ML14042A201

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Part 21 Report Regarding Non-Destructive Testing Did Not Meet Procedural Requirements
ML14042A201
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 01/29/2014
From: Bland D, South M
TriVis
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
12751-NRC-002, 49628
Download: ML14042A201 (6)


Text

0112912014 U.S. NuclearRegulatory Commission OperationsCenter Event Report Paaee I Part 21 (PAR) Event# 49628 Rep Org: TRIVIS INC. Notification Date / Time: 12/13/2013 14:37 (EST)

Supplier: TRIVIS INC. Event Date / Time: 12/13/2013 (CST)

Last Modification: 01/29/2014 Region: 1 Docket #:

City: BIRMINGHAM Agreement State: Yes County: License #:

State: AL NRC Notified by: DAVID BLAND Notifications: RICHARD SKOKOWSKI R3DO HQ Ops Officer: HOWIE CROUCH PART 21 GROUPS EMAIL Emergency Class: NON EMERGENCY 10 CFR Section:

21.21(a)(2) INTERIM EVAL OF DEVIATION PART 21 REPORT - NON-DESTRUCTIVE TESTING DID NOT MEET PROCEDURAL REQUIREMENTS The following information was summarized from the report submitted by TriVis via facsimile:

David Bland, President of TriVis Inc. reported that two contract Non-Destructive Evaluation (NDE) Level II examiners, employed by TriVis, failed to meet NDE procedural requirements for weld testing on the Outer Top Cover Plate (OTCP) on six Transnuclear Model NUHOMS-61 BTH Dry Shield Canisters (DSC) at the Monticello Nuclear Generating Plant.

An NRC inspector observed part of this activity and questioned whether the dwell times for the penetrant and developer used by a NDE Level II employee of TriVis were sufficient to meet procedural requirements. Upon evaluating recorded video of the work location, it was determined that the dwell times for both the penetrant and the developer of the OTCP weld on DSC #16 were not in compliance with the TriVis NDE LPT [Liquid Penetrant Test] Procedure. An extent of condition review of previous LPT exams conducted on DSCs 11 through 16 revealed additional examinations that were not in compliance with the dwell times specified by the procedure as well as other procedural discrepancies.

All six DSCs were declared inoperable at the time of discovery. All work activities associated with dry fuel storage at Monticello were stopped. A timeline and corrective actions are being developed by TriVis and the licensee.

The two NDE Level II examiners were not previously employed by TriVis and did not perform any other NDE activities at Monticello.

Evaluations will be completed by January 31, 2014 or a follow-up interim report will be submitted.

01/29/2014 U.S. Nuclear Regulatory Commission OperationsCenter Event Report Pare 2 Part 21 (PAR) Event# 49628 The licensee notified the NRC Resident Inspector.

  • *
  • UPDATE FROM MIKE SOUTH TO DANIEL MILLS ON 1/29/14 AT 0945 EDT ***

The following information was selected from the report submitted by TriVis via facsimile:

"TriVis has completed its evaluation of the activity and determined that it is limited to procedural non-compliance on DSCs 11 through 16 at [Monticello] only. Based on the results of the evaluation, TriVis believes the procedural non-compliance did not adversely affect the health and safety of the public and does not constitute a substantial safety hazard."

Notified R3DO (Sheldon), and NRR Part 21 Group (via email).

01-29-14;09:45AM; # 1/ 4 A TRIVISi.

January 29, 2014 Ltr No: 12751 - NRC - 002 Document Control Desk U. W. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Final Report of Potential Substantial Safety Hazard in accordance with Title 10 Code of Federal Regulation, Part 21 Event Number 49628 To Whom It May Concern:

The purpose of this letter is to provide a Final Report subsequent to the Interim Report filed on December 13, 2013 for Event Number 49628.

The Final Report, attached to this letter, states that this event is limited to procedural non-compliance and does not constitute a significant safety hazard. Per 10CFR21.21, this Final Report includes a description of the condition, the extent of condition evaluation and corrective actions taken to date. As stated in the Interim Report, TriVis will continue to work with the Licensee to finalize and correct any issues which this event may have caused to the NUHOMS dry storage systems involved.

Should you have any additional questions regarding this matter I can be reached at (205) 621-0106.

Sincerely, TRIVIS INC Mike South, P.E.

Vice President, Engineering CC. Lee Samson, Xcel Nuclear - Monticello Leonard Sueper, Xcel Nuclear 2(00 I*i.:)T* I"irk%'1iy Wij,,i

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01-29-14;09:45AM; # 2/ 4 ENCLOSURE 10 CFR 21 Final Report - Liquid Penetrant Procedure Non-Compliance Event Number 49628 Name and Address of the Individual Informing the Commission Mike South Vice President, Engineering TriVis Inc 200 Beacon Parkway West Birmingham, AL 35209 Identification of the Facility or Activity which fails to comply On October 17, 2013, a nondestructive examination (NDE) liquid penetrant test (LPT) was performed on the final weld pass of the Outer Top Cover Plate (OTCP) on Transnuclear Model NUHOMS-61BTH Dry Shielded Canister (DSC) #16 at Monticello Nuclear Generating Plant (MNGP). An NRC inspector observed part of this activity and questioned whether the dwell times for the penetrant and developer used by a NDE Level II employee of TriVis Inc. (hereafter TriVis) were sufficient to meet procedural requirements. Upon evaluating recorded video of the work location, it was determined that the dwell times for both the penetrant and the developer of the OTCP weld on DSC

  1. 16 were not in compliance with the TriVis NDE LPT Procedure, An extent of condition review of previous LPT exams conducted on DSCs-1 1 through -16 revealed additional examinations that were not in compliance with the dwell times specified by the procedure as well as other procedural discrepancies. All of these examinations were performed by two contract NDE Level IIexaminers employed by TriVis.

Evaluation Status This report is provided to the Commission subsequent to the Interim Report dated 12/13/2013 for Event Number 49628, TriVis has completed its evaluation of the activity and determined that it is limited to procedural non-compliance on DSCs 11 through 16 at MNGP only. Based on the results of the evaluation, TriVis believes the procedural non-compliance did not adversely affect the health and safety of the public and does not constitute a substantial safety hazard.

Identity of the firm supplying the basic component which fails to comply or contains a defect TriVis Inc.

200 Beacon Parkway West Birmingham AL, 35209 Page I of 3

01-29-14;09:45AM; # 3/ 4 Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.

TriVis NDE personnel repeatedly failed to follow the dwell time as well as other procedural requirements for LPT examination of welds during the installation of the field welded components of DSCs-1 1 through 16. While this does not directly impact the quality of the closure weld, the LPT examination is performed to prove a lack of surface imperfections and thus could have an impact.

However, the evaluation performed by TriVis shows that the integrity of the closure welds was not compromised. In addition, successful completion of helium leak testing on all six (6) DSCs has shown the welds to be leak tight. As such, TriVis does not consider the procedural non-compliance to constitute a significant safety hazard.

The date on which the information of such defect or failure to comply was obtained.

October 17, 2013 In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be supplied for, manufactured, or being manufactured for one or more facilities or activities subject to the regqulations in this part.

TriVis has determined that the condition exists only with DSCs 11-16 at MNGP.

The corrective action which has been, is being, or will be taken: the name of the individual or organization responsible for the action: and the length of time that has been or will be taken to complete the action.

All work activities related to the dry fuel storage campaign at MNGP were stopped upon discovery of this condition.

An extent of condition review was conducted to determine the impact of the issue on previous loading campaigns at MNGP. The review concluded the individuals involved had not previously performed other NDE activities on site, nor for TriVis. The investigation suggests that the actions were intentional deviations from the procedural requirements and thus resulted in removal of the subject personnel from future involvement in quality activities. Review of as-written NDE procedures indicates no change is necessary to the established processes.

Further, in support of the affected Licensee, the techniques used by the NDE examiners were tested and found to have been capable of producing interpretable examination results for detection of critical weld flaw sizes. All this information has been provided to Page 2 of 3

01-29-14;09:45AM; # 4/ 4 the affected Licensee for evaluation of overall impact on DSCs 11 - 16 from an operability and licenseability standpoint.

Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

TriVis has determined that the two NDE personnel had not previously been employed by TriVis. Thus, TriVis does not consider any DSCs previously loaded at MNGP or any other site to be in question. TriVis is continuing to work closely with MNGP Licensee personnel in the evaluation of the affected systems.

In the case of an early site permit, the entities to whom an early site permit was transferred.

Not applicable.

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