IR 07200010/2022201
| ML22312A543 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 11/09/2022 |
| From: | Rivera-Verona A NRC/NMSS/DFM/IOB |
| To: | Mckeown M Northern States Power Co, Xcel Energy |
| References | |
| IR 2022201 | |
| Download: ML22312A543 (1) | |
Text
November 9, 2022
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 72-00010/2022-201
Dear Mark McKeown:
From August 22-25, 2022, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection of licensee Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy (Xcel) and of dry storage cask (DSC) designer TN Americas LLC (TN), at the SeAH Besteel Corporation (SBC) facility in Gunsan-si, Jeollabuk-do, Republic of South Korea. TN is under contract with Xcel to design, fabricate, test, and deliver eight (8) TN-40HT spent fuel high burnup, DSCs for the interim storage of spent nuclear fuel at the Prairie Island Nuclear Generating Station (PINGS) Independent Spent Fuel Storage Installation (ISFSI) facility. This was the first NRC inspection performed at SBC in the Republic of South Korea.
With respect to SBC fabrication of the TN-40HT Cask Systems, the inspectors assessed Xcels compliance to Title 10 of the Code of Federal Regulations (10 CFR) Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor Related Greater than Class C Waste; 10 CFR Part 21, Reporting of Defects and Noncompliance; conditions of the PING site-specific License No. SNM-2506, Amendment No. 11; and PINGS ISFSI, safety analysis report (SAR), revision 20 dated October 2021. The inspection was performance based in that the inspectors observed Xcel and TNs implementation of quality assurance (QA) program requirements, as approved by the NRC, that apply to design, purchase, fabrication, assembly, inspection, and testing of the TN-40HT spent fuel high burnup DSC components that are important to safety (ITS). The inspectors observed shop activities, reviewed selected procedures, records, and interviewed specific personnel.
Additionally, the inspectors discussed the preliminary results of this inspection on August 25, 2022, and a final inspection exit with Xcel was conducted on September 26, 2022. The enclosed report presents the results of this inspection.
Based on the results of this inspection, the NRC staff determined that overall, except for one Severity Level IV Noncited violation (NCV) of a NRC requirement, the quality of fabrication, quality controls, and QA oversight were adequate. With respect to the NCV, the NRC inspectors found that implementation of TNs program failed to meet a certain NRC requirement contractually imposed on SBC. The NRC inspectors noted an inadequate SBC corrective action procedure in that SBC failed to adequately prescribe guidance on how to perform a root cause or any other type of causal analysis associated with the identification of significant conditions adverse to quality. The NRC is treating this violation as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The NRCs public website includes the current versions of both the Enforcement Policy and Manual for your reference. The specific violation and references to the pertinent requirements are identified in the enclosure to this letter.
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 20555-0001, with copies to: (1) the Director, Office of Nuclear Materials Safety and Safeguards; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Aida Rivera-Varona, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
Docket No.: 072-10
Enclosure:
NRC Inspection Report No.
07200010/2022-201
Aida E. Rivera-Varona Digitally signed by Aida E.
Rivera-Varona Date: 2022.11.09 10:07:25 -05'00'
ML22312A543 *via email
OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME ELove WWheatley*
ARivera-Varona*
DATE 11//07/2022 11/07/2022 11/07/2022
U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management
Inspection Report
Docket No.:
7200010
Report No.:
72-00010/2022-201
Licensee:
Northern States Power Company, a Minnesota corporation
(NSPM), incorporated in Minnesota as a wholly owned
subsidiary of Xcel Energy Inc.
Facility:
SeAH Besteel Corporation
Location:
Gunsan-si, Jeollabuk-do, Republic of South Korea
Inspection Dates: August 22-25, 2022
Inspectors:
Earl Love, Senior Transportation and Storage Safety
Inspector, Team Leader
Marlone Davis, Senior Transportation and Storage Safety Inspector
Jeremy Tapp, Transportation and Storage Safety Inspector
Approved by:
Aida Rivera-Varona, Chief
Inspection and Oversight Branch
Division of Fuel Management
Office of Nuclear Material Safety
and Safeguards
EXECUTIVE SUMMARY
Xcel Energy
NRC Inspection Report 72-00010/2022-201
The original Prairie Island Nuclear Generating Station (PINGS), site-specific, Independent Spent Fuel
Storage Installation (ISFSI), Special Nuclear Material (SNM) License No. 2506, specified the use of TN
Americas, LLC (TN) TN-40 cask design, which the NRC certified for transport on June 10, 2011. On
August 22, 2022, to August 25, 2022, a U.S. Nuclear Regulatory Commission (NRC) team of inspectors
performed an announced inspection of licensee Northern States Power Company, a Minnesota
corporation, d/b/a Xcel Energy (Xcel) and dry storage cask (DSC) designer TN, at the SeAH Besteel
Corporation (SBC) facility in Gunsan-si, Jeollabuk-do, Republic of South Korea. The inspectors
continued the inspection activities with an in-office review and held an exit meeting on September 26,
2022. The purpose of the inspection was to observed Xcel and TNs conduct and implementation of
quality assurance (QA) requirements that apply to design, purchase, fabrication, assembly, inspection,
and testing of the TN-40HT spent fuel high burnup DSC components that are important to safety (ITS)
for compliance to Title 10 of the Code of Federal Regulations (10 CFR) Part 72; 10 CFR Part 21,
Reporting of Defects and Noncompliance; PINGS License No. SNM-2506, Amendment No.11: and
the PINGS ISFSI safety analysis report (SAR), Revision 20 dated October 2021.
Representatives from the Korean Institute of Nuclear Safety (KINS) observed the inspection. This
observation fostered sharing of bilateral information exchanges on spent nuclear fuel safety regulation
and for the NRC to aid KINS in developing or strengthening their regulatory spent fuel management
program to include oversight of vendors.
The results of this inspection are summarized below.
10 CFR Part 21 Program
The inspectors concluded that SBCs Part 21 process and applicable procedures conformed to the
regulatory requirements of Part 21. The inspectors determined that SBCs personnel were familiar with
the reporting requirements of 10 CFR Part 21; and SBC complied with 10 CFR 21.6, "Posting
requirements." No findings of significance were identified.
Design Control
The inspectors concluded that SBCs design control processes and practices were consistent with
72.146 Design Control, of Subpart G to 10 CFR Part 72, and American Society of Mechanical
Engineers (ASME),Section III, Subsection NB code requirements. The inspectors concluded that
SBCs implementation of these processes and practices provided appropriate design controls. The
inspectors determined, for the items selected for review, that TNs fabrication specifications were
consistent with the design commitments and requirements documented in the SAR, SNM-2506, and
technical specifications. No findings of significance were identified.
Procurement Control / Commercial-Grade Dedication
The inspectors concluded that SBC's processes that addressed procurement, including traceability and
receipt inspection of material was adequate. SBC properly implemented their QA program requirements
and Xcel and TN provided adequate oversight of these activities. Overall, procurement specifications
for materials, fabrication, inspection, and services performed at SBC met design commitments and
requirements contained in the TN-40HT PING SAR and SNM-2506. No findings of significance were
identified.
The inspectors concluded that TNs and SBCs commercial grade dedication (CGD) procedures were
consistent with industry guidance. The inspectors concluded that TN and SBC had adequate
engineering involvement in its dedication process and conducted its CGD activities consistent with its
procedures. No findings of significance were identified.
Control of Special Processes / Fabrication / Assembly / Testing
The inspectors concluded that SBC had established an appropriate means to control fabrication
activities and special processes such as welding, nondestructive examination (NDE), and heat
treatment for applicable TN-40HT components. The inspectors concluded that the SBC QA manual and
associated fabrication and special process procedures and activities were being adequately
implemented by qualified personnel, using qualified equipment and processes. No findings of
significance were identified.
The inspectors examined fabrication specifications, quality plans, engineering drawings, work control
procedures, and travelers. The inspectors confirmed that the SBC manufacturing and testing production
activities were adequate. The inspectors noted shop travelers incorporated witness and hold points for
Xcel, TN, and SBC quality control (QC) inspectors, and identified the applicable drawings, material
specifications, work instructions, and procedures applicable to the manufacturing activity being
performed. Overall, the inspectors determined that fabrication activities were accomplished in
accordance with specified requirements and conducted in the correct sequence. No findings of
significance were identified.
Control of Measuring and Test Equipment
The inspectors concluded that SBC had established appropriate and effective means to control
measuring and test equipment (M&TE). No findings of significance were identified.
Corrective Action and Nonconformance Reports
The inspectors reviewed selected records and interviewed personnel to verify that SBC effectively
implemented a nonconformance reporting (NCR) program in accordance with the regulatory
requirements 72.170 of 10 CFR Part 72. In addition, the inspectors concluded that SBC resolved
conditions adverse to quality identified in corrective action reports (CARs) in a timely manner. The
inspectors concluded that SBC had procedures and controls in place for identifying and writing NCRs
and CARs, resolving fabrication deficiencies, documenting corrective action(s) taken, documenting
actions taken to prevent recurrence, performing CAR closure verification, and tracking CARs to closure.
However, the inspectors identified one Severity Level IV violation of 10 CFR 72.150, Instructions,
procedures, and drawings for SBCs failure to provide sufficient guidance to perform a root cause
analysis (RCA) required by procedure to determine the corrective action necessary to preclude
repetition. Specifically, no RCA process is documented in SB-D-7255A or another quality procedure in
the SBC QA program. Except for the noted Noncited violation (NCV), the inspectors determined that
SBCs corrective action program was consistent with the regulatory requirements of 72.172 Corrective
Action, of Subpart G to 10 CFR Part 72.
Audits
Regarding QA activities, the inspectors concluded that SBC has been audited by the Xcel and TN and
that audits and inspection findings were appropriately handled with corrective actions implemented in a
time frame commensurate with their safety significance. In addition, the inspectors concluded that
supervision and QA personnel perform appropriate oversight during fabrication activities. No findings of
significance were identified.
REPORT DETAILS
a. Inspection Scope
The inspectors reviewed program controls for 10 CFR Part 21, specifically, SB-D-7362A, "Part
21 Procedure," to evaluate if provisions were in place for evaluating deviations that could cause
a substantial safety hazard and complete the required notification in a timely manner. The
inspectors also reviewed SBCs posting of Part 21 requirements in accordance with 10 CFR 21.6, Posting requirements.
b. Observation and Findings
The inspectors assessed that SBC has provisions in place for evaluating deviations and
reporting defects, as required by 10 CFR Part 21. The inspectors noted that SBC did not have
any Part 21 reports for the TN-40HT project. The inspectors also noted that SBC posted Part 21
requirements throughout their office and fabrication facility. No findings of significance were
identified.
c. Conclusions
The inspectors concluded that SBC had adequate procedures in place to ensure that 10 CFR Part 21 was implemented as required, including postings throughout the facility.
2. Design Control
a. Scope
The inspectors reviewed project specific design documents of the TN-40HT DSC system,
fabricated by SBC and determined that construction was in accordance with the commitments
and requirements specified in the PINGS SAR, the NRCs corresponding safety evaluation
report, 10 CFR Part 72 and Xcels SNM-2506. The inspectors reviewed TNs procurement
fabrication specification, design drawings, and fabrication drawings to verify that critical
dimensions and materials, fabrication, inspection, testing, documentation, and quality assurance
for TN-40HT cask were consistent with Xcels licensing drawings. The inspectors reviewed TN
and SBC certificates of conformance and the SBCs construction final documentation package
of PINGS cask serial number TN-40HT-51, along with Xcels 72.48 applicability determinations
and/or screenings of deviations from TNs design drawings as documented by TN NCRs. The
inspectors verified implementation of TNs project specific procedures and observed various
shop activities (e.g., special processes, testing, and NDE examinations). The following is a
partial list of design documents reviewed:
- TN Specification No. TN-40HT-0105, Revision 7, Project Specification for the TN-40HT
Spent Fuel High Burnup Casks and Baskets
- TN Project Plan No. 1042A, Revision 1, Scope and Technical Requirements for the
Engineering, Fabrication and Delivery of TN-40HT Casks (including appendix A,
Technical Specification for Engineering, Supply and Services)
- Xcel Contract Agreement No. 79442, dated September 2019 (including Amendment No.
4 Addendum dated April 2022)
- PINGS Site Specific Safety Analysis Report, Revision 18 and Drawing 10428-4036,
Revision 6, TN-40HT High Burnup Dry Storage Cask Configuration Drawing
- NRC Renewed License SNM-2506, Amendment No. 11, dated October 29, 2020, issued
to Northern States Power Company, a Minnesota corporation (NSPM), Docket 72-10
- NRC Safety Evaluation Report, Materials License SNM-2506, Amendment No. 11
- TN Certificate of Conformance, Cask Serial Number TN-40HT-51, dated May 26, 2022
(including a list of TN design Drawings and Procurement Specifications)
- Xcel 72.48 Applicability Determination and Prescreening No. 8315, TN-40HT Lid Seal
inspection hole misalignment
- Xcel 72.48 Applicability Determination and Prescreening No. 8663 and Screening No.
5741, TN-40HT Overpressure Ports overlay over-thickness
- SBC Certificate of Conformance No. SBC-CoC-220509-01, dated May 09, 2022, Cask
ID: TN-40HT-51
b. Observation and Findings
All selected review areas of TN specification and project related documents along with SBC
manufacturing drawings were confirmed to conform to the requirements of ASME code, 2004
Edition, including 2006 Addenda and Xcels contract agreement. The inspectors found that TN
and Xcels document review and design control developed satisfactorily detailed manufacturing
drawings appropriately signed off and approved from corresponding specifications and design
drawings. The inspectors also evaluated SBCs process for distributing controlled fabrication
drawings and procedures, their locations, and retrieval to verify that old or uncontrolled versions
were not being used.
c. Conclusions
The inspectors concluded that TN and Xcels design control processes and practices
were consistent with 72.146, Design Control, of Subpart G to 10 CFR Part 72, and
ASME code requirements. The inspectors determined, for the items selected for
review, that fabrication specifications were consistent with the design commitments
and requirements and that TN and Xcel implementation of these processes and
practices provided appropriate design controls. No findings of significance were
identified.
3. Procurement Control/Commercial Grade Dedication
a. Scope
The inspectors reviewed SBC's processes that addressed procurement, including traceability
and receipt inspection of material, to verify SBC properly implemented their QA program and
Xcel and TN provided adequate QA oversight of these activities. The inspectors reviewed
selected drawings and records and interviewed selected personnel to verify that the
procurement specifications for materials, fabrication, inspection, and services performed at SBC
met design commitments and requirements contained in the SAR and SNM-2506 of the TN-
40HT at PINGS. The inspectors reviewed the procurement documents specific to the fabrication
of the TN-40HT at SBC including purchase orders (PO) and receipt inspections. The inspectors
reviewed the following implementing procedures and procurement documents:
- SB-D-6152A, Procurement Document Control Procedure, Revision 1
SB-D-6153A, Vendor Qualifications
SB-D-7151A, Receiving Inspection, Revision 2
SB-D-8155A, Designation, Dedication and Control of Commercial Grade Items,
Revision 4
XCL-1901-ASL-001, Approved Suppliers List, Revision 21
The inspectors verified that SBC used Xcel graded approach for identifying ITS components
and applied this graded quality level to component and material procurement documents, which
SBC used to procure items from contractors. The inspectors reviewed procurement documents
related to the following TN-40HT items:
- Lid outer plate (ASME SA350)
Metal Seals
Lid Bolts (ASME SA540)
Inner Shell (ASME SA203)
Welding Material (SFA 5.23/F7P10-ENi3-Ni3 Wire and Flux OP121TT)
TN-40HT Cask Basket Assembly, S/N 4 (manufactured by Hitachi Zosen Corporation,
Japan)
b. Observations and Findings
Overall, the inspectors concluded that SBC had adequate control of the procurement process
for the ITS components selected and reviewed. The inspectors determined that SBC procured
ITS components consistent with design requirements and approved QA implementing
procedures. SBCs material traceability, procurement, and receipt inspection controls were
adequate. The inspectors determined that the POs were adequate and specified the applicable
criteria and requirements including Part 21. The material ordered and received at SBC met the
design requirements, the critical characteristics for dedicated material. Additionally, SBC verified
and maintained the traceability throughout the procurement and receipt process. The inspectors
determined that SBC purchased and applied controls over sub-contractors and vendors
currently on the SBCs approved suppliers list.
c. Conclusions
Overall, the inspectors concluded that SBC had adequate control of the procurement process
for the ITS components selected and reviewed. The inspectors concluded that TN and SBC
implementation of CGD procedures were consistent with industry guidance. The inspectors
concluded that TN had adequate engineering involvement in its dedication process and
conducted CGI dedication activities consistent with its procedures. No findings of significance
were identified.
4. Control of Special Processes / Fabrication / Assembly / Testing
a. Scope
The inspectors reviewed SBCs implementing policies, quality plans, drawings, travelers and
work control procedures for fabrication, welding, NDE, and heat treating. Specifically, for
welding activities, the inspectors observed various shell welding processes (e.g., gas tungsten
arc and submerged arc welding), reviewed shop travelers, weld procedure specifications
(WPS), supporting procedure qualification records (PQR), weld data sheets (WDS), welder
qualifications, and the calibration certificates of M&TE. For NDE, the inspectors observed, and
reviewed examination reports associated with magnetic particle testing (MT), visual testing (VT),
bubble leak testing (BLT), and radiograph testing (RT). The inspectors reviewed Level II and III
inspector and welder qualifications, and the calibration certificates of M&TE. In addition, the
inspectors reviewed the SBC process for welding material control, interviewed personnel at the
welding material station, and reviewed applicable records used for material control process
implementation, including the welding material control log and welding material issue cards.
The following is a listing of fabrication and special processes observed and
documents reviewed:
- Traveler No. XCL-1901-TRV-B03-03, Revision 3, Cask s/ns 52 and 54, Inner Shell
Welding, various weld joints and associated WDSs
associated supporting PQR No. SB-PQR-GA-010 dated May 05, 2020
- Reports of MT examinations Nos. XCL-1901-MTR-366 and 367, dated August 23, 2022,
various weld joints of Upper/Lower Outer Shell Rings and Plates
- XCL-1901-NDE-003, Revision 10, Magnetic Partical Examination
- Reports of VT examination Nos. XCL-1901-VTR-291 and 290, dated August 23, 2022,
various weld joints of Upper/Lower Outer Shell Rings and Plates and removal of
temporary attachments
- XCL-1901-NDE-005, Revision 7, Visual Examination
- BL Examination, Report No. XCL-1901-BLTR-004, dated August 24, 2022, Cask Body
Assembly - Outer Shell welds
- XCL-1901-BLP-001, Revision 5, Bubble Leak Test
- Traveler No. XCL-1901-TRV-B01-10, Revision 1, Cask s/n 49, Sequence A030, BLT
- RT examination, Report No. XCL-1901-RTR-027, Revision 2, dated July 13, 2022, Inner
Shell welds after post weld heat treatment and machining
- XCL-1901-NDE-001, Revision 20, Radiograph Examination
- XCL-1901-HTP-001, Revision 8, Heat Treatment Procedure
- XCL-1901-HTI-202, Revision 2, Heat Treatment Instruction (Cylinder Shell + Bottom
Inner Plate)
- XCL-1901-RTP-001, Revision 9, Random Testing Procedure
b. Observation and Findings
The inspectors confirmed that the SBC manufacturing process used shop travelers to control
shop production activities. The shop travelers incorporated witness and hold points for TN, Xcel
and SBC QC inspectors, and identified the applicable drawings, material specifications, work
instructions, and procedures applicable to the manufacturing activity being performed.
The inspectors found that the shop travelers assured that the fabrication activities were
accomplished in accordance with specified requirements and conducted in the correct
sequence.
The inspectors determined that SBCs welding on ASME code materials and fabrication of
ASME code items was performed by qualified welders and welding operators in accordance
with approved welding procedure specifications. The inspectors noted that SBCs welding
procedure specifications, welders, and welding operators were qualified in accordance with the
requirements of ASME Section III and Section IX, Welding and Brazing Qualifications.
Regarding NDE, the inspectors noted that NDE examiners were qualified as Level III and II in
nondestructive testing methods in accordance with the American Society for Nondestructive
Testing (ASNT) recommended practice No. SNT-TC-1A. The inspectors reviewed a list of SBCs
certified NDE examiners inspectors and reviewed a sample of Level II and III
certification/training records.
The inspector noted, personnel performing welding, QC inspections (e.g., receiving, final, in-
process, pressure testing), and NDE (e.g., helium leak, liquid penetrant, MP, RT, VT) activities
were qualified and were maintaining their qualification in accordance with applicable quality
procedure XCL-1901-NDE-007, Revision 2, NDE Personnel Qualification and Certification
Procedure.
c. Conclusions
The inspectors concluded that SBC had established an appropriate means to control fabrication
and special processes such as welding, NDE, and heat treatment for fabrication assembly and
testing of TN-40HT cask systems. The inspectors concluded that TN-40HT components were
being fabricated and the casks were being assembled and tested per approved drawings and
QA implementing procedures as well as TNs fabrication specification. The inspectors evaluated
SBC's control of the fabrication process through observations, examinations of records, and
personnel interviews in the areas of fabrication and assembly, test and inspection, and tools and
equipment. Overall, TN and SBC fabrication and special process procedures and activities were
being adequately implemented by qualified personnel, using qualified equipment and
processes. No findings of significance were identified.
5. Control of Measuring and Test Equipment
a. Scope
The inspectors reviewed selected M&TE used in the shop, records, and quality procedure SB-
D-7353A, Calibration Control Procedure, Revision 0 to verify that equipment used in activities
affecting quality were properly controlled and calibrated. The inspectors compared a sampling of
M&TE in current use for fabrication activities to determine overall compliance to procedural
requirements.
b. Observation and Findings
The inspectors reviewed calibration records, interviewed calibration personnel, and toured areas
in the shop for storage and calibration of M&TE to verify compliance to the quality procedure
requirements. In addition, the inspectors verified that if the M&TE had been sent offsite for
calibration that the calibration service providers were appropriately qualified.
c. Conclusion
The inspectors concluded that SBC had established an appropriate means for the storage and
calibration of M&TE for the equipment selected and reviewed. The inspectors concluded that
SBC implementation of the storage and calibration procedures were consistent with industry
guidance and that M&TE activities were adequately implemented. No findings of significance
were identified.
6. Corrective Action and Nonconformance Reports
a. Scope
The inspectors determined whether adequate corrective actions for identified issues related to
quality have been implemented in a time frame commensurate with their significance, and
whether NCRs documenting deficiencies have been initiated and adequately resolved.
The inspectors reviewed selected records and interviewed personnel to verify that SBC
effectively implemented a corrective action program in accordance with the requirements of 10 CFR Part 72 and SBCs corrective action procedure, SB-D-7255A, Corrective Action
Procedure, revision 4. The inspectors reviewed a selection of CARs written since the start of
fabrication activities at SBC for the TN-40HT cask and focused the review on CARs that were
designated as significant condition adverse to quality (SCAQ).
In addition, the inspectors reviewed selected records and interviewed personnel to verify that
SBC effectively implemented a nonconformance control program in accordance with the
requirements of 10 CFR Part 72 and approved QA procedures. Specifically, the inspectors
reviewed SB-D-7355A, Nonconformance Control Procedure, revision 5. The inspectors
reviewed a selection of NCRs written since the start of fabrication activities at SBC for the TN-
40HT DSC to verify that the NCRs were identifiable, traceable, and the disposition of the
nonconformance was adequate. The inspectors focused on issues involving ITS structures,
systems, and components and NCRs with a disposition of use-as-is (UAI) or repair, which
require an engineering analysis and potentially a 10 CFR 72.48 evaluation as well. The
inspectors reviewed these NCRs to evaluate if the disposition was appropriate, adequately
performed as necessary, and properly closed out in accordance with SB-D-7355A.
The inspectors also reviewed a selection of TN supplier nonconformance reports (SNCRs)
written because of issues identified by SBC or TN during fabrication of the TN-40HT cask at
SBC. The inspectors verified that TN SNCRs were written for those NCRs dispositioned as UAI
or repair by SBC. The inspectors also verified that for the TN SNCRs reviewed, the UAI or
repair disposition was adequately evaluated.
b. Observations and Findings
The inspectors assessed that SBC generally resolved the issues identified in the CARs
reviewed in a technically sound and, as resources allowed, timely manner. The inspectors also
assessed that SBC had procedures and controls in place for identifying and writing CARs,
documenting corrective action(s) taken, documenting actions taken to prevent recurrence,
performing CAR closure verification, and tracking CARs to closure. However, the inspectors
identified that SBC did not provide adequate guidance to perform RCAs in its quality procedures
as part of the corrective action program.
During the review of CARs sampled during the inspection, the inspectors identified that for some
SCAQ conditions reviewed, the root cause identified by SBC was not adequate. For example,
CAR No. XCL-1901-CAR-065, revision 1, was written for issues identified regarding an
inadequate Management Review Report that included numerous deficiencies to the QA
program requirements. This included failure to perform trending evaluations and an overall QA
program assessment. The root cause identified in the CAR was improper understanding of the
QA requirements, however, this analysis failed to go further to identify the root cause and
determine why SBC personnel had an improper understanding of the QA requirements.
The inspectors reviewed the applicable corrective action quality procedure and identified that
SBC did not provide adequate guidance to perform RCA. During the review of quality procedure
SB-D-7255A, the inspectors noted that Step 5.3.3 requires, in part, the root cause to be
determined for SCAQ. The inspectors reviewed SB-D-7255A and the QA program in general but
did not identify any guidance in the quality procedures on how to perform a root cause or any
other type of causal analysis. The inspectors determined this was a violation of NRC
requirements. Specifically, 10 CFR 72.150, Instructions, procedures, and drawings states, in
part, that the licensee shall prescribe activities affecting quality by documented instructions,
procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above, as of August 25, 2022, SBCs corrective action procedure SB-D-7255A
did not provide sufficient guidance to perform an RCA required by Step 5.3.3 to determine the
corrective action necessary to preclude repetition. Specifically, no RCA process is documented
in SB-D-7255A or another quality procedure in the SBC QA program.
The inspectors dispositioned the violation using the traditional enforcement process in Section
2.3 of the Enforcement Policy. The inspectors determined 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 16.c; because SBC failed to adequately perform
adequate RCA as required. The inspectors characterized the violation as a Severity Level IV
violation in accordance with the NRCs Enforcement Policy, Section 6.5. TN entered the issue
into its CAP under 2022-179. Because this violation was of low safety significance and was
entered into TNs CAP, the issue was not repetitive or willful, this is being treated as an NCV,
consistent with Section 2.3.2.a of the Enforcement Policy. (72-00010/2022-201-01)
c. Conclusions
Overall, the inspectors determined that SBC had an adequate CAP in place to resolve identified
issues, and, in general, completed corrective actions for identified deficiencies in a technically
sound and timely manner. The inspectors identified one violation of NRC requirements
concerning the failure by SBC to have an adequate procedure for the conduct of a cause
analysis to ensure SCAQ receive the necessary corrective actions to preclude repetition. In
addition, the inspectors concluded that SBC and TN effectively implemented their
nonconformance control programs and SBC has adequate procedures in place to ensure
compliance with the applicable regulations and QA program requirements.
7. Audits
a. Scope
The inspectors reviewed the Xcel and TNs audits of the SBC to determine if Xcel and TN
scheduled, planned, and performed the audits and surveillances in accordance with their QA
programs and implementing procedures. The inspectors reviewed audits that Xcel performed on
TN and the audits that TN performed on SBC. Additionally, the inspectors reviewed SBCs
internal audit program to determine if SBC scheduled, planned, and performed audits and
surveillances in accordance with their quality management system and quality implementing
procedures. The inspectors reviewed the following documents:
- SMS-QMS-1004, SeAH Besteel Quality Assurance Manual, Revision 6
SB-D-7253A, Audit Personnel Qualification Procedure, Revision 0
SB-D-7254A, Auditing and Commercial Grade Survey Procedure, Revision 3.
The inspectors selected a sample of audits and evaluations from the initial fabrication to the
present. This included a sample of the lead auditor certifications and qualifications. The
inspectors particularly focused on area identified in Xcel and TN audits to verify SBC resolved
audit findings. The inspectors also reviewed the audit results to determine if SBC identified
deficiencies and addressed these deficiencies within their corrective action program. The
inspectors evaluated whether Xcel, TN, SBC provided adequate supervision with QC/QA
personnel for appropriate oversight during fabrication activities.
b. Observations and Findings
Overall, the inspectors assessed that for the audits and evaluations sampled that SBC generally
conducted oversight with qualified and certified personnel, scheduled and evaluated applicable
quality elements associated with fabrication activities. The inspectors noted that Xcel and TN
also provided oversight representatives to verify that fabrication activities occurring at SBC were
adequate and performed audits of SBC that identified observations and findings in accordance
with implementing procedures. The inspectors also assessed that SBC appropriately identified
issues and implemented corrective actions in a time frame commensurate with their safety
significance when identified in audits and evaluations.
c. Conclusions
Overall, the inspectors assessed that for the audits and evaluations sampled that SBC generally
conducted oversight with qualified and certified personnel, scheduled and evaluated applicable
quality elements associated with fabrication activities. No findings of significance were identified.
8. Exit Meeting
On August 25, 2022, the inspectors presented the inspection scope and findings during a de-
brief meeting with Mark McKeown, NSPM Director, Nuclear Dry Fuel Storage Projects, Xcel and
other TN and SBC personnel. The inspectors continued the inspection activities with an in-office
review and held an exit meeting on September 26, 2022.
ATTACHMENT
1.
PERSONS CONTACTED Director Nuclear Dry Fuel Storage Projects, Xcel
Yeonoh Lee
SBC General Manager, SBC
Yongjin Kim
Executive Vice President, SBC
Jung Jaehun
Nuclear Business Team Manager, SBC
Santash Pawar
Quality Assurance Engineer, SBC
B. Shamsher
Consultant, SBC
G. Guerra
TN
K. OConnor
TN
M. Lopez Solano
TN
J. Burns
TN
C. Laughlin
TN
The following KINS individuals observed the inspection from August 22-25, 2022:
Jeongken Lee
Senior Researcher, Department of Decommissioning and Research
Sang-eun Han
Principal Researcher, Transport & Accelerator Project Manager,
Radiation Regulation Division, Office of Radiation Safety
GyeongMi Kim
Department of Radiation Protection & Radioactive Waste Safety
2.
INSPECTION PROCEDURES USED
IP 60852, ISFSI COMPONENT FABRICATION BY OUTSIDE FABRICATORS
NUREG-6314, 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
72-0010/2022-201-01
Closed
Inadequate quality procedure for
guidance in conducting an RCA
4.
LIST OF ACRONYMS USED
ASNT
American Society for Nondestructive Testing
American Society of Mechanical Engineers
BLT
Bubble Leak Testing
Corrective Action Report
CFR
Code of Federal Regulations
Dry Storage Cask
Important to Safety
Independent Spent Fuel Storage Installation
IP
Inspection Procedure
KINS
Korean Institute of Nuclear Safety
Measuring & Test Equipment
Magnetic Particle Testing
Nonconformance Report
Noncited Violation
NRC
Nuclear Regulatory Commission
PINGS
Prairie Island Nuclear Generating Station
PO
Purchase Order
Quality Assurance
Quality Control
QAM
Quality Assurance Manual
Root Cause Analysis
Radiograph Testing
Safety Analysis Report
Significant Condition Adverse to Quality
TN
TN Americas, LLC
TS
Technical Specification
UAI
Use-as-Is
Visual Testing
Xcel Northern States Power Company, a Minnesota corporation, d/b/a Xcel Energy