ML24029A048
| ML24029A048 | |
| Person / Time | |
|---|---|
| Issue date: | 03/20/2024 |
| From: | NRC/NMSS/DFM/IOB |
| To: | Division of Fuel Management |
| Shared Package | |
| ML24029A045 | List: |
| References | |
| Download: ML24029A048 (18) | |
Text
Enclosure 2 Fiscal Year 2023 Summary of Inspection Violations and Reports Under Title 10 of the Code of Federal Regulations Part 71 and 72 FY 2023 PART 72 INSPECTION VIOLATIONS Type Licensee/
Certificate of Compliance (CoC) Holder Description Applicable Regulation Category SL IV -
non-cited violation (NCV)
Holtec International (Holtec)
Holtec failed to adequately implement a procedure for an activity affecting quality. Specifically, procedure, HSP-477, revision 4, Digital Radiographic Weld Examination, specified that deliquification, dissolution, and adjustment (DDA) calibration (pixel mapping) be performed at the commencement of an inspection period and not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required, instead, Holtec performed the DDA calibrations at 2-week intervals.
Title 10 of the Code of Federal Regulations (10 CFR)
Section 72.150 Instructions, Procedures, and Drawings Procedural Adherence SL IV -
NCV Orano TN Americas LLC Hitachi Zozen Inadequate Supplier Audits TN Americas (TN) quality procedures did not provide sufficient guidance to perform a licensing review for all applicable situations. Specifically, material nonconformances that are not controlled under the TN Quality Assurance Program Description Manual and do not receive a supplier nonconformance are not required to have an associated licensing review conducted under the TN quality program. A licensing review would determine if TN needed additional licensing actions such as the U.S.
Nuclear Regulatory Commission (NRC) approval or an exemption to the regulations to accept the nonconformance to an approved NRC license.
10 CFR 72.150 Instructions, Procedures, and Drawings Procedural Adequacy
2 SL IV -
NCV Northern States Power Company NSPM SeAH Besteel Inadequate quality procedure for guidance in conducting a Root Cause Analysis (RCA) SeAH Besteel Corporation (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 quality assurance program (QAP).
10 CFR 72.150 Instructions, Procedures, and Drawings Procedural Adequacy SL IV - NCV Westinghouse Electric Company Failure to perform adequate corrective actions for a condition adverse to quality. Failed to perform adequate corrective action to address a Corrective Action Program (CAP) issue report. Specifically, Westinghouse failed to perform an adequate extent of condition evaluation for the existing and in service Fuel Solutions DCSS to determine if there were any adverse effects due to the input file error identified for the SENTRY project.
10 CFR 72.172 Corrective Action Corrective Action SL IV -
Holtec As required by 10 CFR 72.48(c)(2)(viii), Changes, tests, and experiments, Holtec failed to obtain CoC amendments pursuant to 10 CFR 72.244 prior to implementing proposed design changes to multi-purpose canister (MPC) continuous basket shims (CBS) for four spent fuel cask designs (i.e., MPC 68M-CBS, MPC 32M-CBS, MPC 89-CBS, and MPC 37-CBS basket variants) that resulted in a departure from the method of evaluations described in the HI-STORM 100 and HI-STORM Flood/Wind (FW) Final Safety Analysis Reports (FSAR) (updated) used in establishing the design bases; The certificate holder Holtec International failed to obtain a CoC amendment pursuant to 10 CFR Section 72.244, prior to implementing proposed changes that would result in a departure from a method of 10 CFR 72.48
- Changes, Tests, and Experiments Design Changes
3 evaluation (MOE) described in the FSAR used in establishing the design bases or in the safety analyses.
Specifically, from November 6, 2020, to July 19, 2021, Holtec made design changes to four multi-purpose canister (MPC) fuel baskets from the standard MPC 68M, 32M, 89, and 37 baskets to the MPC 68M-continuous basket shims (CBS), MPC 32M-CBS, MPC 89-CBS, and MPC 37-CBS basket variants that resulted in a departure from methods of evaluation described in the FSARs (as updated) used in establishing the design bases and failed to submit CoC amendment applications prior to implementing the changes.
SL IV - NOV Holtec As required by 10 CFR 72.48(d)(1),
Changes, tests, and experiments, Holtec failed to maintain records of changes that included written evaluations that provided an adequate bases for the determination that changing to the MPC CBS basket variants did not require CoC amendments pursuant to 10 CFR 72.48(c)(2).
Holtec failed to maintain records of changes in the spent fuel storage cask design made pursuant to paragraph (c) of 10 CFR 72.48 that included a written evaluation which provided the bases for the determination that the change does not require a CoC amendment pursuant to 10 CFR 72.48(c)(2). Specifically, for the MPC 68M-CBS, MPC 32M-CBS, MPC 89-CBS, and MPC 37-CBS variants, as of February 17, 2021, July 19, 2021, May 13, 2020, and November 6, 2020, Holtecs written evaluations failed to provide an adequate bases for the determination that incorporation of the CBS design fuel basket variants did not require a CoC amendment. Holtec did not clearly and thoroughly discuss the impacts on departures from elements of the MOEs described in the FSARs for the original design (all-welded stainless steel fuel basket) that were affected by the changes to the CBS design fuel basket variants (MPC 68M-CBS, MPC 32M-CBS, MPC 89-CBS, and MPC 37-CBS). The 10 CFR 72.48
- Changes, Tests, and Experiments Design Changes
4 impacted elements included the demonstration of the design criteria of the fuel basket; mathematical model associated with material performance and tip-over analysis; calculational framework on connections between fuel basket and shims; use of revised version of software; new assumptions, etc.
SL IV - NOV Holtec As required by 10 CFR 72.146(c),
Design control, Holtec failed to subject design changes for the MPC 68M-CBS, MPC 32M-CBS, MPC 89-CBS, and MPC 37-CBS basket variants to design control measures commensurate with those applied to the original design.
Holtec failed to subject design changes, including field changes, to design control measures commensurate with those applied to the original basket design. Specifically, in four examples prior to February 17, 2021, July 19, 2021, May 13, 2020, and November 6, 2020, Holtec failed to subject design changes from the MPC 68M, 32M, 89, and 37 standard basket designs to the MPC 68M-CBS, 32M-CBS, 89-CBS, and 37-CBS basket variants to design control measures commensurate with those applied to the original design, and made changes in the conditions specified in the license that required prior NRC approval. Holtec failed to perform adequate tip-over calculations and to model the basket shim bolts for the four CBS basket variants. In addition, material strength assumptions were different, the deflection design criteria of the fuel baskets were not demonstrated, and thermal expansion interference was not calculated in the CBS baskets.
10 CFR 72.146 Design Control Design Changes
5 Apparent Violation NAC International (NAC)
NAC failed to submit a written report to the NRC within 30 days of discovery of a design or fabrication deficiency, for any spent fuel storage cask which has been delivered to a licensee, when the design or fabrication deficiency affects the ability of structures, systems, and components important to safety to perform their intended safety function.
Specifically, NAC failed to submit a written report to the NRC within 30 days of discovery of a design error in a fuel rod structural calculation for normal and accident conditions that impacted the NAC-UMS and MAGNASTOR storage systems which had been delivered to general licensees (i.e., Palo Verde, McGuire, Catawba, Zion, Kewaunee, and Three Mile Island) when the design deficiency exceed the design limits.
NAC discovered a design deficiency in calculation 71160-2025 on March 29, 2022, that adversely impacted the licensees computation for bending stresses (i.e., negative margins).
Eventually, NAC submitted the required report to the NRC on March 11, 2023, and updated the report on March 28, 2023 (ML23087A062), this was approximately 11 months after NAC identified the issue.
Recordkeeping and Reports Reporting SL IV - NCV Seabrook Station NextEra Energy
- Seabrook, LLC Improper Removal of Quality Control Hold Points from Dry Cask Storage Procedures.
The inspectors identified a Severity Level IV non-cited violation of NextEra's Quality Assurance Manual when the licensee failed to obtain permission from either the Quality Control Level III Inspector or Nuclear Assurance and Assessment Manager prior to removing quality control hold points as specified in the dry cask storage operations procedure.
10 CFR 72.140 Quality Assurance Requirements Procedural Adherence
6 SL IV - NCV Indian Point DECOM Failure to Verify HI-LIFT Crane Component Seismic Qualification One the NRC identified Severity Level IV NCV of 10 CFR 72.146 is documented because design control measures did not ensure that appropriate quality standards were specified and included in design documents associated with the HI-LIFT crane structure. Specifically, Holtec Decommissioning International failed to ensure suitability of the crane swing arm hydraulic system counterbalance valves during postulated seismic conditions, which are essential to the function of the HI-LIFT crane and therefore important to safety. Holtec Decommissioning International entered the issue into its CAP as IR-IP3-01202 and completed actions to seismically qualify the valves.
10 CFR 72.146 Design Control Design Changes SL IV - NCV Perry Nuclear Power Plant FirstEnergy Nuclear Operating Co.
Zero Profile Transporter The inspectors identified a Severity Level IV NCV of 10 CFR 72.48(d)(1),
Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to the design of the Holtec HI-STORM FW system did not require a license amendment. Specifically, while implementing the HI-STORM FW system, the licensees calculational verification of the Zero Profile Transporter did not adhere to the design requirements resulting in two changes that could result in uncontrolled movements of the HI-STORM FW overpack during transport potentially impacting the shielding function of the overpack.
- Changes, Tests, and Experiments Design Changes
7 Enforcement Discretion Perry Nuclear Power Plant Tornado Hazards Protection at Independent Spent Fuel Storage Installations (ISFSI)
Upon issuance of the 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 FW storage overpack is brought out of the fuel building without a lid installed. This configuration is not explicitly analyzed in the HI-STORM FW FSAR. The 10 CFR Section72.212 (b)(6), states, in part, that "the general licensee must:...
review the Safety Analysis Report (SAR) referenced in the CoC
[Certificate of Compliance] or amended CoC and the related NRC SAR, prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of earthquake intensity and tornado missiles, are enveloped by the cask design bases considered in these reports. The results of this review must be documented in the evaluation made in paragraph (b)(5) of this section."
Tornado hazards are evaluated in the Holtec HI-STORM FW FSAR section 2.2.3.e, "Environmental Phenomena and Accident Condition Design Criteria," and section 12.2.6.2, "Tornado Analysis." These sections of the FSAR do not include an analysis for tornado hazards with the storage overpack lid removed.
Conditions of CoC Tornado Hazards
8 Enforcement Discretion Waterford Steam Electric Station Entergy Operations Inc.
Tornado Hazards Protection at ISFSI Upon issuance of the 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 system's FSAR. Two configurations were identified by the licensee where transport activities did not have a related tornado wind and hazard analysis consistent with the cask's design basis requirements.
These situations occurred during outside operations when the HI-STORM FW overpack was on the low-profile transporter and when the Vertical Cask Transporter carried the overpack using the HI-STORM FW lifting brackets.
The Holtec HI-STORM FSAR section 2.2, HI-STORM FW Design Loading, which includes section 2.2 iv. Short Term Operations, "normal operation evolutions necessary to support fuel loading or unloading activities,"
describes the general design criteria for the cask system. This includes all off-normal condition loads, environmental phenomena, and accident conditions. Specifically, FSAR section 2.2.3.e. Environmental Phenomena and Accident Condition Design Criteria - Tornado, describes that the FW system must withstand pressures, wind loads, and missiles generated by a tornado while maintaining kinematic stability and continued integrity of the canister must be demonstrated. Tornado hazards are evaluated in the FSAR section 3.1.2.1.e., Design Criteria and Applicable Loads - Tornado, section 3.4.4.1 Safety Analysis, and section 12.2.6.1, Tornado Analysis. These sections of the FSAR do not include an analysis for tornado hazards when the overpack was on the low-profile transporter and when the Vertical Cask Transporter carried the overpack using the HI-STORM FW lifting brackets.
Conditions of CoC Tornado Hazards
9 FY 2023 PART 71 INSPECTION VIOLATIONS Type Licensee/
CoC Holder Description Applicable Regulation Category SL IV -
NCV Best Theratronics Ltd.
Failure to perform audits in accordance with QAP The certificate holder (Best Theratonics Limited [BTL]) did not carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the quality assurance program that determined the effectiveness of the program.
Additionally, BTL did not perform the audits in accordance with written procedures. Specifically, BTL missed performing audits and did not complete audits as scheduled in accordance with written procedures.
10 CFR 71.137 Audits Audits SL IV -
NCV Industrial Nuclear Co.
(INC)
Failure to promptly correct conditions adverse to quality INC failed to assure that conditions adverse to quality were promptly corrected. Specifically, INC, failed to promptly correct a condition adverse to quality when actions applicable to CAR 21-005 had not been performed to identify or implement corrective actions to bring Quality Procedure (QP) 7.1 into compliance since August 2021.
10 CFR 71.133 Instructions, Procedures, and Drawings Procedural Adequacy SL IV -
NOV NAC International Failure to notify prior to fabrication NAC did not notify the NRC, in accordance with 10 CFR 71.1, 45 days in advance of starting fabrication of the first packaging under a CoC. Specifically, NAC missed opportunities to notify the NRC of fabrication activities prior to completion of the first packaging for use in the United States under the CoC Docket No. 71-9390. This paragraph applies to the OPTIMUS-L transportation packaging because it has a maximum normal operating pressure more than 103kPa. The NAC self-identified the violation and 10 CFR 71.93 Inspections and Tests Reporting
10 performed a root cause analysis to determine the cause of the violation.
SL IV -
NCV NAC International Failure to establish control of measuring and test equipment NAC did not establish measures to assure that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified times to maintain accuracy within necessary limits.
Specifically, NAC oversight of fabrication activities at Joseph Oat Corporation did not establish measures to assure that the step-wedge film strip used in interpreting film of the CCV shell weld was within the 12-month calibration /
replacement period as required in section 2.3 of SP-1508, revision 3 to maintain accuracy within the necessary limits. At the time when the team discovered this issue, the step-wedge film strip had not been retested and called into question the results of previous tests including radiograph of the CCV shell weld.
10 CFR 71.125 Control of Measuring and Test Equipment M&TE Control
11 SL IV -
NCV Nordion Failure to submit a change to QAP that reduced commitments Nordion did not submit a description of proposed changes to its NRC-approved QAP that reduced commitments in the program description as approved by the NRC and implemented those changes before receiving NRC approval.
Specifically, Nordion reduced its commitments for audits, and specific sections that do not reflect the current practice in the quality program description such as inspection, testing, and operating status as approved by the NRC and implemented those changes before receiving prior NRC approval.
10 CFR 71.106 Changes to Quality Assurance Program Quality Assurance SL IV -
NCV Source Production &
Equipment Co.
(SPEC)
Failure to adequately store records per procedure SPEC did not follow the filing and storage section of Quality Standard Procedure Manual section 17.0 and quality records were lost due to Hurricane Ida. Specifically, some quality records were not filed in storage devices/areas free from environmental threats as required.
10 CFR 71.111 Instructions, Procedures, and Drawings Procedural Adherence SL IV -
NCV SPEC Failure to properly classify and justify sealed source capsule quality category SPEC failed to establish measures to assure that appropriate quality standards were specified and included in design documents.
Measures were also not established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the functions of the materials, parts, and components of the packaging that are important-to-safety.
Specifically, SPEC did not perform an engineering evaluation and provide sufficient justification to support the assignment of ITS Category T to the sealed source capsule, which is defined as the 10 CFR 71.107 Package Design Control Design Changes
12 primary containment vessel in the SPEC-150 and SPEC-300 SARs.
The sealed source capsule was not properly classified as ITS Category A to ensure all required procurement controls are applied.
SL IV -
Failure to evaluate an adverse condition for appropriate corrective actions Specifically, RTs QAPD Section 16, Corrective Action, requires that conditions adverse to quality (e.g.,
deficiencies, deviations, defective material) be documented in corrective action reports (CARs) to evaluate the cause and actions of significant conditions adverse to quality (SCAQ) to prevent recurrence. Contrary to this, although the weld deficiency was repaired, RT failed to disposition the condition (significant vs adverse) and if required, evaluate the cause and actions to prevent recurrence.
10 CFR 71.133 Corrective Action Corrective Action
13 SL IV -
NCV ROBATEL TECHNOLOGIES Failure to comply with procurement control procedure The team reviewed RTs PO No.
185, dated 05/21/2021, issued to NFT-EPD, LLC for performance of annual cask maintenance services for RT-100 cask nos. 1, 2, 3, and 4 in accordance with the RT-100 SAR and RT procedures. The team noted, PO No. 185, invoked a restriction that procedures and personnel used on cask maintenance work to be reviewed and approved by RT, prior to the work being performed. Further, RTs procurement control QP (No.
QP-04-01) requires RT supplier documentation approval. Contrary to these requirements, RTs review, and approval of certain cask maintenance EPD examination procedures were not documented.
In addition, documentation of qualification and certification of nondestructive examination Level III personnel performing review and approval of helium leak testing procedure (No.
2013-015-PR-CB-003) utilized during RT-100 casks annual maintenance was not apparent. The team determined that this was a violation of the NRC requirements.
10 CFR 71.111 Instructions, Procedures, and Drawings Procedural Adherence SL IV -
NCV Nuclear Fuel Services Failure to have adequate packaging inspection procedures Nuclear Fuel Services (NFS) failed to prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, NFS failed to include in the LR package loading procedure Standard Operating Procedure 409-SEC 45, revision 18, all the required operational pre-shipment inspections for visible flaws 10 CFR 71.111 Instructions, Procedures, and Drawings Procedural Adequacy
14 including corrosion, actions in the case of identifying corrosion, and actions for shackle securing or removal as required by the LR package SAR, revision 9, chapter 7.
SL IV -
NCV Nuclear Fuel Services Failure to perform independent internal audits NFS failed to perform internal audits of all applicable areas with auditors not having direct responsibilities in the areas being audited.
Specifically, NFS failed to perform independent audits of the vendor qualification, receipt inspection, and internal audit areas.
10 CFR 71.137 Audits Audits
15 FY 2023 PART 71.95 Reports Docket No.
Package Model No.
Description Report Date Reporting Requirement 07109291 CoC #9291 Liqui-Rad Transport Package (model LR-230)
Westinghouse Electric Company determined that conditions of approval in CoC No. 9291 for the Liqui-Rad Transport Unit Package (model LR-230) were not followed during a shipment on November 9, 2022. This package is used to transport low-enriched uranyl nitrate solutions for repurposing.
Upon receipt of heeled packages at a customer site, the primary lid port plug bolt was determined to have not been properly installed prior to shipment from Westinghouse. The bolt was found uninstalled, sitting inside the boundary of the outer lid and outside containment. The supplier reported this issue to Westinghouse on November 14, 2022. The error likely occurred as a result of imprecise operation and maintenance requirements that led to a human error of missed installment and verification of the bolt. Procedures were modified to add a verification step to ensure installation and torque tightness of the bolt. No known release of contents occurred.
1/06/2023 71.95(a)(3) -
Conditions of approval in the Certificate of Compliance were not observed in making a shipment.
71.95(b) -
Conditions in the Certificate of Compliance were not followed during a shipment.
07109291 CoC #9291 Liqui-Rad Transport Package (model LR-230)
The NFS reported that conditions of approval in CoC No. 9291 for the Liqui-Rad Transport Unit Package (model LR-230) were not followed during shipments. This package is used to transport up to 230 gallons of low-enriched uranyl nitrate solution. During an NRC Transportation Quality Assurance Inspection on March 28, 2023, corrosion was identified on exterior surfaces of a LR-230 container that was being prepared for loading.
Subsequent inspection of a loaded LR-230 trailer indicated similar corrosion on multiple containers.
The corrosion was most significant 5/22/2023 71.95(a)(3) -
Conditions of approval in the Certificate of Compliance were not observed in making a shipment.
71.95(b) -
Conditions in the Certificate of Compliance were not followed
16 on the carbon steel bracing for the packages and on exterior surfaces surrounding the equipment data plates. The corrosion along the carbon steel bracing plates could be described as pitting and blistering. The SAR stated that the package should not be used if corrosion is discovered on the exterior surface. The NFS operating procedure did not specifically include corrosion on the preload inspection checklist. As a result, packages were shipped with corrosion present. NFS has shipped LR-230 trailers for many years, with approximately two to three shipments per week to Westinghouse Corporation. NFS immediately stopped shipments of the loaded LR-230 trailers pending resolution with the package owner (Westinghouse Electric Corporation) and Certificate Holder (Orano TN Americas). The NFS evaluated the safety significance of this issue as low. The NFS sought information needed to determine operability for continued use until the packages could be repaired or refurbished. The NFS planned to modify their procedures to capture all applicable inspection criteria, especially corrosion.
during a shipment.
17 FY 2023 PART 72.242 Reports Docket No.
Cask Type Description Report Date Reporting Requirement 07201004 NUHOMS 61 BTH Type 2 DSC In early November, Orano TN Americas identified fabrication issues during operation activities.
The 72.242 submitted to the NRC is a proprietary document.
11/30/2022 72.242(d) 07201015 07201031 NAC-UMS and MAGNASTOR dry cask storage systems NAC has internally identified a licensing basis deficiency for the NAC-UMS and MAGNASTOR dry cask storage systems. Specifically, a parameter used in the computation of bending stress in the finite element model used to structurally evaluate a fuel rod under the non-mechanistic tip-over accident condition was incorrectly specified resulting in the non-conservative calculation of stresses. More specifically, the calculation uses an ANSYS 2-dimensional elastic beam element, BEAM3, to represent a single fuel rod. The BEAM3 element requires the input of various real constants that define physical properties of the element such as cross-sectional area, area moment of inertia, and height. The height real constant is used by ANSYS in the computation of bending stress in the element and is defined in ANSYS documentation to be the total height of the beam (i.e., rod outer diameter in this case). The input code in question incorrectly set the height real constant using a parameter equal to the outer radius of the rod, which is half of the correct value. Use of the correct value effectively doubles the computed bending stress.
NAC has completed an impact to safety evaluation and determined there is no Impact to Safety or concerns relative to the ability of 3/10/2023 72.242(d)
18 the components to perform their intended safety function based on the error identified. The calculational error is specific to the non-mechanistic tip-over analysis.
Both the MAGNASTOR FSAR and UMS FSAR provide evaluations which determined the loaded systems on the ISFSI pad do not tip-over within licensed conditions.
Additionally, the safety functions of the Vertical Concrete Cask and Transportable Storage Canister e.g., passive heat rejection, environmental protection, TSC confinement, fuel assembly geometry control) are unaffected by the error in fuel rod modeling.
This condition is reportable since the deficiency when corrected results in the non-conservative calculation of fuel rod bending stresses exceeding the licensing basis limits for the NAC-UMS and MAGNASTOR. However, NAC has determined there is no safety consequence. NACs other dry cask storage system, which is the NAC-MPC system, was determined to not have been affected by this issue.
72.75 Reports: None Part 21 Reports: None