ML23151A680
| ML23151A680 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/2023 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Russell Felts NRC/NRR/DRO |
| References | |
| Download: ML23151A680 (8) | |
Text
MEMORANDUM TO: Russ Felts, 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 COMMISSIONS STAFF OF THE NUPIC JOINT UTILITY TEAM AUDIT AT ORANO, TN AMERICAS, LLC.
On May 8-12, 2023, Greg Galletti of the Office of Nuclear Reactor Regulation, Division of Reactor Oversight, and Matthew Learn, of the Office of Nuclear Materials Safety and Safeguards, Division of Fuel Management, Inspections and Operations Branch, observed the performance of a Nuclear Procurement Issues Corporation (NUPIC) joint utility audit of ORANO, TN Americas, LLC., (TN Americas) in Columbia, Maryland and Kernersville, North Carolina.
Energy Harbor Nuclear, LLC., led the audit, with participation from Duke Energy, Xcel Energy, Pacific Gas & Electric, Entergy, Talen Energy, Omaha Public Power District, Constellation, Sacramento Municipal Utility District and the Electric Power Research Institute, using the NUPIC checklist and performance-based supplier audit (PBSA) worksheet. The TN Americas audit number is 25417. The purpose of the staffs observation was to assess the NUPIC quality assurance audit process used for suppliers of components to the nuclear industry. The trip report of the staffs observations includes a list of the NUPIC audit team members that participated in the audit.
CONTACT: Greg Galletti, NRR/DRO Matthew Learn NMSS/DFM (301) 415-1831 (630) 829-9603 June 20, 2023 Signed by Kavanagh, Kerri on 06/20/23
ML23151A680 NRR-106 OFFICE NRR/DRO/IQVB NMSS/DFM/IOB NRR/DIRS/IQVB NAME GGalletti MLearn KKavanagh DATE 6/1/2023 6/1/2023 6/20/2023
Enclosure NUCLEAR PROCUREMENT ISSUES CORPORATION AUDIT OBSERVATION TRIP REPORT Vendor Audited:
ORANO, TN Americas, LLC (TN Americas) 20 Bradley Park Road, East Granby, CT 06026 Lead Licensee:
Energy Harbor Nuclear, LLC.
Contact:
Leonard Weaver NUPIC Lead Auditor Energy Harbor Nuclear, LLC.
weaverl@energyharbor.com Nuclear Industry Activity:
TN Americas, located in Columbia, MD, and Kernersville, NC, produces spent fuel cannisters and transportation casks to the commercial nuclear industry.
Observation Dates:
May 8 - 12, 2023 Observer:
Greg Galletti, NRR/DRO/IQVB Matthew Learn, NMSS/DFM/IOB Approved by:
Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 Subject This trip report documents the observations made members of the U.S. Nuclear Regulatory Commission (NRC), Office Nuclear Reactor Regulation (NRR), Division of Reactor Oversight (DRO), during a Nuclear Procurement Issues Corporation (NUPIC) joint utility audit conducted on May 8-12, 2023, at the ORANO, TN Americas, LLC., (TN Americas) locations in Columbia, MD, and Kernersville, NC.
Background/Purpose NUPIC was formed in 1989 by a partnership involving all domestic and several international nuclear utilities. The NUPIC program evaluates suppliers furnishing safety-related components, services, and commercial-grade items to nuclear utilities. The NUPIC audit was performed using Revision 22 of the NUPIC audit checklist and the results will be provided to NUPIC members that procure parts and services from TN Americas.
The purpose of the NUPIC audit was to evaluate the implementation and effectiveness of TN Americas Quality Assurance (QA) Program at the Columbia and Kernersville facilities. The audit team was comprised of individuals from the following NUPIC member utilities: Energy Harbor Nuclear, LLC., (EHN) who led the audit, with participation from Duke Energy (DPC), Xcel Energy (EXL), Pacific Gas & Electric (PGE), Entergy (ENT), Talen Energy (TLN), Omaha Public Power District (OPP), Constellation (CEG), Sacramento Municipal Utility District (SMD), and the Electric Power Research Institute (EPRI). The technical specialists responsibility was to verify TN Americas ability to control the critical characteristics identified on the Performance Based Supplier Audit Worksheet (PBSA).
The purpose of the NRC staffs observation of this audit was to ensure that the NUPIC audit process continues to meet the requirements of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste. The NRC staff implemented Inspection Procedure 43005, NRC Oversight of Third-Party Organizations Implementing Quality Assurance Requirements, during the observation.
Observation Activities The NRC staff independently assessed and reviewed TN Americas implementation of selected portions of their QA program including special processes and testing, to evaluate whether NUPIC effectively identified and responded to issues. TN Americas provided the QA manual, implementing procedures, and samples of completed work products including, but not limited to, design packages, commercial-grade item dedication technical evaluations and plans, training and qualification records, shop fabrication drawings and process sheets (travelers), and corrective action reports to the NUPIC audit team. The TN Americas QA manual is based on the American Society of Mechanical Engineers Nuclear Quality Assurance standard NQA-1, "Quality Assurance Requirements for Nuclear Facility Applications," 2008/2009 Addenda.
The NRC staff observed that NUPIC appropriately focused their audit efforts on the Appendix B to 10 CFR Part 50 criteria most relevant to TN Americas activities such as design control, commercial-grade dedication, corrective action, control of special processes, inspection, control
3 of measurement and test equipment (M&TE), nonconforming materials, parts, and components, document control, and procurement document control. In addition, the NRC staff observed the NUPIC technical specialist focused on the critical areas described in the PBSA and the technical specialists conclusions were drawn from a review of objective evidence reflective of TN Americas performance. The NRC staff reviewed samples of the documentation provided by TN Americas for the audit team to draw independent conclusions in the areas of special processes and test control and observed activities in progress related to these areas as well as component fabrication. The NRC staff participated in discussions between the NUPIC audit team members and TN Americas staff, while refrained from directing or leading NUPIC, as to not interfere with the conduct of NUPICs audit.
The QA areas reviewed during the audit by the NUPIC member-representatives included the following areas from the NUPIC audit checklist: contract review, design, commercial-grade dedication, procurement, fabrication/assembly activities, material control and handling, storage and shipping, special processes, tests, inspections and calibration, document control/adequacy, organization/program, nonconforming items/10 CFR Part 21, Reporting of Defects and Noncompliance, internal audits, corrective action, and training/certification. The NRC staff accompanied the NUPIC team members while they performed walkdowns of portions of the facility, observations of in-process production activities included: special processes (nondestructive examination and welding), MT&E, and material handling and control, as well as attending discussions between the NUPIC audit team members and TN Americas personnel.
Specific work activities reviewed by NUPIC and observed by the NRC staff, included, but were not limited to: TN Americas design packages, procurement of safety-related and important to safety materials, special processes (circumferential welding of the dry storage cask (DSC) bottom lid, liquid penetrant testing (PT) and visual testing (VT) of the DSC shell), control of M&TE, identification of material tagging, storage of quality related materials and the issuance process for these materials for fabrication, nonconformance control including designated isolation areas for non-conforming materials, in-process fabrication (machining of the DSC shell edges and assembly of the basket structural plates), commercial grade-dedication associated with calibration and testing services, field services, and training and qualification records.
Discussion The NRC staff verified that NUPIC adequately considered TN Americas scope of supply and observed in-process work practices and completed work products to verify that activities were performed in accordance with TN Americas applicable procedures. The NRC staff confirmed the NUPIC audit team was implementing the latest revision of the NUPIC audit checklist, Revision 22, and NUPIC Document No. 11, Joint Audit & Checklist Implementation Guideline, Revision 24, to conduct their assessment activities. The NRC staff observed the NUPIC audit team members completing sections of the NUPIC checklist and documenting objective evidence to support the conclusions discussed during the daily team meetings. The NRC staff also observed NUPICs process for evaluating potential findings and deficiencies, including discussions during internal NUPIC daily team discussions meetings, and during debriefing activities with TN Americas personnel. The NRC staff also discussed their observations with NUPICs lead auditor and team members.
The NUPIC audit team concluded that TN Americas is effectively implementing their QA program in accordance with the applicable requirements of Appendix B to 10 CFR Part 50 and 10 CFR Part 21. There were two findings identified from the audit regarding: (1) lack of positive weld wire program and implementation controls, and (2) a lack of adequate procedural guidance
4 and failure to perform adequate commercial-grade dedications associated with the International Laboratory Accreditation Cooperation (ILAC) accredited calibration services. Additionally, several deficiencies were identified in the following areas: (1) documentation of software verification personnel on test reports, (2) use of sampling plans during receipt inspections and as part of commercial-grade dedication activities, and (3) lack of adequate documentation of personnel qualification and training for a sample of inspection, test, and nondestructive examination (NDE) personnel. The NRC staff observed that TN Americas was generally receptive to the deficiencies identified by the NUPIC audit team and initiated corrective actions to address those deficiencies.
Conclusion The NRC staff observed the NUPIC audit team conduct a review of the TN Americas QA program. The NRC staff confirmed that the NUPIC audit team focused on the most relevant portions of the QA program consistent with the TN Americas scope of supply and performed their assessment activities through a combination of direct observation of in-process work activities and a review of completed work products. The NRC staff confirmed that the NUPIC audit team adequately implemented the guidance in the NUPIC audit checklist, documented objective evidence to support their conclusions, and conducted the audit in a courteous and professional manner. The NRC staff concluded that the NUPIC auditors and the technical specialist adequately completed their assigned programmatic elements in accordance with the NUPIC policies and procedures for conducting joint audit activities and resulted in a thorough and comprehensive evaluation of the vendors program.
Specifically, the NRC staff determined that the NUPIC auditors effectively audited appropriate elements of TN Americas QA program by selecting appropriate representative samples of applicable QA functional areas. The NRC staff determined that the NUPIC auditors possessed the relevant technical knowledge to perform the audit and supplemented technical experts in the areas of dry storage systems, and transportation systems where necessary. Accordingly, the NRC staff determined the NUPIC audit provided elements of effective independent oversight to qualify TN Americas as an approved supplier in accordance with the requirements of Appendix B to 10 CFR Part 50, 10 CFR Part 71, and 10 CFR Part 72 and 10 CFR Part 21.
List of Participants Name Title Affiliation Entrance Exit Len Weaver Audit Team Leader EHN X
X Jasper Adams Audit Team Member DPC X
X Leslie McGinnis Bensend Audit Team Member XEL X
X Mike Fussell Audit Team Member PGE X
X Dan Gallagher Audit Team Member EHN X
X Daryl Gruver Audit Team Member in Training EHN X
X Randy Hugenroth Audit Team Member OPP X
X Herbert Mayes Audit Team Member ETN X
X
5 Kyle Millenaar Audit Team Member PGE X
X Susan Miller Audit Team Member TLN X
X Carrie Wilson Audit Team Member DPC X
X Jay Wingfield Audit Team Member CEG X
X Doug Wright Audit Team Member SMD X
X Steve Mroz Technical Specialist EHN X
X Keith Waldrop Technical Specialist EPRI X
X John Birchfield Quality Assurance Manager TN Americas X
X Marlin Stoltz Director, TN Project Engineer TN Americas X
X Mike Cameron Plant Manager TN Americas X
X Cheryl Morrisette QA Engineer TN Americas X
X Phillip Morris Level III NDE TN Americas X
Austin Craven Welder TN Americas Mark Burleson Can Line Lead TN Americas Lance Gun Manufacturing Lead TN Americas Nelson Melendez Quality Control (QC)
Inspector TN Americas Matt Eubank QA Engineer TN Americas X
X Sam Webb Welder TN Americas X
Tim Allread Welder TN Americas X
Russ Snyder Shop Superintendent TN Americas James Gandy Lead, EOS basket TN Americas Mike Edmunds MTE Coordinator TN Americas Brandon Reeves QC Inspector TN Americas John Sprole Coatings Technician TN Americas Dakota Webber NDE Inspector TN Americas Penny Collins Material Control Coordinator TN Americas Steve Nestor Welder TN Americas Mike Carpenter Welder TN Americas John Brewer Consulting Level II PT/Radiographic Testing TN Americas Brian Boss Director Field Services TN Americas Tammy Johnson QA Lead Auditor TN Americas Jennifer Yee Document Control Records Specialist TN Americas
6 Kristen Vesely Document Control Supervisor TN Americas Glady Llanto Fabrication Project Manager TN Americas Laura Alamillo Human Resources Manager TN Americas Doumer Arcila Machine Operator TN Americas Greg Galletti NRC Inspector NRC X
X Mathew Learn NRC Inspector NRC X
X Documents Reviewed TN Americas TN Americas LLC, Quality Assurance Program Description Manual For 10 CFR Part 71, Subpart H And 10 CFR Part 72, Subpart G, Revision 17, dated February 25, 2022 TNFQAP, Quality Assurance Plan for TN Fabrication (TNF), Revision 2, dated May 3, 2022 FPM 2.3, Qualification & Certification of Non-Destructive Examination Personnel Revision 1, dated January 5, 2020 FPM 9.1, Control of Special Process and Test, dated April 6, 2023 FPM 9.2, Welding Performance Qualification Testing and Records, Revision 5, dated July 28, 2022 NDE-PT; Liquid Penetrant Examination Procedure, Revision 1, dated August 31, 2021 NDE-VT, Non-Destructive Examination Procedure Exhibit A, Visual Examination Report, dated August 21, 2021 DSC-AIR, DSC Pneumatic Test Procedure, Revision 0, dated November 16, 2022 Implementation Procedure (TIP) 3.5, Licensing Reviews, Revision 33, dated February 23, 2023 TIP 11.1, Test Control, Revision 7, dated January 6, 2017 TIP 16.1; Corrective Action, Revision 33, January 24, 2023 A risk informed sample of corrective action review documents.
A risk informed sample of 10 CFR 72.48 evaluations.
NUPIC NUPIC audit checklist, Revision 22 NUPIC Document No. 11, Joint Audit & Checklist Implementation Guideline, Revision 24