ML24130A174
| ML24130A174 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 05/10/2024 |
| From: | Hector Rodriguez-Luccioni NRC/NMSS/DFM/IOB |
| To: | Ocampos B Orano TN Americas |
| References | |
| IR 2024201 | |
| Download: ML24130A174 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Brian Ocampos, Quality Assurance and Environmental Health and Safety Director Orano TN Americas LLC 7135 Minstrel Way, Suite 300 Columbia, MD 21045
SUBJECT:
TN AMERICAS LLC - THE U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 721004/2024201
Dear Brian Ocampos:
On March 26, 2024, through March 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced onsite inspection at Orano TN Americas LLCs (TN) Moyock Casting Facility in Moyock, North Carolina. Moyock fabricates, inspects, tests, and assembles important to safety (ITS) components of their NUHOMS Horizontal Storage Modules (HSMs) designs.
The purpose of the inspection was to verify and assess the adequacy of TNs compliance with the NRC requirements for the design, modification, fabrication, assembly, testing, and procurement of HSM components. TN is the holder of the certificate of compliance (CoC) and designer of the NUHOMS HSMs.
The inspection scope included observations of fabrication activities, reviews of records, and interviews with personnel to determine whether HSM components fabricated for use in an independent spent fuel storage installation (ISFSI), are constructed in accordance with the commitments and requirements specified in the safety analysis report (SAR), the NRCs corresponding safety evaluation report, Title 10 of the Code of Federal Regulations (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, and the CoC and technical specifications (TS); and to determine whether the fabricators activities are conducted in accordance with NRC-approved quality assurance program requirements. The enclosed report presents the results of this inspection, which were discussed with you and other members of your staff on March 28, 2024.
No violations of more than minor significance were identified during this inspection.
May 10, 2024
B. Ocampos 2
In accordance with 10 CFR Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m.
eastern time (ET), Monday through Friday, except Federal holidays.
Sincerely, Hector Rodriguez-Luccioni, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 721004
Enclosure:
NRC Inspection Report No.
721004/2024201 Signed by Rodriguez-Luccioni, Hector on 05/10/24
ML24130A174 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME ADjapari WWheatley HRodriguez DATE 5/9/2024 5/10/2024 5/10/2024
Enclosure UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management Docket:
721004 Report.:
721004/2024201 Enterprise Identifier:
I-2024-201-0031 Certificate Holder:
Orano TN Americas LLC Facility:
Moyock Casting Facility Location:
Moyock, NC Inspection Dates:
March 26, 2024, through March 28, 2024 Inspection Team:
Azmi Djapari, Transportation and Storage Safety Inspector, Team Leader Earl Love, Senior Transportation and Storage Safety Inspector Raju Patel, Transportation and Storage Safety Inspector Darrell Dunn, Senior Materials Engineer Approved By:
Hector Rodriguez-Luccioni, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
2 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management EXECUTIVE
SUMMARY
TN Americas LLC NRC Inspection Report 721004/2024201 On March 26, 2024, through March 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced onsite inspection at Orano TN Americas LLCs (TN) Moyock Casting Facility (MCF) in Moyock, North Carolina. MCF fabricates, inspects, tests, and assembles important to safety (ITS) components of the NUHOMS Horizontal Storage Module (HSM) dry storage system (DSS).
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 NUHOMS HSMs components related to the activities performed at MCF. TN is the holder of the certificate of compliance (CoC) and designer of the NUHOMS HSMs. The inspection also included review of documents and observation of activities related to the fabrication, assembly, inspection, and testing of HSM components.
Quality Assurance Program The team determined that TN had implemented sufficient Quality Assurance Program (QAP) controls at MCF and supporting project plans to perform quality-related activities in accordance with the applicable Quality Assurance (QA) standards outlined in 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. (section 1.1)
Design Control The team determined that for the projects selected for review, the fabrication specifications were consistent with the design commitments and requirements documented in the safety analysis report (SAR), CoC, and technical specifications (TS). (section 1.2)
Corrective Action and Nonconformance Reports The team determined that TN effectively implemented its nonconformance program and corrective action program (CAP) at MCF and has adequate procedures in place to ensure compliance with the applicable regulations and QA requirements. (section 1.3)
3 Personnel Training and Certifications The team found that all personnel involved in quality-related tasks were adequately trained and certified as required. Personnel records show completion of the required QA indoctrination training, and that staff has acquired necessary qualifications to perform their duties. (section 1.4)
Fabrication, Inspection and Testing The team determined that the fabrication personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality control (QC) associated with the construction of the HSMs. (section 1.5)
Procurement The team determined that materials, components, and other equipment received by the fabricator met HSM design procurement specifications, and the procurement specifications conformed to the design commitments and requirements contained in the SAR, CoC, and TS. (section 1.6)
Implementing Procedures The team determined that DSS components were generally being fabricated and inspected per approved quality assurance and 10 CFR Part 21, Reporting of Defects and Noncompliance, implementing procedures and fabrication specifications. In addition, the team concluded that MCF effectively implemented its measuring and test equipment (M&TE) control program and has adequate procedures in place to ensure compliance with the applicable regulations, industry standards and quality requirements. (section 1.7) 10 CFR Part 21 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; MCF personnel were familiar with the reporting requirements of 10 CFR Part 21; and MCF complied with 10 CFR 21.6, "Posting requirements." (section 1.8)
Oversight and Audits The team determined, for the items selected for review that TN was performing oversight and audits at MCF in accordance with their QAP. (section 1.9)
4 REPORT DETAILS 1.0 Inspection Procedure (IP) 60852 Independent Spent Fuel Storage Installation (ISFSI) Component Fabrication by Outside Fabricators 1.1 Quality Assurance Program 1.1.1 Inspection Scope The team reviewed TNs QA manual and various TN implementing procedures (TIPs) to assess the effectiveness of their QAP implementation.
The team conducted reviews of TNs Quality Assurance Program Description Manual (QAPDM), policies, and procedures, to determine whether TN adequately controlled and implemented activities performed at MCF under their NRC approved QAP and quality activities subject to 10 CFR Part 72 regulations. The team interviewed TN personnel regarding QA processes and organizational effectiveness. The following quality procedures and documents were reviewed:
MQAP-01, Quality Assurance Plan for Moyock, NC Casting Facility (MCF),
revision 5 MCF 1.1, Organization at Moyock Casting Facility, revision 2 MCF 2.1, MCF Training Requirements, revision 2 TIP 2.1, "Indoctrination and Training, revision 29 The team also reviewed TN's training matrix and training records for a sample of MCF personnel across the QA, engineering, and project management groups to determine if they received the required QA indoctrination.
1.1.2 Observation and Findings The team assessed that TN has an adequate QAP with implementing procedures in place that are effective in conducting activities at MCF related to the NUHOMS HSMs in accordance with their CoCs.
The team noted that the sample taken of training records for MCF personnel showed the completed training records and matrix matched those required under TIP 2.1, "Indoctrination and Training," and appendix A, "Indoctrination Requirements Matrix." The team assessed that for the sample of training records that were reviewed, each staff member completed the required training and attained the applicable qualifications to perform their duties.
No findings of significance were identified.
1.1.3 Conclusions Overall, the team determined that TN had implemented sufficient QAP controls at MCF and supporting project plans to perform quality-related activities in accordance with the applicable QA standards outlined in 10 CFR Part 72.
5 1.2 Design Control 1.2.1 Inspection Scope The team determined whether the fabrication specifications were consistent with the design commitments and requirements documented in the SAR, CoC, and TSs.
The team reviewed documents associated with project planning, design control, procurement specifications, and preparation of certificates of conformance (see sections 1.5, Fabrication Controls, and 1.6, Procurement, for a list of more procedures, drawings, specifications, and other documents reviewed.) The team focused their review on a sample of HSM fabrication projects, including the Millstone, Surry, Brunswick, and Oconee projects to verify that specifications for each HSM design selected were adequately translated to Technical and Quality Requirements (TQRs) and design and fabrication drawings. More specifically, the team reviewed TN design activities related to Part 72 CoC No. 1042, Amendment No. 2 and CoC No. 1004 Amendment No. 18, and reviewed licensing drawings against the design and fabrication drawings to verify consistency of critical dimensions, material specifications, and testing and inspection requirements.
In addition, the team reviewed project-specific TQRs used for conveying subject requirements pertaining to each fabrication scope executed at MCF in accordance with the corresponding HSM Designs. The team reviewed the following procedures:
TIP 3.1, Design Control, revision 29 TIP 3.5, Licensing Reviews, revision 35 TIP 5.1, Drawing Control, revision 14 TIP 5.2, Specifications, revision 12 TIP 5.5, Preparation of Certificates of Conformance, revision 24 TIP 5.8, Fabrication Drawing Control, revision 2 TIP 7.4 Fabrication Readiness Reviews, revision 10 In addition, the team reviewed a list of 72.48 screenings performed by TN for compliance to 10 CFR 72.48, Changes, tests, and experiments, regulatory requirements. The team selected a representative sample of 72.48 screenings based on construction nonconformance conditions that were dispositioned Repair or Use-As-Is.
1.2.2 Observation and Findings The team determined that MCF was effectively implementing design controls applicable to its scope of work. The team also determined that design controls for the different HSM projects undergoing production were adequate. The team did not identify any discrepancies between the design and fabrication specifications and the SAR licensing drawings. Further, the team verified that the specifications for the reviewed HSM designs were adequately translated to TQRs and drawings. The team noted that TN captured all requirements that were applicable to fabrication and that MCF fabrication drawings contained the relevant information needed for fabrication. The team also noted that MCF does not procure any Category A materials, equipment, and services, as all HSM components are Category B or lower. Additionally, the team determined that TN has effectively implemented its order entry and project planning processes at MCF.
6 The team noted that MCFs main responsibility regarding design control primarily involves receiving new or updated HSM Design and fabrication drawings, specifications, and project plans via TN corporate transmittals. They ensure the integration of these documents into the fabrication process through their document control process.
Additionally, the team noted that TNs Project Manager functions as the TN representative for all matters concerning the daily execution of the work, serving as the primary contact between TN and the licensees. TNs Project Engineer (PE) has the final authority for the technical adequacy of all project-related calculations and drawings. The PE is also the primary point of contact for any design changes required, while the design engineering team offers engineering support to the project by preparing calculations, drawings, and other necessary design documents.
No findings of significance were identified.
1.2.3 Conclusions Overall, the team determined that for the projects selected for review, the fabrication specifications were consistent with the design commitments and requirements documented in the SAR, CoC, and TS.
1.3 Corrective Action and Nonconformance Reports 1.3.1 Inspection Scope The team reviewed a sample of nonconformance reports (NCRs) and corrective action reports (CARs) to verify that TN effectively implemented a nonconformance program and CAP in accordance with the requirements of 10 CFR Part 72. The team verified that TN completed corrective actions for identified deficiencies and nonconformances in a technically sound and timely manner. The team reviewed TNs QA manual and Quality Assurance Plan for MCF, as well as the following implementing procedures to assess their nonconformance program, CAP, and Part 21 reporting:
TIP 7.13, Supplier Findings and Corrective Actions, revision 13 TIP 8.1, Identification and Control of Materials, Parts, and Components, revision 6 TIP 8.2, Identification of Counterfeit, Suspect, and Fraudulent Items, revision 0 TIP 15.1, Reportability Determinations and Postings, revision 19 TIP 15.2, Control of Nonconforming Items, revision 22 TIP 15.3, Review of Supplier Nonconformances, revision 23 TIP 16.1, Corrective Action, revision 33 The team reviewed TNs nonconformance program to assess the effectiveness of controls established for the processing of nonconforming materials, parts, or components. The requirements for implementing the nonconformance program at MCF are contained in the project plans in addition to the TIP 15.2, Control of Nonconforming Items. The team reviewed a sample of NCRs from the previous 3 years at MCF, focusing on those dispositioned as Repair and Use-As-Is, and discussed these documents with TN personnel.
7 The team reviewed the TN CAP implementation at Moyock to assess the effectiveness of controls established for the processing of conditions adverse to quality. Based on this evaluation, the investigation class is determined, whether a root cause or apparent cause investigation is performed and completed, based on the significance level of the CAR. Significance Levels range from 1 through 4 with 13 categorized as events or conditions that result in major, moderate, or minor impact; respectively. Significance level 4 is considered a low-level problem. The team reviewed a sample of Level 2, Level 3, and Level 4 CARs from the previous three years at MCF and discussed these documents with TN personnel. There were no Level 1 CARs initiated at MCF since 2021.
1.3.2 Observation and Findings The team noted that NCRs and corresponding TN Licensing Reviews dispositioned as Repair and Use-As-Is were approved by TNs customers and that completed NCRs were included in the TN final documentation packages. The team assessed that the NCRs reviewed had been appropriately dispositioned and closed in a timely manner.
The team also verified that CARs initiated from the previous NRC inspection of MCF have been corrected adequately and closed in accordance with their procedures. The team assessed that TN appropriately identified issues and implemented corrective actions in a time frame commensurate with their safety significance. The team determined that TN had an adequate nonconformance and CAP in place to resolve deficiencies.
No findings of significance were identified.
1.3.3 Conclusions Overall, the team determined that TN effectively implemented its nonconformance program and CAP at MCF and has adequate procedures in place to ensure compliance with the applicable regulations and QA requirements.
1.4 Personnel Training and Certifications 1.4.1 Inspection Scope The team determined whether individuals performing quality-related activities were trained and certified where required. Specifically, the team reviewed the qualifications and training for selected MCF staff to determine if they met the requirements stated in the QAP including QA indoctrination. The team reviewed the qualification and training records of QC personnel at MCF, along with the qualifications of laboratory staff who are outside contractors responsible for performing the required testing for HSM components. The following quality procedures were reviewed:
MCF 2.1, MCF Training Requirements, revision 2 TIP 2.1, Indoctrination and Training, revision 29 1.4.2 Observation and Findings The team found that all personnel involved in quality-related tasks were adequately trained and certified as required. Personnel records show completion of the required
8 QA indoctrination training, and that staff has acquired necessary qualifications to perform their duties.
No findings of significance were identified.
1.4.3 Conclusions The team determined that individuals performing quality-related activities were trained and certified as required.
1.5 Fabrication, Inspection and Testing 1.5.1 Inspection Scope The team determined whether the fabricator's personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality controls associated with the construction of the DSS.
The team evaluated MCFs 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 interviewed MCF/TN personnel and reviewed documentation of fabrication activities affecting safety aspects of the HSMs to verify that the activities were performed in accordance with approved methods, procedures, specifications, and purchase order (PO) requirements.
The team observed/witnessed the following activities:
Concrete batching Slump test Informational break test Concrete pouring of HSM components o
Door o
Outlet Vent Cover The team reviewed documentation packages and travelers associated with the HSM components being constructed at MCF. The team reviewed the following quality documents:
TN Implementing Procedures:
TIP 5.8, Fabrication Drawing Control, revision 2 TIP 10.1, Inspections, revision 8 TIP 11.1, Test Control, revision 7 TIP 14.1, Inspection and Test Status, revision 6 TIP 15.4, Control of Fabrication Nonconforming Items, revision 7 MCF Service Program Manual (SPM):
SPM-5.21.1, General Construction Requirements and Methods for Fabrication of
9 HSM-H and HSM Model 102, revision 15 SPM-5.21.3, HSM-H Door-Concrete Construction Procedure, revision 12 SPM-5.21.5, HSM-H Base-Concrete Construction, revision 11 SPM-5.21.6, Concrete Mix Design Trial Batching, revision 3 SPM-5.21.8, Concrete Batching and Testing Procedure for Fabrication of HSM-H and HSM Model 102, revision 10 SPM-5.21.9, HSM-H Outlet Vent Cover-Concrete Construction, revision 11 SPM-13.2, Material Storage and Housekeeping at Moyock Casting Facility, revision 1 Drawings:
NUH-03-7103, Base, revision 11 NUH-03-7105, Walls and Outlet Vent Cover, revision 3 NUH-03-7108, Door Type B, revision 5 NUH-03-7109, Embedment revision 11 NUH-03-7112, Fasteners, revision 7 NUH-03-7152, Fabrication drawing HSM-H Roof, revision 2 NUH-03-7156, Fabrication drawing HSM-H outlet vent cover, revision 1 NUH-03-7163, Fabrication drawing HSM-H door, revision 2 Brunswick Configuration Drawing, 11185-7100, ISFSI -Phase IV HSM Configuration, revision 3 NUH-03-7164, Fabrication Drawing HSM-H Base 61BTH/24PTH, revision 9.
Specifications:
NUH-03-0215, Steel Fabrication For NUHMOS-HSM, revision 12 NUH-03-0314, Concrete Construction of NUHMOS-HSM, revision 13 EOS-01-0113, Concrete Construction of NUHOMS EOS HSM & EOS HSMS, revision 4 Project Plans/TQR:
PP-1006553-01, 11185-Brunswick NUHMOS DRY Storage Equipment, revision 1 PP-11069.FD1.HSM and 11069.FD2.HSM, for Dominion Millstone Power Station EOS Segment HSMs and flat plate DSC support structures, revision 2 PP 1049E.FD1.HSM, Dominion Energy-North Anna Power Station, revision 0 PP 1049F.FD1.HSM, Dominion Energy-Surry Power Station, revision 0 TQR 11185.FD1-03, Duke Energy-Brunswick PP-1006553, revision 2 TQR 11069.FD1.HSM-01, Dominion-Millstone Project Plan 11069.FD1.HSM and 11069.FD2.HSM, revision 3 TQR 1049F.FD1.HSM-01, Technical and Quality Requirements for Fabrication of EOS Segmented HSM to Dominion Surry Power Station, revision 1 TQR 1049E.FD1.HSM-01, Technical and Quality Requirements for Fabrication of EOS Segmented HSM for Dominion North Anna Power Station, revision 3.
10 HSM Fabrication Readiness Review Checklist:
Duke-Brunswick Project No. 11185 for HSM-H dated 2/23/2024 Dominion Surry Power Station Project No. 1049F.FD1 for NUHOMOS EOS HSMS-FPS, dated 12/5/2023 Inspection and Test Reports:
Concrete mix ticket number 25030232, for overhead vent cover and door for Brunswick Project Plan PP-1006553-01 Batch Ticket Supplemental sheet for batch ticket number 250302232, inspected by TN QC on 3/27/2024 Plastic Concrete Test results for batch ticket number 25030232 for BNP-OV-A69, and BNP-D-B65, inspected by TN QC on 3/27/2024 Cement Mill Test Report tested to meet American Society of Testing Materials (ASTM) C595 and American Society of State Highway and Transportation Officials M 240 standard requirements dated 3/15/2024 HSM-H-OVC Procedure Traveler for BNP-OV-A69, step 5.7, Curing, inspected by TN QC on 3/27/2024 HSM-H-OVC Procedure Traveler for BNP-D-B65, step 5.5.1, Curing, inspected by TN QC on 3/19/2024 HSM-H/HSM Model 102 Concrete Batching signoff sheet, inspected by TN QC on 3/27/2024 Concrete mix ticket 25030232, truck number 159 for HSM-OVC and door dated 3/28/2024 Certified Material Test Report (CMTR) for Rebar Heat numbers: 2088664, 2109397 and 8011896 CMTR for 13 mm rebar, heat# 8024295, ASTM A615 Grade 420, dated 2/19/2024 CMTR for 16 mm rebar, heat# 219019, ASTM A615 Grade 420, dated 2/21/2024 Certificate of Conformance for stone dated 12/12/2023 Certificate of Verification report for Test Mark tester serial number 160125 calibration due 6/12/2024 Inspection Record of Delivery Fleet for Moyock, North Carolina truck No. 159, dated 5/18/2023, due 6/1/2024 1.5.2 Observation and Findings The team noted that all responsible personnel have adequately performed fabrication activities and were knowledgeable about the specified design, designated fabrication techniques, testing requirements, and QC associated with the construction of the HSM components.
The team observed concrete batching and testing of concrete samples prior to concrete placement in forms to construct the NUHOMS HSM components. The team noted that batching signoff sheets included steps verified by TN QC and confirmed the water-cement ratio, slump test, air content, and concrete temperature verification met the specifications. The team reviewed a sample of reinforced steel rebar CMTRs and confirmed the rebar used met the ASTM specification. The team observed the collection of concrete samples used to make compression test specimens and testing
11 to measure density, air content, and slump. The team noted that results of the concrete tests were documented on appropriate paperwork identified in the procedures.
During the observations and reviews of fabrication, inspection and testing 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 inspection/testing procedures.
No findings of significance were identified.
1.5.3 Conclusions The team determined that the fabrication personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and QC associated with the construction of the HSMs.
1.6 Procurement 1.6.1 Inspection Scope The team determined whether a) materials, components, and other equipment received by the fabricator meet DSS design procurement specifications, and b) the procurement specifications conform to the design commitments and requirements contained in the SAR, CoC, and TS.
The team reviewed MCFs processes that address procurement, including traceability and receipt inspection. The team reviewed drawings (section 1.5) and records and interviewed selected personnel to verify that the procurement specifications for materials and services performed at MCF met design requirements. The team reviewed the following implementing procedures and procurement documents:
TN Implementing Procedures:
TIP 4.1, Procurement Document Control, revision 39 TIP 5.2, Specifications, revision 12 TIP 7.11, Approved Suppliers List, revision 16 Purchase Order (PO):
P2022-0455, dated 5/2/2022 P2023-1208, dated 3/11/2024 P2022-0655 C/O 2, for procurement of fasteners for Brunswick Nuclear Power Plant Phase IV HSM project, dated 07/1/2022 P2023-1217, for ITS Category C concrete mix code 5000CMH2 dated 12/18/2023; P2022-0753 C/O 4, for procurement of ITS category B Door Embedment and HSM DSC support structure flat plate support, dated 2/24/2024
12 Receipt Inspection Reports (RIRs):
RIR 1008607 for ITS category B door embedment under PO# P2022-0660, accepted by QC on 2/12/2024; RIR 1008608 for ITS category B embedment, under P2022-0665 accepted by QC on 1/29/2024; RIR 1008609, for embedment under P2022-0660, QC accepted on 2/8/2024; RIR 1008770, for rebar for HSM-H base, roof, door and outlet vent cover for Brunswick project, under P2023-1208, QC accepted on 3/18/2024; RIR 1008793, for HSM-H Base, Roof, Doors, and Outlet Vent Covers for 11185-Duke Brunswick NUHOMS project under P2023-1208, QC accepted on 3/22/2024.
The team also reviewed the TN Approved Supplier List (ASL) dated 3/21/2024, mainly focusing their review on approved suppliers for MCF.
1.6.2 Observation and Findings The team observed that TN had adequate control of the procurement processes at MCF for the ITS materials and components reviewed. The team noted that MCF does not perform any Commercial-Grade Dedication activities. Overall, TN procured ITS materials and components consistent with design requirements and TNs material traceability, procurement, and receipt inspection controls were adequate.
The team determined that POs for materials used in the fabrication of the components of the HSM-H, including, the reinforcing steel, embedded elements, and cement, ensured that the procured materials adhered to the design specifications and could be traced back to the serial number of the specific component (base, roof, or door) of the HSM-H in which it they were used.
The team verified that materials stored in designated storage areas were controlled, identifiable, and traceable from procurement to fabrication from their review of the receipt inspection reports and certified material test reports.
The team determined that the POs were adequate and specified the applicable material criteria and requirements including Part 21, as necessary. Additionally, TN verified and maintained the traceability throughout the procurement and receipt process. The team determined that TN purchased the components from suppliers on the ASL, as necessary.
No findings of significance were identified.
1.6.3 Conclusions The team determined that materials, components, and other equipment received by the fabricator met DSS design procurement specifications, and the procurement specifications conformed to the design commitments and requirements contained in the SAR, CoC and TS.
13 1.7 Implementing Procedures 1.7.1 Inspection Scope The team determined whether HSM components are being fabricated per approved QA and 10 CFR Part 21 implementing procedures and fabrication specifications. The team evaluated MCFs control of the fabrication process through observations, examinations of records, and personnel interviews in the areas of fabrication and assembly, test, and inspection (section 1.5.) In addition, the team evaluated MCFs fabrication controls through review of their control of M&TE program to determine how they identified, specified, and controlled tools and equipment according to relevant sections of the QAM, quality standard procedures, and regulatory requirements. Specifically, the team reviewed the following quality documents:
TIP Implementing Procedures:
TIP 12.1, Control of Measuring and Test Equipment, revision 11 TIP 17.1, Control of Quality Assurance Records, revision 20 Calibration Records of the following M&TE:
Slump Cone Air Content Meter Thermometer Weight scale Calipers Concrete Cylinder Break Machine The team selected the above sample of the M&TE used in fabricating the HSM components and reviewed calibration certificates to verify that M&TE were correctly identified with serial numbers and calibration dates and used within their rated capacities, consistent with the specifications and procedures.
1.7.2 Observation and Findings The team observed that HSM components were being fabricated to approved procedures. The team assessed that TN established adequate controls on M&TE in accordance with their quality requirements, industry standards and regulatory requirements at MCF. The team noted that MCF uses an outside contractor to perform M&TE calibration. The team verified that these calibration services were provided by approved suppliers. The team assessed that MCF personnel provided the appropriate information on shop travelers in accordance with approved procedures. The team verified that personnel used M&TE within their rated capacities and sensitivities as documented in calibration records and fabrication document packages.
The team also noted that MCF had adequate document control and storage of QA records. 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. The team identified no concerns with the MCF design and documentation control processes for placing TN HSM design/fabrication modifications into HSM production.
14 No findings of significance were identified.
1.7.3 Conclusions The team determined that HSM components were generally being fabricated and inspected per approved QA and 10 CFR Part 21 implementing procedures and fabrication specifications. In addition, the team concluded that MCF effectively implemented its M&TE control program and has adequate procedures in place to ensure compliance with the applicable regulations, industry standards and quality requirements.
1.8 10 CFR Part 21 1.8.1 Inspection Scope The team reviewed the 10 CFR Part 21 procedure TIP 15.1, Reportability Determinations and Postings, revision 19, to verify if provisions were in place for reporting defects that could cause a substantial safety hazard and completed the required notification in a timely manner. The team verified that MCF complied with 10 CFR 21.6, Posting requirements.
1.8.2 Observation and Findings The team assessed that TN has provisions in place at MCF for evaluating deviations and reporting defects that could cause a substantial safety hazard and for design or fabrication deficiencies that could affect the DSSs ITS structures, systems, and components to perform their intended safety function, as required by 10 CFR Part 21 and 72.242(d), respectively. The team noted that the 10 CFR Part 21 posting at the MCF met the approved implementing procedure and the applicable requirements of 10 CFR Part 21.
No findings of significance were identified.
1.8.3 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; MCF personnel were familiar with the reporting requirements of 10 CFR Part 21; and MCF complied with 10 CFR 21.6, "Posting requirements."
1.9 Oversight and Audits 1.8.1 Inspection Scope With regard to 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 since the last NRC inspection, the findings were appropriately handled with corrective actions implemented in a time frame commensurate with their safety significance, and c) supervision and QC/QA personnel perform appropriate oversight during fabrication activities.
15 The team reviewed TNs external audit program to determine if TN scheduled, planned, and performed audits or surveillances of their suppliers in accordance with their QAP.
The team reviewed a sample of supplier evaluations and surveillances of suppliers of category B services and materials which includes calibration and testing services and suppliers of rebar materials.
The team also reviewed TNs audit program to determine if TN scheduled, planned, and performed internal audits at MCF in accordance with their QAP. The team selected a sample of internal audits from the time of the last NRC inspection to the present. This included a sample of lead auditor and auditor certifications and qualification. The team reviewed the internal audit results to determine if TN identified deficiencies and addressed these deficiencies within their CAP. The team also evaluated whether TN provided adequate supervision with QC/QA personnel for appropriate oversight during fabrication activities. The following quality procedures were reviewed:
TIP 7.2, Supplier Audits, revision 13 TIP 18.1, Internal Audits, revision 18 TIP 18.2, Surveillances, revision 5 1.9.2 Observation and Findings Overall, the team assessed, for the audits and surveillances sampled that TN generally conducted oversight with qualified and certified personnel, scheduled and evaluated the applicable quality aspects of TNs QAP associated with fabrication activities. The team assessed that TN appropriately identified issues and implemented corrective actions in a time frame commensurate with their safety significance. The team noted that no internal audits were conducted at MCF in 2021 and 2022 due to the suspension of operations during those years.
No findings of significance were identified.
1.9.3 Conclusions The team determined, for the items selected for review that TN was performing oversight and audits at MCF in accordance with their QAP.
2.0 Entrance and Exit Meeting On March 26, 2024, the NRC inspection team discussed the scope of the inspection during an entrance meeting with Brian Ocampos and other members of Orano TN and MCF. On March 28, 2024, the NRC inspection team presented the inspection results and observations during an onsite exit meeting to Brian Ocampos and other members of Orano TN and MCF. Section 1 of the attachment to this report shows the attendance for the entrance and exit meetings.
Attachment ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES AND INDIVIDUALS INTERVIEWED Name Title Affiliation Entrance Exit Azmi Djapari Inspection Team Leader NRC X
X Earl Love Inspector NRC X
X Raju Patel Inspector NRC X
X Darrell Dunn Technical Reviewer NRC X
X Brian Ocampos QA and Environmental Health
& Safety Director Orano TN X
X Marc Dyer MCF Director Orano TN MCF X
X Ajay Verma QA Engineer Orano TN X
X Victor Abayan HSM Fabrication Engineer Orano TN X
X 2.
INSPECTION PROCEDURES USED IP 60852 ISFSI Component Fabrication by Outside Fabricators NUREG/CR6407 Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety NUREG/CR6314 Quality Assurance Inspections for Shipping and Storage Containers 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description None None None None 4.
LIST OF ACRONYMS USED 10 CFR Title 10 of the Code of Federal Regulations ASL Approved Suppliers List ASTM American Society for Testing and Materials CAP Corrective Action Program CAR Corrective Action Report CMTR Certified Material Test Report CoC Certificate of Compliance DSS Dry Storage System HSM Horizontal Storage Module IP Inspection Procedure
2 ISFSI Independent Spent Fuel Storage Installation ITS Important to Safety M&TE Measuring and Test Equipment MCF Orano TN Moyock Casting Facility NCR Nonconformance Report NRC U.S. Nuclear Regulatory Commission PE Project Engineer PO Purchase Order QA Quality Assurance QC Quality Control QAPDM Quality Assurance Program Description Manual QAP Quality Assurance Program RIR Receipt Inspection Report SAR Safety Analysis Report SPM Service Program Manual TIP TN Implementing Procedure TN Orano TN Americas LLC TQR Technical and Quality Requirements TS Technical Specifications 5.
DOCUMENTS REVIEWED Certificate holder documents reviewed during the inspection were specifically identified in the Report Details above.