ML24358A245
| ML24358A245 | |
| Person / Time | |
|---|---|
| Site: | 07201031, 07201015, 07100018 |
| Issue date: | 01/03/2025 |
| From: | Hector Rodriguez-Luccioni NRC/NMSS/DFM/IOB |
| To: | Jeffrey Hamman NAC International |
| References | |
| IR 2025201 | |
| Download: ML24358A245 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205550001 Joyce Hamman Vice President of Quality NAC International, Inc.
2 Sun Court, Suite 220 Peachtree Corners, GA 30092
SUBJECT:
NAC INTERNATIONAL, INC. - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 72-1031/2025201
Dear Joyce Hamman:
On November 19, 2024, through November 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) inspection team performed an announced onsite inspection of NAC International, Incorporated (NAC) that involved observing construction activities at Palo Verde Generating Station in Tonopah, AZ. NAC is under contract with Arizona Public Service Company (APS) to provide fabrication/construction activities associated with the NAC MAGNASTOR Vertical Concrete Cask (VCC) storage system.
The purpose of the inspection was to review and assess the adequacy of NAC's compliance with NRC requirements for the design, fabrication, assembly, testing, and procurement of the NAC MAGNASTOR VCC components. NAC is the license holder of the certificate of compliance (CoC) and designer of the NAC MAGNASTOR storage system.
The limited inspection scope included observations of construction activities, reviews of records, and interviews with personnel to determine whether a dry storage system, fabricated for use at an independent spent fuel storage installation (ISFSI), is constructed in accordance with the commitments and requirements specified in the safety analysis report, the NRCs corresponding safety evaluation report, Title 10 of the Code of Federal Regulations (10 CFR) Part 72, and the CoC including the technical specifications (TSs). The inspection will also determine whether the licensee (APS) properly reviewed the ISFSI construction activities for determination of no adverse impact for onsite operations or TSs. The enclosed report presents the results of this inspection, which were discussed with you and other members of the NAC and APS staff on November 21, 2024.
Based on the results of this inspection, no findings of significance were identified.
January 3, 2025
J. Hamman 2
In accordance with 10 CFR 2.390, Public inspections, exemptions, request for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm?adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-4154737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
Sincerely, Hector Rodriguez-Luccioni, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 721031
Enclosure:
NRC Inspection Report No.
721031/2025201 Signed by Rodriguez-Luccioni, Hector on 01/03/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management Docket:
721031 Report.:
721031/2025201 Enterprise Identifier: I2025201-0000 Certificate Holder:
NAC International, Incorporated Facility:
Palo Verde Generating Station Location:
Tonopah, Arizona Inspection Dates:
November 18, 2024, through November 21, 2024 Inspection Team:
Marlone Davis, Senior Transportation and Storage Safety Inspector, Team Leader Approved By:
Hector Rodriguez-Luccioni, Branch Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
2 U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management EXECUTIVE
SUMMARY
NAC International, Inc.
NRC Inspection Report 721031/2025201 On November 18, 2024, through November 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) inspection team performed an announced onsite inspection of NAC International, Incorporated (NAC) that involved observing construction activities at the Palo Verde Generating Station (PVGS) in Tonopah, AZ. NAC is currently under contract with Arizona Public Service Company (APS) to fabricate components associated with the NAC MAGNASTOR Vertical Concrete Cask (VCC) storage system for certificate of compliance (CoC) docket number (No.)
72-1031. The inspection team completed the inspection activities on November 21, 2024.
The purpose of the inspection was to review and assess the adequacy of the construction activities related to the design, fabrication, assembly, testing, procurement, and repair of the MAGNASTOR VCCs storage system to determine if NAC conducted these activities in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 72, Packaging and Transportation of Radioactive Material, selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance, safety analysis report (SAR), safety evaluation report, the Quality Assurance (QA) Program, and the CoC including the technical specifications (TSs). The inspection also determined whether the licensee (APS) properly reviewed the independent spent fuel storage installation (ISFSI) construction activities for determination of no adverse impact for onsite operations or TSs.
Onsite Fabrication/Construction Procurement Control and 10 CFR Part 21 The team determined that NAC received materials, components, and other equipment that met design procurement specifications and that the procurement specifications conformed to the design commitments and requirements contained in the SAR, CoC, and TSs. The team also determined that NAC had provisions in place for reporting defects which could cause a substantial safety hazard, as required by 10 CFR Part 21. The team noted that NAC's and APSs personnel were familiar with the reporting requirements of 10 CFR Part 21 (section 1.1).
Onsite Fabrication/Construction Design Control Activities The team determined that for the items selected for review that NAC implemented adequate design control measures. The procurement/fabrication specification was consistent with the design commitments and requirements documented in the SAR, CoC, and TSs. Additionally, for selected design changes, NAC established an effective method for tracking, evaluating, and dispositioning changes to the MAGNASTOR VCCs. The team noted that NACs personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality control associated with the construction of the MAGNASTOR VCCs. The team also noted that NAC had properly trained and qualified individuals performing activities affecting quality and personnel contained the required certification (section 1.2).
3 Onsite Fabrication/Construction Quality Assurance Control Activities The team determined, for the items selected for observation and review that NAC conducted fabrication and test activities consistent with the fabrication specification, which met the SAR and CoC No. 1031 and was in accordance with the NRC approved QA Program. The team determined that NAC performed audits/surveillances for activities related to important to safety (ITS) components and documented non-conforming reports and deficiencies for identified fabrication issues along with their corrective actions (section 1.3).
4 REPORT DETAILS 1.0 Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation (Inspection Procedure (IP) 60853)
The NRC inspection staff (team) performed a limited scope inspection of IP 60853. In accordance with Inspection Manual Chapter (IMC) 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-Than-Class C Waste at ISFSIs and for 10 CFR Part 71 Transportation Packagings, the only inspection requirements of IP 60853 that the team needs to perform are sections 02.01, 02.02, and 02.03.
1.1 Onsite Fabrication/Construction Procurement Control and 10 CFR Part 21 1.1.1 Inspection Scope The team reviewed selected fabrication drawings, quality procedures (QPs), and records related to the concrete and rebar materials, measuring and test equipment (M&TE) used for testing, and procurement services to determine if the fabrication, testing, and construction activities met procurement specifications. This review included a comparison of the purchase orders (POs) requirements with procurement/construction specification associated with the design and fabrication of the VCCs. The team reviewed NAC's processes that addressed procurement, including receipt inspection, traceability of material, and commercial grade dedication. The team also reviewed the procurement specification to determine if the specification conform to the design commitments and requirements contained in the SAR and CoC No. 1031. The team reviewed the following documents:
QP 7-1, Control of Purchased Items and Services, revision 13 QP 7-2, Acceptance of Documentation for Subcontracted Items and Services, revision 18 NAC Procurement/Construction Specification, MAGNASTOR Concrete Cask Concrete and Rebar, No. 71160-S-07, revision 4, dated November 2020 Project Plan 30032-PM-001, Rev. 2, MAGNASTOR Engineering Services &
Hardware Supply - APS PVNGS, dated January 23, 2018 Drawing No.: 30032-062, Reinforcing Bar and Concrete Placement, Concrete Cask MAGNASTOR, APS, sheets 1-4, revision 2 30032-P-02, Installation/Inspection Checklist for Cask No. 187 NAC PO# 846818 (concrete)
NAC PO# 846819 (rebar)
In addition, the team reviewed NACs approved procedure QP 16-2, "Potential Significant Deficiencies and Defects and Regulatory Reporting, revision 10, to determine if provisions were in place for reporting defects that could cause a substantial safety hazard from issues identified during construction. This review also included an assessment for compliance with 10 CFR 72.242(d).
5 1.1.2 Observation and Findings The team assessed that NAC procurement specification conformed to the design commitments and requirements contained in the SAR and CoC No. 1031 for the fabrication of the MAGNASTOR VCCs at the PVGS. The team determined that NAC received materials, components, and used equipment that met design procurement specifications. The team also assessed that NAC has provisions in place for evaluating deviations and reporting defects that could cause a substantial safety hazard, as required by 10 CFR Part 21 and established regulatory reporting guidance for 10 CFR 72.242(d).
No findings of significance were identified.
1.1.3 Conclusions The team concluded that NAC received materials, components, and other equipment that met design procurement specifications and that the procurement specifications conformed to the design commitments and requirements contained in the SAR, CoC, and TSs. The team also determined that NAC had provisions in place for reporting defects which could cause a substantial safety hazard, as required by 10 CFR Part 21.
The team noted that NAC's and APSs personnel were familiar with the reporting requirements of 10 CFR Part 21.
1.2 Onsite Fabrication/Construction and Design Control Activities 1.2.1 Inspection Scope The team interviewed selected personnel and reviewed the procurement/construction specification and fabrication drawings against the licensing drawings to determined that NAC implemented adequate design controls. The team reviewed the procurement specification to determine if the specification conform to the design commitments and requirements contained in the SAR and CoC No. 1031. Additionally, the team reviewed the project plan, commercial grade dedication plan and observed fabrication activities to determine NACs knowledge of designated fabrication techniques, testing requirements, and quality controls associated with the construction of the MAGNASTOR VCCs. The team also requested applicable documentation on design changes and whether NAC evaluated those changes using the 10 CFR 72.48 process. Below are some of the documents the team reviewed associated construction and design control activities:
NAC Procurement/Construction Specification, MAGNASTOR Concrete Cask Concrete and Rebar, No. 71160-S-07, revision 4, dated November 2020 Drawing No.: 71160-561, Structure, Weldment Concrete Cask, MAGNASTOR, APS, sheets 1-5, revision 9.
Drawing No.: 30032-061, Structure, Weldment Concrete Cask, MAGNASTOR, APS, sheets 1-5, revision 3.
Drawing No.: 71160-562, Reinforcing Bar and Concrete Placement, Concrete Cask MAGNASTOR, APS, sheets 1-4, revision 2.
Drawing No.: 30032-062, Reinforcing Bar and Concrete Placement, Concrete Cask MAGNASTOR, APS, sheets 1-4, revision 2.
6 30105-CGCCP-01, Commercial Grade Classification and Characteristics Plan for Reinforcing Steel and Concrete for the APS PVGS MAGNASTOR Batch 4 Project, revision 0.
1.2.2 Observation and Findings The team assessed that NAC implemented adequate design control measures. The procurement/construction specification was consistent with the design commitments and requirements documented in the SAR, CoC, and TSs. Based on the teams review, there were no unexplained discrepancies between the design and fabrication activities including the licensing and fabrication drawings. The team noted that NAC captured all requirements reviewed from the PO and procurement/construction specification associated with the design and fabrication of the VCCs. Additionally, for selected design changes, NAC established an effective method for tracking, evaluating, and dispositioning changes to the MAGNASTOR VCCs. The team noted that NACs personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality control associated with the construction of the MAGNASTOR VCCs. The team also noted that NAC had properly trained and qualified individuals performing activities affecting quality and personnel contained the required certification.
No findings of significance were identified.
1.2.3 Conclusions The team concluded that for the items selected for review that NAC implemented adequate design control measures. The team concluded that NACs personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality control associated with the construction of the MAGNASTOR VCCs. The team also noted that NAC had properly trained and qualified individuals performing activities affecting quality and personnel contained the required certification 1.3 Onsite Fabrication/Construction Quality Assurance Control Activities 1.3.1 Inspection Scope The team reviewed nonconformance records and a surveillance of a subcontractor to determine that NAC effectively implemented commercial grade surveys, nonconformance controls and corrective in accordance with the requirements of 10 CFR Part 72 and commitments made in their NRC approved QA Program. The team reviewed nonconformance reports and surveillance deficiencies to verify that NAC appropriately handled corrective actions in a time frame commensurate with their safety significance, as applicable. The team also reviewed the control of M&TE to evaluate how NAC identified, specified, and controlled tools and equipment used in in-field testing of the concrete. The documents are as follows:
QP 12-1, Control of Measuring and Test Equipment, revision 13 QP 15-1, Control of Nonconforming Items, revision 12 QP 16-1, Corrective Action Reports, revision 7 QP 18-3, Quality Assurance Surveillances, revision 5
7 24-S-26, Supplier Surveillance Report, dated 8/21/24 30105-PM-001, APS PVGS - MAGNASTOR Batch 4, revision 0 1.3.2 Observation and Findings Based on the sample selected, the team assessed that NAC established appropriate means to control the MAGNASTOR VCCs fabrication activities and testing requirements in accordance with applicable requirements as defined in their NRC approved QA Program and implementing procedures. The team assessed that NACs procurement/construction specification, design and fabrication drawings, work control procedures, and travelers were adequate. The team assessed that for the surveillances sampled for the ITS category B reinforcing bar and concrete placement.
The team determined that NAC conducted oversight with qualified and certified personnel, scheduled and evaluated the applicable quality associated with fabrication activities. The team assessed that, in most cases that NAC appropriately identified issues and implemented corrective actions in a time frame commensurate with their safety significance if identified during the construction activities and surveillances, as applicable.
No findings of significance were identified.
1.3.3 Conclusions The team concluded that NAC conducted fabrication and test activities consistent with the procurement/construction specification, which met the SAR and CoC No. 1031 and was in accordance with the NRC approved QA Program. The team determined that NAC performed audits/surveillances for activities related to ITS components and documented non-conforming reports and deficiencies for identified fabrication issues along with their corrective actions.
2.0 Entrance and Exit Meeting On November 18, 2024, the NRC inspection team discussed the scope of the inspection during an entrance meeting with you and other members of NAC and the APS staff. On November 21, 2024, the NRC inspection team discussed the preliminary results and observations during an onsite exit meeting with you and other members of NAC and the APS staff. Section 1 of the attachment to this report shows the attendance for the entrance and exit meetings.
Attachment ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES AND INDIVIDUALS INTERVIEWED Name Title Affiliation Entrance Exit Marlone Davis Team Leader NRC/DFM X
X Joyce Hamman Vice President of Quality NAC X
X Ryan Bailey Vice President, Storage NAC X
X Thomas Skronski Manager, Construction NAC X
X Kurt Steger Project Manager APS X
X 2.
INSPECTION PROCEDURES (IP) and GUIDANCE DOCUMENTS USED IP 60853 Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation IMC 2690 Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-Than-Class C Waste at ISFSIs and for 10 CFR Part 71 Transportation Packagings NUREG/CR6314 Quality Assurance Inspections for Shipping and Storage Containers NUREG/CR6407 Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description None None None None
2 4.
LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System APS Arizona Public Service Company CFR Code of Federal Regulations CoC Certificate of Compliance DFM Division of Fuel Management IMC Inspection Manual Chapter IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation ITS Important to Safety M&TE Measuring and Test Equipment NAC NAC International, Incorporated NRC U.S. Nuclear Regulatory Commission PO Purchase Order PVGS Palo Verde Generating Station QA Quality Assurance QP Quality Procedure SAR Safety Analysis Report TSs Technical Specifications VCC Vertical Concrete Cask VP Vice President 5.
DOCUMENTS REVIEWED Certificate holder and fabricator documents reviewed during the inspection were specifically identified in the Report Details above.