ML25210A568
| ML25210A568 | |
| Person / Time | |
|---|---|
| Site: | 07201031 |
| Issue date: | 08/07/2025 |
| From: | Gerond George, Jeremy Tapp NRC/NMSS/DFM/IOB |
| To: | Jeffrey Hamman NAC International |
| References | |
| IR 2025202 | |
| Download: ML25210A568 (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. 72-1031/2025202
Dear Joyce Hamman:
This letter refers to the inspection conducted on March 31, to April 3, 2025, at Kanadevia Corporation (KVC) formerly Hitachi-Zosen Corporation in Nagasu, Kumamoto, Japan. NAC International, Incorporated (NAC) is the certificate of compliance (CoC) holder and designer for the MAGNASTOR Dry Storage System and is a subsidiary of KVC. The purpose of the inspection was to verify and assess the adequacy of NAC's compliance with the U.S. Nuclear Regulatory Commission (NRC) requirements for the design, modification, fabrication, assembly, testing, and procurement of MAGNASTOR components. The inspection team held a debrief meeting on April 3, 2025, at the end of the onsite inspection week. The team held the final exit meeting on June 26, 2025, when the team received additional information requested from the inspection activities.
The inspection scope included observations of fabrication activities, reviews of records, and interviews with personnel to determine whether a dry cask storage system fabricated by an offsite entity and for use in an independent spent fuel storage installation, 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 and technical specifications; and to determine whether the outside fabricators activities are conducted in accordance with NRC-approved quality assurance program requirements.
Based on the results of this inspection, the NRC inspection team determined that one Severity Level IV violation of NRC requirements occurred. The NRC is treating this violation as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. The NRC inspection team described this NCV in the subject enclosed inspection report.
If you contest this violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington DC 205550001, with copies to: (1) the Director, Office of Nuclear Material Safety and Safeguards; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 205550001.
August 7, 2025
J. Hamman In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any), will be made available electronically for public inspection in the NRC Public Document Room (PDR) or from the NRC's 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 1800-3974209 or 301415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
Sincerely, Gerond George, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 721031
Enclosure:
Inspection Report No. 721031/2025202 Tapp, Jeremy signing on behalf of George, Gerond on 08/07/25
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME MDavis WWheatley JTapp for GGeorge DATE 7/30/2025 8/05/2025 8/07/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management Inspection Report Docket:
721031 Report:
72-1031/2025202 Enterprise Identifier: I-2025-202-0000 (NAC Part 72 Fabrication Inspection at Kanadevia)
Certificate Holder:
NAC International, Inc.
Facility:
Kanadevia Corporation (KVC)
Location:
Nagasu, Kumamoto, Japan Inspection Dates:
March 31, 2025, through April 3, 2025, and June 26, 2025 Inspection Team:
Marlone Davis, Senior Transportation and Storage Safety Inspector, Team Leader Jeremy Tapp, Senior Transportation and Storage Safety Inspector Azmi Djapari, Transportation and Storage Safety Inspector Approved by:
Jeremy Tapp acting on behalf of Gerond George, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
2
SUMMARY
NAC International, LLC NRC Inspection Report 721031/2025202 The planned inspection performed at Kanadevia Corporation (KVC) formerly Hitachi-Zosen Corporation in Nagasu, Kumamoto, Japan from March 31, through April 3, 2025, evaluated the ongoing fabrication activities related to the storage of spent nuclear fuel in an U.S. Nuclear Regulatory Commission (NRC, Commission) approved dry storage system (DSS). NAC International, Incorporated (NAC) is the certificate of compliance (CoC) holder and designer for the MAGNASTOR DSS and is a subsidiary of KVC. The team held the final exit meeting on June 26, 2025, when the team received additional information requested from the inspection activities.
The purpose of the inspection was to determine whether the DSS, fabricated by an offsite entity and for use in an independent spent fuel storage installation (ISFSI), is constructed in accordance with the commitments and requirements specified in the DSSs safety analysis report (SAR), the NRCs corresponding safety evaluation report, Title 10 of the Code of Federal Regulations (10 CFR) Part 72 and, as applicable, the CoC and technical specifications (TS) of the DSS. Additionally, the inspection was to determine whether the outside fabricators conducted activities in accordance with quality assurance program (QAP) requirements.
Based on the results of this inspection, the NRC inspection team determined that one Severity Level IV violation of NRC requirements occurred. The NRC is treating this violation as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NRC inspection team described this NCV in the subject enclosed inspection report.
List of Findings and Violations The team determined that a violation of 10 CFR 72.158, Control of special processes, occurred because the certificate holder, NAC, did not establish measures to ensure that special processes, including nondestructive examination (NDE), were controlled and accomplished in accordance with applicable codes. Specifically, while using a special process of NDE for liquid penetrant testing (PT), NACs fabricator, KVC, did not record indications in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, 2021 Edition,Section V, Article 6, paragraph T-691, Recording of Indications.
Additional Tracking Items None.
3 INSPECTION SCOPES An NRC team of inspectors conducted an inspection using applicable portions of inspection procedure (IP) 60852, ISFSI Component Fabrication by Outside Fabricators, which is a currently approved IP located on the NRCs public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. This public website provides the locations for currently approved IPs. The team reviewed selected procedures and records, observed activities, and interviewed personnel to assess the CoC holders performance and compliance with the Commission rules and regulations, license conditions, quality procedures (QPs), and applicable standards. The team declared the inspection complete when the objectives of the IP were met, consistent with Inspection Manual Chapter (IMC) 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-Than-Class C Waste at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation Packagings.
IP 60852 - ISFSI Component Fabrication by Outside Fabricators Design Controls (IP Section 2.01)
The team reviewed NAC MAGNASTOR licensing drawings against the design and fabrication drawings to verify the consistency of critical dimensions and material specification as well as testing and inspection requirements to determine whether they were consistent with the design and fabrication specifications. Specifically, the team focused on design commitments and requirements for important-to-safety (ITS) category A and B components of the MAGNASTOR Transportable Storage Canister (TSC) design from the NAC MAGNASTOR SAR to design and fabrication drawings and subsequently fabrication sequence diagrams (FSDs).
Additionally, the team reviewed the design controls that were in place for the transmittal and handling of design drawings received from NAC and how KVC transitioned from design to fabrication, as applicable. The team also evaluated the process for distributing controlled drawings.
Nonconformance and Corrective Action Controls (IP Section 2.02)
The team reviewed a sample of nonconformance records and corrective action reports (CARs) to verify that KVC and NAC effectively implemented nonconformance control and corrective action programs (CAPs) in accordance with the requirements of 10 CFR Parts 72 and 21. The team verified that KVC and NAC completed corrective actions for identified deficiencies and nonconformances in a technically sound and timely manner.
The team reviewed a sample of KVC nonconformance reports (NCRs) and CARs since 2022, as well as NAC vendor NCRs (VNCRs) written because of certain KVC NCRs that require NAC review and NAC finding reports (FRs) resulting from NAC audit and surveillance activities. The team also discussed the NCRs, CARs, VNCRs, and FRs with both KVC and NAC personnel, as applicable. The team also toured the shop floor and verified for those components with an open NCR whether KVC tagged or segregated the item as required by QPs.
4 Trained and Certified Personnel Controls (IP Section 2.03)
The team interviewed personnel and reviewed the QAP indoctrination and training records, including the annual QAP refresher training for a sample of KVC personnel working under their QAP. The team reviewed the records of selected quality inspectors and welders that performed nondestructive testing (NDT) and welding, respectively. In addition, the team reviewed lead auditor qualifications of both NAC and KVC personnel.
Fabrication, Assembly and Test Controls (IP Section 2.04)
The team reviewed KVCs fabrication drawings, FSDs, shop travelers, and associated procedures. For welding activities, the team reviewed weld procedure specifications and welder performance qualification records, along with records used as part of KVCs process for welding material control, such as the welding material request cards and welding operation records.
The team observed the following activities:
Dimensional inspection of the Damaged Fuel (DF) Basket Assembly Gas Tungsten Arc Welding of the DF Basket Assembly PT examination of the TSC Shell Visual inspection of the TSC Shell The team also reviewed the control of measuring and test equipment (M&TE) program to evaluate how KVC identified, specified, and controlled tools and equipment in accordance with applicable sections of their Quality Assurance Manual (QAM), quality standard procedures, and regulatory requirements. The team selected a sample of the M&TE used during the fabrication of the MAGNASTOR fuel baskets and TSCs. The sample included a review of shop travelers that identified the use of specific M&TE. The team selected a laser tracker, thermometer, clamp and light meters, and a welding power supply. The team reviewed calibration records to verify calibration dates, testing standards, and traceability of the associated M&TE. The team reviewed the calibration records to verify calibration dates, testing standards, and traceability of the associated M&TE.
Procurement Controls (IP Section 2.05)
The team reviewed KVCs processes that address procurement, including traceability and receipt inspection of material to verify that KVC properly implemented their QAP requirements and NAC provided adequate oversight of these activities. The team reviewed selected drawings and records and interviewed selected personnel to verify that the procurement specifications for materials, fabrication, inspection, and services performed at KVC met design requirements and requirements contained in the SAR and CoC. The team verified that NAC used a graded approach for identifying ITS components during the design process and applied this graded quality to components and material procurement documents for KVC fabrication activities. The team selected ITS components such as the shell assembly closure lid, mounting bolts, and damaged fuel basket assembly to verify procurement controls. The team reviewed the procurement documents specific to the fabrication of these components including purchase orders and receipt inspections.
5 Quality Assurance Program Controls (IP Section 2.06)
The team reviewed KVCs and NACs QAMs and various implementing QPs to assess the effectiveness of their QAP implementation. The team conducted reviews of both quality manuals, policies, and procedures, to determine whether NAC adequately controlled and implemented activities under their NRC approved QAP and quality activities subject to 10 CFR Part 72 regulations. The team reviewed procedures to verify if KVC and NAC clearly defined and documented the quality program authorities and responsibilities and that the quality assurance organizations functioned as independent groups.
Part 21 Controls (IP Section 2.07)
The team reviewed the 10 CFR Part 21 QP to verify if provisions were in place for reporting defects that could cause a substantial safety hazard. The inspectors requested a list of 10 CFR Part 21 evaluations and notifications associated with the fabrication activities and interviewed personnel to verify if they were familiar with the implementing procedure. The team also verified if KVC complied with 10 CFR 21.6, Posting requirements.
Audit Controls (IP Section 2.08)
The team reviewed the NAC audit program to determine if NAC scheduled, planned, and performed audits or surveillances of the fabricator (KVC) in accordance with their QAP. The team selected a sample of audits and surveillances from the time of the last NRC inspection to the present. The team reviewed the audit and surveillance results to determine if NAC identified deficiencies and if NAC and KVC addressed these deficiencies within their respective CAPs as appropriate. The team also evaluated whether NAC provided adequate supervision with quality control/quality assurance personnel to ensure appropriate oversight during fabrication activities.
Specifically, the team reviewed the KVC audit program to determine if KVC scheduled, planned, and performed internal audits and external audits of their suppliers of ITS materials, equipment, and services. The team selected a sample of audits from the time of the last NRC inspection to the present. The team focused on activities related to KVC fabrication activities of the MAGNSTOR TSC. The team reviewed the internal audit results to determine if KVC identified deficiencies and addressed these deficiencies within their CAP. The team also reviewed the results of the external audits performed on ITS Category A suppliers, which included mounting bolts for the DF basket assembly and the steel forging for the closure lid.
The team also reviewed the last two management reviews of the KVC QAP to determine whether KVC performed audits in accordance with approved procedures and performed effective reviews to assess the overall health of their QAP.
INSPECTION RESULTS During a review of NDE activities for the TSC shell, the team observed KVC personnel conduct PT on the longitudinal welds for the TSC inner shell. The qualified PT technician was inspecting the TSC shell following welding and grinding for indications using approved procedures. The inspection team noted several indications of bleed-out in the inspected area and asked the PT technician and supervisor about the indications. Both the PT technician and supervisor contributed the indications of bleed-out to the grinding performed prior to the PT examination and had determined that the indications were not relevant indications without documenting the
6 non-relevant indications. The team discussed this observation with KVC and questioned how the examiner was able to reach that conclusion without documenting or applying the acceptance criteria described in the qualified procedure. KVC stated that the PT technician made the assessment based on experience and personal judgment. However, the team noted that this was not in accordance with the ASME code and this was a violation of NRC requirements, specifically 10 CFR 72.158, Control of special processes.
Title 10 CFR 72.158, Control of special processes, states, in part, that the certificate holder shall establish measures to assure that special processes, including welding, heat treating, and NDT, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, criteria, and other special requirements.
Contrary to the above, as of June 2025, the certificate holder (NAC) and fabricator KVC did not establish measures to assure that special processes, including welding, heat treating, and NDT, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, criteria, and other special requirements.
Specifically, KVC did not establish measures to assure that the special process of NDT (i.e., dye liquid penetrant test) was controlled and accomplished in accordance with applicable codes.
KVC did not record indications in accordance with the requirements of ASME Boiler and Pressure Vessel Code,Section V, Article 6, Paragraph T-691, Recording of Indications, 2021 Edition. This paragraph states, in part, that non-rejectable indications shall be recorded as specified by the referencing Code Section, and rejectable indications shall be recorded. As a minimum, the type of indications (linear or rounded), location and extent (length or diameter or aligned) shall be recorded. KVC did not record any indications in accordance with the applicable code because the qualified technician used judgement and attributed the bleed-out (indications) to prior grinding without documenting the indications.
The team evaluated the violation using the traditional enforcement process in Section 2.2.2 of the NRC Enforcement Policy. The team determined that the violation was of more-than-minor safety significance in accordance with inspection guidance provided in Appendix E, Minor Examples of Vendor and QA Implementation Findings, Example 10e of IMC 0617 Vendor and Quality Assurance Implementation Inspection Reports, because the examiner did not record the indication which would have required an evaluation. The examination was deemed acceptable and was not re-performed. The team characterized the violation as a Severity Level IV violation in accordance with the NRC Enforcement Policy and Manual. KVC entered the issue into their CAP for resolution under CAR C-25-C-05. The team determined that because KVC entered this into their CAP, the violation was of low safety significance, and the issue was not repetitive or willful, the team is treating this violation as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy (72-1031/2025-202-01).
7 EXIT MEETING/DEBRIEFS The NRC inspection team held a debrief meeting on April 3, 2025, at the end of the onsite inspection week. The team held the final exit meeting on June 26, 2025, with Joyce Hammann, Vice President of Quality, when the team received additional information requested from the inspection activities.
DOCUMENTS REVIEWED Type Designation Description or Title Revision or Date 24-E-02 NAC Audit Report June 17, 2024 Nuclear Section September 2024 NTI October 2024 Nuclear Equipment Quality Assurance Section, September 2023 Audits Procurement Dept. 3 Ariake Team October 2023 CAR C-25-C-05 0
CAR C-24-C-14 0
CAR C-24-C-01 2
CAR C-24-C-06 5
CAR C-24-C-11 0
CAR C-23-C-01 1
CAR C-23-C-04 0
CAR C-22-C-06 4
CAR C-22-C-07 6
CAR C-22-C-08 4
Corrective Action Report FR 24-012 November 19, 2024 485-D-DF04A-1 and A-2 Corner Weldment 0
485-P-F01 Closure Lid 1
485-D-11 Shell Assembly Closure Lid Detail 0
485-D-DF11 Shell Assembly for (DF MAGNASTOR) Closure Lid Detail 0
485-P-S02 Shell 0
Drawings 485-P-P03A DF Basket Assembly 0
485-FSD-CS Fabrication Sequence Diagram Canister Shell 5
Fabrication Sequence Diagrams 485-FSD-DFBA Fabrication Sequence Diagram DF Basket Assembly 4
485-NCR-01 0
485-NCR-06 0
Nonconformance Reports 485-NCR-09 0
8 Type Designation Description or Title Revision or Date 485-NCR-10 0
485-NCR-12 0
485-NCR-13 0
485-NCR-16 1
474-NCR-05 0
475-NCR-01 0
475-NCR-07 0
VNCR 846359-01 1
Procurement Specifications 71160S-05-4B Procurement Specification MAGNASTOR TSC 4
UNB-2491 Mounting Bolts 0
UNB-9020 Steel Sheets (Shell) 0 Purchase Orders UNB-2448 Steel Forging 1
M311 (KVC)
Nonconformance Control 0
M321 (KVC)
Corrective Action 0
Q-30-1 (KVC)
Standard for Dedication of Commercial Grade Items 0
Q321 (KVC)
Corrective Action Standard 0
Q322 (KVC)
Implementation of Root Cause Analysis Standard 0
M-06-1 (KVC)
Indoctrination and Training 0
Qualification and Certification of Quality Assurance Audit Personnel 5
M-50-1 (KVC)
Examination, Inspection and Test 9
M-41-1 (KVC)
Welding Control 9
Q-01-2 (KVC)
Qualification Standard for Inspection and Test Personnel 9
Q-01-3 (KVC)
Audit Personnel Qualification Standard 0
Q-01-4 (KVC)
NDE Personnel Qualification and Certification Standard 9
Q202 (KVC)
Reporting Standard of Defects and Noncompliance 0
485-T-VT/PT (KVC)
Visual Weld Examination and Liquid Penetrant Examination Procedure 0
M0401(KVC)
Control of QA Manual 0
M901 (KVC)
Audits 0
Audits, Surveys and Corrective Action 11 QP 18-3 (NAC)
Quality Assurance Surveillance 5
M601 (KVC)
Measuring and Test Equipment Control 9
M602 (KVC)
Gauge Control 4
Procedures M-70-1 (KVC)
Handling, Storage, Shipping, and Preservation 0
9 Type Designation Description or Title Revision or Date F-10-1 Welding Material Control Standard 0
F-40-1 (KVC)
Handling and Storage Standard 0
Q101 (KVC)
Calibration Standard for Measuring and Test Equipment 13 Q102 (KVC)
Calibration Standard for Master and Standard Equipment 9
485-T-VI Visual Inspection Procedure 0
485-T-DT-B Dimensional Inspection Procedure 0
PT-SA-01 Record of Visual Weld/Liquid Penetrant Examination 0
Reports/Records VI-3 Visual Inspection Record 0
DT-270-99-2 Dimensional Inspection Record 0
Q-6GM2-M329 0
Welding Procedure Specification Q-6GM2-M335 0
24-S-15 June 24, 2024 24-S-29 January 3, 2025 23-S-26 April 7, 2023 Surveillances for Audits 22-S-43 July 22, 2022