ML20356A185

International - NRC Form 591S, Part 1, Inspection Report 07201008/2020202, 07201014/2020202, 07201032/2020202 and 72001040/2020202

ML20356A185
Person / Time
Site:	07201032, HI-STORM 100, 07201008, Holtec
Issue date:	12/21/2020
From:	Soler M Office of Nuclear Material Safety and Safeguards
To:	Soler M Holtec
MFDavis - NMSS/DFM/IOB - 301.415.7447
References
IR 2020202
Download: ML20356A185 (10)

Text

NRC FORM 591S PART 1 .,-,~-...., U.S. NUCLEAR REGULATORY COMMISSION f 't~<({°.

0 (10-2013) 10CFR2.201 t~ /j SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION

"'*o **

1. CERTIFICATE/QUALITY ASSURANCE PROGRAM (OAP) HOLDER: 2. NRG/REGIONAL OFFICE Holtec International Headquarters One Holtec Boulevard U.S. Nuclear Regulatory Commission Camden, New Jersey 08104 Mail Stop 3WFN 14C-28 Washington, DC 20555-0001 REPORT NUMBER(S) 72-1014/2020-202

3. CERTIFICATE/OAP DOCKET NUMBER(S) 4. INSPECTION LOCATION 5. DATE(S) OF INSPECTION 72-1008, 72-1014, 72-1032, and 72-1040 Turtle Creek, PA November 2 - 5, 2020 CERTIFICATE/QUALITY ASSURANCE PROGRAM HOLDER:

The inspection was an examination of the activities conducted under your OAP as they relate to compliance with the Nuclear Regulatory Commission (NRC) rules and regulations and the conditions of your OAP Approval and/or Certificate(s) of Compliance. The inspection consisted of selective examinations of procedures and representative records. interviews with personnel, and observations by the inspector. The inspection findings are as follows :

Based on the inspection findings, no violations were identified .

Previous violation(s) closed .

The violations(s), specifically described to you by the inspector as non-cited violations, are not being cited because they were self-identified, non-repetitive, and corrective action was or is being taken, and the remaining criteria in the NRC Enforcement Policy, to exercise discretion, were satisfied.

One Non-cited violation(s) was/were discussed involving the following requirement(s) and Corrective Actions(s):

10 CFR Part 72.150, "Instructions, procedures, and drawings," requires, in part, that the certificate holder shall prescribe activities affecting quality by documented instructions of a type appropriate to the circumstance.

Contrary to, prior to June 2, 2020, Holtec did not prescribe activities affecting quality with documented instructions of a type appropriate to the circumstances. Specifically, Holtec did not provide instructions to welders to assure they maintain line of sight and angle the weld torch to provide consistent weld depth for unique configurations and first of a kind fabrication activities. The welders needed instructions to prevent the failure of an important safety structural weld to prevent a loss of water from the water jacket used for shielding.

Holtec planned to enter this violation in their corrective action program or revise Quality Issue Number 2929.

During this inspection, certain of your activities, as described below and/or attached, were in violation of NRC requirements and are being cited in accordance with NRC Enforcement Policy. This form is a NOTICE OF VIOLATION, which may be subject to posting in accordance with 10 CFR 19.11.

(Violations and Corrective Actions)

Statement of Corrective Actions I hereby state that, within 30 days, the actions described by me to the Inspector will be taken to correct the violations identified. This statement of corrective actions is made in accordance with the requirements of 10 CFR 2.201 (corrective steps already taken, corrective steps which will be taken, date when full compliance will be achieved). I understand that no further written response to NRC will be required, unless specifically requested.

TITLE PRINTED NAME _,,-/ ,,, SIG~ATURE DATE CERTIFICATE/OAP Mark Soler REPRESENTATIVE Vice President of Quality Assurance NRC INSPECTOR Marlone F. Davis 12/21/2020 BRANCH CHIEF Leira Cuadrado-Caraballo for 12/21/2020 NRC FORM 591S PART 1 (10-2013)

INSPECTOR NOTES COVER SHEET Licensee/Certificate Holder Holtec International 1 Holtec Boulevard Camden, New Jersey 08104 Licensee/Certificate Holder contact Mr. Mark Soler Vice President, Quality Assurance of Holtec Docket Nos. 72-1014, 72-1032, and 72-1040 Inspection Report No. 72-1014/2020-202 Inspection Date(s) November 2 - 5, 2020 Inspection Location(s) Holtec Manufacturing Division (HMD)

Turtle Creek, Pennsylvania Inspectors Marlone Davis, Team Leader, Senior Storage and Transportation Safety Inspector (on-site)

Earl Love, Senior Storage and Transportation Safety Inspector (on-site)

Matthew Learn, Storage and Transportation Safety Inspector (remote)

Summary of Findings and Actions During the period of November 2 through 5, 2020, the U.S. Nuclear Regulatory Commission (NRC) conducted a team inspection of Holtecs implementation of their NRC-approved Quality Assurance Program for the review of fabricated equipment at HMD. The team discussed the results of this inspection on November 5, 2020, during a final exit meeting. The team identified one violation of NRC requirements in fabrication control. Holtec planned to enter this violation in their corrective action program for resolution. The team dispositioned the violation as a non-cited violation and assessed the significance as a Severity Level IV, which was consistent with the NRC Enforcement Policy and Manual.

Lead Inspector Marlone Davis Signature/Date

~;,u, r. Dau-u 12/21/2020 Inspector Notes Approval Leira Cuadrado-Caraballo Branch Chief Signature/Date h s To/'{" for 12/21/2020

Inspector Notes On November 2 - 5, 2020, a team of NRC inspectors conducted inspection activities at the Holtec Manufacturing Division (HMD) in Turtle Creek, Pennsylvania to verify and assess Holtec Internationals (Holtec) compliance with Title 10 of the Code of Regulations (10 CFR) Part 72 requirements for the design, modification, fabrication, assembly, testing, and procurement of the HI-STORM 100, and HI-STORM FW storage systems. HMD is a Division of Holtec, which fabricates important to safety (ITS) Category A, B, and C components and subcomponents of dry cask storage systems (DCSSs) that include multi-purpose canisters (MPCs), concrete overpacks, and transfer casks. Holtec is a certificate of compliance (CoC) holder and designer with an NRC Quality Assurance Program (QAP) approval for several storage systems and transportation packages. The CoCs associated with this inspection activity was as follows:

Model # Docket# Amendment# FSAR Revision HI-STORM 100 72-1014 12 17 HI-STORM 100 72-1014 13 18 HI-STORM FW 72-1032 3 6 The NRC had conducted one corporate inspection and one fabrication inspection since the last inspection at HMD. These inspections included one at Holtec Orrvilon in Orrville, Ohio, in August 2020, and Holtec Corporate Office in Camden, New Jersey, in May 2018, both reports are available through the NRCs Agencywide Documents Access and Management System (ADAMS), under ADAMS Accession Numbers (Nos.) ML20262G981 and ML180306A853, respectively. The NRC conducted these inspections to determine if Holtec performed fabrication and design activities in accordance with the requirements of 10 CFR Parts 21, 71, and 72, the applicable CoC, Final Safety Analysis Report (FSAR), and Holtecs NRC-approved Quality Assurance Program.

Similar to the previous inspections, the purpose of this inspection was to determine whether Holtec fabricated DCSS in accordance with the commitments and requirements specified in the FSAR, the NRCs corresponding safety evaluation report (SER), 10 CFR Part 72 and, as applicable, the CoC and technical specifications (TS).

The team conducted the inspection activity requirements in accordance with NRC Inspection Procedure 60852, ISFSI Component Fabrication by Outside Fabricators. The team observed fabrication activities, reviewed selected procedures and records, and interviewed personnel.

The team discussed the results of this inspection on November 5, 2020, during a final exit meeting. The team identified one violation of NRC requirements in fabrication control. Holtec planned to enter this violation in their corrective action program for resolution. The team dispositioned the violation as a non-cited violation and assessed the significance as a Severity Level IV, which was consistent with the NRC Enforcement Policy and Manual. This violation is described in Section 2.02 of this report.

2

INSPECTOR NOTES: AS DESCRIBED BELOW, THE TEAM CONDUCTED AND DOCUMENTED APPLICABLE PORTIONS OF 02.01 THROUGH 02.10 OF INSPECTION PROCEDURE (IP) 60852 USED FOR THIS INSPECTION 02.01: Determine whether the fabrication specifications are consistent with the design commitments and requirements documented in the Safety Analysis Report (SAR), and, as applicable, the Certificate of Compliance (CoC) or the site-specific license and technical specifications.

Design and Fabrication Controls The team reviewed the fabrication specifications associated with HI-TRAC 100-G transfer cask to determine if the fabrication specifications were consistent with the design commitments and requirements documented in the HI-STORM 100 FSAR Revision 20, and as applicable, the HI-STORM CoC No. 72-1014 and TS appendices. The review included the licensing drawings, design and fabrication drawings, and subsequently manufacturing project plans. The team reviewed the 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. Specifically, the team focused on the translation of design commitments and requirements for the ITS Category A, B, and C subcomponents of the HI-TRAC 100-G transfer cask. The team reviewed the following Holtec standard procedures (HSPs) associated with design and fabrication controls during the inspection to verify proper implementation.

• HSP-100202, Project Planning Product Realization and Project Execution, Revision 2

• HSP-100302, Design Specifications and Design Criteria Documents,

• HSP-100501, Engineering Drawings, Revision 4 The team did not identify any unexplained discrepancies between the design and fabrication specifications and the FSAR licensing drawings.

Documentation Controls The team reviewed a sample of documents to verify how HMD handled the control of documents and the storage of quality assurance records at the facility. The team specifically reviewed the following procedures associated with document control and quality records:

HQP-6.0, "Document Control," Revision 14 HQP-17.0, Quality Assurance Records, Revision 27 HSP-100601; Document Transmittal and Classification, Revision 0 Overall, the team assessed that HMD adequately identified fabrication drawings and shop travelers at various work locations with each component as applicable. The team also noted that the documents reflected the correct revisions, as required.

3

02.02 Determine whether corrective actions for identified fabrication deficiencies have been implemented in a time frame commensurate with their significance, and whether nonconformance reports documenting the deficiencies have been initiated and resolved.

Nonconformance and Corrective Action Controls The team reviewed selected records and interviewed personnel to verify that HMD personnel effectively implemented a nonconformance and corrective action control program in accordance with the Holtec approved NRC Quality Assurance Program and the requirements of 10 CFR Part 72. Specifically, the team reviewed Holtecs standard procedures (HSPs):

• HSP - 101502, Control of Nonconforming Conditions, Revision 1, and

• HSP - 101601, Corrective Actions, Revision 2 The team selected several nonconformance reports (NCRs) and quality issues (QIs) from September 2017 to October 2020. The team focused on QIs that were significant based on guidance provided in HSP 101601, and NCRs that required technical justifications. The team interviewed selected personnel to verify that HMD effectively implemented their corrective action and nonconformance control programs.

Overall, the team assessed that Holtec had an adequate nonconformance and corrective action program in place to resolve deficiencies. The team assessed that Holtec appropriately identified issues and implemented corrective actions in a time frame commensurate with their safety significance. As a part of the NCR and QI review, the team identified a violation of NRC requirements. Specifically, the team reviewed QI-2929 and NCR No. 2847105H-1, Revision 7 associated with a weld crack identified in a transfer cask fabricated at HMD, the HI-TRAC 100G.

Holtec wrote QI-2929 and NCR No. 2847105H-1 to resolve and disposition this cracked weld found during a loading operation at a licensees facility because of leaking water coming from the neutron shield of the transfer cask. The NCR noted the location of the weld as being between the neutron shield water jacket shell and water jacket bottom plate below the lower trunnion. The HMD traveler and fabrication drawing required a 3/16-inch bevel weld in order to join the neutron shield water jacket shell and plates to the lower trunnion. Holtec signed the traveler off as completed on June 2, 2020.

Holtec performed an investigation of the as found configuration in QI-2929. Holtec noted inconsistencies in the penetration to the side wall on the bottom plate throughout the depth and at the root of the weld joint. The investigation identified a lack of fusion in the weld and inconsistency in the weld penetration depth. As stated in QI-2929, the lack of fusion created a condition wherein the weld did not meet the requirements of the drawing and traveler as having a 3/16-inch bevel weld.

As a part of this investigation, Holtec performed a failure mode and effect analysis (FMEA) on the cracked weld. The FMEA identified that an improper welding technique was the likely cause of the weld failure. Specifically, Holtec examined the weld location and determined that the trunnion directly above this area most likely obstructed the welders access to this specific weld location of the weld joint. Based on the configuration and position of the weld location, the welder had to angle the weld torch to get the most consistent weld depth penetration. The QI noted that with only a few inches between the trunnion and weld, this configuration likely caused the weld technician to angle the weld torch at a shallower angle, reducing the ability to provide a consistent weld depth. The FMEA also mentioned that this probably forced the weld technician 4

into an uncomfortable position limiting their line of sight while making the weld. The team interviewed Holtec personnel and discussed the information provided in the QI and NCR. In discussions with Holtec, the team asked questions about the qualifications of performing such welds with limiting line of sight and uncomfortable position. Holtec stated that these welds are generally done with the skill of the craft and that weld technicians know to position their bodies to maintain line of sight and angle the weld torch to provide a consistent weld depth. Holtec contributed the root cause as a human performance issue.

The team also asked about the importance of this weld. The team noted that the weld is a structural weld that can impact the water jacket and trunnion safety functions. Based on the review of the traveler, the interviews conducted, and the results of Holtecs investigation, the team determined that the traveler instructions did not prescribe activities to assure that welders appropriately angled their weld torch when challenged with limited line of sight or unique configurations since Holtec did not qualify welders for these types of situations. The team noted that Holtec was relying on the skill of the craft for an ITS structural weld, which if not performed correctly, could rendered the transfer cask non-functional with a loss of water from the water jacket and/or impact the lifting trunnion. The team determined that this was a violation of NRC requirements 10 CFR 72.150.

10 CFR 72.150, Instructions, procedures, and drawings requires, in part, that the certificate holder, shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed. The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, prior to June 2, 2020, the certificate holder did not prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances or include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactory accomplished. Specifically, Holtec did not prescribe activities to assure that welders appropriately angled the weld torch based on challenging configurations (i.e., limited sight lines and position of the weld location) to ensure a consistent weld depth for a weld that maintains a structural boundary for the water jacket and lifting trunnion. Consequently, this weld failed while in service and caused the water jacket to lose water and brought into question the ability of the water jacket and trunnion to perform their safety function. Holtec plans to enter this violation in their corrective action program for resolution or update QI-2929 to address this issue.

The team assessed the significance of the violation using the NRC Enforcement Policy. The team determined that the violation was more than minor because it was like an example listed in Inspection Manual Chapter (IMC) 0617, Vendor and Quality Assurance Implementation Inspection Reports. Specifically, it was similar to example 6.a. of Appendix E to IMC 0617, the failed weld put into question the materials (water jacket) ability to meet its safety function.

Specifically, the weld boundary performs both a function of retaining water in the transfer casks water jacket for neutron shielding and is a structural component of the transfer cask trunnion.

The team characterized the violation as a Severity Level IV violation in accordance with the NRCs Enforcement Policy example 6.5.d.1 because the inspectors concluded that the licensee failed to meet a regulatory requirement, including a QA criterion that was more than minor.

5

Because this violation was of very low safety significance and Holtec plans to enter the violation into their corrective action program or revise QI-2929, it is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.

02.03 Determine whether individuals performing quality-related activities are trained and certified where required.

The team reviewed selected records and interviewed personnel to evaluate if trained and certified individuals were performing quality related activities as required such as welding, inspections, nondestructive examinations. The team reviewed completed welding, inspections, and nondestructive examination records (e.g., helium leak, ultrasonic, liquid penetrant, and radiography) to determine whether individuals performing activities with trained and qualified personnel in accordance with applicable quality procedures. Specifically, the team reviewed various inspection and examination qualification records, weld data sheets, procedure specifications, and welder performance qualification/proficiency records.

The team assessed that HMD had trained and certified personnel performing tasks such as inspections, welding, and nondestructive examinations.

02.05 Determine whether: a) Materials, components, and other equipment received by the fabricator meet DCSS design procurement specifications, and b) The procurement specifications conform to the design commitments and requirements contained in the SAR and, as applicable, the CoC or the site-specific license and technical specifications.

The team reviewed Holtec's process that addresses procurement, including traceability and receipt inspection, to verify it was being properly implemented at HMD. The team reviewed selected drawings and records and interviewed selected personnel to verify that the procurement specifications (PSs) for materials, fabrication, inspection, and services performed at HMD met design requirements of the HI-STORM 100 and HI-STORM FW MPCs. The team reviewed the procurement documents specific to the MPCs and HI-TRAC 100 G transfer cask and the following quality procedures:

• HQP-7.0, Control of Purchased Items and Services, Revision 21

• HQP-8.0, Identification and Control of Items, Revision 9

• HSP-100401, Processing of Purchase Orders, Revision 2

• HSP-100402, Purchase Specifications, Revision 2

• HSP-100701, Receipt Inspection, Revision 5

• HSP-100704, Approved Vendor List, Revision 4

• PS-117, Fabrication Specification for the HI-TRAC Transfer Cask 100 and 125, Revision 26

• PS-101, Procurement Specification for the Fabrication of Holtec HI-STORM MPCs, Revision 75

• PS-301, Procurement Specification for the Fabrication of MPC-32ML, MPC-37, and MPC-89 for the HI-STORM FW, Revision 11 The team verified that Holtec used a graded approach for identifying ITS components during the design process and applied this graded quality level to component and material procurement documents. The team reviewed a sample of ITS Category A and B related material supplier, 6

fabrication and services purchase orders (POs) along with receiving inspection records, as applicable. Specifically, the team reviewed external audit reports of Dubose National Energy Services (HI-TRAC trunnion forgings), Mittal Steel (shell plate), Lincoln Electric (weld material),

Element Materials Technology (material testing and nondestructive examination (NDE) services), Exelon Power Labs (calibration and material testing) and Industrial Testing Lab Services (NDE, Inspection and material testing).

Overall, the team assessed that Holtec had adequate control of the procurement process for the ITS Category A and B components reviewed. The team determined that Holtec procured ITS components consistent with design requirements and their implementing procedures. Holtecs material traceability, procurement, and receipt inspection controls were adequate. The team determined that the POs were adequate and specified the applicable criteria and requirements including Part 21. The material ordered and received at HMD appear to meet the design requirements, the critical characteristics and were adequate for the material dedicated, as applicable. Additionally, Holtec verified and maintained the traceability throughout the procurement and receipt process. The team determined that Holtec purchased the components from vendors currently on the Holtecs Approved Suppliers List (ASL). Procurement personnel clearly understood the procurement process and the procedures used. Methods used to approve addition of suppliers to the ASL were appropriate and the audits and surveillances used to qualify and maintain suppliers on the ASL were adequate.

02.06 Determine whether DCSS components are being fabricated per approved quality assurance (QA) and 10 CFR Part 21 implementing procedures and fabrication specifications.

Fabrication Controls The team evaluated Holtecs control of the fabrication process through limited observations, examinations, and personnel interviews in the areas of fabrication and assembly, test and inspection. The team reviewed various Holtec final assembly documentation packages and certification records associated with completion of cask components in accordance with Holtecs NRC QAP, implementing procedures and standards. The completed documentation packages (CDP), component completion records (CCR), fabrication/licensing drawings, and procurement specifications:

• CDP No.: DOC-1026-012, Revision 0 dated July 13, 2020, HI-TRAC-100G (72-1014),

S/N 2847105H-1125499-1-A;

• Fabrication Drawing: 11254, Revision 7

• License Drawing: 11396 Revision 4

• Procurement Specification: PS-117, Revision 26

• Licensee: Ginna Nuclear Power Plant

• CDP No.: DOC-101-099, Revision 0 dated July 29, 2019, MPC-89 (72-1032), S/N: 99,

• Fabrication Drawings: 8728 Revision 22, 8798 Revision 19

• License Drawing: 6512 Revision 31

• Procurement Specification: PS-301, Revision 10

• Licensee: Nine Mile Point Nuclear Station

• CDP No.: DOC-1021-697, Revision 0 dated 5, 2020, MPC-68M (72-1014), S/N: 697,

• Fabrication Drawings: 8728 Revision 22, 8798 Revision 19

• License Drawing: 6512 Revision 31 7

• Procurement Specification: PS-301, Revision 10

• Licensee: Pilgrim Nuclear Power Station Overall, design and fabrication controls were adequate with respect to the transmittal and handling of production drawings received from Holtecs corporate office and how HMD transitioned these into production activities. The team verified that all aspects of the design process were verifiable, controlled, and traceable from the onset of the design through the completion of systems fabrication, assembly and testing. Based on the teams assessment, there were no issued identified with the fabrication specifications or fabrication drawings.

Measure and Test Equipment (M&TE)

The team reviewed selected measuring and test equipment including records (e.g., radiographic densitometer, helium gas leak standard, distance meter, ultrasonic thickness meter) and procedures to assure that equipment used in activities affecting quality were properly controlled and calibrated. The team compared a sampling of measuring and test equipment in current use for fabrication activities and determined overall compliance to procedural requirements. The calibration records reviewed documented the date of calibration, item description, serial number, due date for next calibration, calibration frequency, "As-found" and "As Left" condition at each calibration or check point, reference procedure used, test standard identification, and allowable tolerance; as applicable for each device.

Overall, Holtec adequately implemented measuring and test equipment calibration, tracking, and record retention requirements.

02.07 With regard to fabrication activities, determine whether: a. They are conducted under an NRC-approved QAP (10 CFR 72.140). b. The provisions of 10 CFR Part 21, Reporting of Defects and Noncompliance for reporting defects that could cause a substantial safety hazard have been implemented. c. The fabricators personnel are familiar with the reporting requirements of 10 CFR Part 21. d. The fabricator has complied with 10 CFR 21.6, Posting requirements.

The team reviewed HSP-101501, "Reporting of Defects and Noncompliances per 10 CFR Part 21, Revision 0, to evaluate if provisions were in place for evaluating deviations that could cause a substantial safety hazard and complete the required notification in a timely manner. The team requested a list of Part 21 evaluations and notifications associated with the fabrication of Holtecs DCSS and interviewed personnel to verify if they were familiar with the implementing procedure HSP-101501. The team also reviewed HMDs posting of Part 21 requirements in accordance with the 10 CFR 21.6, Posting requirements.

The team assessed that HMD has provisions in place for evaluating deviations and reporting defects, as required by 10 CFR Part 21. The team noted that HMD did not have any Part 21 reports within the last three years. The team also noted that HMD posted Part 21 requirements throughout their fabrication facility.

8

02.08 With regard to QA activities, determine whether: a. The fabricator has been audited by either the licensee or CoC holder. b. For selected audits and inspection findings from (as applicable) QA audit or surveillance and/or inspection reports issued in the previous 2 years, the findings were appropriately handled with corrective actions implemented in a time frame commensurate with their safety significance. c. Supervision and QC/QA personnel perform appropriate oversight during fabrication activities.

The team reviewed Holtec's internal audits and surveillances to determine if Holtec at HMD scheduled, planned, and performed audits and surveillances in accordance with their approved implementing procedures. The team reviewed procedures, schedules, plans and records associated with the internal audit program. The team reviewed internal audit reports from the previous three years. The team also reviewed corrective actions associated with audit findings as applicable. Additionally, the team reviewed auditor qualification and certification records.

The team reviewed the following procedures:

• HQP-18.0, Audits, Revision 0

• HSP 101801, Certification of Audit Personnel, Revision 0

• HSP 101802, Audits, Revision 3

• HSP 101803, Internal QA Surveillance and Document Reviews, Revision 0 Overall, the team assessed that Holtec adequately implemented their internal audit program as described in HQP-18.0. The team noted that Holtec conducted the audit program in accordance with their NRC-approved QAP requirements. The team assessed that Holtec appropriately identified issues and implemented corrective actions in a time frame commensurate with their safety significance.

9