ML050610153
| ML050610153 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/15/2005 |
| From: | Martin R NRC/NRR/DLPM/LPD2 |
| To: | Barron H Duke Energy Corp |
| Martin R, NRR/DLPM, 415-1493 | |
| References | |
| TAC MB7863, TAC MB7864 | |
| Download: ML050610153 (11) | |
Text
April 15, 2005 Mr. H. B. Barron Executive Vice President Nuclear Generation Duke Energy Corporation 526 South Church Street Charlotte, NC 28202
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2 - REPORT OF QUALITY ASSURANCE AUDITS CONCERNING MIXED OXIDE LEAD FUEL ASSEMBLIES (TAC NOS. MB7863 AND MB7864)
Dear Mr. Barron:
By letter dated February 27, 2003, Duke Energy Corporation submitted an application for amendments to the renewed facility operating licenses for Catawba Nuclear Station, Units 1 and 2 (Catawba) to allow the use of four mixed oxide (MOX) Lead Test Assemblies (LTAs) at Catawba. The enclosures report on the Nuclear Regulatory Commission staffs audits of the programs and processes utilized by Framatome Advanced Nuclear Power to manufacture the MOX LTAs that are proposed to be used at Catawba.
Please contact me on (301) 415-1493 if you have any other questions on these issues.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414
Enclosures:
- 1. Audit Report Conducted April 29 - May 6, 2004
- 2. Audit Report Conducted November 12-19, 2004 cc w/encl: See next page
- See previous concurrence NRR-106 OFFICE PDII-1/PM PDII-1/LA IPSB SRXB PDII-1/SC(A)
NAME RMartin CHawes GGalletti UShoop JANakoski DATE 04/ 06 /05 04/ 13 /05 03/14/05 03/01/05 04/ 15 /05
ENCLOSURE 1 REPORT OF QUALITY ASSURANCE AUDIT CONDUCTED APRIL 29 - MAY 6, 2004 REGARDING MIXED OXIDE (MOX) LEAD TEST ASSEMBLIES DUKE POWER COMPANY CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414
1.0 INTRODUCTION
The Duke Energy Corporation (Duke) submitted an application for amendments of the facility operating licenses and technical specifications for the Catawba Nuclear Station, Units 1 and 2, (Catawba) to allow insertion of MOX lead test assemblies (LTAs) on February 27, 2003. The amendment request included, in part, a description of the quality assurance (QA) activities associated with the fabrication of the LTAs. Framatome Advanced Nuclear Power (FANP) is the fuel vendor contracted by Duke to manufacture four MOX LTAs for use in one of the Catawba units. FANP is undertaking the fabrication of the LTAs at the COGEMA facilities in Cadarache and MELOX, France.
Representatives of the Nuclear Regulatory Commission (NRC) staff conducted audits of the programs and processes utilized by FANP to manufacture the MOX LTAs. This report (Enclosure 1) presents the results of the audit conducted from April 29 through May 6, 2004, in the COGEMA Cadarache facility in Saint-Paul-Iez-Durance, France, and in the COGEMA MELOX facilities in Bagnols-sur-Ceze Cedex, France. The following report (Enclosure 2) presents the results of a further audit conducted from November 12 -19, 2004. The purpose of the audits was to verify that the COGEMA quality program descriptions conform to the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, 10 CFR Part 21, Reporting of Defects and Noncompliance, and to review the FANP audit processes used to qualify the COGEMA Cadarache and MELOX facilities as approved suppliers to FANP, and to verify that the as-fabricated pellets and rods met the design criteria provided in the topical report, BAW-10238 (P), MOX Fuel Design Report.
2.0 DISCUSSION The audit was conducted at the COGEMA Cadarache and COGEMA MELOX facilities located in Cadarache and Bagnols-sur-ceze, France, respectively. A list of participants from FANP, Duke Energy, Duke Cogema Stone & Webster (DCS) and the NRC staff is included at the end of this report.
On Friday, April 29, 2004, audit activities involved representatives from FANP, DCS, and COGEMA at the Cadarache fuel fabrication facility at Cadarache, France. The Cadarache facility has been selected to fabricate the fuel pellets and fuel rods for the MOX LTAs. The facility will receive the polished plutonium oxide powder furnished by Los Alamos National Laboratory, blend it with depleted uranium oxide powder, press the blended powder into MOX pellets, load the sintered and ground pellets into FANP supplied fuel rods, and pressurize and weld the fuel rod end caps. Discussions included a brief history of the fabrication facility, an overview of the MOX fuel fabrication process, details of the Cadarache QA organization and QA program implementation, and a discussion of the FANP audit process and results from the earlier system audit conducted by FANP in February 2004. Following these discussions, the NRC staff toured the fabrication facility and associated analytical test laboratories. Throughout the tour the Cadarache personnel described the processes used to assure quality production of MOX fuel to meet the defined specifications of a fuel order and described various systems and controls designed to ensure safe operation.
On Monday, May 3, 2004, audit activities were held at the MELOX facility at Bagnols-sur-ceze, France. COGEMA receives the finished fuel rods from Cadarache at the MELOX facility. The MELOX facility will then assemble the MOX LTAs using Mark-BW/MOX structural components, provided by FANP, into fuel bundles using qualified tooling and procedures approved by FANP.
COGEMA will also provide all traceability and design records for fabrication with a certificate of conformance to allow FANP to certify the MOX LTAs for delivery to Duke. Topics covered included a brief history of the MELOX fabrication facility, a brief overview of the MOX fuel fabrication process, detailed discussions of the MELOX QA organization and QA implementation, and a discussion of the FANP audit process and NRC audit activities to be conducted by FANP during the following several days. NRC staff also toured the MELOX facility and observed fuel pellets, rods, and assemblies in various stages of fabrication. The NRC staff also observed several types of fully-fabricated MOX fuel assemblies in temporary storage awaiting final shipment to their destinations.
On May 4, 5, and 6, 2004, the NRC staff conducted a review of the COGEMA MELOX QA Program, including review of selected implementation guidance, and observed the FANP audit processes. The DCS/FANP contract with COGEMA includes requirements that the subcontractor (COGEMA) shall meet the quality assurance requirements as stated in 10 CFR Part 50, Appendix B, 10 CFR Part 21, and ANSI N45.2-1977. The audits conducted by FANP were conducted to verify that the COGEMA quality program conforms to these requirements, and to subsequently qualify the COGEMA Cadarache and MELOX facilities as approved suppliers to FANP for the purposes of fabricating and supplying the MOX LTAs.
In addition, the NRC staff noted that the COGEMA Cadarache and MELOX Facilities at Cadarache and Bagnols-sur-ceze, France, are implementing a QA program consistent with established international standards and requirements including: (1) ISO 9001-2000, International Organization for Standardization, Quality Management Systems - Requirement; (2) Ministerial Order of August 10, 1984, French Regulation Relative to the Quality of the Design, Construction, and Operation of Nuclear Facilities; (3) German Standard KTA 1401, June 1996, General Requirements Regarding Quality Assurance; and (4) IAEA 50-CQA, Safety Code for Nuclear Power Plants: Quality Assurance, (Revision 1), French version, 1989.
Additionally, the QA program at COGEMA has been recognized for excellence by the Ministry of France.
The COGEMA QA program consists of a hierarchy of administrative controls and operational processes. The MELOX Quality Management Manual, Revision E, describes processes for documentation establishment and management, quality related records control, processing deviations, corrective and preventive actions, and evaluation of the quality management system.
These processes are accomplished through various levels of implementation procedures and work instructions. This complement of implementation procedures and work instructions forms the foundation for a program that is consistent with the standards described above, as well as, the requirements of 10 CFR Part 50, Appendix B.
The COGEMA QA organization consists of the Quality Safety Division and several sections which oversee the quality operations of the facility. The Quality Methods Office is the main section responsible for site quality assurance. The section has responsibility for handling the quality management system, defining staff QA training, establishing and controlling the administrative procedures, performing assessments of the quality management system, performing assessment of all suppliers quality systems, monitoring the corrective and preventive action programs, and championing total quality management for the facility.
The system audit performed by FANP for the MELOX facility included review of the MELOX Quality Management Manual and supporting documentation such as implementing procedures, work instructions, procurement documents, internal and external audit reports, fabrication records for the various manufacturing activities, material certifications, measurement and test equipment calibration records, personnel qualification and training records, inspection and test records, nonconformance and corrective action reports, and other applicable documents.
The FANP team leader presented the results of the FANP audit which concluded that the COGEMA program was in compliance with the DCS/FANP contract and NRC regulatory requirements regarding 10 CFR Part 50, Appendix B, and acknowledged that the issue mentioned in item 5 below, would be clarified as part of the development of the detailed QA implementation processes prior to initiation of fabrication activities.
During the audit, the NRC staff observed that the Cadarache and MELOX fuel fabrication facilities personnel were knowledgeable on all technical and quality assurance activities and noted the professionalism exhibited during all interactions with NRC staff members. The NRC staff concluded that participation in the FANP audit and touring the fuel fabrication facilities was very beneficial in enhancing the NRC staffs understanding of the MOX LTA fabrication program and the supporting quality assurance activities.
Following the conduct of the audit, the NRC staff discussed its findings from the audit with the FANP audit team and COGEMA MELOX facility representatives. The NRC staffs findings on the QA program and implementation documentation and FANP audit activities are as follows:
1.
The FANP audit process was very comprehensive. Each pertinent Appendix B criterion included on the audit checklist was adequately reviewed and included discussions with personnel, review of implementation guidance and procedures, and review of specific examples or process results for the area being reviewed.
2.
The COGEMA QA program was well-documented with organizational roles and responsibilities clearly described. The Quality Methods organization was maintained separate from production, to provide objective oversight and critical review of plant processes, sub-suppliers, and self-assessments. Administrative documentation and implementation procedures were well-detailed and pertinent to the activities affecting quality. Corrective actions were described and implementation of those corrective actions were well-maintained for accountability purposes and subsequent assessment.
3.
COGEMA personnel were knowledgeable of process requirements, quality objectives, and guidance contained in administrative procedures, purchase specifications, and internal corrective action and self-assessment reports.
4.
Training and qualification records were maintained current. The sample reviewed by the NRC staff provided verification that personnel assigned tasks affecting quality were trained and qualified to standards established for such by the facility.
5.
The NRC staff also reviewed FANPs commitment to 10 CFR Part 21 for the MOX LTA fabrication activities. The NRC staff identified an area that both FANP and COGEMA will need to evaluate and clarify prior to commencing the MOX LTA fabrication activities at Cadarache and MELOX. The process for the reporting of defects under 10 CFR Part 21 was not formally documented in the QA program. Both COGEMA and FANP agreed during the audit to evaluate and clarify the appropriate 10 CFR Part 21 reporting requirements as part of the QA activities prior to implementation of the COGEMA QA processes during the MOX LTA fabrication.
The NRC staff concludes that, based on its review of the above described Framatome ANP quality system audit, independent review of the COGEMA QA program by the NRC staff, and the discussions with FANP and COGEMA personnel, with the exception of the issue in item 5 above, the COGEMA program is structured to comply with the international codes, standards, and regulations, including 10 CFR Part 50, Appendix B. Both COGEMA and FANP committed to address the item 5 issue as noted above.
3.0 PENDING ACTIONS Further audits by FANP of the implementation of the quality program requirements at the COGEMA Cadarache and MELOX facilities for actual fabrication activities of the DCS/FANP MOX fuel pellets, rods, and LTA assemblies were scheduled for the winter of 2004 - 2005. An additional report on the NRC staffs continued review to verify the effectiveness of the quality assurance program implementation for MOX fabrication activities and to verify compliance with the requirements of 10 CFR Part 50, Appendix B, and 10 CFR Part 21 during that period will be issued.
List of
Participants:
NRC FANP COGEMA DCS Greg Galletti William Tibbs Jean-Pierre Bariteau Thomas Doering Richard McIntyre Charles Armontrout Marie-Trinite Becle Dennis Ivey Jeffrey Tucker Jean-Claude Batailles-Lannes Jurgen Krellmann Michel Pibarot
ENCLOSURE 2 REPORT OF QUALITY ASSURANCE AUDIT CONDUCTED NOVEMBER 12 -19, 2004 REGARDING MIXED OXIDE (MOX) LEAD TEST ASSEMBLIES
1.0 INTRODUCTION
From November 12 - 19, 2004, representatives of the NRC staff performed an on-site audit of activities associated with the fabrication of the MOX pellets and the implementation of the Quality Assurance (QA) program at the COGEMA Fuel Fabrication Facility at Cadarache, France. COGEMA is an approved fuel supplier to Framatome Advanced Nuclear Power (FANP). The NRC staff representatives observed fuel pellet fabrication, and reviewed the FANP audit processes associated with this phase of the lead test assembly (LTA) pellet and rod fabrication activities. Additional background on the MOX LTA program is provided in the preceding Enclosure 1. A list of participants in the audit is provided at the end of this report.
Summary of Pertinent Points/Issues During the visit the NRC staff observed that the Cadarache fuel fabrication facilities personnel were knowledgeable on all technical and QA activities and noted the professionalism exhibited during all interactions with NRC team members. Observation of actual MOX fuel pellet fabrication activities further enhanced the teams understanding of the MOX LTA fabrication program and supporting QA, site surveillance, and facility testing and acceptance activities. The NRC staff concluded that the audit and observation of the fabrication and testing activities was very beneficial.
Overall, the NRC staff concluded that the COGEMA Cadarache facility was effectively implementing the requirements of their quality program and meeting the technical specifications of the LTA-specific fabrication plans. The laboratory assessment of the final pellets demonstrated the pellets are well below the physical limits that affect performance. The NRC staffs audit covered the review of the Cadarache Fuel Pellet and Fuel Rod Quality Plans and supporting documentation, pellet manufacturing, rod testing, production equipment calibration, and associated on-line and laboratory testing to verify the quality of the product. This included auditing the floor production, laboratory testing practices, and review of production plans, work instructions, surveillance reports, and the final pellet reports for all of the pellet lots that had been produced.
2.0 DISCUSSION During the 4-day visit, the NRC staff performed audit activities and observed fuel pellet and fuel rod fabrication activities at the Cadarache facility located in Cadarache, France. Additional audit teams from the FANP corporate office, Duke, and DCS were present.
On Monday, November 15, 2004, the NRC staff met with representatives from FANP, Duke Cogema Stone & Webster (DCS), and COGEMA at the Cadarache MOX fuel fabrication facility to review the MOX fabrication process. The fabrication process consists of the following general activities: (1) receipt of the polished plutonium oxide powder furnished by Los Alamos National Laboratory; (2) blending of the plutonium oxide powder with depleted uranium oxide powder; (3) pressing the blended powder into pellets; (4) sintering of the finished pellets; (5) grinding and inspecting the finished pellets; (6) loading of the finished pellets into fuel rods; and (7) pressurization and welding the fuel rod end caps. During the fabrication process additional calibration, surveillance, and testing activities were conducted to ensure that the pellets meet the design specifications for the campaign.
Following discussions regarding the pelletizing and rod assembly fabrication processes, the NRC staff performed an independent audit of the Cadarache LTA fuel fabrication and testing activities and observed the FANP audit process.
Specifically, during November 15-17, 2004, the NRC staff conducted a review of the Cadarache QA program and technical requirements implementation, that included a review of the Cadarache Fuel Pellet and Fuel Rod Quality Plans and supporting documentation, pellet manufacturing, rod assembly, production equipment calibration, and associated on-line and laboratory testing to verify that the product specifications were being met. This included auditing the floor production, laboratory testing practices, and review of production plans, work instructions, surveillance reports, and the final pellet reports for all of the pellet lots that had been produced. Detailed information of the new technologies developed specifically for the production of MOX pellets was provided (MOX pellets must be manufactured in glove boxes requiring technologies that replace manual operations currently performed during the production of uranium pellets.) Although rod production had not begun, a demonstration of the rod end cap welding, evacuation and pressurization, and seal welding of the rods was performed.
The NRC staff discussed the findings of the previous audit, as discussed in Enclosure 1, regarding the process for the reporting of defects under 10 CFR Part 21 with the FANP representatives and verified that the COGEMA Quality plans do address the Part 21 issue.
Specifically, Cadarache procedures, 660/PAQ-P.01.01, Revision 08, "Processing of Product - Related Deviations (Events - Incidents), and 660/PAQ-P.04.01 Revision 3, Quality Assurance Plan Applicable to Eurofab Manufacturing Operations, requires that the Cadarache facility identify events involving deviations in products from design specifications. The Cadarache methods department must define the range of products potentially affected and prepare a deviation report detailing the findings. The procedures require that the customer (FANP) be involved for disposition of the delivered product. Various reporting requirements and corrective actions are further described. The MELOX facility has a similar process, which will be evaluated during a forthcoming NRC staff audit.
The NRC staff found that COGEMA has a very detailed production plan, fabrication and acceptance instructions, and knowledgeable staff who understand the process and machinery and demonstrated the ability to correct the process to account for the differences between reactor and weapons grade plutonium material and to obtain fuel pellet parameters that meet and frequently exceed specification. The laboratory assessment of the final pellets showed that the pellets are well below the physical limits that affect performance. The assessment showed that the MOX fuel products produced by COGEMA at the Cadarache facility will provide acceptable and expected performance characteristics under irradiation and that the MOX fuel pellets and rods are being built in accordance with the FANP MOX Fuel Design Report (ML042990091).
The NRC staff observed an FANP system audit at Cadarache which included a detailed review of the Cadarache Quality Production plans for the fabrication of the fuel pellets and fuel rods as well as field inspections of pellet fabrication activities. The FANP audit was conducted in accordance with FANP guidelines for the conduct of site audits and included a series of detailed checklists for the evaluation. The FANP auditors performed detailed documentation reviews, including evaluation of work instructions, fabrication records for the various manufacturing activities, material certifications, measurement and test equipment calibration records, personnel qualification and training records, inspection and test records, nonconformance and corrective action reports, and other documents as applicable. Additionally, the FANP auditors walked through every step of the pellet production and testing process to ensure that the pellets would meet the specifications.
Following the FANP audit, the NRC staff met with the FANP audit team and representatives of the Cadarache facility to discuss the findings of the FANP audit. The NRC staff provided comments on the fabrication process and QA program and implementation documentation, and provided observations on the FANP audit activities. These observations included:
1)
The Cadarache fabrication implementation program was documented in accordance with the facility QA program requirements. Administrative documentation, implementation procedures, design specifications, test results, calibration records, and surveillance reports were well-detailed and pertinent to the activities affecting quality.
2)
COGEMA personnel were knowledgeable of process requirements, quality objectives, and guidance contained in implementation procedures (shop procedures), design specifications, and test result reports. Training and qualification records were maintained current. The sample reviewed by the team provided verification that personnel assigned tasks affecting quality were trained and qualified to applicable standards established for such by the facility.
3)
The laboratory assessment of the final pellets demonstrated that the pellets are well below the physical limits that affect performance.
4)
The FANP audit process was very comprehensive. Each of the pertinent criteria, such as individual technical design specifications, test result reviews, and surveillance observations included on the audit checklists was adequately evaluated. This included discussions with personnel, review of implementation guidance and procedures, and review of specific examples or process results for the area being reviewed.
5)
The NRC staff also received specific feedback on the process for identifying and reporting defects for the MOX LTA fabrication activities.
The FANP team leader presented the results of the FANP audit which concluded that the COGEMA program was in compliance with the DCS/FANP contract. However, several potential issues were identified by the FANP audit team that will require additional evaluation by COGEMA. These potential issues include: (1) control of foreign material along the fabrication line; (2) verification of adequate lighting in areas where visual inspections are being performed; (3) verification that sampling standards in use are equivalent to those referenced in the pellet and rod specifications; and (4) verification of the time-limit specification between rod welding and helium leak testing. FANP plans to follow-up on these issues further during the audit continuation planned for the week of December 13, 2004.
Overall, the Cadarache MOX fuel plant has been producing MOX pellets and rods for a substantial amount of time. Therefore, COGEMA has a very detailed production plan, fabrication and acceptance instructions, and knowledgeable staff who understand the process and machinery and demonstrated the ability to correct the process to account for the differences between reactor and weapons grade plutonium material and to obtain fuel pellet parameters that meet and frequently exceed specification. The laboratory assessment of the final pellets demonstrated that the pellets are well below the physical limits that affect performance. The assessment showed that the MOX fuel products produced by Cadarache will provide acceptable and expected performance characteristics under irradiation and that the MOX fuel pellets and rods are being built per the approved FANP MOX Fuel Design Report (ML042990091).
3.0 PENDING ACTIONS FANPs audit of the implementation of the fabrication program for the fuel pellets, rods, and fuel assemblies at the COGEMA Cadarache and MELOX facilities by FANP is ongoing and will continue through the first quarter 2005. Continued NRC staff review is undertaken to verify the effectiveness of the quality assurance program implementation for MOX fabrication activities and to verify compliance with requirements of 10 CFR Part 50, Appendix B, and 10 CFR Part 21. The NRC staff performed a quality program implementation audit during the week of February 21 - 25, 2005. A report on that audit will be issued in the near future.
Individuals Contacted During the Audit U.S. NRC DCS Partners COGEMA Greg Galletti William Tibbs Jean-Pierre Bariteau Undine Shoop Michael Bale Michel Pibarot Rick Burge Jean-Claude Deckers George A. Meyer Bernard Garcia Loren Ernst (Duke)
Sylvie Fillet Tracy Saville (Duke)
Therese Fournier Dennis Ivey (DCS)
Didier Micheau Alain Dubouchet Marc Dalmier J. P. Bariteau