Text

IR 05000298-09-006, 07200066-09-001, on 02/23-26/2009, Cooper Nuclear Station Independent Spent Fuel Storage Installation
	ML092430509
Person / Time
Site:	Cooper
Issue date:	08/28/2009
From:	Spitzberg D; NRC Region 4
To:	Minahan S; Nebraska Public Power District (NPPD)
References
	IR-09-001, IR-09-006
	Download: ML092430509 (30)
	v • d • e

UNITED STATES NU C LE AR RE G ULATO RY C O M M I S S I O N ust 28, 2009

SUBJECT:

NRC INSPECTION REPORT 050-298/09-006; 072-066/09-001

Dear Mr. Minahan:

An NRC inspection was conducted at the TriVis facility in Pelham, AL on February 23-26, 2009, as part of the Cooper Nuclear Station Independent Spent Fuel Storage Installation (ISFSI) pre-operational testing program. The purpose of the inspection was to determine if the personnel, processes and equipment demonstrated at the TriVis facility were adequate to perform canister sealing, vacuum drying, helium backfill and canister unloading operations as required by the conditions of your general ISFSI license. On August 6, 2009, a telephonic exit briefing was conducted with Mr. Art Zaremba, Director of Nuclear Safety Assurance, and other members of your staff. The enclosed report presents the scope and results of that inspection.

The inspection determined that the processes and equipment demonstrated at the TriVis facility were in compliance with the Commission=s rules and regulations and within the conditions of the Cooper Nuclear Station ISFSI license. There were no violations identified. However, the majority of the procedures used during this inspection were in draft form and several aspects of the demonstrations could not be completed. As a result, several issues were identified that need further NRC review prior to Cooper Nuclear Station initiating dry fuel loading activities.

These issues are described in detail in the enclosed report.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this inspection, please contact the undersigned at (817) 860-8191 or Ray L. Kellar at (817) 860-8164.

Sincerely,

/RA J. Vincent Everett for D. Blair Spitzberg/

D. Blair Spitzberg, Ph.D., Chief Repository and Spent Fuel Safety Branch

Nebraska Public Power District -2-Docket: 050-298 072-066 License: DPR-46

Enclosure:

NRC Inspection Report 050-298/09-006; 072-066/09-001 Attachments:

(1) Supplemental Inspection Information (2) Cooper ISFSI - Inspector Notes

REGION IV==

Docket: 050-298; 072-066 License: DPR-46 Report: 050-298/09-006; 072-066/09-001 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Avenue Brownville, NE 68321 Dates: February 23-26, 2009 Inspectors: R. Kellar, P.E., RIV/DNMS, Lead C. Morell, NMSS/SFST Accompanied By: L. Brookhart, RIV/DNMS Approved By: D. B.Spitzberg, Ph.D., Chief Repository and Spent Fuel Safety Branch, Region IV Attachments: 1. Supplemental Inspection Information 2. Inspector Notes ENCLOSURE 1

EXECUTIVE SUMMARY Cooper Nuclear Station Independent Spent Fuel Storage Installation NRC Inspection Report 050-298/09-006; 072-066/09-001 Nebraska Public Power District elected to use a general license to load and store spent nuclear fuel at the Cooper Nuclear Station Independent Spent Fuel Storage Installation (ISFSI). The technology chosen to store the spent nuclear fuel was the Transnuclear (TN) NUHOMS Horizontal Modular Storage System, Certificate of Compliance (CoC) 1004. The initial inspection associated with the welding and fluid operations phase of pre-operational demonstrations was held at the TriVis facility on February 23-26, 2009. The remaining pre-operational inspections were scheduled to be conducted at Cooper Nuclear Station during the spring of 2009. On May 28, 2009, Cooper Nuclear Station notified Region IV that a decision had been made to delay the remaining pre-operational demonstrations and the initial dry fuel loading campaign to a latter date. On June 17, 2009, Cooper Nuclear Station notified Region IV that the reactor building overhead crane upgrade, necessary to lift the TN transfer cask, would not be completed at this time and that the crane would be returned to service using a rated load of 100 tons. The ASME B30.2 requirement to perform a load test of the crane using a test weight of approximately 125 percent of the 100 ton rated load was completed on July 13, 2009.

This inspection report covers the inspection visit made by NRC to the TriVis facility on February 23-26, 2009. The pre-operational loading demonstrations included canister welding, vacuum drying, helium backfill and non-destructive examination (NDE) activities. Portions of the pre-operational unloading demonstrations were also conducted which included removal of the canister lid welds and refilling the canister with water. Several minor problems were encountered during the demonstrations, which were resolved during the course of the inspection. There were several aspects of the demonstrations that could not be completed and will require additional follow-up by the inspectors. The licensee staff was observed practicing effective ALARA (as low as is reasonably achievable) principles during the demonstrations.

Drying/Helium Backfill

Procedure 10.38 specified the helium backfill pressure range for the canister to be 1.6 to 3.4 psig. The helium pressure was established at approximately 2.5 psig and held for a minimum of 30 minutes during the preoperational demonstration (Attachment 2, Helium Backfill Final Pressure - 61BT, page 1).

Procedure 10.38 required that the vacuum pressure be maintained equal to or less than 2.8 torr for the required 30 minute hold time. During the demonstration the vacuum pressure was held at 1.4 torr for approximately 31 minutes (Attachment 2, Vacuum Drying Final Pressure, page 1).

Non-Destructive Examinations (NDE)

The acceptance criteria for the helium test was less than or equal to 2.0 X 10-7 std-cc/sec of helium. Section 4.0 of Procedure HMSLD-1004 established the minimum sensitivity of the instrument to be 1.0 X 10-9 std-cc/sec. During the demonstration the-2- ENCLOSURE 1

instrument was able to detect to a sensitivity of 1.07 X 10-10 std-cc/sec (Attachment 2, HMSLD Minimum Sensitivity, page 6).

Procedure 06260-CNS-OPS-01-R0 required that the results of the dye penetrant examinations be recorded in Attachment 9.3 of the procedure. These attachments documented the acceptance or rejections of the dye penetrant examinations and are stored with the other permanent canister records after the canister was loaded (Attachment 2, Permanent Record, page 8).

Unloading Operations

Section 4.2 of Procedure 10.38.1 provided instructions for refilling the canister during the unloading process. A caution was included to limit the water fill so that the vent pressure did not exceed 20.0 psig during the refilling operation. During the licensee demonstration, a pressure gage was included in the flow path and monitored during the filling operation to ensure that limiting pressure of 20.0 psig was not exceeded (Attachment 2, Water Fill Rate, page 13).

Welding

The welding procedure specifications (WPS's) were reviewed and determined to contain the GasTungsten Arc Weld (GTAW) essential variables required by the ASME Code (Attachment 2, GTAW Essential Variables, page 16).

Procedure 06260-CNS-OPS-01-R0, was reviewed and determined to provide adequate controls for grinding, machining and non-destructive examination of surface defects (Attachment 2, Weld Repairs - Surface Defects, page 18).

-3- ENCLOSURE 1

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel:

N. Bahr, Radiation Protection P. Donahue, ISFSI Project Manager J. Smith, Welding Program Supervisor TriVis Personnel:

J. Kelly, Operations Manager L. Kinney, Cask Loading Supervisor Transnuclear Personnel:

J. Chapman, Manager, Site Projects M. Stoltz, Director, Fuel Loading Services INSPECTION PROCEDURES USED 60854.1 Preoperational Testing of an Independent Spent Fuel Storage Installations at Operating Plants ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None ATTACHMENT

LIST OF ACRONYMS ALARA As Low As is Reasonably Achievable ASME American Society of Mechanical Engineers CFR Code of Federal Regulations CoC Certificate of Compliance CNS Cooper Nuclear Station DSC Dry Shielded Canister FSAR Final Safety Analysis Report GTAW Gas Tungsten Arc Weld HMSLD Helium Mass Spectrometer Leak Detector ITS Important-To-Safety ISFSI Independent Spent Fuel Storage Installation M&TE Measuring and Test Equipment NDE Non Destructive Examination NITS Not-Important-To-Safety NRC Nuclear Regulatory Commission PQR Procedure Qualification Record PT Liquid Penetrant Test QA Quality Assurance TS Technical Specification VT Visual Test WPQ Welder Performance Qualification WPS Welding Procedure Specification WML Welder Maintenance Log-2- ATTACHMENT

ATTACHMENT 2 Inspector Notes Cooper ISFSI (Table of Contents)

Category Topic Page #

Drying/Helium Backfill Helium Backfill Final Pressure - 61BT 1 Drying/Helium Backfill Vacuum Drying Final Pressure 1 Drying/Helium Backfill Vacuum Drying Time Limits - 61BT 1 NDE Certification Exams Level I GENERAL Exam 2 NDE Certification Exams Level II Exam Grading 2 NDE Personnel Quals Certification Records 2 NDE Personnel Quals MSLT Level I & II Candidates 3 NDE Personnel Quals PT Level I & II Candidates 3 NDE Personnel Quals Recertification 4 NDE Personnel Quals Visual Acuity 4 NDE Personnel Quals VT Level I & II Candidates 5 NDE Personnel Quals Written Practice 5 NDE Procedures - HT HMSLD Minimum Sensitivity 6 NDE Procedures - PT Acceptance Criteria 6 NDE Procedures - PT Contaminants 7 NDE Procedures - PT Final Interpretation 7 NDE Procedures - PT Light Intensity 7 NDE Procedures - PT Minimum Elements 7 NDE Procedures - PT Non Standard Temperature 8 NDE Procedures - PT Permanent Record 8 NDE Procedures - PT Removing Excess Penetrant 8 NDE Procedures - PT Surface Preparation 9 NDE Procedures - VT Acceptance Criteria - Fusion 9 NDE Procedures - VT Acceptance Criteria - Lengths 9 NDE Procedures - VT Acceptance Criteria - Undercut 10 NDE Procedures - VT Eye Position and Lighting 10 NDE Procedures - VT Minimum Elements 10 NDE Procedures - VT Procedure Requalification 11 NDE Procedures - VT Procedure Validation 11 Page 1 of 2

Category Topic Page #

Quality Assurance Measuring & Test Equipment 11 Radiation Protection Canister Unloading Operations 11 Training Unloading Operations 12 Unloading Operations Hydrogen Monitoring 12 Unloading Operations Water Fill Rate 13 Weld Testing Helium Leak Rate Limits - 61BT 13 Weld Testing Liquid Penetrant Testing 14 Welding Canister Confinement Welds 14 Welding Explosive Gas Monitoring 14 Welding Personnel Quals Expiration 15 Welding Personnel Quals Welder Performance Qualification (WPQ) 15 Welding Personnel Quals Welder Performance Qualification Test (WPQ) 15 Welding Personnel Quals Welding Operator Performance Qualification 15 Welding Procedures GTAW Essential Variables 16 Welding Procedures GTAW Non Essential Variables (1-14) 16 Welding Procedures GTAW Non Essential Variables (15-27) 16 Welding Procedures GTAW Supplementary Essential Variables 17 Welding Procedures Procedure Qualification Record (PQR) 17 Welding Procedures Tack Welds 17 Welding Procedures Weld Repairs - Base Metal Defects 18 Welding Procedures Weld Repairs - Surface Defects 18 Welding Procedures Welding Procedure Specification (WPS) 18 Page 2 of 2

COOPER ISFSI (Docket 72-066)

(INSPECTOR NOTES)

Category: Drying/Helium Backfill Topic: Helium Backfill Final Pressure - 61BT Reference: CoC 1004, Tech Spec 1.2.3.a Requirement: The 61BTcanisters are backfilled with helium to a pressure of 1.5 to 3.5 psig and the pressure must remain stable for 30 minutes after filling.

Finding: The intent of this requirement was achieved. Procedure 10.38, Section 4.6 performed the final Dry Shielded Canister (DSC) helium backfill operation. The helium backfill pressure range was specified as 1.6 to 3.4 psig. The helium pressure was established at approximately 2.5 psig and held for a minimum of 30 minutes during the preoperational demonstration.

Documents CNS Procedure 10.38, "Dry Shielded Canister Sealing," Revision 0 Reviewed:

Category: Drying/Helium Backfill Topic: Vacuum Drying Final Pressure Reference: CoC 1004, Tech Spec 1.2.2 Requirement: All canisters must be vacuum dried to 3 mm Hg (torr) or less and held for 30 minutes or more. This level of dryness must be achieved in both the initial pump-down and the final pump-down.

Finding: The intent of this requirement was achieved. Procedure 10.38, Sections 4.4.41 and 4.5.24 recorded the vacuum readings and time limits as specified in NUHOMS Technical Specification 1.2.2. The procedure required that the vacuum pressure be maintained equal to or less than 2.8 torr for the required 30 minute hold time. During the demonstration the vacuum pressure was held at 1.4 torr for approximately 31 minutes.

Documents CNS Procedure 10.38, "Dry Shielded Canister Sealing," Revision 0 Reviewed:

Category: Drying/Helium Backfill Topic: Vacuum Drying Time Limits - 61BT Reference: CoC 1004, Tech Spec 1.2.17 Requirement: The time limit for vacuum drying a 61BT canister with a decay heat load of greater than 17.6 kW is 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months . For decay heat loads of 17.6 kW or less there is no the time limit.

If the canister cannot be vacuum dried to 3 mm Hg (torr) or less for 30 minutes or more within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the canister must be backfilled with helium to 0.1 atmospheres or greater within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The licensee must determine the cause of the failure to achieve vacuum drying pressure. After the cause is determined, the licensee is to initiate vacuum drying actions or unload the DSC within 30 days.

Finding: This requirement was not applicable for the initial loading campaign. The licensee indicated that the first eight canisters loaded would all have a heat load less than 17.6 kW. Therefore the time limits specified in the Technical Specification would not apply for the planned loading campaign.

Page 1 of 18

Documents CNS Procedure 10.38, "Dry Shielded Canister Sealing," Revision 0 Reviewed:

Category: NDE Certification Exams Topic: Level I GENERAL Exam Reference: SNT-TC-1A, Section 8 Requirement: The GENERAL examination is written. The GENERAL examination for VT and PT should contain a minimum of 30 questions related to the basic principles of the method.

Finding: This requirement was achieved. The minimum number of required exam questions for VT and PT examiners was located in Table 2 of Qualify Procedure 06260-CNS-QP-9.200-R0. The minimum requirements specified in Table 2 were consistent with the SNT-TC-1A criteria.

Documents TriVis NDE Services, LLC., Quality Procedure: 06260-CNS-QP-9.200-R0, "Written Reviewed: Practice for the Qualification & Certification of Nondestructive Examination (NDE)

Personnel," Revision 0 Category: NDE Certification Exams Topic: Level II Exam Grading Reference: SNT-TC-1A, Section 8 Requirement: Level II candidates take 3 examinations; GENERAL, SPECIFIC, and PRACTICAL. A composite grade should be determined by simple averaging of the results of the 3 examinations. A passing composite grade should be 80 percent with no one examination below 70 percent.

Finding: This requirement was met. Section 8.0 of Quality Procedure 06260-CNS-QP-9.200-R0 for TriVis (VT/PT personnel) was consistent with the requirements for Level II examinations and composite grading as specified per SNT-TC-1A. Section 8.9 of Procedure 100.0 for RRL NDT Consulting (LT personnel) was also found to be consistent with the requirements for Level II examinations and composite grading as specified per SNT-TC-1A.

Documents TriVis NDE Services, LLC., Quality Procedure 06260-CNS-QP-9.200-R0, "Written Reviewed: Practice for the Qualification & Certification of Nondestructive Examination (NDE)

Personnel," Revision 0; RRL NDT Consulting, LLC., Procedure No. 100.0, "Procedure for Qualification and Certification of Nondestructive Examination Personnel," Revision 3 Category: NDE Personnel Quals Topic: Certification Records Reference: SNT-TC-1A, Section 9 Requirement: Certification records should contain the name of the certified individual, the certification level and method, the individual's educational background and NDE experience, a statement of satisfactory completion of training per the employers written practice, visual examination results, evidence of successful completion of examinations including grades, date of certification, and the signature of the employer.

Finding: This requirement was achieved. The NDE examiner certification packages for the TriVis VT/PT personnel and for RRL LT personnel consisted of a Certification Record, Visual Acuity Record, and resume of the NDE examiners. The Certification Records and resumes contained the name of the certified individual, the certification level and method, the individual's educational background, NDE experience, a statement of satisfactory Page 2 of 18

completion of training per the employers written practice, evidence of successful completion of examinations including grades, date of certification, and the signature of the employer. The Visual Acuity Records contained results of the near distance and far distance acuity tests, and the color differentiation test.

Documents TriVis Quality Procedure 06260-CNS-QP-9.200-R0, "Written Practice for the Reviewed: Qualification & Certification of Nondestructive Examination (NDE) Personnel,"

Revision 0; RRL NDT Consulting, LLC., Procedure 100.0, "Procedure for Qualification and Certification of Nondestructive Examination Personnel," Revision 3 VT/PT and LT Certification Records VT/PT and LT Visual Acuity Records VT/PT Examiner Resumes Category: NDE Personnel Quals Topic: MSLT Level I & II Candidates Reference: SNT-TC-1A, Section 6, Table 6.3.1 Requirement: An MSLT Level I candidate who is a high school graduate or equivalent must have 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months of training and 4 months of work time experience.

An MSLT Level I candidate who has completed 2 years of engineering or science study must have 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months of training and 4 months of work time experience.

An MSLT Level II candidate who is a high school graduate or equivalent, must have 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of training and 6 months of work time experience.

An MSLT Level II candidate who has completed 2 years of engineering or science study must have 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of training and 6 months of work time experience.

Finding: The intent of this requirement was achieved. During the welding demonstration the individual that performed the helium leak test was a Level III MSLT inspector.

However, the inspectors identified that the minimum training requirements specified for a Level II MSLT in Procedure 100.0 did not meet the specified SNT-TC-1A-1992 requirements. This was brought to the attention of TriVis QA personnel who initiated Condition Report CR2009-021209-04. This deficiency has been properly documented in the corrective action system and will be corrected prior to loading. No further action is required.

Documents RRL NDT Consulting, LLC., Procedure 100.0, "Procedure for Qualification and Reviewed: Certification of Nondestructive Examination Personnel," Revision 3 Category: NDE Personnel Quals Topic: PT Level I & II Candidates Reference: SNT-TC-1A, Section 6, Table 6.3.1 Requirement: A PT Level I candidate who is a high school graduate or equivalent, or who is has completed 2 years of engineering or science study, must have 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of training and 1 month of work time experience.

A PT Level II candidate who is a high school graduate or equivalent, must have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of training and 2 months of work time experience.

A PT Level II candidate who has completed 2 years of engineering or science study must have 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of training and 2 months of work time experience.

Finding: This requirement was achieved. Table 1 of Procedure 06260-CNS-QP-9.200-R0 contained the minimum training and experience requirements for Level I and Level II certifications. The minimum requirements were consistent with SNT-TC-1A criteria.

Page 3 of 18

Documents TriVis Quality Procedure 06260-CNS-QP-9.200-R0, "Written Practice for the Reviewed: Qualification & Certification of Nondestructive Examination (NDE) Personnel,"

Revision 0 Category: NDE Personnel Quals Topic: Recertification Reference: SNT-TC-1A, Section 9 Requirement: Maximum recertification intervals are 3 years for Levels I and II, and 5 years for Level III. Recertification may be granted without testing provided there is documented continuing satisfactory performance. "Continuing" must be defined in the written practice. Without documented continuing satisfactory performance, reexamination is required for those sections deemed necessary by the Level III examiner.

Finding: This requirement was met. Section 13.0 of TriVis Procedure 06260-CNS-QP-9.200-R0 for VT/PT examiners and Section 9.4 of RRL Consulting Procedure 100.0 for LT examiners stated the NDE Level I and II personnel shall be recertified by re-examination at intervals not to exceed 3 years and NDE Level III personnel shall be recertified at intervals not to exceed 5 years by evidence of continuing satisfactory performance or by re-examination. The Certification Records for VT/PT and LT examiners contained both certification and recertification dates which were compliant to the SNT-TC-1A criteria.

Documents TriVis Quality Procedure 06260-CNS-QP-9.200-R0, "Written Practice for the Reviewed: Qualification & Certification of Nondestructive Examination (NDE) Personnel",

Revision 0 RRL NDT Consulting, LLC., Procedure 100.0, "Procedure for Qualification and Certification of Nondestructive Examination Personnel," Revision 3 Category: NDE Personnel Quals Topic: Visual Acuity Reference: SNT-TC-1A, Section 8.2 Requirement: The NDE examiner should have natural or corrected near-distance acuity in at least one eye capable of reading Jaeger Number 1 at a distance of not less than 12 inches on a standard Jaeger test chart, or capable of perceiving a minimum of 8 on an Ortho-Rater test pattern. This should be verified annually. The NDE examiner should demonstrate the capability of distinguishing and differentiating contrast among colors used in the applicable method. This should be verified every 3 years.

Finding: The intent of this requirement was achieved. The results of the visual exam for the leak test examiner were acceptable, however the documentation was not properly recorded based upon the requirements that were contained in RRL NDT Consultation, LLC.,

Procedure 100.0, Attachment F "Visual Acuity Examination Record". This was brought to the attention of TriVis QA personnel and Condition Report CR2009-021209-01 was initiated and the deficiency was subsequently corrected.

The documentation for the VT/PT examiners met the requirements of TriVis Quality Procedure 06260-CNS-QP-9.200-R0. Visual Acuity Records from VT/PT and leak test examiners used the Jaeger Number 1 chart for near distance, the Snellen Test chart for far distance acuity, and the Ishihara Test for color differentiation. Both VT/PT and LT examiners received an annual vision test. VT/PT examiner is due for their next test in October 2010 and LT examiner is due for their next test in January 2010.

Page 4 of 18

Documents TriVis Quality Procedure 06260-CNS-QP-9.200-R0, "Written Practice for the Reviewed: Qualification & Certification of Nondestructive Examination (NDE) Personnel,"

Revision 0; RRL NDT Consulting, LLC., Procedure 100.0, "Procedure for Qualification and Certification of Nondestructive Examination Personnel," Revision 3 VT/PT and LT Visual Acuity Records Category: NDE Personnel Quals Topic: VT Level I & II Candidates Reference: SNT-TC-1A, Section 6, Table 6.3.1 Requirement: Level I: A VT candidate who is a high school graduate or equivalent, must have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of training and 1 month of work time experience. A VT candidate who has completed 2 years of engineering or science study, must have 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of training and 1 month of work time experience.

Level II: A VT candidate who is a high school graduate or equivalent, must have 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of training and 2 months of work time experience. A VT candidate who has completed 2 years of engineering or science study, must have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of training and 2 months of work time experience.

Finding: The intent of this requirement was achieved. None of the inspections that were performed during the demonstration utilized a Level I or II VT inspector. The individual that performed the VT inspections during the demonstration was a Level III, with considerable more experience than the required minimum level. However during the review of Procedure 06260-CNS-QP-9.200-R0, the inspector discovered that the minimum required experience for Level II VT personnel listed in Table 1 of Qualify Procedure 06260-CNS-QP-9.200-R0 did not meet requirements of SNT-TC-1A-1992.

This was brought to the attention of TriVis QA personnel who initiated Condition Report CR2009-021209-03 and the information was subsequently corrected. The listed minimum training and experience requirements for the Level 1 VT personnel were consistent with the SNT-TC-1A criteria.

Documents TriVis Quality Procedure 06260-CNS-QP-9.200-R0, "Written Practice for the Reviewed: Qualification & Certification of Nondestructive Examination (NDE) Personnel,"

Revision 0 Category: NDE Personnel Quals Topic: Written Practice Reference: SNT-TC-1A, Section 5 Requirement: The employer shall establish a written practice for control and administration of NDT personnel training, examination and certification. The written practice should describe the responsibility of each level of certification for determining the acceptability of material or components. The written practice shall describe the training experience and examination requirements for each level of certification.

Finding: This requirement was achieved. Quality Procedure 06260-CNS-QP-9.200-R0, Section 2.0 and 8.0 described the responsibilities and capabilities for each certification level to determine the acceptability of material or components. Table 1 of Qualify Procedure 06260-CNS-QP-9.200-R0 contained the minimum training and experience requirements for each level of NDE certification. Tables 2 and 3 of Quality Procedure 06260-CNS-QP-9.200-R0 contained the examination requirements for each level of certification. RRL NDT Consulting, LLC., Procedure 100.0, Section 4.0 described the responsibilities and Page 5 of 18

capabilities for each certification level to determine the acceptability of material or components. Table 1 of Procedure 100.0 contained the minimum training and experience requirements for each level of NDE certification. Table 2 of Procedure 100.0 contained the examination requirements for each level of certification.

Documents TriVis Quality Procedure 06260-CNS-QP-9.200-R0, "Written Practice for the Reviewed: Qualification & Certification of Nondestructive Examination (NDE) Personnel,"

Revision 0; RRL NDT Consulting, LLC., Procedure 100.0, "Procedure for Qualification and Certification of Nondestructive Examination Personnel," Revision 3 Category: NDE Procedures - HT Topic: HMSLD Minimum Sensitivity Reference: ANSI N14-5, Section 8.4 Requirement: The helium mass spectrometer leak detector (HMSLD) shall have a minimum sensitivity of 1/2 the acceptance leak rate. For example, a package with a leaktight acceptance criteria of 1.0 X 10(-7) ref-cc/sec requires a minimum HMSLD sensitivity of 5.0 X 10(-

8) ref-cc/sec. This sensitivity requirement applies to both the hood and detector probe methods. The HMSLD shall be calibrated to a traceable standard.

Finding: This requirement was achieved. The acceptance criteria for the helium test was less than or equal to 2.0 X 10-7 std-cc/sec of helium. Section 4.0 of Procedure HMSLD-1004 established the minimum sensitivity of the instrument to be 1.0 X 10-9 std-cc/sec.

During the demonstration the instrument was able to detect to a sensitivity of 1.07 X 10-10 std-cc/sec.

Documents RRL NDT Consulting Procedure Transnuclear-HMSLD-1004, "Specific Procedure for Reviewed: HMSLD Leak Testing of Transnuclear NUHOMS Horizontal Modular Storage System For Irradiated Nuclear Fuel Inner Top Cover Plate and Vent and Siphon Port Cover Plates," Revision 0 Category: NDE Procedures - PT Topic: Acceptance Criteria Reference: ASME Section III, Article NB-5352 Requirement: Only indications with major dimensions greater than 1/16 inch should be considered relevant. The following relevant indications are unacceptable: (1) any cracks or linear indications. Linear indications have a length at least 3 times greater than the width; (2)

rounded indications with dimensions greater than 3/16 inch (4.8 mm); (3) more than four rounded indications in a line, separated by 1/16 inch (1.6 mm) or less edge to edge; and (4) more than ten rounded indications in any 6 square inch area in the most unfavorable location relative to the indications being evaluated.

Finding: This requirement was achieved. Procedure QP 06260-CNS-QP-9.202-R1 included the ASME Section III, Article NB acceptance criteria specified above. The inspector observed the NDE technician using the acceptance criteria to categorize rejectable indications during the root pass of the welding demonstration on the lid-to-shell weld.

The indications were removed and after subsequent welding operations, the PT results were found to be acceptable.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Page 6 of 18

Category: NDE Procedures - PT Topic: Contaminants Reference: ASME Section V, Article 6, T-641 Requirement: The user shall obtain certification of contaminant content for all liquid penetrant materials used on austenitic stainless steels. The certifications shall include the manufacturers batch number and sample results. Sub-article T-641(b) limits the total halogen (chlorine plus fluorine) content of each agent (penetrant, cleaner and developer)

to 1.0 weight percent (wt.%) when used on austenitic stainless steels.

Finding: This requirement was achieved. The ASME requirements for contaminants were included in Procedure QP 06260-CNS-QP-9.202-R1. During the demonstration, the inspector verified that the Sherwin K019, Batch 658-F56, remover met the contamination requirements. The information for the Sherwin KO17, Batch 421-K54,penetrant and Sherwin D350, Batch 527-B71, developer were provided to the inspector post demonstration and verified to be satisfactory.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - PT Topic: Final Interpretation Reference: ASME Section V, Article 6, T-676.1 Requirement: Final interpretation shall be made after allowing the penetrant to bleed-out for 7-60 minutes under standard temperatures (50 and 125 degrees F). The 7-60 minute clock starts immediately after application of a dry developer. For wet developer, the clock starts when the coating is dry.

Finding: This requirement was achieved. Procedure QP 06260-CNS-QP-9.202-R1, Section 6.2 included the specified requirements for allowing the penetrant to bleed out. The correct use of the procedure was observed by the inspector during the welding demonstration.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - PT Topic: Light Intensity Reference: ASME Section V, Article 6, T-676.3 Requirement: For color contrast penetrants, a minimum light intensity of 50 foot-candles (500 lux) is required to ensure adequate sensitivity during examination and evaluation of indications.

Finding: This requirement was achieved. Procedure QP 06260-CNS-QP-9.202-R1 specified that a minimum light intensity of 100 foot-candles be verified using a calibrated light meter at the inspection site. The inspector witnessed the NDE technician using a calibrated light meter to verify the lighting conditions of the inspection area.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - PT Topic: Minimum Elements Reference: ASME Section V, Article 6, T-621 Requirement: Each liquid penetrant (PT) procedure shall include the: (1) materials, shapes or sizes to be Page 7 of 18

examined; (2) type of each penetrant, remover, emulsifier, and developer; (3) pre-examination cleaning and drying, including the cleaning materials used and minimum time allowed for drying; (4) applying the penetrant, the length of time the penetrant will remain on the surface (dwell time), and the temperature of the surface during examination; (5) removing excess penetrant and drying the surface before applying the developer; (6) length of developing time before interpretation; and (7) post-examination cleaning.

Finding: This requirement was achieved. The requirements for the minimum elements of the dye penetrant process were present in Procedure QP 06260-CNS-QP-9.202-R1.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - PT Topic: Non Standard Temperature Reference: ASME Section V, Article 6, T-653 Requirement: When performing liquid penetrant examinations outside the range of 50 to 125 degrees F, the examiner may use a standard temperature procedure or a non-standard temperature procedure. In either case, the examination procedure requires qualification at the proposed higher or lower temperature. This shall require the use of a quench cracked aluminum block, also designated as a liquid penetrant comparator block.

Finding: This requirement was achieved. The information necessary to demonstrate compliance with this requirement was provided to the inspector after the demonstration. The inspector determined that the high temperature quench blocks qualification test results were satisfactory.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1,"Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - PT Topic: Permanent Record Reference: ASME Section V, Article 6, T-676 Requirement: The inspection process, including findings (indications), shall be made a permanent part of the user's records by video, photographic, or other means which provide an equivalent retrievable record of weld integrity. The video or photographic records should be taken during the final interpretation period.

Finding: This requirement was achieved. Procedure 06260-CNS-OPS-01-R0 required that the results of the dye penetrant examinations be recorded in Attachment 9.3 of the procedure. These attachments documented the acceptance or rejections of the dye penetrant examinations and are stored with the other permanent canister records after the canister was loaded.

Documents Procedure 06260-CNS-OPS-01-R0, "Spent Fuel Cask Welding-61BT NUHOMS Reviewed: Canisters," Revision 0 Category: NDE Procedures - PT Topic: Removing Excess Penetrant Reference: ASME Section V, Article 6, T-673.3 Requirement: Excess solvent removable penetrants shall be removed by wiping with a cloth or Page 8 of 18

absorbent paper until most traces of the penetrant have been removed. The remaining traces shall be removed by lightly wiping the surface with a cloth or absorbent paper moistened with solvent. Care shall be taken to avoid the use of excess solvent.

Finding: This requirement was met. Procedure QP 06260-CNS-QP-9.202-R1 included the ASME Code requirements for removal of the excess penetrant specified above. The inspector witnessed the NDE technician removing the excess penetrant according to the instructions specified above during the welding demonstration.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - PT Topic: Surface Preparation Reference: ASME Section V, Article 6, T-642 (b)

Requirement: Prior to each liquid penetrant examination, the surface to be examined and all adjacent areas within one inch must be dry and clean.

Finding: This requirement was met. Procedure QP 06260-CNS-QP-9.202-R1 specified that the surface to be examined and all adjacent areas within one inch must be dry and clean. The inspector observed the NDE technician ensuring that the surface preparation met the specified requirements during the welding demonstration.

Documents TriVis Procedure QP 06260-CNS-QP-9.202-R1, "Color Contrast Liquid Penetrant (PT)

Reviewed: Examinations Using the Solvent Removable Method," Revision 1 Category: NDE Procedures - VT Topic: Acceptance Criteria - Fusion Reference: ASME Section III, Article NF-5360 Requirement: For fillet welds, incomplete fusion of more than 3/8" (10 mm) in any 4" (102 mm)

segment is unacceptable. For fillet welds, incomplete fusion of more than 1/4" (6 mm) in welds less than 4" (102 mm) is unacceptable. For groove welds, any incomplete fusion is unacceptable. Rounded end conditions (starts and stops) shall not be considered indications of incomplete fusion.

Finding: This requirement was achieved. Procedure QP-9.201 included the acceptance criteria for fusion defined by the ASME Code in Section 6.1.B.