The licensee identified that during the Monticello 2008
ISFSI loading campaign a contractor performing
non-destructive examinations (
NDE) on two dry shielded canisters (
DSCs) failed to follow a step of TriVis Procedure QP-9.202,Revision 3, Color Contrast
Liquid Penetrant (
PT) Examination Using the Solvent-Removable Method, which required the base metal temperature of the surface for the
NDE to be below 250 degrees F. Specifically, the base metal temperature for
DSC 002 was 270 degrees F and 253 degrees F for
DSC 005 when the
NDE was performed. The licensee immediately evaluated the situation and held a stand down to emphasize the importance of procedural adherence. Since the loaded and welded canisters were already stored in the Horizontal Storage Modules on the
ISFSI pad at the
time of discovery of the discrepancies, the licensee performed qualification
PT examinations using two comparator blocks at a procedural non-standard temperature of 325 degrees F. The
NDE products adequately identified flaws on the comparator blocks even beyond the qualified procedure range for the base metal temperature. Title
10 CFR 72.150, Instructions, Procedures, and Drawings, requires, in part, that the licensee prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and requires that these instructions, procedures, and drawings be followed. The violation was addressed by traditional enforcement since
10 CFR Part 72 is not risk based and is not covered under the Reactor Oversight Process. The inspectors reviewed the examples in the
Enforcement Policy, Supplement I and determined that the failure to follow the procedure was a violation that had more than minor safety or environmental significance but did not rise to a
Severity Level I, II, or III violation due to the above mentioned results of the comparator blocks and the fact that the test port plug (weld no. 5) did not serve a structural or pressure retaining function. The inspectors determined that the violation had more than minor safety significance because failure to follow procedures and keep the base metal temperature below the temperatures at which the
PT examination materials function properly could have
lead to errors in identifying potential flaws in more critical welds that serve as pressure boundaries. The licensee entered these issues into its corrective action program as
AR 01156986 and
AR 01155771