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{{#Wiki_filter:Enclosure 2 FY22 Summary of Independent Spent Fuel Storage Installation Inspection Findings Type       Licensee/     Description                                             Applicable   Category CoC Holder                                                             Regulation SL IV - NCV NAC           NAC failed to obtain a CoC amendment for changes to     10 CFR 72.48 Design International ACI-318 requirements for the MAGNASTOR cask             Changes,     Changes system that required a change to the specifications     Tests, and incorporated in the MAGNASTOR System CoC No.             Experiments 1031 Amendments 0-6.
{{#Wiki_filter:Enclosure 2 FY22 Summary of Independent Spent Fuel Storage Installation Inspection Findings
SL IV - NCV NAC           Petersen failed to ensure a final dimensional           10 CFR       Procedural International verification occurs after adjusting the MAGNASTOR       72.150       Adherence fuel basket within fabrication procedures.               Instructions, Procedures, and Drawings SL IV - NCV NAC           Petersen failed to perform an adequate Magnetic         10 CFR       Testing International particle testing (MT) inspection of a fuel tube seam     72.158 weld.                                                   Control of Special Processes SL IV - NOV ORANO-       Container Products Corporation (CPC) took               10 CFR       Corrective Transport     inadequate corrective actions during the previous       71.133       Action Logistics     inspection to ensure that applicable suppliers on its   Corrective International QSL received a triennial audit as required by the CPC   Action Inc.         QAM Section QAP-1007, and that the QSL was maintained current with qualified vendors. Specifically, Airgas Performance Plus Division and Branham Corporation have not been audited in the past three years but remained on the QSL.
 
SL IV - NCV TN           10 CFR 72.48(c)(1)(ii)(B) - Change incorporated in the   10 CFR 72.48 Design Americas,     CoC. TN made changes in the spent fuel storage cask     Changes,     Changes LLC           design as described in sections A.2.1.4 and A.2.4.2 of   Tests, and the NUHOMS EOS UFSAR (as updated)                       Experiments without meeting the requirements in the CoC.
Type Licensee/ Description Applicable Category CoC Holder Regulation
 
SL IV - NCV NAC NAC failed to obtain a CoC amendment for changes to 10 CFR 72.48 Design International ACI-318 requirements for the MAGNASTOR cask Changes, Changes system that required a change to the specifications Tests, and incorporated in the MAGNASTOR System CoC No. Experiments 1031 Amendments 0-6.
SL IV - NCV NAC Petersen failed to ensure a final dimensional 10 CFR Procedural International verification occurs after adjusting the MAGNASTOR 72.150 Adherence fuel basket within fabrication procedures. Instructions, Procedures, and Drawings SL IV - NCV NAC Petersen failed to perform an adequate Magnetic 10 CFR Testing International particle testing (MT) inspection of a fuel tube seam 72.158 weld. Control of Special Processes SL IV - NOV ORANO-Container Products Corporation (CPC) took 10 CFR Corrective Transport inadequate corrective actions during the previous 71.133 Action Logistics inspection to ensure that applicable suppliers on its Corrective International QSL received a triennial audit as required by the CPC Action Inc. QAM Section QAP-1007, and that the QSL was maintained current with qualified vendors. Specifically, Airgas Performance Plus Division and Branham Corporation have not been audited in the past three years but remained on the QSL.
SL IV - NCV TN 10 CFR 72.48(c)(1)(ii)(B) - Change incorporated in the 10 CFR 72.48 Design Americas, CoC. TN made changes in the spent fuel storage cask Changes, Changes LLC design as described in sections A.2.1.4 and A.2.4.2 of Tests, and the NUHOMS EOS UFSAR (as updated) Experiments without meeting the requirements in the CoC.
Specifically, ORANO modified the UFSAR requirements for the MX-LC without performing an evaluation for an accident drop as required by CoC Condition 5, Heavy Loads Requirements and TS 5.2.1 because the MX-LC failed to meet the single failure proof requirements in the ASME NOG-1 2015 standard.
Specifically, ORANO modified the UFSAR requirements for the MX-LC without performing an evaluation for an accident drop as required by CoC Condition 5, Heavy Loads Requirements and TS 5.2.1 because the MX-LC failed to meet the single failure proof requirements in the ASME NOG-1 2015 standard.
SL IV - NCV TN           10 CFR 72.48(d)(1)(c)(2)(i) and (c)(2)(vi)               10 CFR 72.48 Design Americas,     TN revised UFSAR to remove the words to prevent         Changes,     Changes LLC           boiling in the annulus and instead provided guidance   Tests, and on how to manage the TC/DSC annulus water level         Experiments during loading and unloading. TN failed to provide a bases for the determination that the presence of boiling water in the DSC and TC annulus does not require a CoC amendment.
SL IV - NCV TN 10 CFR 72.48(d)(1)(c)(2)(i) and (c)(2)(vi) 10 CFR 72.48 Design Americas, TN revised UFSAR to remove the words to prevent Changes, Changes LLC boiling in the annulus and instead provided guidance Tests, and on how to manage the TC/DSC annulus water level Experiments during loading and unloading. TN failed to provide a bases for the determination that the presence of boiling water in the DSC and TC annulus does not require a CoC amendment.
Encl. 2 - 1


SL IV - NCV TN       TN failed to subject design changes, including field     10 CFR     Design Americas, changes, to design control measures commensurate         72.146     Changes LLC       with those applied to the original design in that TN     Design supported a field change for a general licensee and did Control not properly analyze for tornado wind pressures without considering all assumptions from the original design.
Encl. 2 - 1 SL IV - NCV TN TN failed to subject design changes, including field 10 CFR Design Americas, changes, to design control measures commensurate 72.146 Changes LLC with those applied to the original design in that TN Design supported a field change for a general licensee and did Control not properly analyze for tornado wind pressures without considering all assumptions from the original design.
SL IV - NOV Croft     Croft took inadequate corrective action from the NRC     10 CFR     Corrective 2017 inspection of Croft and the NRC 2019 inspection     71.133     Action of Croft fabricator Oxford Engineering Limited.         Corrective Specifically, in 2017, Croft wrote Corrective Action     Action Report (CAR) 136 to address that Croft Associates Procedure (CAP) 12-01, Issue S, Audit Procedure, failed to require a periodicity for internal audits as required by 10 CFR, Section 71.137, Audits to ensure all applicable quality assurance criteria are audited on a periodic basis. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected. In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition.
 
SL IV - NOV Croft Croft took inadequate corrective action from the NRC 10 CFR Corrective 2017 inspection of Croft and the NRC 2019 inspection 71.133 Action of Croft fabricator Oxford Engineering Limited. Corrective Specifically, in 2017, Croft wrote Corrective Action Action Report (CAR) 136 to address that Croft Associates Procedure (CAP) 12-01, Issue S, Audit Procedure, failed to require a periodicity for internal audits as required by 10 CFR, Section 71.137, Audits to ensure all applicable quality assurance criteria are audited on a periodic basis. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected. In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition.
However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In 2019, Croft wrote CAR 147 to address that CAP 06-08, Approved Supplier, Step 2.2.1 required that a Quality Category A supplier shall have a current assessment and approval to an appropriate quality system standard. Croft assessed Oxford Engineering Limited to qualify them to encompass the additional requirements of 10 CFR Part 71, but Oxford Engineerings internal auditor did not meet those requirements, nor did Oxford Engineering have a quality procedure or process in place for qualifying internal auditors. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In 2019, Croft wrote CAR 147 to address that CAP 06-08, Approved Supplier, Step 2.2.1 required that a Quality Category A supplier shall have a current assessment and approval to an appropriate quality system standard. Croft assessed Oxford Engineering Limited to qualify them to encompass the additional requirements of 10 CFR Part 71, but Oxford Engineerings internal auditor did not meet those requirements, nor did Oxford Engineering have a quality procedure or process in place for qualifying internal auditors. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.
In addition, during the 2022 inspection, several Croft Encl. 2 - 2


internal audits were sampled, and it was determined that no CARs had been written when findings had been identified as a result of the audits. CAP 12-01, Audit Procedure, Section 2.3 states that when carrying out an internal audit, nonconformances must be recorded on the CAR database.
In addition, during the 2022 inspection, several Croft
SL IV - NCV Croft        Inadequate procedures. CAP- 02-02, Project Quality        10 CFR        Procedural Plan; CAP-02-04, Project Specifications; and CAP      71.111        Adequacy 05, Project Plan; are no longer current with what Croft    Instructions, is actually doing to fill out Croft form QF 376, Project  Procedures, Quality Plan. The form QF 376 had been revised, but        and Drawings procedures CAP 02-02, CAP 02-04, and CAP 02-05, in which procedural guidance was to be provided on how to fill out QF 376, were no longer current with what Croft was actually doing to fill out form QF 376.
SL IV - NCV Xcel Energy/  SeAH Besteel Corpration's (SBC) corrective action          10 CFR        Procedural TN Americas  procedure failed to provide sufficient guidance to        72.150        Adequacy perform root cause analysis for significant conditions    Instructions, adverse to quality to determine the corrective action      Procedures, necessary to preclude repetition.                          and Drawings SL IV - NCV NAC          Hitachi Zosen failed to perform an adequate audit of a    10 CFR        Procurement International suppliers QA program to ensure it meets all applicable    72.154 requirements of 10 CFR Part 72, Subpart G.                Control of purchased material, equipment, and services Enforcement Limerick      The inspectors identified a violation of 10 CFR 72.48      10 CFR 72.48  Tornado Discretion  Generating    associated with tornado hazard protection. 10 CFR          Changes,      Hazards Station      72.48(c)(2)(ii) requires, in part, that a general licensee Tests, and shall request that the certificate holder obtain a CoC    Experiments amendment pursuant to 10 CFR 72.244, prior to implementing a proposed change, if the change would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety (ITS) previously evaluated in the FSAR. This requirement includes the configuration where the HI-STORM FW overpack is lifted by the hydraulic lifting gantry (HLG) as part of ISFSI operations. The HLG is an ITS component used in cask handling operations and is not designed to be operated in wind speeds exceeding 35 mph. The introduction of the ITS HLG met the criterion that resulted in more than minimal increase in the likelihood of occurrence of a malfunction of an SSC ITS previously evaluated in the FSAR. The general design criteria require ITS structures used in ISFSI operations to be designed to withstand the effects of tornado missiles and winds.
VLSSIR      Joseph M. Cask Transfer Operations Outside of the Fuel              10 CFR        Tornado Farley        Handling Building                                          72.122 (b)    Hazards Nuclear      The inspectors identified that at the Farley Nuclear      Overall Plant        Plant, the licensee performs cask transfer operations      Requirements outside of the fuel handling building. Following this operation, a mating device from the HI-STORM is            10 CFR removed, leaving the MPC within the HI-STORM              72.212(b) exposed to natural phenomena and after a short            Conditions of duration the HI-STORM lid is placed onto the HI-          CoC STORM.
Encl. 2 - 3


Enforcement Dresden    Tornado Hazards Protection at Independent Spent          10 CFR        Tornado Discretion  Nuclear    Fuel Storage Installations                              72.212(b)    Hazards Power      Upon issuance of U.S. NRC Enforcement Guidance          Conditions of Station    Memorandum (EGM) 22-001 (ML22087A496), dated            CoC 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 100 storage overpack is brought out of the reactor building without a lid installed. This configuration is not explicitly analyzed in the HI-STORM 100 FSAR. Tornado hazards are evaluated in the Holtec HI-STORM Final Safety Analysis Report (FSAR) section 3.4.8, Tornado Wind and Missile Impact, and section 11.2.6.2, Tornado Analysis. These sections of the FSAR do not include an analysis for tornado hazards with the storage overpack lid removed. Similarly, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles specifically for the configuration where a loaded storage overpack was outdoors with the lid off.
Encl. 2 - 2 internal audits were sampled, and it was determined that no CARs had been written when findings had been identified as a result of the audits. CAP 12-01, Audit Procedure, Section 2.3 states that when carrying out an internal audit, nonconformances must be recorded on the CAR database.
Enforcement H.B.        Tornado Hazards Protection at Independent Spent          10 CFR       Tornado Discretion  Robinson    Fuel Storage Installations                              72.212(b)    Hazards Steam      Upon issuance of U.S. NRC Enforcement Guidance          Conditions of Electric    Memorandum 22-001 (ML22087A496), dated April 15,         CoC Plant      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. Several configurations were identified by the licensee including when a loaded Dry Shielded Canister (DSC) with the shield plug is transferred out of the Spent Fuel Pool to the Cask Handling Facility and when the transfer cask lid is removed to insert the DSC into the Horizontal Storage Module (HSM). These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 FSAR. Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
SL IV - NCV Croft Inadequate procedures. CAP- 02-02, Project Quality 10 CFR Procedural Plan; CAP-02-04, Project Specifications; and CAP 71.111 Adequacy 05, Project Plan; are no longer current with what Croft Instructions, is actually doing to fill out Croft form QF 376, Project Procedures, Quality Plan. The form QF 376 had been revised, but and Drawings procedures CAP 02-02, CAP 02-04, and CAP 02-05, in which procedural guidance was to be provided on how to fill out QF 376, were no longer current with what Croft was actually doing to fill out form QF 376.
Enforcement South Texas Tornado Hazards Protection at Independent Spent          10 CFR        Tornado Discretion  Project     Fuel Storage Installations                              72.212(b)    Hazards Upon issuance of U.S. NRC Enforcement Guidance          Conditions of Memorandum (EGM) 22-001 (ML22087A496), dated            CoC 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 systems FSAR. Two configurations were identified by the licensee where transport activities did not have a related tornado wind and hazard analysis consistent with the casks design basis requirements. These situations occurred during outside operations when the HI-STORM FW overpack was on the low-profile transporter with the HI-STORM FW overpack lid bolts not engaged and when the Vertical Cask Transporter carried the overpack using the HI-STORM FW lifting brackets.
SL IV - NCV Xcel Energy/ SeAH Besteel Corpration's (SBC) corrective action 10 CFR Procedural TN Americas procedure failed to provide sufficient guidance to 72.150 Adequacy perform root cause analysis for significant conditions Instructions, adverse to quality to determine the corrective action Procedures, necessary to preclude repetition. and Drawings
Encl. 2 - 4


Enforcement Surry Power   Tornado Hazards Protection at Independent Spent         10 CFR       Tornado Discretion Station       Fuel Storage Installations                               72.212(b)     Hazards Dominion       Upon issuance of U.S. NRC Enforcement Guidance           Conditions of Energy         Memorandum (EGM) 22-001 (ML22087A496), dated             CoC 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. Several configurations were identified by the licensee including when the transfer cask lid is removed to insert the Dry Shielded Canister (DSC) into the Horizontal Storage Module (HSM) and prior to the HSM lid being reinstalled. These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 Final Safety Analysis Report (FSAR).
SL IV - NCV NAC Hitachi Zosen failed to perform an adequate audit of a 10 CFR Procurement International suppliers QA program to ensure it meets all applicable 72.154 requirements of 10 CFR Part 72, Subpart G. Control of purchased material, equipment, and services
 
Enforcement Limerick The inspectors identified a violation of 10 CFR 72.48 10 CFR 72.48 Tornado Discretion Generating associated with tornado hazard protection. 10 CFR Changes, Hazards Station 72.48(c)(2)(ii) requires, in part, that a general licensee Tests, and shall request that the certificate holder obtain a CoC Experiments amendment pursuant to 10 CFR 72.244, prior to implementing a proposed change, if the change would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety (ITS) previously evaluated in the FSAR. This requirement includes the configuration where the HI-STORM FW overpack is lifted by the hydraulic lifting gantry (HLG) as part of ISFSI operations. The HLG is an ITS component used in cask handling operations and is not designed to be operated in wind speeds exceeding 35 mph. The introduction of the ITS HLG met the criterion that resulted in more than minimal increase in the likelihood of occurrence of a malfunction of an SSC ITS previously evaluated in the FSAR. The general design criteria require ITS structures used in ISFSI operations to be designed to withstand the effects of tornado missiles and winds.
VLSSIR Joseph M. Cask Transfer Operations Outside of the Fuel 10 CFR Tornado Farley Handling Building 72.122 (b) Hazards Nuclear The inspectors identified that at the Farley Nuclear Overall Plant Plant, the licensee performs cask transfer operations Requirements outside of the fuel handling building. Following this operation, a mating device from the HI-STORM is 10 CFR removed, leaving the MPC within the HI-STORM 72.212(b) exposed to natural phenomena and after a short Conditions of duration the HI-STORM lid is placed onto the HI-CoC STORM.
 
Encl. 2 - 3 Enforcement Dresden Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Nuclear Fuel Storage Installations 72.212(b) Hazards Power Upon issuance of U.S. NRC Enforcement Guidance Conditions of Station Memorandum (EGM) 22-001 (ML22087A496), dated CoC 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 100 storage overpack is brought out of the reactor building without a lid installed. This configuration is not explicitly analyzed in the HI-STORM 100 FSAR. Tornado hazards are evaluated in the Holtec HI-STORM Final Safety Analysis Report (FSAR) section 3.4.8, Tornado Wind and Missile Impact, and section 11.2.6.2, Tornado Analysis. These sections of the FSAR do not include an analysis for tornado hazards with the storage overpack lid removed. Similarly, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles specifically for the configuration where a loaded storage overpack was outdoors with the lid off.
Enforcement H.B. Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Robinson Fuel Storage Installations 72.212(b) Hazards Steam Upon issuance of U.S. NRC Enforcement Guidance Conditions of Electric Memorandum 22-001 (ML22087A496), dated April 15, CoC Plant 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. Several configurations were identified by the licensee including when a loaded Dry Shielded Canister (DSC) with the shield plug is transferred out of the Spent Fuel Pool to the Cask Handling Facility and when the transfer cask lid is removed to insert the DSC into the Horizontal Storage Module (HSM). These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 FSAR. Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
Enforcement South Texas Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Project Fuel Storage Installations 72.212(b) Hazards Upon issuance of U.S. NRC Enforcement Guidance Conditions of Memorandum (EGM) 22-001 (ML22087A496), dated CoC 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 systems FSAR. Two configurations were identified by the licensee where transport activities did not have a related tornado wind and hazard analysis consistent with the casks design basis requirements. These situations occurred during outside operations when the HI-STORM FW overpack was on the low-profile transporter with the HI-STORM FW overpack lid bolts not engaged and when the Vertical Cask Transporter carried the overpack using the HI-STORM FW lifting brackets.
 
Encl. 2 - 4 Enforcement Surry Power Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Station Fuel Storage Installations 72.212(b) Hazards Dominion Upon issuance of U.S. NRC Enforcement Guidance Conditions of Energy Memorandum (EGM) 22-001 (ML22087A496), dated CoC 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. Several configurations were identified by the licensee including when the transfer cask lid is removed to insert the Dry Shielded Canister (DSC) into the Horizontal Storage Module (HSM) and prior to the HSM lid being reinstalled. These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 Final Safety Analysis Report (FSAR).
Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
SL IV NCV   Indian Point   Failure to follow procedures that are relied upon to     10 CFR       Procedural ensure that combustible material surrounding a loaded   72.150       Adherence HI-STORM is less than the maximum evaluated.             Instructions, Procedures, and Drawings SL IV NCV   Calvert Cliffs Did not notify the NRC using instructions in 10 CFR     10 CFR       General Nuclear       72.4 at least 90 days before first storage of spent fuel 72.212       License Power Plant   under their general license. 72.212(b)(1).               Conditions of Conditions CoC SL IV NCV   Duane         Failure to conform to the terms, conditions, and         10 CFR       General Arnold         specifications of Certificate of Compliance (CoC) 1004, 72.212       License Amendment 17, Revision 0, Appendix B, condition         Conditions of Conditions 4.3.3, which required monitoring for hydrogen during     CoC welding of the inner top cover plate. 72.212(b)(3).
SL IV NCV Indian Point Failure to follow procedures that are relied upon to 10 CFR Procedural ensure that combustible material surrounding a loaded 72.150 Adherence HI-STORM is less than the maximum evaluated. Instructions, Procedures, and Drawings SL IV NCV Calvert Cliffs Did not notify the NRC using instructions in 10 CFR 10 CFR General Nuclear 72.4 at least 90 days before first storage of spent fuel 72.212 License Power Plant under their general license. 72.212(b)(1). Conditions of Conditions CoC SL IV NCV Duane Failure to conform to the terms, conditions, and 10 CFR General Arnold specifications of Certificate of Compliance (CoC) 1004, 72.212 License Amendment 17, Revision 0, Appendix B, condition Conditions of Conditions 4.3.3, which required monitoring for hydrogen during CoC welding of the inner top cover plate. 72.212(b)(3).
NCV         Browns         Failure to perform a 10 CFR 50.59 evaluation in         10 CFR 50     Procedural GREEN       Ferry         accordance with site procedures. The inspectors         Appendix B   Adherence (SL IV)     Nuclear       identified a Green, non-cited violation of 10 CFR Part Plant         50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of site procedure NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments. Specifically, site personnel made changes to procedure 0-TI-561, Underground Piping and Tanks Integrity Program, a procedure described in the UFSAR, without performing a 10 CFR 50.59 evaluation as required by site procedures.
NCV Browns Failure to perform a 10 CFR 50.59 evaluation in 10 CFR 50 Procedural GREEN Ferry accordance with site procedures. The inspectors Appendix B Adherence (SL IV) Nuclear identified a Green, non-cited violation of 10 CFR Part Plant 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of site procedure NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments. Specifically, site personnel made changes to procedure 0-TI-561, Underground Piping and Tanks Integrity Program, a procedure described in the UFSAR, without performing a 10 CFR 50.59 evaluation as required by site procedures.
NCV         Joseph M.     Failure to incorporate acceptance criteria for the spent 10 CFR 50     Procedural GREEN       Farley         fuel bridge crane. The inspectors identified a Green     Appendix B   Adequacy (SL IV)     Nuclear       finding and associated non-cited violation (NCV) of 10 Plant         CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events.
NCV Joseph M. Failure to incorporate acceptance criteria for the spent 10 CFR 50 Procedural GREEN Farley fuel bridge crane. The inspectors identified a Green Appendix B Adequacy (SL IV) Nuclear finding and associated non-cited violation (NCV) of 10 Plant CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events.
Encl. 2 - 5
 
Encl. 2 - 5 NCV North Anna Failure to translate the licensing basis into instructions 10 CFR 50 Procedural GREEN Power for fuel handling activities. The inspectors identified a Appendix B Adequacy (SL IV) Station Green, non-cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to translate the maximum cask lift elevation and the locking of the trunnion axis into site procedures.
NCV Sequoyah Inadequate design control for ISFSI operations. 10 CFR 50 Procedural GREEN Nuclear The team identified three examples of a Green, non-Appendix B Adequacy (SL IV) Plant cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to develop appropriate acceptance criteria associated with the ISFSI haul path and the railway access hatch hoisting system and failed to verify the adequacy of the Auxiliary Building Crane testing program.
SL IV - NCV Surry Power The team identified a Severity Level IV non-cited 10 CFR 72.48 Design Station violation (NCV) of 10 CFR 72.48(d)(1), Changes, Changes, Changes Dominion Tests, and Experiments, because the licensee did not Tests, and Energy perform an adequate written evaluation which provided Experiments the bases for the determination that the change, test, or experiment does not require a license or Certificate of Compliance (CoC) amendment pursuant to paragraph (c)(2) of this section. Specifically, the licensee did not provide the bases for the determination that the presence of boiling water in the Dry Shielded Canister (DSC) and Transfer Cask (TC) annulus does not require a CoC amendment.
SL IV - NCV Surry Power The inspectors identified a Severity Level IV, non-cited 10 CFR Testing Station violation of 10 CFR Part 72.162, Test Control, for the 72.162 Dominion licensees failure to perform testing in accordance with Test Control Energy written test procedures incorporating design basis requirements and acceptance limits. Specifically, design basis flow rates for the EOS Forced Air Cooling units (FAC) were not incorporated into testing procedures or other instructions to test the system on an ongoing basis. As a result, unacceptable degradation of the FAC would not have been identified.


NCV        North Anna  Failure to translate the licensing basis into instructions 10 CFR 50    Procedural GREEN      Power      for fuel handling activities. The inspectors identified a  Appendix B  Adequacy (SL IV)    Station    Green, non-cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to translate the maximum cask lift elevation and the locking of the trunnion axis into site procedures.
NCV        Sequoyah    Inadequate design control for ISFSI operations.            10 CFR 50    Procedural GREEN      Nuclear    The team identified three examples of a Green, non-        Appendix B  Adequacy (SL IV)    Plant      cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to develop appropriate acceptance criteria associated with the ISFSI haul path and the railway access hatch hoisting system and failed to verify the adequacy of the Auxiliary Building Crane testing program.
SL IV - NCV Surry Power The team identified a Severity Level IV non-cited          10 CFR 72.48 Design Station    violation (NCV) of 10 CFR 72.48(d)(1), Changes,          Changes,    Changes Dominion    Tests, and Experiments, because the licensee did not      Tests, and Energy      perform an adequate written evaluation which provided      Experiments the bases for the determination that the change, test, or experiment does not require a license or Certificate of Compliance (CoC) amendment pursuant to paragraph (c)(2) of this section. Specifically, the licensee did not provide the bases for the determination that the presence of boiling water in the Dry Shielded Canister (DSC) and Transfer Cask (TC) annulus does not require a CoC amendment.
SL IV - NCV Surry Power The inspectors identified a Severity Level IV, non-cited  10 CFR      Testing Station    violation of 10 CFR Part 72.162, Test Control, for the  72.162 Dominion    licensees failure to perform testing in accordance with  Test Control Energy      written test procedures incorporating design basis requirements and acceptance limits. Specifically, design basis flow rates for the EOS Forced Air Cooling units (FAC) were not incorporated into testing procedures or other instructions to test the system on an ongoing basis. As a result, unacceptable degradation of the FAC would not have been identified.
Encl. 2 - 6
Encl. 2 - 6


ML23030B924; ML23030B923
ML23030B924; ML23030B923
* via email OFFICE             NMSS/DFM/IOB   NMSS/DFM/IOB       NMSS/DFM         NMSS/DFM/IOB*
* via email OFFICE NMSS/DFM/IOB NMSS/DFM/IOB NMSS/DFM NMSS/DFM/IOB*
SHelton NAME               ADjapari     AD ARivera-Varona AR                    ARivera-Varona AR JZimmerman for JZ DATE               Jan 31, 2023   Feb 14, 2023       Feb 16, 2023     Feb 16, 2023}}
NAME ADjapari AD ARivera-Varona ARSHelton ARivera-Varona AR JZimmerman for JZ DATE Jan 31, 2023 Feb 14, 2023 Feb 16, 2023 Feb 16, 2023}}

Revision as of 10:16, 15 November 2024

Enclosure 2 - FY2022 Table of Inspection Findings
ML23030B923
Person / Time
Issue date: 02/16/2023
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ML23030B924 List:
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Download: ML23030B923 (1)
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Text

Enclosure 2 FY22 Summary of Independent Spent Fuel Storage Installation Inspection Findings

Type Licensee/ Description Applicable Category CoC Holder Regulation

SL IV - NCV NAC NAC failed to obtain a CoC amendment for changes to 10 CFR 72.48 Design International ACI-318 requirements for the MAGNASTOR cask Changes, Changes system that required a change to the specifications Tests, and incorporated in the MAGNASTOR System CoC No. Experiments 1031 Amendments 0-6.

SL IV - NCV NAC Petersen failed to ensure a final dimensional 10 CFR Procedural International verification occurs after adjusting the MAGNASTOR 72.150 Adherence fuel basket within fabrication procedures. Instructions, Procedures, and Drawings SL IV - NCV NAC Petersen failed to perform an adequate Magnetic 10 CFR Testing International particle testing (MT) inspection of a fuel tube seam 72.158 weld. Control of Special Processes SL IV - NOV ORANO-Container Products Corporation (CPC) took 10 CFR Corrective Transport inadequate corrective actions during the previous 71.133 Action Logistics inspection to ensure that applicable suppliers on its Corrective International QSL received a triennial audit as required by the CPC Action Inc. QAM Section QAP-1007, and that the QSL was maintained current with qualified vendors. Specifically, Airgas Performance Plus Division and Branham Corporation have not been audited in the past three years but remained on the QSL.

SL IV - NCV TN 10 CFR 72.48(c)(1)(ii)(B) - Change incorporated in the 10 CFR 72.48 Design Americas, CoC. TN made changes in the spent fuel storage cask Changes, Changes LLC design as described in sections A.2.1.4 and A.2.4.2 of Tests, and the NUHOMS EOS UFSAR (as updated) Experiments without meeting the requirements in the CoC.

Specifically, ORANO modified the UFSAR requirements for the MX-LC without performing an evaluation for an accident drop as required by CoC Condition 5, Heavy Loads Requirements and TS 5.2.1 because the MX-LC failed to meet the single failure proof requirements in the ASME NOG-1 2015 standard.

SL IV - NCV TN 10 CFR 72.48(d)(1)(c)(2)(i) and (c)(2)(vi) 10 CFR 72.48 Design Americas, TN revised UFSAR to remove the words to prevent Changes, Changes LLC boiling in the annulus and instead provided guidance Tests, and on how to manage the TC/DSC annulus water level Experiments during loading and unloading. TN failed to provide a bases for the determination that the presence of boiling water in the DSC and TC annulus does not require a CoC amendment.

Encl. 2 - 1 SL IV - NCV TN TN failed to subject design changes, including field 10 CFR Design Americas, changes, to design control measures commensurate 72.146 Changes LLC with those applied to the original design in that TN Design supported a field change for a general licensee and did Control not properly analyze for tornado wind pressures without considering all assumptions from the original design.

SL IV - NOV Croft Croft took inadequate corrective action from the NRC 10 CFR Corrective 2017 inspection of Croft and the NRC 2019 inspection 71.133 Action of Croft fabricator Oxford Engineering Limited. Corrective Specifically, in 2017, Croft wrote Corrective Action Action Report (CAR) 136 to address that Croft Associates Procedure (CAP) 12-01, Issue S, Audit Procedure, failed to require a periodicity for internal audits as required by 10 CFR, Section 71.137, Audits to ensure all applicable quality assurance criteria are audited on a periodic basis. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected. In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition.

However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.

In 2017, Croft wrote CAR 137 to address that CAP 05-17, Issue E, Conditions Adverse to Quality, and CAP 12-03, Issue M, QMS Corrective Action, did not provide guidance to determine the cause of Significant Conditions Adverse to Quality and the corrective action necessary to preclude repetition. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.

In 2019, Croft wrote CAR 147 to address that CAP 06-08, Approved Supplier, Step 2.2.1 required that a Quality Category A supplier shall have a current assessment and approval to an appropriate quality system standard. Croft assessed Oxford Engineering Limited to qualify them to encompass the additional requirements of 10 CFR Part 71, but Oxford Engineerings internal auditor did not meet those requirements, nor did Oxford Engineering have a quality procedure or process in place for qualifying internal auditors. However, the actions taken by the CAR did not directly align with the issue and the issue was not corrected.

In addition, during the 2022 inspection, several Croft

Encl. 2 - 2 internal audits were sampled, and it was determined that no CARs had been written when findings had been identified as a result of the audits. CAP 12-01, Audit Procedure, Section 2.3 states that when carrying out an internal audit, nonconformances must be recorded on the CAR database.

SL IV - NCV Croft Inadequate procedures. CAP- 02-02, Project Quality 10 CFR Procedural Plan; CAP-02-04, Project Specifications; and CAP 71.111 Adequacy 05, Project Plan; are no longer current with what Croft Instructions, is actually doing to fill out Croft form QF 376, Project Procedures, Quality Plan. The form QF 376 had been revised, but and Drawings procedures CAP 02-02, CAP 02-04, and CAP 02-05, in which procedural guidance was to be provided on how to fill out QF 376, were no longer current with what Croft was actually doing to fill out form QF 376.

SL IV - NCV Xcel Energy/ SeAH Besteel Corpration's (SBC) corrective action 10 CFR Procedural TN Americas procedure failed to provide sufficient guidance to 72.150 Adequacy perform root cause analysis for significant conditions Instructions, adverse to quality to determine the corrective action Procedures, necessary to preclude repetition. and Drawings

SL IV - NCV NAC Hitachi Zosen failed to perform an adequate audit of a 10 CFR Procurement International suppliers QA program to ensure it meets all applicable 72.154 requirements of 10 CFR Part 72, Subpart G. Control of purchased material, equipment, and services

Enforcement Limerick The inspectors identified a violation of 10 CFR 72.48 10 CFR 72.48 Tornado Discretion Generating associated with tornado hazard protection. 10 CFR Changes, Hazards Station 72.48(c)(2)(ii) requires, in part, that a general licensee Tests, and shall request that the certificate holder obtain a CoC Experiments amendment pursuant to 10 CFR 72.244, prior to implementing a proposed change, if the change would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety (ITS) previously evaluated in the FSAR. This requirement includes the configuration where the HI-STORM FW overpack is lifted by the hydraulic lifting gantry (HLG) as part of ISFSI operations. The HLG is an ITS component used in cask handling operations and is not designed to be operated in wind speeds exceeding 35 mph. The introduction of the ITS HLG met the criterion that resulted in more than minimal increase in the likelihood of occurrence of a malfunction of an SSC ITS previously evaluated in the FSAR. The general design criteria require ITS structures used in ISFSI operations to be designed to withstand the effects of tornado missiles and winds.

VLSSIR Joseph M. Cask Transfer Operations Outside of the Fuel 10 CFR Tornado Farley Handling Building 72.122 (b) Hazards Nuclear The inspectors identified that at the Farley Nuclear Overall Plant Plant, the licensee performs cask transfer operations Requirements outside of the fuel handling building. Following this operation, a mating device from the HI-STORM is 10 CFR removed, leaving the MPC within the HI-STORM 72.212(b) exposed to natural phenomena and after a short Conditions of duration the HI-STORM lid is placed onto the HI-CoC STORM.

Encl. 2 - 3 Enforcement Dresden Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Nuclear Fuel Storage Installations 72.212(b) Hazards Power Upon issuance of U.S. NRC Enforcement Guidance Conditions of Station Memorandum (EGM)22-001 (ML22087A496), dated CoC 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 100 storage overpack is brought out of the reactor building without a lid installed. This configuration is not explicitly analyzed in the HI-STORM 100 FSAR. Tornado hazards are evaluated in the Holtec HI-STORM Final Safety Analysis Report (FSAR) section 3.4.8, Tornado Wind and Missile Impact, and section 11.2.6.2, Tornado Analysis. These sections of the FSAR do not include an analysis for tornado hazards with the storage overpack lid removed. Similarly, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles specifically for the configuration where a loaded storage overpack was outdoors with the lid off.

Enforcement H.B. Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Robinson Fuel Storage Installations 72.212(b) Hazards Steam Upon issuance of U.S. NRC Enforcement Guidance Conditions of Electric Memorandum 22-001 (ML22087A496), dated April 15, CoC Plant 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. Several configurations were identified by the licensee including when a loaded Dry Shielded Canister (DSC) with the shield plug is transferred out of the Spent Fuel Pool to the Cask Handling Facility and when the transfer cask lid is removed to insert the DSC into the Horizontal Storage Module (HSM). These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 FSAR. Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.

Enforcement South Texas Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Project Fuel Storage Installations 72.212(b) Hazards Upon issuance of U.S. NRC Enforcement Guidance Conditions of Memorandum (EGM)22-001 (ML22087A496), dated CoC 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 systems FSAR. Two configurations were identified by the licensee where transport activities did not have a related tornado wind and hazard analysis consistent with the casks design basis requirements. These situations occurred during outside operations when the HI-STORM FW overpack was on the low-profile transporter with the HI-STORM FW overpack lid bolts not engaged and when the Vertical Cask Transporter carried the overpack using the HI-STORM FW lifting brackets.

Encl. 2 - 4 Enforcement Surry Power Tornado Hazards Protection at Independent Spent 10 CFR Tornado Discretion Station Fuel Storage Installations 72.212(b) Hazards Dominion Upon issuance of U.S. NRC Enforcement Guidance Conditions of Energy Memorandum (EGM)22-001 (ML22087A496), dated CoC 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. Several configurations were identified by the licensee including when the transfer cask lid is removed to insert the Dry Shielded Canister (DSC) into the Horizontal Storage Module (HSM) and prior to the HSM lid being reinstalled. These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 Final Safety Analysis Report (FSAR).

Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.

SL IV NCV Indian Point Failure to follow procedures that are relied upon to 10 CFR Procedural ensure that combustible material surrounding a loaded 72.150 Adherence HI-STORM is less than the maximum evaluated. Instructions, Procedures, and Drawings SL IV NCV Calvert Cliffs Did not notify the NRC using instructions in 10 CFR 10 CFR General Nuclear 72.4 at least 90 days before first storage of spent fuel 72.212 License Power Plant under their general license. 72.212(b)(1). Conditions of Conditions CoC SL IV NCV Duane Failure to conform to the terms, conditions, and 10 CFR General Arnold specifications of Certificate of Compliance (CoC) 1004, 72.212 License Amendment 17, Revision 0, Appendix B, condition Conditions of Conditions 4.3.3, which required monitoring for hydrogen during CoC welding of the inner top cover plate. 72.212(b)(3).

NCV Browns Failure to perform a 10 CFR 50.59 evaluation in 10 CFR 50 Procedural GREEN Ferry accordance with site procedures. The inspectors Appendix B Adherence (SL IV) Nuclear identified a Green, non-cited violation of 10 CFR Part Plant 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of site procedure NPG-SPP-09.4, 10 CFR 50.59 Evaluations of Changes, Tests, and Experiments. Specifically, site personnel made changes to procedure 0-TI-561, Underground Piping and Tanks Integrity Program, a procedure described in the UFSAR, without performing a 10 CFR 50.59 evaluation as required by site procedures.

NCV Joseph M. Failure to incorporate acceptance criteria for the spent 10 CFR 50 Procedural GREEN Farley fuel bridge crane. The inspectors identified a Green Appendix B Adequacy (SL IV) Nuclear finding and associated non-cited violation (NCV) of 10 Plant CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate acceptance criteria for the Spent Fuel Bridge Crane lower runway and upper railway into FNP-0-MP-30.3, Spent Fuel Cask Crane Periodic Mechanical Check, to ensure it can respond to design basis events.

Encl. 2 - 5 NCV North Anna Failure to translate the licensing basis into instructions 10 CFR 50 Procedural GREEN Power for fuel handling activities. The inspectors identified a Appendix B Adequacy (SL IV) Station Green, non-cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to translate the maximum cask lift elevation and the locking of the trunnion axis into site procedures.

NCV Sequoyah Inadequate design control for ISFSI operations. 10 CFR 50 Procedural GREEN Nuclear The team identified three examples of a Green, non-Appendix B Adequacy (SL IV) Plant cited violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis was correctly translated into procedures and instructions. Specifically, the inspectors identified that the licensee failed to develop appropriate acceptance criteria associated with the ISFSI haul path and the railway access hatch hoisting system and failed to verify the adequacy of the Auxiliary Building Crane testing program.

SL IV - NCV Surry Power The team identified a Severity Level IV non-cited 10 CFR 72.48 Design Station violation (NCV) of 10 CFR 72.48(d)(1), Changes, Changes, Changes Dominion Tests, and Experiments, because the licensee did not Tests, and Energy perform an adequate written evaluation which provided Experiments the bases for the determination that the change, test, or experiment does not require a license or Certificate of Compliance (CoC) amendment pursuant to paragraph (c)(2) of this section. Specifically, the licensee did not provide the bases for the determination that the presence of boiling water in the Dry Shielded Canister (DSC) and Transfer Cask (TC) annulus does not require a CoC amendment.

SL IV - NCV Surry Power The inspectors identified a Severity Level IV, non-cited 10 CFR Testing Station violation of 10 CFR Part 72.162, Test Control, for the 72.162 Dominion licensees failure to perform testing in accordance with Test Control Energy written test procedures incorporating design basis requirements and acceptance limits. Specifically, design basis flow rates for the EOS Forced Air Cooling units (FAC) were not incorporated into testing procedures or other instructions to test the system on an ongoing basis. As a result, unacceptable degradation of the FAC would not have been identified.

Encl. 2 - 6

ML23030B924; ML23030B923

  • via email OFFICE NMSS/DFM/IOB NMSS/DFM/IOB NMSS/DFM NMSS/DFM/IOB*

NAME ADjapari AD ARivera-Varona ARSHelton ARivera-Varona AR JZimmerman for JZ DATE Jan 31, 2023 Feb 14, 2023 Feb 16, 2023 Feb 16, 2023

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