ML21222A051
| ML21222A051 | |
| Person / Time | |
|---|---|
| Issue date: | 08/10/2021 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Chris Miller NRC/NRR/DRO |
| Armstrong A | |
| References | |
| Download: ML21222A051 (4) | |
Text
August 10, 2021 MEMORANDUM TO: Chris Miller, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
TRIP REPORT BY THE NUCLEAR REGULATORY COMMISSION STAFF VIRTUAL MDEP VENDOR INSPECTION AT FRAMATOME SAINT-MARCEL FRANCE, SESSIONS 1 & 2 On May 2, 2021 through May 6, 2021 (Session 1) and June 28, 2021 through July 02, 2021 (Session 2), Aaron Armstrong, of the Office of Nuclear Reactor Regulation, Division of Reactor Oversight, Quality Assurance and Vendor Inspection Branch, and John Honcharik, of the Office of Nuclear Reactor Regulation, Division of New and Renewed Licenses (DNRL), Piping and Head Penetrations Branch, participated on a virtual Multinational Design Evaluation Program (MDEP) Vendor Inspection Cooperation Working Group (VICWG) of Framatome in Saint Marcel, France. The inspection was led by the French regulator, French Nuclear Safety Authority (ASN), and included inspectors from France, United Kingdom, Finland, South Africa, and the US. The purpose of this MDEP inspection was to obtain more information on the issues identified with Framatomes post weld heat treatment and welding processes.
CONTACT:
Aaron Armstrong, NRR/DRO/IQVB (301) 415-8396
Enclosure:
NRC International Trip Report Signed by Kavanagh, Kerri on 08/10/21
ML21222A051 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NAME AArmstrong KKavanagh DATE 8/5/2021 8/10/2021
Enclosure NRC INTERNATIONAL TRIP REPORT Traveler, Office, Division:
Aaron Armstrong, Reactor Operations Engineer, Office of Nuclear Reactor Regulation (NRR),
Division of Reactor Oversite (DRO), Quality Assurance and Vendor Inspection Branch (IQVB)
Honcharik, John, Senior Materials Engineer, Piping and Head Penetrations Branch (NPHP)
Division of New and Renewed Licenses (DNRL), Office of Nuclear Reactor Regulation (NRR)
Subject:
TRIP REPORT BY THE NUCLEAR REGULATORY COMMISSION STAFF VIRTUAL MDEP VENDOR INSPECTION AT FRAMATOME SAINT-MARCEL FRANCE, SESSIONS 1 & 2 Date of Travel and Countries/Organizations Visited:
Virtual Session 1: May 02, 2021 through May 06, 2021 at Saint Marcel, France - Framatome Virtual Session 2: June 28, 2021 through July 02, 2021 at Saint Marcel, France - Framatome Background/Purpose From May 02, 2021 through May 06, 2021 and June 28, 2021 through July 02, 2021 the NRC inspectors participated in a Joint Multinational Design Evaluation Program (MDEP) Vendor Inspection Cooperation Working Group (VICWG) inspection Framatome at Saint Marcel, France. MDEP VICWG inspections are a tool to gain vendor performance insights with efficiencies gained by sharing inspection resources from the participating regulators. The MDEP VICWG document used in the implementation of this inspection was:
MDEP Protocol VICWG-01, "Common Position: Witnessed, Joint, and Multinational Vendor Inspection Protocol, Version, 1 Dated November 4, 2020 The MDEP VICWG inspection focused on Framatome oversight of its Quality Improvement Plan (QIP) and Post Weld Heat Treatment (PWHT) deviations identified at the Saint Marcel plant from 2000 until 2015. Framatome presentations discussed Framatomes manufacturing processes, quality assurance (QA)/quality management (QM) system, and oversight of Framatome activities.
The MDEP VICWG inspectors reviewed Framatome documentation and procedures, conducted interviews of Framatome personnel, watched a virtual walked down of Framatomes manufacturing shop, and virtual observed Framatomes welding operations.
The purpose of this MDEP multinational vendor inspection is to evaluate the ability of Framatome to ensure that the equipment delivered from its Saint-Marcel site meet the applicable participating regulators requirements. Framatome manufactures heavy nuclear island components including nuclear reactor vessels, steam generators, pressurizers, reactor coolant pumps, and primary piping that connects the reactor to the steam generators. The Saint-Marcel site is dedicated to the assembly of vessels, steam generators, pressurizers, and primary piping.
The Saint-Marcel site identified technical issues in 2019 with their PWHT (electrical resistance
2 and blankets process) involving several global nuclear customers. These identified issues are applicable to past USA, Finland, and France projects, as well as ongoing France and United Kingdom projects. The MDEP VICWG inspection team consisted of 7 ASN (The French Nuclear Safety Authority) inspectors, 5 ONR (Office for Nuclear Regulation, United Kingdom) inspectors, 2 NRC inspectors (Nuclear Regulatory Commission, United States), 2 NRR inspectors (National Nuclear Regulator, South Africa) and 1 STUK inspector (Radiation and Nuclear Safety Authority, Finland) inspectors.
Summary of MDEP Inspection as it Relates to US Licensees:
The NRC inspectors were able to review and evaluate Framatomes 10 CFR Part 21 evaluations for affected U.S. nuclear power plants. The NRC inspectors also selected and reviewed applicable criterion of Appendix B to 10 CFR Part 50, which included corrective actions, special process, and audits. This report addresses both sessions of the MDEP inspection. Framatome discussed with the NRC inspectors that currently there are no US basic components on order or under construction at the time of this inspection.
The NRC reviewed the current basis for the PWHT (below minimum required temperature) evaluations of the steam generator (SG) and pressurizer components for ANO Unit 1, Callaway, Millstone Unit 2, Prairie Island Unit 2, Salem Unit 2, and St. Lucie Units 1 and 2. The NRC inspectors confirmed Framatome performed specific material testing related to fracture toughness of the material with PWHT below the minimum required temperature, however, the additional generic material testing of low temperature PWHT is ongoing to confirm the analyses, accuracies and margins used in the initial evaluations are acceptable.
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Conclusion:==
The NRC inspectors noted challenges and limitations associated with performing a virtual inspection which included documentation availability at the time of the inspection. The implementation of special process procedures, including welding, could not be easily verified due to the virtual inspection providing limited access to both the special processes being performed and the implementing procedures. Due to the industrial setting, background noise obscured the shop employees ability to effectively communicate with the virtual inspectors which inhibited the desired inspection results. There were logistical issues in performing the inspection remotely which affected the quality of the evidence gathered compared to what would be expected during an in-person inspection. Nonetheless, the inspection did provide information of the ongoing testing and QIP being implemented by Framatome. No findings of significance were identified for the limited documents available for NRC inspectors.