ML110270028
| ML110270028 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, 07201029  |
| Issue date: | 01/26/2011 |
| From: | David Pstrak NRC/NMSS/SFST/LID/RIOB |
| To: | Neider T Transnuclear |
| Love E, NMSS/SFST 301-492-3170 | |
| References | |
| Download: ML110270028 (3) | |
Text
January 26, 2011 EA-10-126 Ms. Tara J. Neider President and CEO Transnuclear, Inc.
7135 Minstrel Way, Suite 300 Columbia, MD 21045
SUBJECT:
TRANSNUCLEAR INC. - NRC INVESTIGATION REPORT NO. 4-2010-071 -
NON-CITED VIOLATION, CERTIFCATE OF COMPLIANCE NO. 72-1029
Dear Ms. Neider:
This refers to the U.S. Nuclear Regulatory Commission (NRC) investigation conducted by the NRC Office of Investigations during September 11, 2009, and May 25, 2010. The purpose of this investigation was to determine if a contractor employee failed to follow procedural requirements for travel speed during welding operations which occurred at Southern California Edisons (SCE) cask fabrication facility. This facility is located on the Mesa Facility near San Onofre Nuclear Generating Station (SONGS) and is under contract to a 10 CFR Part 72 Certificate holder, Transnuclear, Inc. (TN), to perform cask fabrication activities of dry storage canisters (DSCs) to the Standardized Advanced NUHOMS System.
Based on the results of this investigation, the panel concluded that the SCE welder did not deliberately cause the certificate holder to violate 10 CFR 72.150 and did not commit deliberate misconduct pursuant to a violation of a certificate holder procedure according to 10 CFR 72.12(c)(2). This violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The Enforcement Policy is located on the NRCs Web site http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The Division of Spent Fuel Storage and Transportation (SFST) determined that this failure to follow procedure had minimal impact on the overall quality of the weld in that the welds successfully passed the required 100% visual exam on both the inside and outside surfaces of the guide sleeve seams, and therefore this violation is considered to have a very low safety significance. It was also noted that travel speed for this material and application is not an essential variable per the American Society of Mechanical Engineers (ASME),Section IX, Code Requirements of the Gas Tungsten Arc Welding (GTAW) process used, but is rather a user-defined non-essential variable. Further, the slight increase in heat input to an already low heat input value was determined not to cause degradation in the material mechanical properties or corrosion resistance and that the requirement was considered by ASME standards and NRC staff to be a non-essential quality factor. In addition, subsequent to the incident, the certificate holders subcontractor (SCE) stated that the welding procedure was changed to more closely follow engineering standards and that the individual would not have been in violation of the procedures upon implementation. Furthermore, there was no actual safety consequence associated with this failure to follow procedure.
T. Neider In reviewing this issue the staff noted that your actions included: (1) self-identification by your subcontractor during the performance of an internal audit; (2) documentation of the discrepancy on a nonconformance report; and (3) adequate corrective actions taken, including a determination of compliance to the licensing basis documents and contract requirements.
The NRC has concluded that the corrective actions taken have adequately addressed this issue. You are not required to respond to this letter. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this letter, 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, Division of Spent Fuel Storage and Transportation; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response, if you provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
Please contact me if you have any questions at telephone number (301) 492-3299.
Sincerely,
/RA/
David W. Pstrak, Chief Rules, Inspections, and Operations Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket Nos.: 72-1029, 50-361 & 50-362 cc: R. McWey, Southern California Edison (SCE)
T. Neider In reviewing this issue the staff noted that your actions included: (1) self-identification by your subcontractor during the performance of an internal audit; (2) documentation of the discrepancy on a nonconformance report; and (3) adequate corrective actions taken, including a determination of compliance to the licensing basis documents and contract requirements.
The NRC has concluded that the corrective actions taken have adequately addressed this issue. You are not required to respond to this letter. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this letter, 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, Division of Spent Fuel Storage and Transportation; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response, if you provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
Sincerely,
/RA/
David W. Pstrak, Chief Rules, Inspections, and Operations Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket Nos.: 72-1029, 50-361 & 50-362 cc: R. McWey, Southern California Edison (SCE)
DISTRIBUTION: Docket 72-1029 SFST r/f VOrdaz JDavis OE: RSummers NHilton OGC: LGoldin RIV: RKeller WJones G:/SFST/TSISQA/REPORTS/TRANSNUCLEAR/EA10126 NCV cmf.docx ADAMS ACCESSION NO.: ML110270028 OFC SFST/RIOB SFST/RIOB SFST/LB OE/EB SFST/RIOB SFST/LID NAME ELove RWharton WWheatley CFaria-Ocasio DPstrak DWeaver DATE 01/03/2011 01/04/2011 01/04/11 email 1/18/2011 01/10/11 1/26/2011 OFFICAL RECORD COPY