IR 07100018/2025201
| ML25055A215 | |
| Person / Time | |
|---|---|
| Site: | 07100018 |
| Issue date: | 02/28/2025 |
| From: | Gerond George NRC/NMSS/DFM/IOB |
| To: | Jeffrey Hamman NAC International |
| References | |
| IR 20250201 | |
| Download: ML25055A215 (1) | |
Text
SUBJECT:
NAC INTERNATIONAL, INC. - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 710018/2025201
Dear Joyce Hamman:
On January 14, 2025, through January 16, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced onsite inspection at the NAC International, Inc. (NAC)
corporate office in Peachtree Corners, Georgia, to verify and assess NAC compliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, and 10 CFR Part 21, Reporting of Defects and Noncompliance.
The purpose of the inspection was to verify and assess the adequacy of NAC implementation and compliance with the NRC requirements for the design, modification, fabrication, assembly, testing, procurement, repair and maintenance of transportation packaging(s) to determine if NAC performed these activities in accordance with the requirements of 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance. NAC is the certificate of compliance (CoC)
holder of the NAC-LWT, NAC-STC, UMS Universal, MAGNATRAN, OPTIMUS-L, and OPTIMUS-H transportation packagings.
The inspection scope included an examination of selected procedures and representative records, observations of activities, when applicable, and interviews with personnel to determine whether NAC designed, fabricated, and maintained selected transportation packagings in accordance with the commitments and requirements specified in the applicable safety analysis reports for packaging, the NRCs corresponding safety evaluation report, CoC, and NRC-approved quality assurance program requirements. The enclosed report presents the results of this inspection, which were discussed with you and other NAC representatives on January 16, 2025.
Based on the results of this inspection, the NRC inspection team determined that one CoC holder identified, Severity Level IV violation of NRC requirements occurred. The NRC is treating this violation as a Non-cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report.
If you contest this violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington DC 205550001, with copies to: (1) the Director, Office of February 28, 2025 Nuclear Materials Safety and Safeguards; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 205550001.
In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 18003974209 or 3014154737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
Sincerely, Gerond George, Acting Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 710018 Enclosure:
NRC Inspection Report No.
710018/2025201 Signed by George, Gerond on 02/28/25
ML25055A215 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME JTapp SFigueroa GGeorge DATE 2/24/2025 2/25/2025 2/28/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management Docket:
710018 Report.:
710018/2025201 Enterprise Identifier: I20252010002 Certificate Holder:
NAC International, Inc.
Facility:
Corporate Location:
Peachtree Corners, GA Inspection Dates:
January 14 - 16, 2025 Inspection Team:
Jeremy Tapp, Senior Transportation and Storage Safety Inspector, Team Leader Marlone Davis, Senior Transportation and Storage Safety Inspector Raju Patel, Transportation and Storage Safety Inspector Approved By:
Gerond George, Acting Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management
EXECUTIVE SUMMARY
NAC International, Inc.
NRC Inspection Report 710018/2025201 From January 14 -16, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced onsite inspection at the NAC International, Inc. (NAC) corporate office in Peachtree Corners, Georgia. The staff held an exit meeting on January 16, 2025.
The purpose of the inspection was to verify and assess the adequacy of NAC implementation and compliance with the NRC requirements for the design, modification, fabrication, assembly, testing, procurement, repair, and maintenance of transportation packaging(s) to determine if NAC performed these activities in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, and selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance.
Based on the results of this inspection, the NRC inspection team assessed that overall, the implementation of NACs quality assurance program (QAP) was adequate. One certificate of compliance (CoC) holder identified violation was documented for failure to ensure that all applicable regulatory requirements were met for design of the MAGNATRAN packaging.
Quality Assurance Program The team determined that NAC conducted quality related activities such as design, procurement, maintenance, and fabrication of transportation packaging(s) in accordance with the CoCs, as well as their QAP and had effective implementing procedures in place. (section 1.1)10 CFR Part 21 The team determined that the provisions of 10 CFR Part 21 were implemented, NAC personnel were familiar with the reporting requirements of 10 CFR Part 21 and NAC complied with 10 CFR 21.6, "Posting requirements." (section 1.2)
Design Control The team concluded that NAC is effectively implementing its design control program and has adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements. (section 1.3)
Fabrication, Testing, and Maintenance The team concluded that NAC provided adequate oversight of fabrication activities and conducted maintenance and test activities consistent with the fabrication specification, commitments in the safety analysis report (SAR), and conditions in the CoC for the items selected for review related to the fabrication of the OPTIMUS-H and the maintenance on the NAC-LWT packagings. (section 1.4)
Procurement Control The team concluded that NAC is implementing its procurement document control and supplier oversight programs in accordance with the applicable regulatory requirements of 10 CFR Part 71, Subpart H. Based on the limited sample of documents reviewed, the team determined that NAC is adequately implementing its procedures associated with the procurement document control and supplier oversight programs. (section 1.5)
Nonconformance and Corrective Action The team concluded that overall, NAC is effectively implemented its nonconformance control program and corrective action program (CAP) and had adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements. A CoC holder identified violation was documented for failure to ensure that all applicable regulatory requirements were met for design of the MAGNATRAN packaging. (section 1.6)
Personnel Training and Quality Assurance Oversight The team concluded that NAC had trained and qualified individuals performing activities affecting quality and that NAC management provided appropriate oversight of quality related activities, as applicable. (section 1.7)
Audit Program The team concluded that NAC had an adequate internal audit program in place to schedule, evaluate, and document the results. The team determined that NAC appropriately identified issues and documented them in the CAP as required. (section 1.8)
REPORT DETAILS
1.0 Applicable portions of Inspection Procedure 86001 - Design, Fabrication, Testing, and Maintenance of Transportation Packagings 1.1 Quality Assurance Program 1.1.1 Inspection Scope The team reviewed the NAC QAP, Quality Assurance Manual, edition 2, revision 11 and implementing quality procedures (QPs) to assess the effectiveness of the QAP implementation. The team conducted reviews of NACs quality program, policies, and procedures to determine whether activities subject to 10 CFR Part 71 were adequately controlled and implemented under NACs NRC-approved QAP. The team also reviewed the QAP to determine if changes were made and, if so, were performed in accordance with the requirements of 10 CFR 71.106, as applicable.
The team reviewed the QAP authorities and responsibilities to determine if they were clearly defined and documented, and that the quality assurance (QA) organization functioned as an independent group. The team reviewed NACs graded approach to quality as documented in the QAP to verify NAC identified important-tosafety components in its packaging designs in a graded approach, as described. The team also reviewed the QAP regarding the requirements for annual management reviews of NACs QAP and samples of those review reports.
1.1.2 Observations and Findings The team assessed that NAC had a QAP and implementing procedures in place that were generally effective in conducting activities in accordance with NACs NRC-approved QAP and CoCs as well as Part 71 requirements. The team verified that the QA organization operated in a manner sufficiently independent from cost and schedule, when opposed to safety considerations. The team determined that no changes to the NRC-approved QAP occurred since the last NRC inspection of NAC corporate in 2023.
The team found that NAC used a graded approach to categorize components important-tosafety in its packaging designs. The team reviewed the adequacy of the categorizations as a part of the design control review documented in section 1.3 of this report.
No findings of significance were identified.
1.1.3 Conclusions The team determined that NAC conducted quality related activities such as design, procurement, maintenance, and fabrication of transportation packaging(s) in accordance with the CoCs and QAP. The team determined that NAC had effective implementing procedures in place.
1.2 10 CFR Part 21 1.2.1 Inspection Scope The team verified that provisions are in place for reporting defects which could cause a substantial safety hazard, as required by 10 CFR Part 21. The team reviewed the 10 CFR Part 21 procedure QP 162, Potential Significant Deficiencies and Defects and Regulatory Reporting, revision 10, to verify if provisions were in place for reporting defects that could cause a substantial safety hazard and whether NAC would complete the required evaluation and notification in a timely manner. The team requested a list of 10 CFR Part 21 evaluations and notifications associated with NAC quality activities. The team also verified if NAC complied with 10 CFR 21.6, Posting requirements.
1.2.2 Observation and Findings The team assessed that NAC has provisions in place for evaluating deviations and reporting defects that could cause a substantial safety hazard, as required by 10 CFR Part 21. The team noted that for the 10 CFR Part 21 postings sampled at NACs Peachtree Corners, GA, facility met the applicable requirements of 10 CFR Part 21. No Part 21 reports were made to the NRC regarding Part 71 activities since the last routine Part 71 inspection in 2018.
No findings of significance were identified.
1.2.3 Conclusions The team determined that the provisions of 10 CFR Part 21 were implemented, NAC personnel were familiar with the reporting requirements of 10 CFR Part 21 and NAC complied with 10 CFR 21.6, "Posting requirements."
1.3 Design Control 1.3.1 Inspection Scope The team interviewed selected personnel and reviewed selected design documentation to determine that adequate design controls are implemented. The team reviewed the sections of the NACs QAP, and the QPs specifically related to design development, design control, and modification of design activities. The team focused its review on NAC design activities related to the following Part 71 transportation packaging designs: NAC-LWT, NAC-STC, and MAGNATRAN. The team reviewed the following NAC implementing procedures associated with design control to verify the procedures were adequately followed:
- QP 31, Control of Design Input, revision 6
- QP 32, "Preparation and Checking of Design Calculations," revision 16
- QP 33, Preparation and Checking of Design and/or License Drawings, Specifications and Technical Reports/Manuals, revision 30
- QP 34, Design Verification, revision 13
- QP 35, Computer Program Verification, revision 10
- QP 36, Identification and Control of Computer Program Errors, revision 6
- QP 73, Graded Quality Categories, revision 10
- QP 7-4, Dedication of Commercial Items and Services, revision 10
- EA913PER001, Program Error Reports (PER) Master Book, revision 13
- CGCCP002, Commercial Grade Dedication and Test Plan Characteristics for Commercially Procured Software Used in Safety-Related Applications, revision The team reviewed selected design documentation to determine if NAC implemented adequate design controls associated with a new basket design for the NAC-LWT cask that incorporated the caddy assembly within the basket to store NRU/NRX fuel assemblies prior to transport.
1.3.2 Observation and Findings The team followed-up on an unresolved item from the 2018 inspection as documented in NRC Inspection Report 710018/2018201 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18089A291) related to a design calculation of the NRU/NRX fuel basket. Specifically, related to lifting operations and the weld quality factors for the bottom plates associated with the caddy assembly operation and inspection activities documented in calculation No. 650077002000, NAC/NRX Basket and Spacer Assemblies Structural Evaluation, for NAC-LWT-AECL NRU/NRX Fuel Transport Project. The team reviewed Lifting Evaluation of Fuel Caddy and Grapple Assembly, dated 11/23/2015, and Appendix G, Load Test Evaluation for Caddy Assembly, dated 1/25/2016, and confirmed NAC design calculations took credit for the weld quality factors for the caddy assembly bottom plates invoking American Society of Mechanical Engineers Code,Section III, subsection NG. Based on review of the above, the team determined that the unresolved item is considered closed.
The team reviewed NACs design change request (DCR) process for licensing documents (DCR(L)) that provides methods for the preparation and checking of design and/or licensing drawings. The team selected a sample of DCR(L)s and DCRs to verify appropriate design change controls were prescribed in accordance with the requirements of QP 33.
The team performed follow-up to the 2023 apparent violation A documented in the NRC Inspection Report 721031/2023201 (ADAMS Accession No. ML2383A238)through review of sample calculations and interviews with NAC engineering personnel.
The team verified NACs design controls for verifying or checking the adequacy of design through design reviews or calculation methods.
The team noted appropriate preparation, checks, and approvals for accuracy and completeness. The team also noted that NAC submitted their revised calculations that impacted the license to the NRC for review and approval. Based on review of the above, the team determined that NAC adequately implemented their QAP and QP 32.
The team reviewed NACs software commercial grade dedication (CGD) package for LSDYNA program revision 11.1.0 (Calculation No. 913CGD0300, revision 0), SCALE program, version 6.3.1Category 2 (Calculation No. 913CGD0501, revision 3, dated 7/5/2024) and MCNP 6.3.0 (Calculation No. 913CGD0401, revision 0) to verify the software programs were verified and validated and results documented as described in 91150CGCCP002, Commercial Grade Dedication and Test Plan Characteristics for Commercially Procured Software Used in Safety-Related Applications, revision 0, and QP 35. The team noted that computer programs were procured through CGD by Method 1 Special Tests and Inspections in accordance with QP 74. The team noted the critical characteristics associated with the safety function of the computer program were satisfactorily confirmed, as prescribed within verification and validation reports EA9131040-009 for SCALE, EA9131060-008 for MCNP and EA9131030-200 for LSDYNA. The team noted that calculations were successfully run and verified on NAC computers and that the verification package satisfied the requirements of QP 35.
Graded Quality NAC QP 73 provides criteria for establishing a graded approach to quality based on the importance to safety of an item or service. The team reviewed Quality Category Assessment forms for NAC-LWT and NAC-STC components. The team noted that components critical to safe operation, important-tosafety category A (ITS-A), and items that have a major or minor impact on safety were appropriately categorized and documented either by special forms or existing fabrication drawings (NAC-LWT). The team reviewed a sample of NACs technical justifications used to derive the resultant quality categories, specifically ITS-A components. In each case reviewed by the team, NAC adequately identified critical characteristics relating to the specified safety function, potential failure mode, and performance requirement along with NAC QA requirements to confirm compliance.
No issues of significance were identified.
1.3.3 Conclusions The team concluded that NAC is effectively implementing its design control program and has adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements.
1.4 Fabrication, Assembly, Maintenance and Testing 1.4.1 Inspection Scope The team reviewed selected drawings, procedures, and records to determine whether the fabrication, assembly, testing, and maintenance activities met fabrication specifications, SAR design commitments, procedures, and requirements documented in the CoC. The team reviewed the final documentation packages for fabrication activities related to the OPTIMUS-H fabrication since there was no ongoing fabrication activities to observe. The team also reviewed maintenance activities for the NAC-LWT because no maintenance activity had occurred on the OPTIMUS-H or OPTIMUS-L transportation packagings.
Fabrication and Assembly The team reviewed selected drawings, procedures, and records related to the OPTIMUS-H fabrication activities to determine if the fabrication, testing, and assembly activities met the SAR design commitments, requirements documented in the CoC, and if NAC performed these activities in accordance with approved methods, procedures, and specifications. The team selected the cask containment vessel and impact limiter assembly because of their important-tosafety (ITS) category designation. The team reviewed OPTIMUS-H common books contained in the final documentation packages for serial numbers 1 and 9 that included, but not limited to, the following documents:
- 7000.14PL-1, Commercial Grade Classification and Characteristics Plan, revision 1
- 7000.14001, Packaging Assembly OPTIMUS-H, sheets 19, revision 4
- 7000.14020, OSV Assembly OPTIMUS-H, sheets 12, revision 4
- 7000.14030, Impact Limiter Assembly OPTIMUS-H, sheets 15, revision 7
- 70000.14L501, Packaging Assembly, sheets 15, revision 1P
- 70000.14L520, OSV Assembly, revision 0P
- 70000.14L530, Impact Limiter Assembly, sheets 12, revision 1P Maintenance and Testing The team reviewed selected records and interviewed personnel to verify that NAC effectively implemented a maintenance control program in accordance with their NRC-approved QAP, CoC conditions, SAR design requirements, and the requirements of 10 CFR Part 71 for the transportation of radioactive material. The team focused its review on maintenance activities pertaining to the NAC-LWT packaging and reviewed maintenance records for a period of five years for model numbers 2, 4, and 6.
The team evaluated annual maintenance activities conducted at NACs maintenance and storage facility in Wampum, PA. The evaluation included a review of maintenance requirements, inspection and maintenance procedures, completed records, and personnel training and qualification records.
The team reviewed the following quality and maintenance implementing procedures:
- QP 101, Inspection and Verification, revision 13
- 315P-03, NAC-LWT Annual Maintenance Procedure, revision 22, dated July 2020
- 7000.14P-05, NAC OPTIMUS Packaging Maintenance Procedure, revision 3, dated January 2024
- MSLT-NAC4, Helium Concentration Analysis Procedure, revision 5, dated October 2023 1.4.2 Observation and Findings Based on the samples selected from final documentation package, the team assessed that the fabricators and NAC 1) established appropriate means to control the OPTIMUS-H fabrication activities and special processes described in the specific and common books, and 2) met the SAR design commitments and fabrication specifications. The team examined NACs procurement/fabrication specification, design and fabrication drawings, project plan, and specific and common books completed for OPTIMUS-H fabrication activities and confirmed that the fabrication and testing activities were adequate. The team noted that the specific and common books identified the applicable drawings, material specifications, work instructions, and procedures used to fabricate the OPTIMUS-H ITS components.
The team also assessed that NAC used appropriate maintenance materials, tools, and equipment to conduct the annual maintenance activities for the NAC-LWT packaging.
The team verified that the inspections were comprehensive and met acceptance criteria for tests identified in the maintenance records and procedures. The team assessed and verified the results of the load and helium leakage testing of the NAC-LWT packaging.
The team also verified that NAC appropriately inspected attributes of the packaging body and cavity, and personnel recorded the proper information on the applicable forms and data sheets, as defined and required within the NAC quality and maintenance procedures. Overall, the team assessed that the maintenance tests satisfied the requirements identified in the NAC-LWT SAR and CoC.
No findings of significance were identified.
1.4.3. Conclusion The team concluded that NAC is effectively implementing its fabrication and maintenance programs through use of adequate material specifications, work instructions, and procedures to ensure compliance with the applicable regulations, SAR commitments, CoC conditions, and QAP requirements.
1.5 Procurement Control 1.5.1 Inspection Scope:
The team determined whether a) materials, components, and other equipment received by NAC meet applicable transportation packaging design procurement specifications, and b) the procurement specifications conform to the design commitments and requirements contained in the safety analysis report and CoC.
The team reviewed NACs processes that address procurement, including traceability and receipt inspection. The team reviewed drawings and records and interviewed selected personnel to verify that the procurement specifications for materials and services performed at NAC met design requirements. The team reviewed the following implementing procedures associated with procurement to verify the procedures were adequately followed:
- QP 41, Procurement Document Control, revision 15
- QP 71, Control of Purchased Items and Services, revision 13
- QP 73, Graded Quality Categories, revision 10 1.5.2 Observation and Findings:
The team verified that procurement of selected ITS-A and B items and services for design and fabrication of NAC-LWT transportation packaging internals and NAC-STC transportation packaging were made to suppliers listed on NACs qualified vendor list (QVL). The team reviewed a sample of procurement documents related to ITS-A components for NAC-STC and NAC-LWT projects and confirmed that purchase orders (POs) included scope of work, right of access to the suppliers facilities, and extension of contractual requirements to sub-suppliers. The team noted assigned quality categories to procurement documents that were developed in accordance with QP 73. The team confirmed that the POs adequately imposed the applicable technical, regulatory, and quality requirements. The team reviewed a sample of completed receipt inspection records to verify that inspections were conducted in accordance with receipt inspection procedures and that the procured materials met the applicable procurement specifications.
The team noted that NAC commercially dedicated some of their ITS-A components and maintained traceability from receipt of items until completion of CGD and receipt inspection. The team assessed that NAC provides adequate documentation of traceability as shown in the CGD reports, quality plans, purchase specifications, material test and examination reports, and a final receipt inspection report. The team assessed implementation of the CGD process through review of a dedication package for commercially procured Orings and seals. No findings of significance were identified.
The team reviewed NACs external audit program to determine if NAC scheduled and performed supplier audits, source surveillance, and annual evaluations in accordance with approved quality procedures. The team selected a sample of suppliers from the QVL to review the methodology for conducting and documenting audits and the review of third-party audits to verify adequate evaluation of the suppliers' controls for meeting the applicable requirements of 10 CFR Part 71, Subpart H.
Overall, the team identified no concerns with NACs procurement control, supplier survey, audit, and supplier evaluation programs. The team verified that for the audits sampled, NAC conducted the audit and survey with qualified and certified personnel, scheduled and evaluated applicable elements of the QAP, and resolved findings, and observations in a timely manner. The team also verified that audits performed by the Nuclear Industry Assessment Committee (NIAC) were evaluated by NAC in accordance with its written procedures for applicability to its scope of activities. The team discussed the procurement document control and supplier oversight programs with NACs management and technical staff. The attachment to this inspection report lists the documents reviewed by the team.
No findings of significance were identified.
1.5.3 Conclusions:
The team concluded that NAC is implementing its procurement document control and supplier oversight programs in accordance with the applicable regulatory requirements of 10 CFR Part 71, Subpart H. Based on the limited sample of documents reviewed, the team determined that NAC is adequately implementing its procedures associated with the procurement document control and supplier oversight programs.
1.6 Nonconformance and Corrective Action Programs 1.6.1 Inspection Scope The team reviewed sample of NACs nonconformance reports (NCRs), corrective action reports (CARs), and finding reports (FRs) and interviewed selected personnel to verify that NAC effectively implemented their nonconformance control program and CAP. The review included an evaluation of how NACs nonconformance control program and CAP addressed materials, parts, and components that do not conform to requirements and identified quality deficiencies. The team reviewed the following NAC quality procedures:
- QP 161, "Corrective Action Reports," revision 7
- QP 151, Control of Nonconforming Items, revision 12
- SP404, "Performance of Root Cause Analysis," revision 1
- QP 182, Audits, Surveys and Corrective Action, revision 11 The team reviewed a sample of NCRs, CARs, and FRs since the last NRC Part 71 inspection in 2018. The team discussed the nonconformances and corrective actions with the NAC staff to understand the process and issue identified. The team focused the NCR review on use-asis and repair type dispositions to evaluate how NAC technically justified the approved dispositions. The CARs and FRs were reviewed to determine whether NAC completed corrective actions for identified deficiencies in a technically sound and timely manner, including assessment of associated cause analyses and reporting in accordance with parts 21 and 71, as applicable.
1.6.2 Observation and Findings Overall, the team found that NAC had adequate nonconformance and corrective action controls in place to identify, track, and resolve quality related issues. The team noted from the nonconformances, and corrective actions reviewed that overall, NAC appropriately dispositioned and resolved the issues in a timely manner and in accordance with their implementing procedures.
During review of FR 23020, the team noted that NAC identified that the required side drop evaluation for the MAGNATRAN transportation packaging performed for hypothetical accident conditions did not acknowledge or address the impact the rotation trunnions would have on the impact limiters. NAC determined that considering the rotation trunnions in the side drop evaluation analytical model, accelerations and stresses experienced by the cask would be adversely affected and requires a design change. The team determined that this was a CoC holder identified violation of 10 CFR 71.107(a).
Title 10 CFR 71.107(a), states in part, the certificate holder for a CoC shall establish measures to assure that applicable regulatory requirements and the package design, as specified in the CoC for those materials and components to which this section applies, are correctly translated into specifications, drawings, procedures, and instructions.
These measures must include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from standards are controlled.
Contrary to the above, since November 2023, NAC failed to ensure that all applicable regulatory requirements were correctly translated into the design of the MAGNATRAN packaging. Specifically, NAC failed to translate requirements of10 CFR 71.73(c)(1) for (hypothetical accident conditions into the design where maximum damage is expected on the impact limiters due to the rotation trunnions.
The team dispositioned the violation using the traditional enforcement process in section 2.3 of the NRC Enforcement Policy. The team determined that the violation was of more-than-minor safety significance in accordance with Inspection Manual Chapter (IMC) 0617, Vendor and Quality Assurance Implementation Inspection Reports, Appendix E, Minor Examples of Vendor and QA Implementation Findings, Example 4a, because the design required reevaluation and a design change to meet regulatory requirements. The team characterized the violation as a Severity Level IV violation in accordance with the NRCs Enforcement Policy, section 6.8. NAC identified this issue and had entered it into its CAP under FR 23020. Because this violation was a Severity Level IV violation, was entered into NACs CAP, and the issue was not repetitive or willful, this violation was treated as a Non-cited Violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy. (710018/202520101)
The team noted that no MAGNATRAN packagings have been fabricated to date so there is no current safety concern regarding package transportation activities by licensees.
NAC also performed an extent of condition review and found that this issue does not affect NACs other transportation packaging designs. NAC plans to submit a design change in a future license amendment to the NRC to resolve this issue.
1.6.3 Conclusions The team concluded that overall, NAC is effectively implemented its nonconformance control program and CAP and had adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements. A CoC holder identified violation was documented for failure to ensure that all applicable regulatory requirements were met for design of the MAGNATRAN packaging.
1.7 Personnel Training and Certifications 1.7.1 Inspection Scope The team reviewed selected records and procedures and interviewed selected personnel to verify that individuals performing activities affecting quality are properly trained and qualified, and to verify that management and QA staff are cognizant and provide appropriate oversight.
The team reviewed selected records and procedures, interviewed personnel, and discussed the fabrication common books and maintenance activities affecting the safety aspects of the packaging to verify that NAC provided oversight and had trained and qualified individuals performing activities affecting quality for the fabrication of the OPTIMUS-H and maintenance activities for the NAC-LWT. The team also reviewed a sample of indoctrination and training records of engineering personnel.
1.7.2 Observation and Findings The team found for the sample of NAC staff members records reviewed, each had completed the required QA indoctrination and training and attained the applicable qualifications to perform their duties.
No findings of significance were identified.
1.7.3 Conclusions The team concluded that NAC had trained and qualified individuals performing activities affecting quality and that NAC management provided appropriate oversight of quality related activities, as applicable.
1.8 Audit Program 1.8.1 Inspection Scope The team reviewed selected records and interviewed personnel to verify that NAC effectively implemented an internal audit program in accordance with the NRC-approved QAP and the requirements of 10 CFR Part 71. Specifically, the team reviewed NACs approved procedure QP 182, "Audits, Surveys and Corrective Action, revision 11.
The team reviewed selected internal audits since the last NRC inspection of NAC corporate in 2023 to determine if they were performed in accordance with QP 182, if NAC identified deficiencies, and whether NAC addressed these deficiencies within their CAP. The team also reviewed a selection of internal audit schedules to determine if all areas of the QAP were planned to be audited each year as required.
1.8.2 Observation and Findings For the 2023 and 2024 internal audits reviewed, the team assessed that the audits were adequately performed per QP 182, comprehensive in nature, and covered a representative sample of NACs activities in the area being audited.
No findings of significance were identified.
1.8.3 Conclusions The team concluded that NAC had an adequate internal audit program in place to schedule, evaluate, and document the results. The team determined that NAC appropriately identified issues and documented them in the CAP as required.
2.0 Entrance and Exit Meeting On January 14, 2025, the NRC inspection team discussed the scope of the inspection during an entrance meeting with NAC staff. On January 16, 2025, the NRC inspection team discussed the results and observations during an exit meeting with NAC staff.
ATTACHMENT
1. ENTRANCE/EXIT MEETING ATTENDEES AND INDIVIDUALS INTERVIEWED
Name Title Affiliation Entrance Exit Jeremy Tapp Inspection Team Leader NRC X
X Marlone Davis Inspector NRC X
X Raju Patel Inspector NRC X
X Kent Cole President and CEO NAC X
X Joyce Hamman VP, Quality NAC X
X George Carver VP, Engineering and Support Services NAC X
X Mike McMahon VP, Transportation and Strategic Projects NAC X
X Mike Valenzano Director of Transportation Projects NAC X
X Heath Baldner Director, Licensing NAC X
X David Jensen QA Manager NAC X
X Marc Griswold Manager, Applied Mechanics Analysis NAC X
Sahar Torabzadeh QC Manager NAC X
X Calvin Barnett QC Manager NAC X
X James Smith Transportation Project Engineer NAC X
X Dylan Ward Transportation Project Engineer NAC X
X Jimmy Toliuszis Transportation Project Engineer NAC X
X David Oliver Transportation Project Engineer NAC X
X Kelly Sicafoose Technical Editor NAC X
Chris Delance Administrative Assistant NAC X
Bianca Barner Document Control (DCRM)
NAC X
X
2. INSPECTION PROCEDURES USED
IP 86001 Design, Fabrication, Testing, and Maintenance of Transportation Packagings NUREG/CR6314 Quality Assurance Inspections for Shipping and Storage Containers Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material
3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Item Number Status Type Description 710018/202520101 Opened and Closed NCV MAGNATRAN Side Drop Evaluation
4. LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CAR Corrective Action Report CGD Commercial Grade Dedication CoC Certificate of Compliance DCR Design Change Request DCR(L)
Design Change Request Licensing FR Finding Report IMC Inspection Manual Chapter IP Inspection Procedure ITS Important-toSafety ITS-A Important-to-Safety Category A NAC NAC International, Inc.
NCR Nonconformance Report NCV Non-cited Violation NIAC Nuclear Industry Assessment Corporation NRC U.S. Nuclear Regulatory Commission PDR Public Document Room PO Purchase Order QA Quality Assurance QAP Quality Assurance Program QC Quality Control QP Quality Procedure QVL Qualified Vendor List SAR Safety Analysis Report
5.
PARTIAL LIST OF
DOCUMENTS REVIEWED
Corrective Action Reports
CAR 2003, dated 11/2/2020
CAR 2104, dated 7/23/2021
CAR 2204, dated 9/16/2022
Design Calculations:
650077002000, NRU/NRX Basket and Spacer Assemblies Structural Evaluation, for
NAC-LWT AECL NRU/NRX Fuel Transport Project, revision 3
Appendix F, of 650077002000, revision 2, Lifting Evaluation of Fuel Caddy and Grapple
Assembly, dated 11/23/2015
Appendix G, of 650077002000, revision 2, Load Test Evaluation for Caddy Assembly,
dated 1/25/2016
232020, PWR High Burnup Fuel Rod 30-ft Side Drop and Fatigue Evaluation for NAC-
STC, revision 1
Calculation EA7902519, PWR Fuel Rod Evaluation for the UMS Storage Tip-Over
Accident, revision 0
EA7902520, UMS BWR Fuel Assembly Structural Evaluation, revision 1
EA7902524, Fuel Rod Evaluation for the UMS Transport Cask 30-ft Side Drop Accident,
revision 0
711602139, PWR and BWR Fuel Assembly Fatigue Evaluation for MAGNATRAN,
revision 1
Design Change Request (DCR):
DCR(L) No.71160001-6 A, Assembly, Transport Cask, MAGNATRAN, Document No.
71160-001, dated 7/6/2024
DCR(L) No. 30067306-0 A, Port Coverplate Assembly, Inner Lid, NAC-STC Cask, dated
10/4/2018
DCR No(L) No. 423807-5 A, Assembly, Port Cover, NAC-STC Cask, dated 6/12/2018
DCR No. 71160002-9 A, Transport Cask Body, MAGNATRAN, - Document No.
71160002, revision 9, dated 8/14/2024
DCR No. 70000.38S-011 A, Volunteer Package Design Specification 70000.38-S-01,
revision 1, dated 1/23/2024
DCR No. 71160059-3B, Lifting Trunnion, Transport Cask, MAGNATRAN, dated 3/1/2024
DCR No. 70000.38.1162 A, Port Cover Assembly, Metal Seal, Volunteer,-70000.38116
design drawing revision 2, dated 3/13/2024
DCR No. 71160002-9 A, Transport Cask Body, MAGNATRAN, dated 8/14/2024
DCR No. 71160001-6 A, Assembly, Transport Cask, MAGNATRAN, dated 7/26/2024
Finding Reports
FR 21004, dated 2/17/2021
FR 21007, dated 5/4/2021
FR 22007, dated 3/30/2022
FR 22008E, dated 5/31/2022
FR 22015, dated 7/11/2022
FR 23008, dated 3/27/2023
FR 23012, dated 8/23/2023
FR 23019, dated 1/2/2024
FR 23020, dated November 2023
FR 24025, dated 12/9/2024
Quality Category:
Document No. 315Q-03, Quality Category Assessment of the LWT Transportation
Packaging Internals, revision 2
Document No. 315Q-02, Quality Category Assessment of the NAC Legal Weight Truck
Cask, revision 18
Document No. Q423306-A, Quality Category Assessment of the Port Coverplate
Assembly, Inner Lid NAC-STC Cask, revision 3
Document No. Q423303-A, Quality Category Assessment of the Lid Assembly-Inner,
NAC-STC Cask, revision 18
Document No. 70000.14Q-01, Quality Category Assessment for the OPTIMUS
Transportation Packaging, revision 12
Purchase Orders (POs)
PO# 845871 to ALLTEK Seal & Packaging for commercial Parker ORings for NAC-STC
cask spares, dated 6/29/2018
PO# 846801 to Instrument Calibration Solutions, for calibration services dated 7/10/2024
PO# 846439 to TECHNETICS, Group, for Alt. B Port Cover Metallic ORings dated
6/14/2022
PO# 846017 c/o 2 to Petersen Inc., for NAC-STC canister lid seals spares, dated
9/22/2020
PO# 846629, c/o 7, to Joseph Oats Corporation, for OPTIMUS-L GEO Basket Assembly,
dated 12/4/2024
PO# 845912 to Applied Technical Services (ATS) for testing services of ORings for CGD,
dated 10/10/2018
PO# 846808, to Vacuum Technology Inc., for calibration services of vacuum gauges, dated
7/8/2024
PO# 846832 to ATS for calibration services of measuring and test equipment dated
10/6/2024
Receipt Inspection Checklist (RIC):
RIC for PO# 846439 dated 2/27/2023 for metallic ORings from TECHNETICS Group
RIC for PO# 846808, dated10/7/2024 for calibration service of vacuum transducers from
Vacuum Technology, Inc.
RIC for PO# 846832, dated 12/2/2024, for Project# 99100 - calibration services of Mitutoyo
calipers by ATS
RIC for PO# 846007, dated 10/1/2019, for Project# 5005300-002, Parker ORings, from
United Seal & Rubber Corporation
Supplier Documentation Review Report (SDRR) 846015SDRR03 dated 3/13/2020 for
NAC-STC ORings test reports from ATS
SDDR 845912SDDR001, dated 5/1/2019, for NAC-STC cask ORings material testing
from ATS
SDDR 846017FDP-TRIGA, revision 3, dated 11/20/2020, for TRIGA Fuel Basket
Assemblies Damaged Fuel Cans, from Petersen, Inc.
Supplier Audit/Surveillance Reports:
NIAC Audit Report #31503, of Joseph Oats Corporation dated 7/26/2024
NIAC Assessment Evaluation form of NIAC Audit Report # 28012 of ENPRO Holdings, Inc.-
TECHNETICS Group Columbia dated 6/29/2023
NIAC Assessment Evaluation form of NIAC Audit Report 31507 of Peterson Inc., dated
9/16/2024
Surveillance Report #19S-12, of ATS dated 3/13/2019
Surveillance Report #24S-37 of Joseph Oats Corporation dated 11/2225/2024
Miscellaneous:
Qualified Vendor List, QVL-12/10/2024
Document No. 30067CGCCP001, Commercial Grade Dedication and Test Plan
Characteristics For CGN-URC NAC CASK O-Rings, revision 0
Standard Practice No. SP222, Analysis Guideline-Methods to Ensure Accurate Modeling
and Durable Interpretation of Results, revision 0
Nonconformance Reports
NCR 18001, dated 3/12/2018
NCR 18013, dated 7/2/2018
NCR 18025, dated 8/15/2018
NCR 19011, dated 6/26/2019
NCR 20016, dated 9/22/2020
NCR 21015, dated 6/16/2021
NCR 22033, dated 10/27/2022
NCR 23004, dated 1/31/2023