ML23030B923
| ML23030B923 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/2023 |
| From: | NRC/NMSS/DFM/IOB |
| To: | |
| Shared Package | |
| ML23030B924 | List: |
| References | |
| Download: ML23030B923 (1) | |
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Encl. 2 - 1 FY22 Summary of Independent Spent Fuel Storage Installation Inspection Findings Type Licensee/
CoC Holder Description Applicable Regulation Category SL IV - NCV NAC International NAC failed to obtain a CoC amendment for changes to ACI-318 requirements for the MAGNASTOR cask system that required a change to the specifications incorporated in the MAGNASTOR System CoC No.
1031 Amendments 0-6.
- Changes, Tests, and Experiments Design Changes SL IV - NCV NAC International Petersen failed to ensure a final dimensional verification occurs after adjusting the MAGNASTOR fuel basket within fabrication procedures.
10 CFR 72.150 Instructions, Procedures, and Drawings Procedural Adherence SL IV - NCV NAC International Petersen failed to perform an adequate Magnetic particle testing (MT) inspection of a fuel tube seam weld.
10 CFR 72.158 Control of Special Processes Testing SL IV - NOV ORANO-Transport Logistics International Inc.
Container Products Corporation (CPC) took inadequate corrective actions during the previous inspection to ensure that applicable suppliers on its QSL received a triennial audit as required by the CPC QAM Section QAP-1007, and that the QSL was maintained current with qualified vendors. Specifically, Airgas Performance Plus Division and Branham Corporation have not been audited in the past three years but remained on the QSL.
10 CFR 71.133 Corrective Action Corrective Action SL IV - NCV TN
- Americas, LLC 10 CFR 72.48(c)(1)(ii)(B) - Change incorporated in the CoC. TN made changes in the spent fuel storage cask design as described in sections A.2.1.4 and A.2.4.2 of the NUHOMS EOS UFSAR (as updated) without meeting the requirements in the CoC.
Specifically, ORANO modified the UFSAR requirements for the MX-LC without performing an evaluation for an accident drop as required by CoC Condition 5, Heavy Loads Requirements and TS 5.2.1 because the MX-LC failed to meet the single failure proof requirements in the ASME NOG-1 2015 standard.
- Americas, LLC 10 CFR 72.48(d)(1)(c)(2)(i) and (c)(2)(vi)
TN revised UFSAR to remove the words to prevent boiling in the annulus and instead provided guidance on how to manage the TC/DSC annulus water level during loading and unloading. TN failed to provide a bases for the determination that the presence of boiling water in the DSC and TC annulus does not require a CoC amendment.
- Changes, Tests, and Experiments Design Changes
- Americas, LLC TN failed to subject design changes, including field changes, to design control measures commensurate with those applied to the original design in that TN supported a field change for a general licensee and did not properly analyze for tornado wind pressures without considering all assumptions from the original design.
10 CFR 72.146 Design Control Design Changes SL IV - NOV Croft Croft took inadequate corrective action from the NRC 2017 inspection of Croft and the NRC 2019 inspection of Croft fabricator Oxford Engineering Limited.
Specifically, in 2017, Croft wrote Corrective Action Report (CAR) 136 to address that Croft Associates Procedure (CAP) 12-01, Issue S, Audit Procedure, failed to require a periodicity for internal audits as required by 10 CFR, Section 71.137, Audits to ensure all applicable quality assurance criteria are audited on a periodic basis. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected. In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition.
However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In 2019, Croft wrote CAR 147 to address that CAP 06-08, Approved Supplier, Step 2.2.1 required that a Quality Category A supplier shall have a current assessment and approval to an appropriate quality system standard. Croft assessed Oxford Engineering Limited to qualify them to encompass the additional requirements of 10 CFR Part 71, but Oxford Engineerings internal auditor did not meet those requirements, nor did Oxford Engineering have a quality procedure or process in place for qualifying internal auditors. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In addition, during the 2022 inspection, several Croft 10 CFR 71.133 Corrective Action Corrective Action
Encl. 2 - 3 internal audits were sampled, and it was determined that no CARs had been written when findings had been identified as a result of the audits. CAP 12-01, Audit Procedure, Section 2.3 states that when carrying out an internal audit, nonconformances must be recorded on the CAR database.
SL IV - NCV Croft Inadequate procedures. CAP- 02-02, Project Quality Plan; CAP-02-04, Project Specifications; and CAP 05, Project Plan; are no longer current with what Croft is actually doing to fill out Croft form QF 376, Project Quality Plan. The form QF 376 had been revised, but procedures CAP 02-02, CAP 02-04, and CAP 02-05, in which procedural guidance was to be provided on how to fill out QF 376, were no longer current with what Croft was actually doing to fill out form QF 376.
10 CFR 71.111 Instructions, Procedures, and Drawings Procedural Adequacy SL IV - NCV Xcel Energy/
TN Americas SeAH Besteel Corpration's (SBC) corrective action procedure failed to provide sufficient guidance to perform root cause analysis for significant conditions adverse to quality to determine the corrective action necessary to preclude repetition.
10 CFR 72.150 Instructions, Procedures, and Drawings Procedural Adequacy SL IV - NCV NAC International Hitachi Zosen failed to perform an adequate audit of a suppliers QA program to ensure it meets all applicable requirements of 10 CFR Part 72, Subpart G.
10 CFR 72.154 Control of purchased
- material, equipment, and services Procurement Enforcement Discretion Limerick Generating Station The inspectors identified a violation of 10 CFR 72.48 associated with tornado hazard protection. 10 CFR 72.48(c)(2)(ii) requires, in part, that a general licensee shall request that the certificate holder obtain a CoC amendment pursuant to 10 CFR 72.244, prior to implementing a proposed change, if the change would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety (ITS) previously evaluated in the FSAR. This requirement includes the configuration where the HI-STORM FW overpack is lifted by the hydraulic lifting gantry (HLG) as part of ISFSI operations. The HLG is an ITS component used in cask handling operations and is not designed to be operated in wind speeds exceeding 35 mph. The introduction of the ITS HLG met the criterion that resulted in more than minimal increase in the likelihood of occurrence of a malfunction of an SSC ITS previously evaluated in the FSAR. The general design criteria require ITS structures used in ISFSI operations to be designed to withstand the effects of tornado missiles and winds.
- Changes, Tests, and Experiments Tornado Hazards VLSSIR Joseph M.
Farley Nuclear Plant Cask Transfer Operations Outside of the Fuel Handling Building The inspectors identified that at the Farley Nuclear Plant, the licensee performs cask transfer operations outside of the fuel handling building. Following this operation, a mating device from the HI-STORM is removed, leaving the MPC within the HI-STORM exposed to natural phenomena and after a short duration the HI-STORM lid is placed onto the HI-STORM.
Overall Requirements 10 CFR 72.212(b)
Conditions of CoC Tornado Hazards
Encl. 2 - 4 Enforcement Discretion Dresden Nuclear Power Station Tornado Hazards Protection at Independent Spent Fuel Storage Installations Upon issuance of U.S. NRC Enforcement Guidance Memorandum (EGM) 22-001 (ML22087A496), dated April 15, 2022, the licensee performed an assessment of all outdoor dry cask storage activities that are not explicitly analyzed for tornado hazards in the cask licensing basis. One configuration was identified by the licensee when a loaded Holtec HI-STORM 100 storage overpack is brought out of the reactor building without a lid installed. This configuration is not explicitly analyzed in the HI-STORM 100 FSAR. Tornado hazards are evaluated in the Holtec HI-STORM Final Safety Analysis Report (FSAR) section 3.4.8, Tornado Wind and Missile Impact, and section 11.2.6.2, Tornado Analysis. These sections of the FSAR do not include an analysis for tornado hazards with the storage overpack lid removed. Similarly, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles specifically for the configuration where a loaded storage overpack was outdoors with the lid off.
Conditions of CoC Tornado Hazards Enforcement Discretion H.B.
Robinson Steam Electric Plant Tornado Hazards Protection at Independent Spent Fuel Storage Installations Upon issuance of U.S. NRC Enforcement Guidance Memorandum 22-001 (ML22087A496), dated April 15, 2022, the licensee performed an assessment of all outdoor dry cask storage activities that are not explicitly analyzed for tornado hazards in the cask licensing basis. Several configurations were identified by the licensee including when a loaded Dry Shielded Canister (DSC) with the shield plug is transferred out of the Spent Fuel Pool to the Cask Handling Facility and when the transfer cask lid is removed to insert the DSC into the Horizontal Storage Module (HSM). These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 FSAR. Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
Conditions of CoC Tornado Hazards Enforcement Discretion South Texas Project Tornado Hazards Protection at Independent Spent Fuel Storage Installations Upon issuance of U.S. NRC Enforcement Guidance Memorandum (EGM) 22-001 (ML22087A496), dated April 15, 2022, the licensee performed an assessment of all outdoor dry cask storage activities that were not explicitly analyzed for tornado hazards in the systems FSAR. Two configurations were identified by the licensee where transport activities did not have a related tornado wind and hazard analysis consistent with the casks design basis requirements. These situations occurred during outside operations when the HI-STORM FW overpack was on the low-profile transporter with the HI-STORM FW overpack lid bolts not engaged and when the Vertical Cask Transporter carried the overpack using the HI-STORM FW lifting brackets.
Conditions of CoC Tornado Hazards
Encl. 2 - 5 Enforcement Discretion Surry Power Station Dominion Energy Tornado Hazards Protection at Independent Spent Fuel Storage Installations Upon issuance of U.S. NRC Enforcement Guidance Memorandum (EGM) 22-001 (ML22087A496), dated April 15, 2022, the licensee performed an assessment of all outdoor dry cask storage activities that are not explicitly analyzed for tornado hazards in the cask licensing basis. Several configurations were identified by the licensee including when the transfer cask lid is removed to insert the Dry Shielded Canister (DSC) into the Horizontal Storage Module (HSM) and prior to the HSM lid being reinstalled. These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 Final Safety Analysis Report (FSAR).
Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
Conditions of CoC Tornado Hazards SL IV NCV Indian Point Failure to follow procedures that are relied upon to ensure that combustible material surrounding a loaded HI-STORM is less than the maximum evaluated.
10 CFR 72.150 Instructions, Procedures, and Drawings Procedural Adherence SL IV NCV Calvert Cliffs Nuclear Power Plant Did not notify the NRC using instructions in 10 CFR 72.4 at least 90 days before first storage of spent fuel under their general license. 72.212(b)(1).
10 CFR 72.212 Conditions of CoC General License Conditions SL IV NCV Duane Arnold Failure to conform to the terms, conditions, and specifications of Certificate of Compliance (CoC) 1004, Amendment 17, Revision 0, Appendix B, condition 4.3.3, which required monitoring for hydrogen during welding of the inner top cover plate. 72.212(b)(3).
10 CFR 72.212 Conditions of CoC General License Conditions NCV GREEN (SL IV)
Browns Ferry Nuclear Plant Failure to perform a 10 CFR 50.59 evaluation in accordance with site procedures. The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of site procedure NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments. Specifically, site personnel made changes to procedure 0-TI-561, Underground Piping and Tanks Integrity Program, a procedure described in the UFSAR, without performing a 10 CFR 50.59 evaluation as required by site procedures.
10 CFR 50 Appendix B Procedural Adherence NCV GREEN (SL IV)
Joseph M.
Farley Nuclear Plant Failure to incorporate acceptance criteria for the spent fuel bridge crane. The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events.
10 CFR 50 Appendix B Procedural Adequacy
North Anna Power Station Failure to translate the licensing basis into instructions for fuel handling activities. The inspectors identified a Green, non-cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to translate the maximum cask lift elevation and the locking of the trunnion axis into site procedures.
10 CFR 50 Appendix B Procedural Adequacy NCV GREEN (SL IV)
Sequoyah Nuclear Plant Inadequate design control for ISFSI operations.
The team identified three examples of a Green, non-cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to develop appropriate acceptance criteria associated with the ISFSI haul path and the railway access hatch hoisting system and failed to verify the adequacy of the Auxiliary Building Crane testing program.
10 CFR 50 Appendix B Procedural Adequacy SL IV - NCV Surry Power Station Dominion Energy The team identified a Severity Level IV non-cited violation (NCV) of 10 CFR 72.48(d)(1), Changes, Tests, and Experiments, because the licensee did not perform an adequate written evaluation which provided the bases for the determination that the change, test, or experiment does not require a license or Certificate of Compliance (CoC) amendment pursuant to paragraph (c)(2) of this section. Specifically, the licensee did not provide the bases for the determination that the presence of boiling water in the Dry Shielded Canister (DSC) and Transfer Cask (TC) annulus does not require a CoC amendment.
- Changes, Tests, and Experiments Design Changes SL IV - NCV Surry Power Station Dominion Energy The inspectors identified a Severity Level IV, non-cited violation of 10 CFR Part 72.162, Test Control, for the licensees failure to perform testing in accordance with written test procedures incorporating design basis requirements and acceptance limits. Specifically, design basis flow rates for the EOS Forced Air Cooling units (FAC) were not incorporated into testing procedures or other instructions to test the system on an ongoing basis. As a result, unacceptable degradation of the FAC would not have been identified.
10 CFR 72.162 Test Control Testing
ML23030B924; ML23030B923 OFFICE NMSS/DFM/IOB NMSS/DFM/IOB NMSS/DFM NMSS/DFM/IOB*
NAME ADjapari ARivera-Varona SHelton JZimmerman for ARivera-Varona DATE Jan 31, 2023 Feb 14, 2023 Feb 16, 2023 Feb 16, 2023