ML14042A202

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Part 21 Report Regarding Unqualified Material Used in Electrical Penetration Assemblies
ML14042A202
Person / Time
Site: Monticello, Oconee, Point Beach, Turkey Point, Crystal River, Ginna, Cook  Constellation icon.png
Issue date: 02/05/2014
From: Macdonald J
Mirion Technologies (Conax Nuclear)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14042A202 (9)


Text

0210512014 U.S. Nuclear Regulatory Commission OperationsCenter Event Report Page I Part 21 (PAR) Event# 49301 Rep Org: MIRION TECHNOLOGIES CONAX NUCLEAR Notification Date I Time: 08/23/2013 12:54 (EST)

Supplier: MIRION TECHNOLOGIES CONAX NUCLEAR Event Date / Time: 08/23/2013 (EDT)

Last Modification: 02/05/2014 Region: 1 Docket #:

City: BUFFALO Agreement State: Yes County: License #:

State: NY NRC Notified by: JOHN MacDONALD Notifications: WAYNE SCHMIDT R1DO HQ Ops Officer: MARK ABRAMOVITZ ROBERT HAAG R2DO Emergency Class: NON EMERGENCY LAURA KOZAK R3DO 10 CFR Section: PART 21 GROUP NRR 21.21(a)(2) INTERIM EVAL OF DEVIATION PART-21 NOTIFICATION - UNQUALIFIED MATERIAL USED IN ELECTRICAL PENETRATION ASSEMBLIES The following information was received via fax:

"Material supplied to MTCN [Mirion Technologies (Conax Nuclear)] by approved sub-suppliers audited to NCA-3800 by MTCN was considered to be ASME [American Society of Mechanical Engineers] qualified source material for Section II and Section III requirements. During triennial survey of MTCN by the ASME for renewal of our N Type Certificates of Authorization, it was identified by the ASME survey team that material supplied by two (2)

MTCN approved sub-suppliers should be considered unqualified source material. At that time, MTCN's Quality Program did not include the use of unqualified source material.

"Testing of the coupons for materials used with the basic components supplied to the operating plants is expected to be completed within the next 30 days."

The potentially defective components are electrical penetration headerplates, mounting weldment rings and weld neck flanges for mounting the electrical penetration assemblies.

The affected facilities are: Oconee, Ginna, Crystal River, Point Beach, Monticello, Cook, and Turkey Point.

Point of contact: John MacDonald 716-681-1973

  • *
  • UPDATE FROM JOHN MACDONALD TO HOWIE CROUCH ON 9/23/13 AT 1747 EDT ***

MTCN has determined the material supplied to U.S. plants does not impact the material safety or performance of the EPAs (Electrical Penetration Assemblies) delivered. Chemical and mechanical re-verification test results to

f .

02/05/2014 U.S. Nuclear Regulatory Commission OperationsCenter Event Report Pa-e 2 Part 21 (PAR) Event # 49301 date indicate there have been no test failures compared to the ASME SA-240 material requirements.

Notified R1DO (Welling), R2DO (Seymour), R3DO (Riemer), and NRR Part 21 Group (email only).

      • UPDATE FROM JOHN MACDONALD TO HOWIE CROUCH (VIA EMAIL) ON 2/5/14 AT 1627 EDT ***

MTCN has determined that chemical and mechanical tests indicate that the materials used in the EPAs delivered met ASME requirements and does not impact safety or performance of the delivered devices.

Due to the evaluation results, the vendor submitted this update to provide final closure of this Part 21 issue.

Notified R1 DO (Lilliendahl), R2DO (Masters), R3DO (Orlikowski) and the Part 21 group (via email).

FEB 05 '14 (WED) 05:24 IST CONAX 716 681 1139 PAGE. 1/7 Sensing Systems Division Tel: (716) 681-19.73

-M IR IO N Mirlon Technologies (Conax Nuclear), Inc.

402 Sonwil Drive Fax: (716)681-1139 www.mirion.com TECH NO :LOG I ES. Buffalo, NY 14225-5530 FeaturIng Fax: 301-816-5151, NRC Operations Center DATE: February 5, 2014 U.S. Nuclear Regulatory Commission NRC Document Control Desk Washington, DC 20555-0001

SUBJECT:

FINAL REPORT For component ASME Material supplied by Mirion Technologies (Conax Nuclear), Inc. (MTCN), as part of Containment Electric Penetration Assemblies (EPA)

Reference:

U.S. NRC Event Number 49301 MTCN Initial Notification & Interim Report Letter dated August 23, 2013 MTCN Interim Report letter dated September 23, 2013 Gentlemen/Ladies:

The purpose of this letter is to provide our final report to the Nuclear Regulatory Commission regarding a potential non-conformance of materials supplied to operating US nuclear power plants by Mirion Technologies (Conax Nuclear), Inc. (MTCN) with Containment Electric Penetration Assemblies (EPA).

Our initial notification was submitted August 23, 2013 and was updated by the interim report dated September 23, 2013. This final report, attached hereto, is submitted in compliance with the requirements of 10 CFR 21.

As a result of our Part 21 evaluation, we have determined that those Identified Basic Components that were installed in U.S. nuclear facilities have been determined to meet the requirements of ASME NCA-3800. Therefore, no substantial safety hazard exists as a result of the previously reported condition, this condition is not reportable under 10 CFR 21 and this letter is final closure of the Part 21 evaluation.

Mirlon Technologies (Conax Nuclear), Inc.

By: JO"S.

la Hae dQ John D. MacDonald, Director of Operations Cc: Mirion: I. Wilson, CEO; President, Sensing Systems Division Mirion: P. E. Couchman, Quality Engineer Mirlon: R. L. Nikander, Chief Engineer Mirion: M. L. Staskiewicz, Sales Manager HSB: P. M. McCarthy, ANI Supervisor Page 1 of 5

FEB. 05 '14 (WED) 05:24 IST CONAX 716 681 1139 PAGE. 2/7

- M IR IO N Sensing Systems Division Mirlon Technologies (Conax Nuclear), Inc.

402 Sonwil Drive Tel: (716) 681-1973 Fax: (716) 681-1139 www.mirion.com TECHNOLOGIES Buffalo, NY 14225-5530 Featuring lot=

February 5, 2014 Mirlon Technoloaies (Conax Nuclear) Inc., 10 CFR 21 Final Report Attachment "A" I. Reporting Individual:

J. D. MacDonald, Director of Operations Mirion Technologies (Conax Nuclear) Inc.

402 Sonwil Drive Buffalo, NY 14225-5530 Tel: 716-681-1973, ext. 203 Fax: 716-681-1139 e-mail: imacdonald@mirion.com

11. Identification of Basic Components supplied which have a potential defect:
a. The following materials supplied with the Electric Penetration Assemblies (EPAs):
i. Headerplates Ii. Mounting weldment rings
b. Flanges:
i. Weld-neck flanges for mounting of EPA Ill. Identification of the firm suoolvin2 the Basic Component:

Mirion Technologies (Conax Nuclear) Inc.

402 Sonwil Drive Buffalo, NY 14225-5530 IV. Nature of Potential Defect (Updated):

MTCN's initial Notification reported that material supplied to MTCN by approved sub-suppliers audited to NCA-3800 by MTCN was considered to be ASME qualified source material for Section II and Section III requirements. During triennial Survey of MTCN by the ASME for renewal of our N Type Certificates of Authorization, it was identified by the ASME Survey team that material supplied by two (2) MTCN approved sub-suppliers should be considered unqualified source material. At that time, MTCN's Quality Program did not include the use of unqualified source material.

Since MTCN's initial Notification and subsequent Interim Report, we have completed our Part 21 evaluation and provide the following final information to close out our 10 CFR 21 Report:

1. In accordance with ASME NCA-3855.5, MTCN has completed additional independent laboratory material testing on each plate of headerplate and mounting weldment ring material in accordance with ASME SA-240. The additional testing verified that such material met the -requirements of NCA-3800 and therefore does not Impact material safety or Performance of the EPAS delivered. This Is discussed more fully in Section VII below.

Page 2 of 5

FEB 05 '14 (WED) 05:25 IST CONAX 716 661 1139 PAGE. 3/7 MIRION Sensing Systems Division Tel: (716) 681-1973 ru, TECHNOLOGIES Mirlon Technologies (Conax Nuclear), Inc.

402 Sonwll Drive Buffalo, NY 14225-5530 Fax: (716) 681-1139 www.mlrion.com Featti,,ng

2. No identified Weld-Neck Flanges have been, or will be, installed. Weld-neck flanges were only supplied in the U.S. to the Oconee Nuclear Power Plant and have either now been destroyed or placed "on hold" for disposition. Since all weld-neck flanges were never installed and are not now, nor will be, in use, there is no issue pertaining to material safety or performance and thus no additional laboratory testing was undertaken.

V. Date the potential defect was discovered:

June 20, 2013 VI. Number and location of basic components in use at, supplied for, being supplied for, manufactured or being manufactured for facilities subiect to the regulations in this part (Updated):

Reflecting the results of MTCN investigation as of the date of this report, an updated tabulation is presented as follows:

Basic Components supplied ....

Plant Name No. Basic Component Use Status as of February 4, 2014 Oconee 23 Weld-Neck Flanges 18 scrapped from Duke Energy's inventory.

5 in plant stock, placed On Hold.

MTCN to coordinate disposition with Oconee.

Ginna 1 Headerplate(s) Installed, 2009.

Crystal River 2 Headerplates(s) Not installed. Plant closing. On Hold Mounting weldment ring(s)

Point Beach 2 Headerplate(s) Not installed. On Hold Monticello 1 Headerplate(s) Installed in 2011.

D. C. Cook 1 Headerplate(s) Not Installed. On Hold Turkey Point 3 Headerplates(s) Not installed. On Hold Basic Components being manufactured Materials on-hand for Basic Components being manufactured were identified and segregated at time of Notification. With revision to MTCN's Quality Program Manual and re-issue by the ASME of our "N" and "NPT" Certificates of Authorization, the unqualified source material has been tested, reviewed and approved for use.

VII. Corrective action taken, being taken, or will be taken, and the name of the organization responsible for the action (Updated):

Mirion Technologies (Conax Nuclear), Inc. is the organization responsible for the corrective actions.

Actions taken, being taken, or will be taken to the extent known at this time:

a. MTCN has reviewed all purchases of all other ASME Code materials used with the EPA Page 3 of 5

FEB, 05 ' 14 (WED) 05: 25 IST CONAX 716 681 1139 PAGE. 4/7 Sensing Systems Division Tel: (716) 681-1973 M IR IO N Mirlon Technologies (Conax Nuclear), Inc.

402 Sonwil Drive Fax: (716) 681-1139 www.mirion.com Buffalo, NY 14225-5530 Featuring and verified all such supply has been from ASME Quality System Certificate (QSC)

Holders. The scope of this Notification is confirmed to be limited to the materials identified in Section II above.

b. Subject materials identified in Section II above were supplied with Certified Material Test Reports (CMTRs) which were reviewed at receipt to meet the ASME Code requirements for the material.
c. MTCN's Quality Program Manual has now been revised, and approved by the relevant Authorized Nuclear Inspector Surveillance (ANIS), to include the use of unqualified source material.
d. On October 28, 2013, ASME reauthorized MTCN for ASME "N" Certificate of Authorization Number N-1849 and for ASME "NPT" Certificate of Authorization Number N-1850 (copies attached), valid until September 3, 2016.
e. In accordance with ASME NCA-3855.5, MTCN has completed additional independent laboratory material testing on coupon samples of each plate of headerplate and mounting weldment ring material in accordance with ASME SA-240. The independent testing was performed by an MTCN Approved Supplier test lab to re-verify the mechanical properties of ASME Code materials.

Based on the testing results showing that the EPA headerplate and mounting ring material supplied by MTCN to U.S. plants (see Section VI above) meet the requirements of ASME SA-240, we have determined that such material meets the requirements of ASME NCA-3800 and does not Impact material safety or performance of the EPAs delivered.

L Traceability of material samples was verified for the EPA SA-240 materials supplied.

ii. Compliance to ASME SA-240 material requirements has been verified by testing of the material properties of samples.

iii. Chemical and mechanical re-verification test results indicate there have been no test failures comoared to the ASME SA-240 material requirements, indlcatlnx the materials are not defective:

" Chemistry test results meet the requirements for ASME SA-240 material.

" Mechanical test results meet or exceed the minimum requirements for SA-240 material:

  • tensile strength
  • yield strength
  • elongation
  • Material is below the maximum hardness for ASME SA-240 material.
  • Material passed the Inter-granular Stress Corrosion Cracking testing in Page 4 of 5

FEB. 05 '14 (WED) 05:26 IST CONAX 716 681 11399 PAGE. 5/7 Sensing Systems Division Tel: (716) 681-1973 M IR IO N Mirion Technologies (Conax Nuclear), Inc. Fax: (716) 681-1139 STECH NOLOGI ES 402 Sonwil Drive Buffalo, NY 14225-5530 www.mirlon.com Featurn.

Featuring accordance with ASTM A-262-13, Practice E.

As noted above, testingt has verified the EPA material s.qpplIed meets the requirements of ASME NCA-3B00 and does not impact material safety or Performance of the EPAs delivered.

f. For all U.S. licensees of plants identified in Section Vi to whom MTCN shipped materials identified in Section II above, MTCN is revising the Quality Assurance (QA) Data Package for the EPAs to include revised CMTRs for the ASME SA-240 unqualified source materials used with the EPA. The revised QA Data Packages and revised CMTRs are being supplied to each plant listed.

VIII. Advice related to the potential defect about the basic component that has been. is being or will be tiven to the purchasers or licensee (Updated):

Licensees noted above in Section VI were notified of the potential defect and were requested to supply MTCN with usage status (i.e., whether components are installed, destroyed or in stock).

All licensees listed in the table in Section IVabove supplied MTCN with usage status as reflected in Section VI.

With regard to weld-neck flanges for mounting of EPA, no Identified weld-neck flanges have been, nor will be, installed by any US licensee. Weld-neck flanges were only supplied to one U.S.

site (Oconee Nuclear Power Plant) and have either now been destroyed or placed "on hold" for appropriate disposition.

With regard to the headerplate and mounting weldment ring materials, MTCN has determined that these Basic Components meet the requirements of NCA-3800. Accordingly, MTCN is revising the applicable QA Data Package of the EPA for the supplied Material for each licensee listed in Section VI and is providing revised QA Data Packages to each.

Based on the foregoing, no substantial safety hazard exists as a result of the previously reported condition. Therefore, this condition is not reportable under 10 CFR 21 and this letter is final closure of the Part 21 evaluation.

Page 5 of 5

FEB. 05 '14 (WED) 05:26 IST CONAX 716 681 1139 PAGE. 6/'7 CERTIFICATE OF AUTHORIZATION N

The named company is authorized by the American Society of Mechanical Engineers (ASME) for the scope of activity shown below in accordance with the applicable rules of the ASME Boiler and Pressure Vessel Code. The use of the certification mark and the authority granted by this Certificate of Authorization are subject to the provisions of the agreement set forth in the application. Any construction stamped with this certification mark shall have been built strictly in accordance with the provisions of the ASME Boiler 0

ca and Pressure Vessel Code.

MNi COMPANY:

Mirlon Technologies (Conax Nuclear), Inc.

402 Sonwil Drive Cheektowaga, New York 14225-5530 SCOPE:

_.9 Construction of Class 1, 2,3, & MC vessels and Class 1, 2, & 3 valves at the above location and with additional Code activities as described In the Quality Program UJ Manual at 456 Sonwil Drive, Cheektowaga, New York 14225 0

MNOW AUTHORIZED: October 28, 2013 CI EXPIRES: September 3, 2016 CERTIFICATE NUMBER: N-1849 0

E 1- Vice President, Conformity Assessment Director, Conformity Assessment

FEB. 05 14 (WED) 05:26 IST CONAX 716 681 1139 PAGE. T./'7 CERTIFICATE OF AUTHORIZATION NPT The named company: Is authorized by the American Society of Mechanical Engineers (ASME) for the scope of activity shown below in accordance with the applicable rules of the ASME Boiler and Pressure Vessel Code. The use of the certification mark and the authority granted by. this:Certificate of Authorization are subject to the provisions of the agreement set forth in the application. Any construction stamped with this certification mark shall have been builtstrictly in accordance with the provisions of the ASME Boiler and Pressure Vessel Code.

  • ~COMPANY.  !*

CO N :MIrlon Technologles.:(Conax Nuclear), Inc.

S. 402 Sonwil Drive LU I Cheektowaga, New York 142264630 SCOPE:

Class 1. 2, 3, & MC fabrication without: design responsibility and fabrication with design retponsibility.for Class ., 2, 3,.& MC appurtenances and as a Material 0 Organization manufacturing and supplying ferrous & nonferrous material at the above location and with additional Code activities as described :in the Quality Program Manual at 456 Sonwil Drive,:.Cheektowaga, New York 14225 0

ar)

AUTHORIZED: October 28, 2013 CC EXPIRES: Septem ber 3,2016 CERTIFICATE NUMBER N-1 850 I- Vice President, Conformity Assessment Director, Conformity Assessment