e-28731 us nuclear regulatory commission hwa shin bolt ...hitachi zosen (hz) corporation, ariake...

AAREVA

TRANSNUCLEAR, INC.

E-28731

Report to the US Nuclear Regulatory Commission (USNRC)

Unsubstantiated Certified Material Test Reports

Hwa Shin Bolt Industrial Co., Ltd.

October 30, 2009

PURPOSE OF REPORT

Pursuant to the requirements of 10 CFR 21, Transnuclear, Inc. is providing the enclosed thirty day writtenreport 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 andfollow-up written notification to the NRC Operations Center of a potential deviation and failure to complyassociated with unsubstantiated certified material test reports (CMTRs) for certain small parts utilized inproducts 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 thisreport.

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 ShieldedCanisters (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 failureto comply discussed in this report does not and cannot result in loss of safety function such that asubstantial safety hazard could be created. Information supporting this statement is presented in thesections of this report titled "Engineering Evaluations and Significant Safety Hazard Determination" and "Listof 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 ofthese 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 organizationresponsible 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 IOr 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 hasbeen, 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 thedefect or failure to comply discussed within this report. Additionally, Transnuclear has notified othersuppliers utilized by Transnuclear for the fabrication of products required to meet the requirements of 10CFR 72 of the condition discussed in this report and confirmed that these TN subcontractors have notprocured 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 (Chief Executive Officer

Transnuclear, Inc.

7135 Minstrel Way, Suite 300

Columbia, MD 2104

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Executive Summary

BACKGROUND

Transnuclear Inc. (TN), utilizes Hitachi Zosen (HZ) Corporation, Ariake Works in Nagasu, Japan, as afabricator of Dry Shielded Canisters (DSC's) for supply by TN to multiple 10 CFR 50 licensees for the drystorage of spent nuclear fuel assemblies under the provision of 10 CFR 72. In general, DSC's consist ofan outer stainless steel shell (canister assembly) with a welded lid that serves as the confinementboundary for the radioactive materials being stored. Internally, a DSC utilizes a welded stainless steelframe (basket) to position and hold the spent nuclear fuel elements along with any necessary neutronpoison material. The basket has shaped segmented "rail" assemblies that are bolted to this frame toshape the basket into a cylindrical form that is designed to fit inside the canister assembly. The fabricationprocess generally requires the use of materials procured from multiple suppliers and includes productsand items such as stainless steel plate and forgings (dependent upon the design) for the canister, basketand rails along with nuts, bolts, studs and screws that are used to attach the rail assembly to the basketand 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 DSCsintended for use at the PGN Brunswick Nuclear Plant (these DSCs are still in fabrication and have yet tobe delivered for use).

On September 9, 2009, TN was informed by PGN that two panhead screws had been removed from theHZ shop by the PGN QA Representative and that PGN had subjected them to testing at the PGN HarrisEnergy & Environmental Center. The PGN report of this testing indicated that the material of compositionfor these screws appeared to be something other than what was represented in the Certified MaterialTest 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 ASMESA193, Grade B8 (or equivalent) and that a Certified Material Test Report must be provided tosubstantiate 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 HZassess the concern raised and to provide TN with any actions necessary to address the identifiedconcern. TN also notified PGN of this communication with HZ on the same day.

E-28731 of 24

On September 18, 2009, HZ provided TN with a copy of a letter that they had received from Hwa ShinBolt Industrial Company (the supplier of the panhead screws for the PGN - Brunswick project) that statedthat the panhead screws provided were not manufactured from the material that had been certified to inthe CMTR. Upon receipt of this information, TN requested that HZ initiate an internal Corrective ActionReport and identify all material procured by HZ from Hwa Shin. Additionally, on September 18, 2009, TNnotified PGN of the information received from HZ and that HZ had been requested by TN to initiate aCorrective 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 BoltIndustrial 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 tosubstantiate the material provided was suspect. This determination was provided by HZ to the TNrepresentative at HZ who then passed this information to TN personnel in the Columbia, MD offices onSeptember 25, 2009.

On September 24, 2009, TN issued Supplier Finding Report (SFR) No. 2009-058 to HZ for the purposesof requesting corrective action for the condition identified with the panhead screws and to also identify theextent of the condition (all material procured from Hwa Shin). TN also initiated an internal CorrectiveAction Report (CAR) No. 2009-086 to start the internal review processes for determining if the conditionwas potentially reportable under the provisions of 10 CFR 21. At this time, TN also initiated discussionswith NRC staff from the Division of Spent Fuel Storage and Transportation to notify them of the identifiedcondition 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 understoodthat the condition did impact DSCs that were being fabricated for PGN - Brunswick and that none ofthese DSCs had been delivered for use. The extent of condition determination on the part of HZ forprojects other than PGN - Brunswick was still being developed.

On October 1, 2009, a TN management representative visited the HZ facility in Japan to review correctiveactions being taken or planned and the status of the extent of condition determination. The initial HZextent of condition review was provided to TN at that time and based on a review of the information it wasdetermined that Hwa Shin had provided items that had been utilized in multiple projects and included alarge 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 thepotential for a reportable condition under the requirements of 10 CFR 21. This verbal notification was alsofollowed-up with a written confirmation of the phone call. As part of this notification to the NRC, TN statedthat "Transnuclear is in the process of performing a 10 CFR 21 but does not believe that the issue hassafety significance. TN is reporting this issue because Hwa Shin may have supplied parts to others thatmay have safety significance."

Between the notification to the NRC on October 1, 2009 and the date of this report, TN has conductedreviews and evaluations of technical and licensing requirements for the DSC models and Transfer Caskimpacted by this condition, worked with HZ to develop and institute a testing program in order to obtainadditional information on the material properties of the items supplied by Hwa Shin, and initiated orimplemented other corrective actions determined necessary to address the potential for impact on safetyas a result of this event.

Although many of the planned corrective actions are incomplete at this time, and TN and its subcontractorHZ have yet to complete the root cause(s) determination such that appropriate preventative actions canbe identified and implemented, TN has been able to conclude that:

1. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into loadedDSC Models 61 BT and 32PT do not and cannot create a condition that results in a loss of safetyfunction such that a Substantial Safety Hazard could be created. TN has made this conclusion

E-28731 of 24

based on a review of design calculations, testing of available Hwa Shin materials and review oflicensing documents.

2. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into TransferCask Model OS-197H delivered to Constellation - Ginna Nuclear Power Plant will be replacedby TN prior to first use. As such, the condition does not create a condition that results in a lossof safety function such that a Substantial Safety Hazard is created. Replacement of these partswill 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 byfabrication activities into a DSC will be replaced with items procured from a different HZ auditedand approved source. Disposal of these items will be controlled under the TN approved HZQuality Assurance Program.

4. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into a DSC byfabrication activities will be replaced and disposed of if replacement of the items does not raisethe potential of damage to the DSC. Replacement of these items will be controlled under the TNapproved HZ Quality Assurance Program and/or the TN NRC approved Quality AssuranceProgram. Necessary approvals will also be obtained from the NRC 10 CFR 50 licensee prior toimplementing the replacement plan.

5. Items provided by Hwa Shin Bolt Industrial Company that have been incorporated into a DSCand cannot be removed due to concerns with damaging the DSC will not be removed. Approvaland justification for use for the items not removed will be provided to HZ by TN as required bythe TN NRC approved Quality Assurance Program. In addition, TN will provide the documentedjustification for not removing these items from each DSC to each affected NRC 10 CFR 50licensee for its approval prior to implementing the disposition and recertification of the DSC tothe conditions of the applicable 10 CFR 72 NRC Certificate of Compliance. This applies to DSCsthat have been delivered (both loaded and not loaded) and DSCs that are still at the HZ facility inJapan.

E-28731 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 identificationof 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)

Status of All TN Projects related to HWA SHIN BOLT Maturials (Reference TN SFR No.2009-058, HZ CAR No.C-00-C-12)Attaho0ment I

774520010,0. DS~sa8760164 001000 NO. 16F231 1W.29.20o

16100 4003 30?Ole cache60 forobPTa 162212310 an652204D 1,2

IN. Wm'uedo ca SHP*d "Pe TNN , rý U. -N. N. M.ý6.1 CMTRo N. O~o NCR RrNo.01,, 6. U1Y RantII T6p 7 N.Um DSC0S1 D.SC2SINo

16FI36 - 05co 06.606 -4P" -L 1- Willed I0 ,

1604 PM Io01 n N 6 .4. 1T 001'-010 [007 01¢a 009-010 %91-30Z27 03 A479Typn304 HSC0309-003 18--23 C ,31-NCR-Not Used (001-008)[001-010)

16F044 -01 PP c7 "- 61770 0774 001-030 040200167F00 J 0rN5NOoo6"07 200425 526

16708 P-2001,019 0 n O6)A,•C..% 15er-m 0110-018 Us6 16201 11O-9--27 0201646S-183 -- 6 Ty94 304 0SOC3•-2)•0•94-23 C 0-MCR-35

16=025 42017 46 40 Ra514 420F00THL 601-Hz04 N0Ud

1-7,1- .42MtDF4 .. ... 6 20T 00Z01-O N30Use.20 5I

76073 004 265010 771. 00146066,0 OII T 2013029 0.6 02-00sooAd6

i6GM39 1;;;19 JIMA 2m'o 4PHBL HII-Z1('.1t2 tN01!led ....

1616•05 •-00-16d 601BT 001-024 Ud 4- 21I04 I I~D.ILC Ps~m2PN 0-0 Vue

Mos-4' 05411 S55 69 all.3 _• 2PTHI 001"070 00 U_ I _ 1--T, , P161306 61-0015 cm3765P M0 07922T2-4-40z6 to11-5.4iSF3DB PZ0•:W5 D-W W,cls9 I cFr i0-0"•KCIS Usd HZ0910--H.015 =H 64=1-N B 10154.3D-3 14mm 349 FW (31),4)1~t 08 KNIM 3 * P-p-49 A 36 2

I 3DCR-29

6654 004 46P BA.4761Typo304

10061-2 FWa1566 440 S5.400T"0 304 0141. 013 0--09 N16F308 P202lM ,t - -GT 025-rm Ud• 025-032 . ý" W" 463 S.AtST17me4WC-110961.3D.15 V.ell3MPht R 60 ISAM791rypaW40 084(M0"14 30"-14 A

0Wo*146 464P 2SM79 Y" 304

0-6ol clay 001001764 746~3 10951- 1 -2 F0alW ll " OlR I SA241 o O0T 4 M U M S 311 4-0 A M -NCR-24036-00 W7 H0 Nut 4OS I.2, 3470T0104 031CCR-

00961-30016 6enm PW 1P4 60 I5.4M79".334 06C44004 0 11-P-14 5

los I F~Wt.,S ,. . i :A4Tye04 08,HCAG3 312-P W AH. N.0 404 5A479 T 27pe 304

1261.30-16 Ve146P071Pk G2o 404797Typ004 064 401424 312.P-14 At"•I31I P20 111aw ,* -k 13` 019"- Q•022 "le ol- 09840-21 TnCp,T.Wladý 79 - I A4797my 54 0S•-14 S 312-P.M A 312 .C 13

4c54-6•401mCbpTnnlSci~t 070 A0419T056304 08-H00003 312-P-25 221

I4011010-4027 M6,, 84 FW 210 43* 312-P-27 000Wald Sbud 46P ,SA479 TyP3O4

l41-3-2 Ra4t W h. 46R SA040Type304 -HCM023 31 2,P-09 A

1 01 41 1-30-1 0I0 V o5t7PW 60 SA4O9Typ. oo 4

08446CM024 312-P-14 A 1J Stu-AS6 21548 $S447Type M0

46 6 76.246•4 3 60 •00 09-006.212 61170 SH 2 7N-I02 AUHBT4 FIW=W• 217AM SiA0Type 304

1WOMaW.1- 219 RA Typ3041

Don"•0) NUH6t 144000 Tell ftt•plng 014 GAM79 Ty'p304 c9-Hics11 ilmH4-;po4 A 312BP.NCR-15ISF3120 ,12D"P54 ý e aadf SH 0100- 21 S13E 91CR15•T.. No1"w10 " (0-"010). NUID1TH40,2 Pmkec 8.-1 V&9 B $HM2 618THP-7

(005"010) NlI4418114D-492 H.0NA4 I 47..44 S- 231A 0A194 Gr 403.240 60011.TP-706 A

N $61114T,40 LCckWmh0m5 216 ATm &saaTp344 2009. 4-220 61070r1--P7-09 0I

7T. " opO6.N6 mnOS 67 25.4180Ill4 20-5.06M-034 610M1T-P-P10 A004 -A Ua~d300-140-NC31

160303 P•07•70393 ,JC,- G SIFT 001-010 4 " 08} OD1,-002 003"0o" NU 2PT-2003 H. 349 F594-1 304) 09-4'004-02 310-p-723 A 03-160-3250o5U64C1(' •06-0019 010-6CR.204720-0163 NCR_

007315 IP2-7-451Jolla 0-010 24PHBL H2117-H1"31 N06L206

(005-036) 03104386 U11-30-2 Flat2066 40R SA a4OTy 30044 09-11C1,1 1 317-P-702 A 31722.-00R4016F3"17 P20s PPI. &, DinT 0•~0 NodUodri) (03"B4) ýeNu 46S Mk7Tp30 1E-•.W.R037-0 l0-30-1 V__ _ or1005. 60 SA479Tysou 0900C12 4 317.P,,

VftW saw48P SAU Type 3D4

109140W 2 0-3018 1 .1R 7A24D Type 304 0040040,00 317-7-7 A1SP017 P2004-4408 01tw UW p~l 51ST 001143 Not U4ed V-) - 001"OU) ft Ny

1091.-30-16 SVMWS 40 4A477945T0e304 0MHCM-022 317-7 A

WM Setu5d 40P 479 Type 3041632 ue 005 P 1-09 10 F103W76,0 460 014240 Type 377 04 0-H0062 01--t2-P2 A

0680716 4as 00.67144.00 M1SF322 72•03.070 [685ob04 10.6640.7266 628'r 03-e22 I 01ur0710 - T00y-416 400•106479175837 ,__A4 0 1"A

10400-05-16 74en6th2 Po7b S444Typo 304 05-70CM-90 06-7.726

(1) : H4Z6-06o65O0e46ma0(rbl hor 4I54e6t l52k.7

Table 1: Extent of Condition for DSCs fabricated by Hitachi Zosen

E-28731 of 24

OS 197 Transfer Cask

The materials provided to HZ by Hwa Shin also included items incorporated into one transfer cask thatwas delivered to Ginna. TN has confirmed that this Transfer Cask has not been put into service byConstellation Energy. These parts will be replaced.

HZ TN 14105 Type ý ShO UnlP~ p7

ed~ Rd-o

16F72 25040557 D..mO NO' S 577 1-2 W40 759 ___

IGFV3 42M0 COPPO FaCto OS197L 05197L-N ote

15F035 2505012 0otfi~m LMýs OSISIS 0519515 NOV0

t5Fo43 P25090&5 FF9. siýoe 0S50 797-I N0U5UW___

16F301 P2504-574 EhNO Le-a OS1N7H 05997744 54490 _____

167394M P357.39 41Do.5 SCoo..B 00S19794 0519714-7PI B04 01

-1F Cw.1,4 - 14050 SS44)o 34H&-lM9.4449 74417 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 beendelivered for use but not put into service or have been put into service by a 10 CFR 50 licensee in theUnited States. Of the 59 DSCs with Hwa Shin items, 39 have been delivered with 17 of these havingbeen loaded and placed in the NUHOMS Horizontal Storage Modules (HSM) and the remainder (22) instorage waiting to be loaded. The one Transfer Cask with Hwa Shin parts has been shipped to its USlicensee but has not been put into service.

ExelonOyster Creek

1004 61 BTDSC

009 OCG61 B-009-C YES YES YES1098 161F231010 OCG61B-010-C YES

YES YES

011 OCG61B-011-C YES YES YES



Exelon 1004 61BT 10982 16F018 014 OCG61B-014-C YES YES YES

Oyster Creek DSC 015 OCG611B-015-C YES YES YES


017 OCG61B-017-C YES YES NO On Site


DOM-Millstone

1004 32PTDSC

11066 16F306 MPS32PT-S100-A-HZ010 YESHZ01 0 YES YES

MPS32PT-S1 00-HZ011 A-HZ011 YES YES YES

MPS32PT-S100-HZ012 A-HZ012 YES YES NO On Site



E-28731 of 24

bS32P -S1A-HZ015 YES On SiteHZ01 5 YES NO

MPS32PT-S100-.. A-HZ016 NO

FabricationCompleteHZ016 NO NO

MPS32PT-S100- FabricationHZ017 I A-HZ017 NO NO NO Complete

MPS32PT-S100-A-HZ018

FabricationCompleteHZ018 NO NO NO

025 SSE61B-025-A YES YES YES

026 SSE61 B-026-A YES YES YES


PPL- 1004 61BT 10963 16F308 028 SSE61B-028-A YES YES NO On SiteSusquehanna DSC 029 SSE61B-029-A YES YES YES


031 SSE61B-031-A YES YES NO On Site

032 SSE61 B-032-A YES YES NO On Site

PPL- 1004 61BT 10964 16F312 033 SSE61B-033-A YES YES YESSusquehanna DSC 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 On SiteFabrication'

NPPD- 1004 61B 11203 16F311 004 CNS61B-004-A NO NO NO on HoldCooper DSC B0 Y YSO i


006 CNS61B-006-A YES YES NO On Site


___ ___ 008 CNS61 B-008-A YES YES NO On Site


Exelon- 1004 61BT 10983 16F312 020 OCG61B-020-C YES YES NO On SiteOyster Creek DSC 021 OCG61B-021-C YES YES NO On Site

022 OCG61 B-022-C YES YES NO On SiteNot Yet

035 Assigned NO NONot Yet

PPL- 1004 61BT 10965 16F317 036 Assigned NO NOSusquehanna DSC Not Yet


038 Assigned NO NO

Not Yet001 Assigned NO NO

Not YetProgress- 1004 61BTH 11171 16F312 002 Assigned NO NOBrunswick DSC Not Yet


004 Assigned NO NO ---

Constellation- 1004 I 32PT 11202Ginna I DSC

16F313 1 001 REG32PT-S125-A-16-001 YES YES NO On Site

REG32PT-S125- -YES YES ] NO002 1 A-16-002 __ES YES NO On Site

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k.saus

003 A-i16-003 NO NOREG32PT-S125-

004 A-16-004 NO NO ---REG32PT-S125-

005 A-16-005 NO NO ---REG32PT-S125-

006 A-16-006 NO NO ---REG32PT-S125-

007 A-16-007 NO NO ---REG32PT-S125-

008 A-16-008 NO NO ---REG32PT-Si25-

009 A-1 6-009 NO NO

010REG32PT-S125-

A-1 6-010 NO NO

OS197H 1 9 1rConstellation- Transfer OS197H-Ginna 1004 Cask 11203 16F314 7 OS197H-7 YES YES NO On Site

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Engineering Evaluations and Significant Safety HazardsDetermination

ENGINEERING EVALUATIONS

Justification for Continued Operations

In order to support operability determinations on the part of licensee with loaded DSCs subject to thecondition described in this report, TN provided the following information:

Transnuclear Memo E-28630, dated 10/09/09, Justification for Continued Operability for LoadedNUHOMS 32PT DSCs Serial Numbers MPS32PT-S100-A-HZ010 and -HZ01 I at Dominion NuclearConnecticut's Millstone Power Station

Transnuclear Memo E-28634, dated 10/08/09, Justification for Continued Operability for LoadedNUHOMS 61BT DSCs at PPL Electric Steam Utilities Corp's Susquehanna Steam and Electric Station

Transnuclear Memo E-28726, dated 10/29/09, Justification for Continued Operability for LoadedNUHOMS 61BT DSCs Serial Numbers OCG-61B-009-C thru -016-C at Exelon's Oyster Creek GeneratingStation

These memos concluded that that the subject DSCs remain capable of performing the design functions ofconfinement, heat removal, shielding and criticality control associated with the safe storage of spentnuclear 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, 2009Substantial Safety Hazard Determination

The subject corrective action report resulted from the identification that small screws supplied to one ofTransnuclear's canister fabricators, Hitachi Zosen, by Hwa Shin Bolt Industries is suspected of being a differentmaterial than that specified and certified. Hwa Shin supplied studs, screws, nut and washers. In addition, theyprovided material for the test port plugs, tool sockets and alignment legs. Until determined otherwise, all materialssupplied 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 areaffected are Exelon/Oyster Creek, Dominion/Millstone, PPL/Susquehanna, NPPD/Cooper, ProgressEnergy/Brunswick, and Constellation/Ginna. In addition, the Transfer Cask, 0S197H-7 purchased by Nine MilePoint and delivered to Ginna is also affected by this CAR. DSCs affected range from some with loaded fuel to somein 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 thereference [1].

Hitachi Zosen is performing material testing (chemistry and hardness) on materials from Hwa Shin that were inHitachi Zosen's inventory, waiting to be used for the DSCs or Hwa Shin materials left over from previouslyfabricated DSCs. Hitachi Zosen provided TN with the test results and based on this information TN has concludedthat all materials exhibit the chemistry of 300 series stainless steel except for lock washers which exhibit thechemistry of 200 series stainless steel. The vent (test) port plug and the weld studs exhibit hardness characteristic of

E-28731 of 24

annealed material; washers, screws, and nuts exhibit hardness characteristic of cold-worked materials. All materialswere 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 ofthe 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 identifiedduring fabrication process as a result of visual inspection, weldability issues, corrosion, liquid penetrationexamination, etc.

An evaluation was performed on the parts supplied by Hwa Shin [1]. A summary of the evaluation is providedbelow:

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 creditwas 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 theoriginally 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 theconfinement boundary, and substitution of an alternate austenitic stainless steel would not affect itsfunction. 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 isto minimize the gap between the top shield plug and the basket. After installation, the spacer disk willperform its function as it will be captured between the basket and the top shield plug and the function of theshoulder screw is not required.

In consideration of items A - E cited above, Transnuclear determines that this condition does not and cannot resultin the loss of safety function such that a Substantial Safety Hazard is created.

References:

1. CAR 2009-086, Condition Evaluation

Prepared By$t 1 , P. Shih, Director of Engineering and LicensingF L.

Reviewed By: 1 • J. Bondre, VP of Engineering

Approved . .,x• R. Grubb, Chief Operating Officer

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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 theTransfer Cask. The applicable drawings are also listed in the table with the part (item) number and originalmaterial 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 ondrawings 11064-30-3 and NUH32PT-2003.

NUHOMS® 61BT DSC

Quality Mtra pcfeHZ Item Number TN Item Number Description Category Material Specified

46P 46P Weld stud A SA 479 type 30446R 46R Flat washer A 304 SST46S 46S Hex nut A 304 SST60 60 Vent (test) port plug A SA 479 type 304

Reference: Transnuclear drawings 10961-30-2 & 1098-30-2

Additional parts for damaged fuel option (61 BT)HZ Item Number TN Item Description Quality

Number Category Material Specified79D 79D Top Cap, Tool Socket A SA 479 type 30480E 80E Bottom Cap, Tool Socket NITS 304 SST83 83 Shoulder Screw C AISI 304 or 31684 84 Machine Screw NITS SST

Reference: Transnuclear drawings 1098-30-27

NUHOMS® 61BTH Type 2 DSC

HZ Item ultSNumber TN Drawing-Item Number Description Quality Material Specified

215A/B NUH61 BTH-4002-15 Stud A SA 479 type 304216 NUH61BTH-4002-16 Hex Nut C SST

217A/B NUH61BTH-4002-17 Flat Washer C SST219 NUH61BTH-4002-19 Oval Washer NITS SST014 NUH61BTH-4000-14 Test Port plug A SA 479 type 304231 NUH61BTH-4002-31 Panhead Screw A SA 193 B8

231A NUH61BTH-4002 Hex Nut A SST(DWG Note 29)

218 NUH61BTH-4002-18 Lock washer NITS SST602J NUH61 BTH-4006-2J Alignment Leg A SA 479 type 304

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NUHOMS® OS197H Transfer Cask

HZ Item TN Drawing-Item Number Description Quality Material SpecifiedNumber Category

410 NUH-06-8021-10 Hex Bolt B SA 193 B7325 NUH-06-8003-25 Washer NITS ASTM F436327 NUH-06-8003-27 Washer NITS ASTM F436314 NUH-06-8003-14 Cap Screw NITS 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 DSCsin various stages of fabrication at HZ have these parts installed. Where possible pictures were taken of thepart to show what the part looks like and generally where it is located.

FIGURE 2: 32PT Hex Nut (Item 49)

Top ShieldPlug Modified

CanisterShell

Top Spacer

Shoulder Screw -

FuelCompartmentExtension

Fuel Basket

Figure 3: 61 BT (for Short Damaged Fuel) Shoulder Screw (Item 83)

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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)

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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)

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MATERIAL CONTROL

Control of Non-Conforming Items

HZ has collected all Hwa Shin items that remained unused, has placed the unused items in a controlledarea away from the area where fabrication is being performed and has tagged the items to prevent furtheruse. 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

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ISSUE CHRONOLOGY

The following provides the sequence of events starting at the point TN became aware of the potentialissue with material supplied to HZ by Hwa Shin and to the point of TN's notification to the NRCOperations 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 panheadscrews (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 ASMESA193 B8. The panhead screws were obtained by PGN oversight personnel at theHitachi Zosen facility during the assembly of the initial 61BTH DSCs for PGN BrunswickStation / TN Project No. 11171. No DSCs have been delivered under this order by TN toPGN at this time

09/10/09 TN notified Hitachi Zosen of the information provided by Progress Energy and requesteda Hitachi Zosen evaluation and response

09/18/09 Hitachi Zosen notified TN of the results of their follow-up discussions with Hwa Shin BoltIndustrial Company. Hwa Shin states by letter to HZ that the material they supplied wasnot the material that they certified

9/18/09 TN notified Progress Energy of the HZ evaluation. Copies of the Hwa Shin Bolt IndustrialCompany letter and material specification requirements provided

09/23/09 Discussions held between TN and HZ on actions being planned by HZ in response to theHwa 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 ofcondition and corrective action for materials supplied to by Hwa Shin Bolt IndustrialCompany

09/24/09 TN initiated CAR 2009-086 (Level 1) in order to obtain a reportability determination. TNProcedures TIP 7.13, 16.1 and 15.1 provide procedural instructions to determine 10 CFR21 reporting

09/24/09 TN initiated and held a telecon with the Director and several staff of the USNRC Divisionof Spent Fuel Storage and Transportation to discuss the identified condition and potentialreportability under 10 CFR 21. TN participants in this phone call were President, ChiefOperating Officer and Director, Corporate Quality Assurance

09/25/09 The TN oversight representative at HZ provided TN Columbia with a summary of theresults of the HZ visit to Hwa Shin. The HZ visit confirmed that the CMTR provided byHwa Shin was false and that this condition applied to all small parts provided by HwaShin. 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 andTransportation and the TN Chief Operations Officer. NRC requested and TN provided acopy of the Hitachi Zosen purchase order to Hwa Shin for the panhead screws

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10/01/09 A meeting was held between HZ and TN personnel at the HZ facilities in Japan. Thepurpose of the meeting was to understand the HZ status with respect to correctiveactions associated with Hwa Shin and determine if HZ had completed its determination ofthe extent of condition with respect to the procurement of materials and items from HwaShin

10/01/09 10/1/09 - email / TN personnel at HZ notify senior management at TN Columbia officesthat the HZ extent of condition for parts procured by HZ from Hwa Shin extend beyondthe 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 containsuspect parts (both shipped or at HZ)

10/01/09 TN determined that the condition is potentially reportable under the provisions of 10 CFR21.21 and the NRC Operations Center is notified via telephone call by T. Neider. Follow-up email is provided to the NRC to confirm the call

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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 orplanned to be taken as a result of the condition discussed in this report. TN expects that this correctiveaction plan will to be modified as more information is developed. These actions are current as of the dateof this report and are being controlled and tracked under TN CAR 2009-086.

Transnuclear Corrective Action Plan

Action Responsible Due Date CommentsOrganizationor Position

1 Brief all TN staff on the Hwa Shin issue COO 9/10/09 Complete

See Note 12 Initiate SFR to request Hitachi Zosen Corrective QA 9/24/09 Complete

Action and Extent of Condition for Hwa Shinitems See Note 2

3 Initiate CAR to ensure 10 CFR 21 reportability QA 9/24/09 Completeconsiderations are addressed and obtain anynecessary internal corrective actions See Note 3

4 Notify NRC Operations Center of the potential President & 10-1-09 Completefor a reportable condition under 10 CFR 21 CEO

See Note 45 Notify all impacted customers of the Hwa Shin Sr. Mgmt. 10/14/09 Complete

issue and support operability determinations asrequested. See Note 5

6 Notify the TN Users Group of the Hwa Shin Management 10/15/09 Completedissue.

See Note 67 Complete substantial safety hazards COo 10/30/09 Complete

determination.See Notes 7 & 8

8 Provide written report to NRC as required by 10 President & 10/30/09 CompleteCFR 21.21 (d) (3)(ii). Report to be transmitted as CEOrequired by 10 CFR 21.5

9 Provide User Group with the report provided to Management 10/30/09 Completethe NRC

See Note 2010 Provide written notification to all current TN QA 10/7/09 Complete

fabricators regarding the Hwa Shin issue.See Note 9

11 Perform oversight of the second visit to Hwa QA 10/7/09 CompleteShin by HZ.

See Note 1012 Request all current major TN fabricators provide QA 10/20/09 Complete

written descriptions of procedural controlsutilized for the detection of Counterfeit and See Note 11

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# Action Responsible Due Date CommentsOrganizationor Position

Fraudulent Items (C/Fl)

13 Determine if Hwa Shin was utilized by other QA 12/3/09 Workingfabricators of TN equipment.

See Note 1214 Perform oversight of HZ audit to qualify a new QA 10/23/09 Complete

supplier to replace Hwa ShinSee Note 13

15 Review TN fabricator controls for Counterfeit QA 11/30/09 Waiting onand Fraudulent Items (C/Fl). responses from

fabricatorsDetermine if any corrective action is needed

16 Develop language to be inserted into TN QA 11/19/09 Not Started as ofprocurement specification requiring supplier to 10/28/09provide TN with material sample (at TN'sdiscretion) for testing to determine acceptabilityof material supplied. Obtain internal agreementon the language

17 Develop language to be inserted into TN QA 11/19/09 Not Started as ofprocurement specification (fabricators of major 10/28/09equipment) requiring supplier to institute arandom screening program for material suppliersfor the purpose of periodically substantiatingmaterial certifications provided. Use of toolssuch as XRF analyzers or qualified laboratoriesshould be provided as an option.

The requirement should include languagerequiring the supplier to submit the randomtesting program to TN for its review andapproval.

Obtain internal agreement on the language18 Identify specifications and schedule for Engineering 12/8/09 Not Started as of

implementing revised TN Procurement 10/28/09Specification language for C/Fl controls

19 Review TN procurement controls against QA 12/04/09 Not Started as ofinformation provided in NRC GL 82-02 and other 10/28/09generic communications provided by the NRC todetermine if the procurement controlsencompass appropriate provisions for requiringTN suppliers to take actions to preclude theentry of fraudulent and substandard materialsinto the supply chain. As determined necessary,identify any additional corrective actions basedon the results of this review.

20 Review TN supplier oversight controls against QA 12/18/09 Not Started as ofinformation provided in NRC GL 82-02 and other 10/28/09generic communications provided by the NRC todetermine if the controls provide for appropriate

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# Action Responsible Due Date CommentsOrganizationor Position

oversight and verification of supplier controls forfraudulent and substandard items. Asdetermined necessary, identify any additionalcorrective actions based on the results of thisreview.

21 Review and re-classify as necessary the parts Engineering 12/10/09discussed in this report to ensure thatappropriate Quality Classifications are assigned(TIP 3.6)

22 Revise all impacted TN design and fabrication Engineering 12/10/09documents as a result of the re-classification ofparts.

23 Conduct Root Cause Determination to identify QA 12/18/09 Not Started as ofwhy this condition was identified by a TN 10/28/09customer as part of their oversight and not byTN.

24 Based on the results of the root cause, identify QA 12/18/09 Not Started as ofpreventative actions necessary to preclude 10/28/09recurrence (if not already taken)

25 Provide notification of the Hwa Shin event to QA 10/30/09 CompleteAREVA Corporate for dissemination

Note 1926 Notify NIAC Organization of Event at the QA 11/6/09

November annual meeting27 Review NIAC Audit Checklist and determine if QA 11/6/09

process controls include appropriate criteria forCounterfeit and Fraudulent Materials. Discussreview results at NIAC Meeting in November

28 Based on NIAC Meeting discussion determine if QA 11/19/09TN needs to utilize at supplemental checklist inconjunction with NIAC checklist to ensureappropriate assessment of Counterfeit andFraudulent Materials controls

29 Track and Verify that HZ NCRs are QA TBDdispositioned, 72.48 evaluations completed,approval provided by TN and Licensee (whenrequired), Disposition is Implemented, TN Re-Certification Complete & Records SystemUpdated (both TN and Licensee)

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Hitachi Zosen Actions

The following HZ corrective action plan details known corrective actions that have been, are being orplanned to be taken planned as a result of the condition discussed in this report. TN expects that HZ mayneed to modify or otherwise change this plan as more information is developed. These actions are currentas of the date of this report and are being controlled and tracked under HZ CAR No. C-09-C-12. Theseactions are subject to TN's review and approval.

Hitachi Zosen Corrective Action Plan

HZ Action Responsibility Due Comments# Date

12 Perform fact-finding visit to Hwa Shin to verify Hitachi Zosen 9/23/09 Completeissue

See Note 1414 Remove Hwa Shin from AVL Hitachi Zosen 9/30/09 Complete

See Note 15El Identify all materials from Hwa Shin for all Hitachi Zosen 10/1/09 Complete

existing projects (extent of condition)See Note 16

15 Write Non-Conformance Reports (NCRs) for all Hitachi Zosen 10/1/09 CompleteProjects in shop. Identify, collect, tag andsegregate all Hwa Shin parts See Note 17

13 Issued NCR on all existing DSCs and shipped Hitachi Zosen 10/1/09 CompletedDSCs on which materials procured from HwaShin were used. See Note 17

E3 Identify all previously shipped DSCs on which Hitachi Zosen 10/1/09 Complete Seematerials form Hwa Shin had been used. Reference 7

17 Perform audit of lab Hitachi Zosen 10/13/09 Complete SeeReference 17

Develop a testing plan for Hwa Shin Parts that Hitachi Zosen 10/22/09 Completehave been used in DSC that have been Revision 2delivered to Utilities approved by TNPerform Audit of new vendor for Hwa Shin parts Hitachi Zosen 10/21- Complete

24/09See Note 18

I1 Get results of material test for panhead screw, in Hitachi Zosen 10/26/09question, from lab

-E2 Send out samples (all heats) selected from the Hitachi Zosen 10/27/09above materials to the lab for testing and/orperform chemical analysis and hardness test (byHZ) using X-Ray Fluorescence Analyzer andhandy-type hardness tester (Equo Tip)Complete all HZ testing of parts Hitachi Zosen TBDReceive all chemical composition results from Hitachi Zosen TBDLabReceive all mechanical test results from Lab Hitachi Zosen TBD

18 Issue report detaining all activities completed. Hitachi Zosen 11/30/09C1 Procure new materials from other qualified Hitachi Zosen 11/30/09

supplierC2 Establish procedure to identity counterfeit Hitachi Zosen 11/30/09

materials or items

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NOTES:

1 Staff briefing held in the Columbia office with all available TN staff. This briefing was intended asinformational and no attendance records or other documents were developed as a result thismeeting

2 SFR 2009-058 issued to Hitachi Zosen on 9/24/093 CAR 2009-086 issued on 9/24/094 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 equipmentsubject to the requirements of 10 CFR 72 being delivered for use by TN to a 10 CFR 50 licensee.

5 Project Managers have notified each customer by telephone and operability determinations wereprovided to Dominion, PPL and Exelon. The operability determinations are documented under Eletter Numbers E-28634 for PPL, E-28630 for Dominion and E-28726 for Exelon.

6 Discussion of the Hwa Shin condition was provided to the TN users group via Telecon on10/15/09. Minutes of this meeting were not developed as the phone call was for informationalpurposes.

7 The notification made to NRC on 10/1/09 stated that "Transnuclear is in the process of performinga 10 CFR Part 21 but does not believe that this issue has safety significance. TN is reporting thisissue 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.

8 Substantial safety hazard determination complete 10/28/09. The evaluation concluded that thecondition does not and cannot create a condition that results in a loss of safety function such thata Substantial Safety Hazard is created.

9 Notification made by E-Letter with copies provided to CAR 2009-086 file.10 SSR 2009-108 issued to document result of visit.11 TN Letters E-28682 through E-28628 issued with copies provided to CAR 2009-086 file.12 Request to fabricators made. Four responses received (no use of Hwa Shin) waiting on balance

of responses13 SSR-2009-110 issued to document this surveillance.14 No report of this visit generated by HZ - trip summary provided by email15 TN oversight has verified that HZ has removed Hwa Shin from the HZ Approved Suppliers List.16 The HZ extent of condition review was provided to TN in the response to TN SFR 2009-058.17 HZ NCRs are identified on the extent of condition matrix provided by HZ in response to TN SFR

2009-058.18 TN performed oversight of the HZ audit of the new supplier. The results of this oversight activity

are provided in TN SSR 2009-110.19 Notification provided on 10/30/09 by email with copy of report attached to email.20 Notification provided on 10/30/09 by email with copy of report attached to email.

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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) andHex 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

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e-28731 us nuclear regulatory commission hwa shin bolt ...hitachi zosen (hz) corporation, ariake...

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