ML22063B166
| ML22063B166 | |
| Person / Time | |
|---|---|
| Site: | 07201004, 07201042 |
| Issue date: | 03/16/2022 |
| From: | Matthew Learn NRC/NMSS/DFM/IOB |
| To: | Ocampos B TN Americas LLC |
| E LOVE NRC/NMSS/DFM/IOB 3014157011 | |
| Shared Package | |
| ML22063B164 | List: |
| References | |
| IR 2022201 | |
| Download: ML22063B166 (11) | |
Text
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management Docket:
07201004 and 07201042 Report.:
72-1004/2022-201 Enterprise Identifier: I-2022-201-0004 Certificate Holder:
TN Americas, LLC Facility:
TN Fabrication Location:
Kernersville, NC Inspection Dates:
January 25, through January 27, 2022 Inspection Team:
Earl Love, Senior, Transportation and Storage Safety Inspector, Team Leader Marlone Davis, Senior Transportation and Storage Safety Inspector Jeremy Tapp, Transportation and Storage Safety Inspector Omar Khan, Materials Engineer, Materials and Structural Branch Azmi Djapari, Inspector in Training Approved By:
Hipolito Gonzalez, Acting Branch Chief Inspections and Operations Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management EXECUTIVE
SUMMARY
TN Americas LLC NRC Inspection Report 72-1004/2022-201 On January 25, through January 27, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced onsite inspection of TN Fabrication (TNF) located in Kernersville, NC. TNF fabricates storage and transport systems for spent fuel and radioactive materials, classified as important-to-safety (ITS), subject to the requirements of Title 10 of the Code of Federal Regulations 10 CFR Part 72; and associated NRC Certificate(s) of Compliance (CoCs).
The purpose of the inspection was to verify and assess the adequacy of TN's compliance with the NRC requirements for the design, modification, fabrication, assembly, testing, and procurement of dry cask storage systems (DCSS). The scope of the inspection was specific to TNs NUHOMS EOS and Standardized Horizontal Modular Storage Systems, CoC Nos. 1042 and 1004, respectively.
Design Control The team determined, for the items selected for review, that the fabrication specifications were consistent with the design commitments and requirements documented in the safety analysis report (SAR), the CoC, and technical specifications (TS). (Section 1.1)
Corrective Action and Non-Conformance Reports The team determined that generally corrective actions for identified fabrication deficiencies were implemented in a time frame commensurate with their significance, and nonconformance reports documenting the deficiencies were initiated and resolved. (Section 1.2)
Personnel Training and Certifications The team determined that individuals performing quality-related activities were trained and certified as required. (Section 1.3)
Human Performance The team determined that fabricator's personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality controls associated with the construction of the DCSS. (Section 1.4)
Procurement The team determine that materials, components, and other equipment received by the fabricator meet DCSS design procurement specifications, and the procurement specifications conform to the design commitments and requirements contained in the Final Safety Analysis Report (FSAR), CoC and TS. (Section 1.5)
Implementing Procedures The team determined that DCSS components were being fabricated and inspected per approved quality assurance (QA) and 10 CFR Part 21 implementing procedures and fabrication specifications. (Section 1.6) 10 CFR Part 21 The team determined that: fabrication activities were conducted under an NRC-approved QAP; the provisions of 10 CFR Part 21 were implemented; the fabricator's personnel were familiar with the reporting requirements of 10 CFR Part 21; and the fabricator complied with 10 CFR 21.6, "Posting requirements". (Section 1.7)
Oversight and Audits The team determined, for the items selected for review, that the CoC holder is performing oversight and audits in accordance with their QA program. (Section 1.8)
2 REPORT DETAILS 1.0 ISFSI Component Fabrication by Outside Fabricators (Inspection Procedure (IP) 60852) 1.1 Design Control 1.1.1 Inspection Scope The team determined whether the fabrication specifications were consistent with the design commitments and requirements documented in the SAR, the CoC, and TSs.
The team reviewed NUHOMS EOS and Standardized Horizontal Modular Storage Systems licensing drawings against the design and fabrication drawings to verify the consistency of critical dimensions and material specification as well as testing and inspection requirements to determine whether they were consistent with the design.
Specifically, the team focused on design commitments and requirements for ITS Category A and B, components of the NUHOMS EOS-37PTH and Standardized 61BTH dry shielded canisters (DSC) from TNs FSARs to design and fabrication drawings, and subsequently shop manufacturing plans.
The team reviewed TNs Fabrication Programs Manual (FPM) as well as NextEra Energy Duane Arnold (NEDA) and Dominion Energy (DE) project specific procedures associated with design and fabrication of DSCs to verify proper implementation.
Additionally, the team observed various special processes, testing, and nondestructive examinations as described in Section 1.4.1. The following is a list of documents reviewed:
EOS-37PTH: TN CoC 1042, Amendment 2 11069.FD1, Dominion Energy Project Plan, Millstone Power Station, Revision 3 EOS01-0105, TN Procurement Specification DSC and Basket, Revision 10 EOS01-1000, Main Assembly, Revision 12 EOS01-1001, Shell Assembly, Revision 5 EOS01-1012, Basket Assembly, Revision 11 EOS-37PTH: CoC 1042, Amendment 1 1049D.FD1, Dominion Energy Project Plan, Surry Power Station, Revision 4 1049C.FD1, Dominion Energy Project Plan, North Anna Power Station, Revision 4 EOS01-1000, Main Assembly, Revision 15 TN CoC 1042, Amendment 1, specific to DSC serial Number NAN-EOS-37PTH-006-B 1049A.FD4, Dominion Energy Project Plan, North Anna Power Station, Revision 7 EOS01-0105, TN Procurement Specification DSC and Basket, Revision 5 EOS01-1000, Main Assembly, Revision 10 EOS01-1001, Shell Assembly, Revision 4 EOS01-1010, Basket Assembly, Revision 9
3 DE - North Anna, Surry and Millstone DSC Procedures:
NDE-RT, Radiograph Examination, Revision 0 2010-2011 A-RTNB, RT Acceptance Criteria for ASME Section III NB, 2010 Edition, 2011 Addenda, Revision 0 NEDA DSC Specification, Drawings, and Procedures (61BTH: CoC 1004, Amendment 17):
1269-DSC, NextEra Energy Project Plan, NextEra Energy Duane Arnold (NEDA),
Revision 10 NUH61BTH-0105, Procurement Specification for 61BTH Type 1 and Type 2 Dry Shielded Canisters, Revision 14 NUH61BTH-4000, 61BTH Type 2 Main Assembly, Revision 15 NUH61BTH-4001, 61BTH Type 2 Shell Assembly, Revision 10 NUH61BTH-4002, 61BTH Type 2 Basket Assembly, Revision 15 NDE-HMSLD-01, HMSLD Leak Test of Dry Shielded Canisters: 61BTH2, Revision 1
NDE-PT, Liquid Penetrant Examination, Revision 0 61BTH2-PTNB, PT acceptance Criteria for ASME Section III NB, Revision 0 WPS 08081-101, GTAW Manual, Revision 10 WPS 08084-101, SAW, Machine, Revision 8 The team evaluated the design controls that were in place for the transmittal and handling of the above mentioned design drawings received from TN and how TNF transitioned from design to fabrication, as applicable. The team also evaluated the process for distributing controlled drawings, their locations, and retrieval to verify that old or uncontrolled versions were not being used.
1.1.2 Observation and Findings The team did not identify any discrepancies between the design and fabrication specifications and the FSAR licensing drawings. The team noted that TNF captured all requirements that were applicable to fabrication and noted that TNF fabrication drawings contained the relevant information needed for fabrication and had adequate document control and storage of quality assurance (QA) records.
Overall, the team did not identify any issues of concerns in the translation of design information. The team noted fabrication drawings, shop travelers, and procedures were adequately identified at various work locations with each component as necessary and that documents reflected the correct revisions, as applicable.
No findings were identified.
1.1.3 Conclusions The team determined, for the items selected for review, that the fabrication specifications were consistent with the design commitments and requirements documented in the FSAR, the CoC, and TS.
1.2 Corrective Action and Non-Conformance Reports
4 1.2.1 Inspection Scope The team determined whether corrective actions for identified fabrication deficiencies have been implemented in a time frame commensurate with their significance, and whether nonconformance reports documenting the deficiencies have been initiated and resolved.
The team reviewed a sample of records and interviewed personnel to determine whether TNF effectively implemented corrective actions identified for fabrication deficiencies in a time frame commensurate with their significance and in accordance with their QA program procedure. Specifically, the team reviewed TIP 16.1, Corrective Action, Revision 32. The team selected and reviewed 11 corrective action reports (CARs) from December 2019 to January 2022. The team focused the review on Level 2 CARs that require an apparent cause determination and preventive actions. The team also included a review of CAR number 2019-413 to follow-up on the corrective actions because development of the actions was still on-going during the previous inspection performed at TNF in February 2020.
In addition, the team reviewed selected records and interviewed personnel to verify that TNF effectively implemented a nonconformance control program in accordance with the requirements of 10 CFR Part 72 and approved QA procedures. Specifically, the team reviewed TIP 15.2, Control of Nonconforming Items, Revision 21 and TIP 15.4, Control of Fabrication Nonconforming Items, Revision 3 that is specifically implemented at TNF. The team selected 21 nonconformance reports (NCRs) to verify that the NCRs were identifiable, traceable, and the disposition of the nonconformance was adequate. The team reviewed NCRs since the December 2019 inspection and concentrated on issues involving ITS structures, systems, and components (SSCs). The team reviewed these NCRs to evaluate if the disposition was appropriate, adequately performed as necessary, and properly closed out in accordance with the approved procedure TIP 15.4. The team focused the review on NCRs with accept-as-is and repair dispositions because generally these required a technical justification or engineering evaluation against the licensing basis and potentially 10 CFR 72.48 as well.
1.2.2 Observations and Findings The team assessed that TNF adequately implemented the overall TN CAP in place at TNF to resolve conditions and, if necessary, significant conditions adverse to quality based on the review of the approved procedure TIP 16.1. Based on the review of CARs, the conditions adverse to quality TNF entered into the CAP were generally resolved in a technically sound and as resources allowed, a timely manner.
The team assessed that TNF in general, adequately dispositioned and closed each selected NCR in accordance with the requirements of TIP 15.4, as applicable.
No findings were identified.
1.2.3 Conclusions Overall, the team determined that TNF had an adequate CAP in place to resolve identified issues. The team determined that TNF, in general, completed corrective actions for identified deficiencies in a technically sound and timely manner. The team concluded that TNF effectively implemented its nonconformance control program and
5 has adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements.
1.3 Personnel Training and Certifications 1.3.1 Inspection Scope The team determined whether individuals performing quality-related activities were trained and certified where required. The team reviewed the records of two selected quality inspectors (Stamp No.s QC-3 and QC-23) and three welders (Stamp Nos: W-8, 72 and 125) that performed DSC nondestructive examinations and welding and reviewed selected records, interviewed personnel. The following quality procedures were reviewed:
FPM 2.3, Qualification and Certification of Nondestructive Examination Personnel, Revision 1 FPM 9.2, Welding Performance Qualification Testing and Records; Revision 3 1.3.2 Observation and Findings The team noted welder performance qualifications and welder continuities conformed to Section IX of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. For the welding qualification records reviewed, the team noted that the welders were qualified in each applicable process, and that welding continuity was maintained for each of the welding processes qualified to date. The team also noted that TNF qualifies nondestructive testing (NDT) personnel in accordance with the American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A, which includes the required training, experience, medical testing, and education.
No findings were identified.
1.3.3 Conclusions The team determined that individuals performing quality-related activities were trained and certified as required.
1.4 Human Performance 1.4.1 Inspection Scope The team determined whether the fabricator's personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality controls (QC) associated with the construction of the DCSS.
The team evaluated TNF's control of the fabrication process through observations, examinations of records, and personnel interviews in the areas of fabrication and assembly, test and inspection, and familiarity with tools and equipment. The team observed/witnessed the following activities:
DSC bottom forging-to-shell submersible arc weld
6 Liquid Penetrant (PT) examination of longitudinal shell welds, support ring, and lift lugs Welding of EOS R45 basket rails Control and storage of ITS Category A materials and components (e.g., forgings, top cover plates, shells, weld wire and flux, R45 basket rail components)
Radiograph examination of a bottom forging-to-shell weld repair applicable to DSC Serial No. 37PTH-009 Shell assembly helium leak test applicable to DSC Serial No. DAE-61BTH-060 PT examination of a scratch/gouge on outside shell of DSC Serial No. WC-EOS-37PTH-002-B4L (TN NCR 2021-208)
The team also reviewed a selection of shop travelers for completed EOS and 61BTH DSCs as a part of the review of final document package numbers Duane Arnold Energy-61BTH-2-D-2H-047 and North Anna Nuclear-EOS-3-006-B-01 to determine if the travelers were being completed adequately. This document packages review also included but were not limited to TN CoCs, shop travelers, NDE, functional test, and dimensional inspection reports, as well as NCRs.
1.4.2 Observation and Findings The team noted that TNF personnel performed fabrication activities were adequate and that TNF staff were knowledgeable about the specified design, designated fabrication techniques, testing requirements, and QC associated with the construction of the DSCs.
During the observations of fabrication and NDE activities the team determined that the work was well controlled, individuals were knowledgeable of the applicable fabrication process, and the work was being performed in accordance with the applicable fabrication procedures, shop travelers and weld procedure specifications (WPS).
No findings were identified.
1.4.3 Conclusions The team determined that the offsite fabricator's personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and QC associated with the construction of the DCSs.
1.5 Procurement 1.5.1 Inspection Scope The team determine whether: a) Materials, components, and other equipment received by the fabricator meet DCSS design procurement specifications, and b) The procurement specifications conform to the design commitments and requirements contained in the FSAR, CoC, and TS.
The team reviewed TNs processes that address procurement, including traceability and receipt inspection. The team reviewed selected drawings and records and interviewed selected personnel to verify that the procurement specifications for materials, fabrication, inspection, and services performed at TNF met design requirements. The team verified that TN used a graded approach for identifying ITS components during the design process and TN applied this graded quality to components and material procurement
7 documents. The team selected ITS components such as the neutron absorbers, fuel compartment tubes, and the DSC inner top cover plate for review. The team reviewed the following implementing procedures and procurement documents:
TIP 7.3, Dedication of Commercial Grade Items, Revision 15, TIP 7.9, Receipt Inspection, Revision 11, TIP 7.11, Approved Suppliers List, Revision 16 NUH61BTH-0105, Procurement Specification for the NUHOMS 61BTH Type 1 and 2 Dry Shielded Canisters, Revision 14 The team also reviewed the following purchase order (PO) and receipt inspection reports (RIR):
PO No. P2019-0785 RIR No. 1002636, Stainless Steel Sub Arc Flux RIR No. 1002635, SAW Weld Wire 1.5.2 1.5.2 Observation and Findings The team observed that TN had adequate control of the procurement processes for the ITS components reviewed. Overall, TN procured ITS components consistent with design requirements and their implementing procedures. Further, TNs material traceability, procurement, and receipt inspection controls were adequate. The team determined that the purchase orders were adequate and specified the applicable criteria and requirements including Part 21. The material ordered and received by TNF met the design requirements, the critical characteristics and were adequate for the material dedicated. Additionally, TNF verified and maintained the traceability throughout the procurement and receipt process. The team determined that TN purchased the components from vendors on the TN approved vendors list.
No findings were identified.
1.5.3 Conclusions The team determined that materials, components, and other equipment received by the fabricator met DSC design procurement specifications, and the procurement specifications conform to the design commitments and requirements contained in the FSAR, CoC and TS.
1.6 Implementing Procedures 1.6.1 Inspection Scope The team determined whether DCSS components are being fabricated per approved quality assurance (QA) and 10 CFR Part 21 implementing procedures and fabrication specifications. The team evaluated TNF's control of the fabrication process through observations, examinations of records, and personnel interviews in the areas of fabrication and assembly, test and inspection, and tools and equipment.
The team reviewed selected measuring and test equipment (M&TE) records and procedure FPM 12.1, Control of Measuring and Test Equipment, Revision 1 to assure
8 that equipment used in activities affecting quality were properly controlled and calibrated.
The team compared a sampling of measuring and test equipment in current use for fabrication activities and determined overall compliance to procedural requirements.
The calibration records reviewed documented the date of calibration, item description, serial number, due date for next calibration, calibration frequency, "As-found" and "As Left" condition at each calibration or check point, reference procedure used, test standard identification, and allowable tolerance, as applicable for each device. In addition, the team verified that if the M&TE had been sent offsite for calibration that the calibration service providers were appropriately qualified.
1.6.2 Observation and Findings No findings were identified.
1.6.3 Conclusions The team determined that DSC components were generally being fabricated and inspected per approved QA and 10 CFR Part 21 implementing procedures and fabrication specifications.
1.7 10 CFR Part 21 1.7.1 Inspection Scope The team reviewed program controls for 10 CFR Part 21, specifically, TIP 15.1, "Reporting of Defects and Noncompliances," to evaluate if provisions were in place for evaluating deviations that could cause a substantial safety hazard and complete the required notification in timely manner and interviewed personnel to verify if they were familiar with the TIP. The team also reviewed TNFs posting of Part 21 requirements in accordance with the 10 CFR 21.6, Posting requirements.
1.7.2 Observation and Findings The team assessed that TNF has provisions in place for evaluating deviations and reporting defects, as required by 10 CFR Part 21. The team noted that TNF did not have any Part 21 reports within the last six years. The team also noted that TNF posted Part 21 requirements throughout their office and fabrication facility.
No findings were identified.
1.7.3 Conclusions The team determined that: fabrication activities were conducted under an NRC-approved QAP (10 CFR 72.140); the provisions of 10 CFR Part 21 were implemented; the fabricator's personnel were familiar with the reporting requirements of 10 CFR Part 21; and the fabricator complied with 10 CFR 21.6, "Posting requirements."
1.8 Oversight and Audits 1.8.1 Inspection Scope
9 Regarding QA activities, the team determined whether: a. The fabricator has been audited by either the licensee or CoC holder. b. For selected audits and inspection findings from (as applicable) QA audit or surveillance and/or inspection reports issued in the previous 2 years, the findings were appropriately handled with corrective actions implemented in a time frame commensurate with their safety significance.
The team reviewed the TN internal audit program to determine if TN scheduled, planned, and performed audits and surveillances in accordance with their approved implementing procedures. Specifically, the team reviewed TN quality procedure TIP 18.1, Internal Audits, Revision 18. The team selected a sample of audits and surveillances from the previous NRC inspection to the present. This included a sample of the lead auditor certifications and qualifications. The team particularly focused on activities related to fabrication of the 61BTH and EOS DSCs. The team reviewed the audit results to determine if TN identified deficiencies and addressed these deficiencies within their corrective action program. The team also evaluated whether TN provided adequate supervision with QC/QA personnel for appropriate oversight during fabrication activities.
Additionally, the team reviewed TNs supplier evaluations and audits associated with specified ITS components. Specifically, the team focused on supplier evaluations and audits for the neutron absorbers, material steel suppliers, and weld wire. The team reviewed the following procedures:
TIP 7.1, Supplier Evaluations, Revision 25, TIP 7.2, Supplier Audits, Revision 13, TIP 7.6, Commercial Grade Surveys, Revision 9, and TIP 7.13, Supplier Findings and Corrective Action, Revision 13.
1.8.2 Observation and Findings Overall, the team assessed that for the audits, surveillances, and evaluations sampled, TN conducted oversight with qualified and certified personnel, scheduled and evaluated applicable quality elements of TNF fabrication activities and approved suppliers. The team assessed that both TN and TNF appropriately identified issues and implemented corrective actions in a time frame commensurate with their safety significance.
No findings were identified.
1.8.3 Conclusions The team determined, for the items selected for review, that TN adequately performed audits, surveillances, and evaluations.
2.0 Exit Meeting The team presented the results of the inspection at an exit meeting on January 27, 2022.
TN acknowledged the results presented and did not identify any of the information discussed as proprietary.