
21
22
23
24
25
Action
oversight and verification of supplier controls for
fraudulent and substandard items. As
determined necessary, identify any additional
corrective actions based on the results of this
review.
Review and re-classify as necessary the parts
discussed in this report to ensure that
appropriate Quality Classifications are assigned
(TIP 3.6)
Revise all impacted TN design and fabrication
documents as a result of the re-classification of
parts.
Conduct Root Cause Determination to identify
why this condition was identified by a TN
customer as part of their oversight and not by
TN.
Based on the results of the root cause, identify
preventative actions necessary to preclude
recurrence (if not already taken)
Provide notification of the Hwa Shin event to
AREVA Corporate for dissemination
Responsible
Organization
or Position
Due Date
Comments
Engineering
12/10/09
Engineering
12/10/09
QA
12/18/09
Not Started as of
10/28/09
QA
12/18/09
Not Started as of
10/28/09
QA
10/30/09
Complete
Note 19
26
27
28
29
Notify NIAC Organization of Event at the
November annual meeting
Review NIAC Audit Checklist and determine if
process controls include appropriate criteria for
Counterfeit and Fraudulent Materials. Discuss
review results at NIAC Meeting in November
Based on NIAC Meeting discussion determine if
TN needs to utilize at supplemental checklist in
conjunction with NIAC checklist to ensure
appropriate assessment of Counterfeit and
Fraudulent Materials controls
Track and Verify that HZ NCRs are
dispositioned, 72.48 evaluations completed,
approval provided by TN and Licensee (when
required), Disposition is Implemented, TN ReCertification Complete & Records System
Updated (both TN and Licensee)
QA
11/6/09
QA
11/6/09
QA
11/19/09
QA
TBD
E-28731
Page 21 of 24
Hitachi Zosen Actions
The following HZ corrective action plan details known corrective actions that have been, are being or
planned to be taken planned as a result of the condition discussed in this report. TN expects that HZ may
need to modify or otherwise change this plan as more information is developed. These actions are current
as of the date of this report and are being controlled and tracked under HZ CAR No. C-09-C-12. These
actions are subject to TN's review and approval.
Hitachi Zosen Corrective Action Plan
HZ
#
12
Perform fact-finding visit to Hwa Shin to verify
issue
Hitachi Zosen
Due
Date
9/23/09
14
Remove Hwa Shin from AVL
Hitachi Zosen
9/30/09
See Note 14
Complete
El
Identify all materials from Hwa Shin for all
existing projects (extent of condition)
Hitachi Zosen
10/1/09
See Note 15
Complete
15
Write Non-Conformance Reports (NCRs) for all
Projects in shop. Identify, collect, tag and
segregate all Hwa Shin parts
Issued NCR on all existing DSCs and shipped
DSCs on which materials procured from Hwa
Shin were used.
Identify all previously shipped DSCs on which
materials form Hwa Shin had been used.
Perform audit of lab
Hitachi Zosen
10/1/09
See Note 16
Complete
Hitachi Zosen
10/1/09
See Note 17
Completed
Hitachi Zosen
10/1/09
Hitachi Zosen
10/13/09
Develop a testing plan for Hwa Shin Parts that
have been used in DSC that have been
delivered to Utilities
Perform Audit of new vendor for Hwa Shin parts
Hitachi Zosen
10/22/09
Hitachi Zosen
10/2124/09
Hitachi Zosen
10/26/09
Hitachi Zosen
10/27/09
Hitachi Zosen
Hitachi Zosen
TBD
TBD
Hitachi Zosen
Hitachi Zosen
Hitachi Zosen
TBD
11/30/09
11/30/09
Hitachi Zosen
11/30/09
13
E3
17
Action
Responsibility
Comments
Complete
See Note 17
Complete See
Reference 7
Complete See
Reference 17
Complete
Revision 2
approved by TN
Complete
See Note 18
I1
Get results of material test for panhead screw, in
question, from lab
-E2 Send out samples (all heats) selected from the
above materials to the lab for testing and/or
perform chemical analysis and hardness test (by
HZ) using X-Ray Fluorescence Analyzer and
handy-type hardness tester (Equo Tip)
Complete all HZ testing of parts
Receive all chemical composition results from
Lab
Receive all mechanical test results from Lab
18
Issue report detaining all activities completed.
C1 Procure new materials from other qualified
supplier
C2
Establish procedure to identity counterfeit
materials or items
E-28731
Page 22 of 24
NOTES:
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Staff briefing held in the Columbia office with all available TN staff. This briefing was intended as
informational and no attendance records or other documents were developed as a result this
meeting
SFR 2009-058 issued to Hitachi Zosen on 9/24/09
CAR 2009-086 issued on 9/24/09
NRC Operations Center notified on 10/1/09 with follow-up confirmation of the call provided by
email. Notification made as a result of the HZ extent of condition review identifying equipment
subject to the requirements of 10 CFR 72 being delivered for use by TN to a 10 CFR 50 licensee.
Project Managers have notified each customer by telephone and operability determinations were
provided to Dominion, PPL and Exelon. The operability determinations are documented under E
letter Numbers E-28634 for PPL, E-28630 for Dominion and E-28726 for Exelon.
Discussion of the Hwa Shin condition was provided to the TN users group via Telecon on
10/15/09. Minutes of this meeting were not developed as the phone call was for informational
purposes.
The notification made to NRC on 10/1/09 stated that "Transnuclear is in the process of performing
a 10 CFR Part 21 but does not believe that this issue has safety significance. TN is reporting this
issue because Hwa Shin may have supplied parts to others that may have safety significance."
As such, the final safety impact determination by TN had not been completed at the time.
Substantial safety hazard determination complete 10/28/09. The evaluation concluded that the
condition does not and cannot create a condition that results in a loss of safety function such that
a Substantial Safety Hazard is created.
Notification made by E-Letter with copies provided to CAR 2009-086 file.
SSR 2009-108 issued to document result of visit.
TN Letters E-28682 through E-28628 issued with copies provided to CAR 2009-086 file.
Request to fabricators made. Four responses received (no use of Hwa Shin) waiting on balance
of responses
SSR-2009-110 issued to document this surveillance.
No report of this visit generated by HZ - trip summary provided by email
TN oversight has verified that HZ has removed Hwa Shin from the HZ Approved Suppliers List.
The HZ extent of condition review was provided to TN in the response to TN SFR 2009-058.
HZ NCRs are identified on the extent of condition matrix provided by HZ in response to TN SFR
2009-058.
TN performed oversight of the HZ audit of the new supplier. The results of this oversight activity
are provided in TN SSR 2009-110.
Notification provided on 10/30/09 by email with copy of report attached to email.
Notification provided on 10/30/09 by email with copy of report attached to email.
E-28731
Page 23 of 24
List of Tables and Figures
TABLES
Table 1:
Extent of Condition for DSCs Fabricated By Hitachi Zosen
Table 2:
Extent of Condition for Transfer Cask Fabricated By Hitachi Zosen
Table 3:
Current Status of DSCs and Transfer Cask
Table 4:
List of Affected Parts
FIGURES
Figure 1:
Panhead Screw Installed in DSC
Figure 2:
32PT Hex Nut (TN Item 49 / HZ Item 349)
Figure 3:
61 BT (for short damaged fuel) Shoulder Screw (Item 83)
Figure 4:
61 BT Weld Stud (Item 46P), Flat Washer (Item 46R), and Hex Nut (Item 46R)
Figure 5:
61 BT Vent (Test) Port Plug (Item 60), and 61 BTH Test (Vent) Port Plug (Item 14)
Figure 6:
61BTH Stud (TN Item 15 / HZ Item 215A/B) (61BT Stud is Similar)
Figure 7:
61BTH Stud (TN Item 15 / HZ Item 215A/B) (61BT Stud is Similar)
Figure 8:
61BTH Weld Stud (Item 15), Flat Washer (Item 17), Oval Washer (Item 19) and
Hex Nut (Item 16)
Figure 9:
61BTH Panhead Screw (Item 31)
Figure 10:
61BTH Hex Nut (DWG Note 29)
Figure 11:
61BTH Alignment Leg for Top Grid Assembly (TN Item 2J / HZ Item 602J)
Figure 12:
Hwa Shin Items - Tagged with NCR and in Segregated Storage
Figure 13:
Hwa Shin Items -Tagged with NCR and in Segregated Storage
E-28731
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