ML24297A608

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Inspection Report No. 71-009319/2024-201 - Framatome, Inc. (MAP-12 at Tn Fabrication)
ML24297A608
Person / Time
Site: 07109319
Issue date: 10/23/2024
From: Hector Rodriguez-Luccioni
NRC/NMSS/DFM/IOB
To: Flanagan B
Framatome
References
IR 2024201
Download: ML24297A608 (1)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Bryan Flanagan, Principal Engineer, Licensing & Compliance FRAMATOME, Inc.

2101 Horn Rapids Road Richland, WA 99354-5102

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 71-09319/2024-201

Dear Bryan Flanagan:

On September 10, 2024, through September 12, 2024, the U.S. Nuclear Regulatory Commission (NRC) conducted an announced onsite team inspection at Transnuclear Fabrication (TNF) facility located in Kernersville, NC. TNF is under contract with FRAMATOME, Inc. (Framatome) for the fabrication of transportation packagings associated with the certificate of compliance number (No.) 71-9319, Revision 14, MAP-12. The team discussed the preliminary results of this inspection with TNF and Framatome representatives on September 12, 2024. The enclosed report presents the results of this inspection.

The purpose of the inspection was to verify and assess the adequacy of activities related to the design, fabrication, assembly, testing, and procurement for the transportation packaging of the MAP-12 packaging to determine if Framatome performed these activities in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, and selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance.

The inspection scope included observations of TNF fabrication activities, documentation reviews, and interviews with personnel to determine whether fabrication of the transportation packagings is in accordance with the commitments and requirements specified in Framatomes MAP PWR Fuel Shipping Package, safety analysis report, as well as Framatomes NRC-approved quality assurance program requirements.

In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (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, October 23, 2024 please send an email to PDR.Resource@nrc.gov or call 18003974209 or 3014154737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.

No reply to this letter is required. We appreciate your cooperation.

Sincerely, Hector Rodriguez, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 719319

Enclosure:

NRC Inspection Report Karmiol, Benjamin signing on behalf of Rodriguez-Luccioni, Hector on 10/23/24

ML24297A608 C = COVER E = COVER & ENCLOSURE N = NO COPY *via email OFFICE NMSS/DFM NMSS/DFM NMSS/DFM (A)

NAME ELove WWheatley* BKarmiol for HRodriguez-Luccioni DATE 10/22/2024 10/23/2024 10/23/2024 U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management

Inspection Report

Docket No.: 7109319

Report No.: 7109319/2024201

Enterprise Identifier: I-2024-201-0050 (MAP-12 at TNF)

Certificate Holder: FRAMATOME, Inc.

Location: TN Fabrication Kernersville, NC

Inspection Dates: September 10-12, 2024

Inspectors: Earl Love, Senior Transportation and Storage Safety Inspector, Team Leader Raju Patel, Transportation and Storage Safety Inspector Azmi Djapari, Transportation and Storage Safety Inspector Andres Rowe, Inspector in-training

Approved by: Hector Rodriguez, Branch Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management

EXECUTIVE

SUMMARY

FRAMATOME, Inc.

NRC Inspection Report 7109319/2024201

On September 10, 2024, through September 12, 2024, the U.S. Nuclear Regulatory Commission (NRC) conducted an announced onsite team inspection at Transnuclear Fabrication (TNF) in Kernersville, NC. FRAMATOME, Inc. (Framatome), is the certificate of compliance (CoC) holder for the MAP-12 packaging under CoC No. 71-9319, Rev. 14 which was approved by the NRC on February 6, 2023. TNF is the fabricator of components associated with the MAP-12 CoC. As described in the CoC No. 71-9319, (Revision 14), the MAP-12 is designed to transport two unirradiated uranium fuel assemblies with core components. The package consists of two components: a base and lid. The containment system of the MAP-12 package is the fuel rod cladding.

The purpose of the inspection was to verify and assess the adequacy of activities related to the design, fabrication, assembly, testing, and procurement of the transportation packaging for the MAP-12 to determine if Framatome performed these activities in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, and selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance.

The inspection scope included observations of TNF fabrication activities, documentation reviews, and interviews with personnel to determine whether fabrication of the transportation packagings is accordance with the commitments and requirements specified in Framatomes safety analysis report for packaging (SARP), as well as Framatomes NRC-approved quality assurance program (QAP) requirements. The inspection team verified that the fabrication activities surrounding the transportation packaging for the MAP-12 complied with the Framatome QAP and 10 CFR Parts 21 and 71 requirements in general as summarized below and in this enclosed report.

Quality Assurance Program

The team determined that Framatome conducted quality related activities on the transportation packaging in accordance with their NRC-approved QAP (section 1.1).

10 CFR Part 21

The team determined that provisions are in place for reporting defects which could cause a substantial safety hazard for transportation packaging activities, and that Framatome and TNF personnel were familiar with the reporting and posting requirements of 10 CFR Part 21 (section 1.2).

2 Design Control

The team determined, for the items selected for review and the personnel interviewed that Framatome implemented an adequate design control program in accordance with their approved CoC and SARP, written procedures, and design specifications, as applicable (section 1.3).

Fabrication, Assembly, and Testing

The team determined, for the items selected for observation and review that TNF performed fabrication, assembly, and testing in accordance with Framatomes approved SARP, written procedures, and specifications, as applicable (section 1.4).

Procurement

The team determined that materials, components, and other equipment received by TNF for fabrication activities met procurement specifications, and the specifications conform to the requirements in the SARP and applicable 10 CFR Part 71 requirements. This included the use of the commercial-grade dedication process to procure commercial items and calibration services using NRC endorsed guidance documents (section 1.5).

Nonconformance and Corrective Action

The team concluded that TNF effectively implemented its nonconformance and corrective action control programs and has adequate procedures in place to ensure compliance with applicable regulations and quality assurance requirements (section 1.6).

Personnel Training and Quality Assurance Oversight

The team determined that TNF had trained and qualified individuals performing activities affecting quality and that Framatome provided appropriate oversight of quality related activities, as applicable (section 1.7).

Audit Program

The team determined for the most part that the licensee performed internal and external (supplier) audits as scheduled in accordance with QAP requirements for transportation packaging activities (section 1.8).

3 REPORT DETAILS

1.0 Design, Fabrication, Testing, and Maintenance of Transportation Packagings (Inspection Procedure (IP) 86001)

1.1 Quality Assurance Program

1.1.1 Inspection Scope

The team reviewed the Framatomes Quality Assurance Program, FS1-0011462, Revision 7.0, "10 CFR 71, Subpart H Quality Assurance Program Description for Packaging and Transportation of Radioactive Materials for US Fuel" as well as TNFs quality assurance program description manual (QAPDM), Revision 17 to assess the effectiveness of their Quality Assurance (QA) program implementation. The team conducted reviews of TNFs quality program and policies and determined activities were adequately controlled and implemented subject to 10 CFR Parts 71 and 21 regulations.

The team verified TNF clearly defined and documented the quality program authorities and responsibilities and that the QA organization functioned as an independent group.

The team also reviewed Framatomes graded approached for identifying Important to Safety (ITS) components and whether TNF applied this graded quality level to procurement documents for MAP-12.

1.1.2 Observation and Findings

The team assessed that TNF has an adequate QA program that included applicable implementing procedures in place to conduct effective quality activities in accordance with the transportation SARP, CoC, and 10 CFR Parts 21 and 71 requirements. The team also verified that TNF clearly defined and documented the quality program authorities and responsibilities and that the quality assurance organization functioned as an independent group as described in TNFs QAPDM. Additionally, the team verified that Framatomes quality assurance procedures discussed a graded approach for identifying ITS components.

No findings were identified.

1.1.3 Conclusions

The team determined that the fabricator conducted quality related activities on the transportation packaging in accordance with the CoC, as well as their QAPDM, and had effective implementing procedures in place.

1.2 10 CFR Part 21

1.2.1 Inspection Scope

The team reviewed program controls for 10 CFR Part 21, specifically, Transnuclear Implementing Procedure (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

4 TNFs posting of Part 21 requirements in accordance with the 10 CFR 21.6, Posting requirements.

1.2.2 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.

1.2.3 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."

1.3 Design Control

1.3.1 Inspection Scope

The team interviewed selected personnel and reviewed the procurement/fabrication specification and fabrication drawings against Framatomes licensing drawings to determined that TNF implemented adequate design controls. The team verified the consistency of material specifications and critical dimensions as well as testing and inspection requirements to determine whether the procurement/fabrication specifications were consistent with the design. Specifically, the team focused on the translation of design commitments and requirements for the ITS category B, and category C components of the MAP-12 and design specifications, including associated licensing drawings in the SARP, and subsequent fabrication and quality plans. The team reviewed the following documents associated with design control during fabrication to verify proper implementation. The documents are as follows:

  • Engineering Information Record, No. 51-9048054-007, Safety Component Classification Document for MAP PWR Shipping Package, Revision 7
  • FS1-0038397, MAP PWR Fuel Shipping Package - USA/9319/B(U)F-96, Revision 5
  • 22329.FRA.001, MAP 12 Project Plan, dated 9/12/2023
  • FS1-0037712, MAP Series Shipping Container Specification, Revision 6
  • Framatome Purchase Order, No. 1023034525, up to change order No. 8, dated 07/29/2024.

The team also reviewed a sample of quality classification evaluations for the MAP-12 packaging. The team selected components classified as ITS category A, B and C to determine if Framatome classified the component in accordance with the guidance in NUREG/CR6407 Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety.

5 1.3.2 Observation and Findings

Based on the teams review, there were no unexplained discrepancies between the design and fabrication activities including the licensing and fabrication drawings. The team noted that TNF captured all requirements reviewed from the purchase order (PO) and procurement/fabrication specification associated with the design and fabrication of the MAP-12. The team noted that Framatome had appropriate justification for the quality classification of the ITS components and were consistent with the descriptions in the SARP.

No findings were identified.

1.3.3 Conclusions

The team determined that for the items selected for review that Framatome and TNF implemented adequate design control measures. The procurement/fabrication specification was consistent with the design commitments and requirements documented in the SARP and the transportation packaging CoC No. 9319 for the MAP-12.

1.4 Fabrication, Assembly, and Testing

1.4.1 Inspection Scope

The team reviewed selected drawings, procedures, and records, and observed selected activities related to MAP-12 to determine if the fabrication, testing, and assembly activities met the SARP design commitments and requirements documented in the CoC.

The team also interviewed selected personnel and reviewed the MAP-12 TNFs procurement specification, drawings, and travelers to determined that TNF implemented adequate instructions, requirements, and acceptance criteria controls. The team observed welding and nondestructive examinations on MAP-12 subassemblies. The team reviewed the following documents:

  • Various Transnuclear Implementing, Fabrication Program Manual Procedures, and Fabrication Drawings
  • FS1-0037712, MAP Series Shipping Container Specification, Revision 6

Fabrication Travelers

  • TR-MAP-12-ILW-001, Inner Lid Weldment, Serial Number (S/N) 47976
  • TR-MAP-12-FILW-003 and 010, Forward Impact Limiter Weldment, S/Ns 47495 and 47488
  • TR-MAP-12-IW-007, Inner Weldment, S/N 47320
  • TR-MAP-12-AILW-011 and 13, Aft Inner Lid Weldment, S/Ns 47481 and 47483
  • MAP-12-WM-001, Manufacturing Plan Quality Record Weld Map, Revision 9, S/Ns 47320 and 47976

6 The team observed activities affecting safety aspects of the packaging such as welding, assembly, and nondestructive examination (NDE) various MAP-12 subassemblies to verify that TNF performed these tasks in accordance with approved methods, procedures, and specifications. The team reviewed the fabrication process through observations, examinations of records, and personnel interviews in the areas of fabrication, assembly, and inspection, along with control of measuring & test equipment.

The team witnessed welding as well as in-process visual and liquid penetrant examinations in accordance with travelers noted in Section 1.4.1. The following procedures were reviewed in support of the activities performed in the shop:

  • NDE-VT, Visual Examination Procedure, Revision 4
  • 22329-SS-VT, Visual Testing Acceptance Criteria for AWS D1.6 Structural Welding Code Stainless Steel, Revision 1
  • 22329-SS-PT, Penetrant Testing Acceptance Criteria for ASME B&PV Code
  • Revision 0
  • 08081-101, Weld Procedure Specification - Gas Tungsten Arc Welding, Revision 10
  • 08082-124, Weld Procedure Specification - Gas Metal Arc Welding, Revision 0

The team reviewed the control of measuring and test equipment (M&TE) program to evaluate how the fabricator identified, specified, and controlled tools and equipment in accordance with their standard procedures. The team selected a sample of the M&TE used during welding. The sample included a review of travelers that identified the use of specific M&TE that the team selected such as a light meter, digital thermometer, and a welding machine. The team reviewed the calibration records to verify calibration dates, testing standards, and traceability of the associated M&TE.

1.4.2 Observation and Findings

The team assessed that TNF established appropriate means to control the MAP-12 fabrication activities and special processes that met the SARP design commitments and requirements documented in the CoC. The team examined Framatomes procurement/fabrication specification, TNFs design and fabrication drawings, work control procedures, and travelers and confirmed that the fabrication and testing activities were adequate. The team noted that TNF implemented their QA implementing procedures, fabrication manual, and special processes with qualified personnel, using approved procedures for assembly, welding, and testing. The team noted that TNF personnel performed welds in accordance with the applicable drawings using qualified procedures and qualified welding personnel. The team also noted that welds were inspected by qualified personnel in accordance with the applicable drawing requirements. Further, inspection and examination results of welds were documented in the appropriate travelers and examination reports in accordance with quality procedures and that shop travelers identified the applicable drawings, material specifications, work instructions, and procedures applicable to the manufacturing and examination activities.

7 1.4.3 Conclusions

The team determined that TNF personnel were familiar with the specified design, designated fabrication techniques, testing requirements, and quality control associated with the fabrication of the MAP-12 packaging that met SARP design commitments and requirements documented in the CoC.

1.5 Procurement

1.5.1 Inspection Scope

The team determined whether the procurement specifications for materials, equipment, and services received met the design requirements. The team reviewed TNFs 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 and services performed at TNF met design requirements. The team reviewed audits for suppliers of ITS materials, and service and reviewed the following implementing procedures, drawings, and procurement documents:

  • TIP 4.1, Procurement Document Control, revision 39
  • TIP 7.1, Supplier Evaluations, revision 25
  • TIP 7.2, Supplier Audits, revision 13
  • TIP 7.9, Receipt Inspection, revision 13
  • TIP 7.11, Approved Vendor List, revision 16
  • FPM 5.3, Procurement Specification, revision 4
  • FPM 7.1, Receipt Inspection, revision 0
  • MAP 12.0103, Procurement Specification for Boral Neutron Absorber Panels for MAP Nuclear Fuel Transportation Packages, revision 2
  • MAP 12.0104, Procurement Specification for 6 and 10 lb8/5/2024/ft 3 (pcf) Foam for the MAP Series of Shipping Containers, Revision 7
  • TNF technical and quality requirement No. 22329.FRA.001, Technical and Quality Requirements for Fabrication, revision 6
  • TNF PO P2024-0058 to GP dated January 17, 2024
  • TNF supplier audit report No. SA 2021-004 of GP dated August 30-September 21, 2021
  • PO P2023-1182 to Textile Industrial Welding, Inc., dated December 19, 2023
  • TNF supplier evaluation (SE)-2023-024 of audit report No. 28037 of Applied Technical Services, dated March 5, 2023
  • SE-2023-047of audit report No. 28074 of TW Metals LLC, dated May 23, 2023
  • Commercial-Grade Survey Report No. 2018-09-07 of TIW, dated February 9, 2023
  • Commercial-Grade Dedication Report (CGDR) No. 2024-03, revision 1 for Unfilled Nylon 6.6 blocks, dated May 31, 2024
  • CGDR No. 2023-12, revision 0, for Extren Plate and Angle for MAP-12, dated July 5, 2024
  • CGGR No. 2023-09, revision 0, for Intec Tecsil Braided Sleeving, dated May 3, 2024
  • Framatome Inc., Drawing No. 904702, MAP-12 Shipping Container (SC), revision 5
  • Framatome Inc., PO 1023034525, version 8, to TNF, dated August 5, 2024

8 The team also reviewed TNFs Approved Suppliers List (ASL) dated August 16, 2024, certified material testing reports, and receipt inspection reports (RIRs). The review of RIRs included foam material under RIR No. 1008931, revision 0, weld wire ER308LSi under RIR No. 1009313, revision 0, and stainless-steel plate under RIR No. 1008224, revision 0.

1.5.2 Observation and Findings

Overall, the team assessed that TNF had adequate control of the procurement process for the ITS components selected and reviewed. The team determined that TNF procured ITS components consistent with design requirements and their QA implementing procedures. TNF also purchased and applied controls over subcontractors and vendors currently on the ASL. The team reviewed a sample of procurement documents related to ITS components for MAP-12 project and confirmed that POs included scope of work, right of access to the suppliers facilities, and extension of contractual requirements to sub-suppliers. The team confirmed that the POs adequately imposed the applicable technical, regulatory, and quality requirements. The team reviewed a sample of completed RIRs to verify that inspections were conducted in accordance with receipt inspection procedures and that the procured materials met the applicable procurement specification.

The team noted that TNF commercially dedicate certain ITS category B components and adequality maintained traceability from receipt of items until completion of commercial-grade dedication (CGD) and receipt inspection. The team assessed that TNF provides layers of traceability as shown in the CGD reports, quality plans, purchase specifications, material test and examination reports, and a final RIR. The team assessed implementation of CGD through review of a dedication package for commercially procured steel plates.

The team noted Framatomes ITS classification of closed-cell polyurethane foam as category B. Further, Framatome document No. 51-9048054-007, Safety Component Classification Document for MAP-12 PWR Shipping Package, Revision 7, depicts polyurethane foam as safety-related ITS-B component. Previously (Agencywide Document Administration System (ADAMS) Accession No. ML24290A096) the NRC identified that TNF failed to adequately qualify (via external audit) a supplier (General Plastics) QAP to ensure polyurethane foam procured met all applicable requirements of 10 CFR Part 71, Subpart H. To address this issue, TNF initiated corrective action report (CAR) No. 2024-088. The team noted that the scope of CAR 2024-088 includes applicability of this adverse condition to MAP-12. The team noted TNF is in the process of evaluating corrective actions specific to procurements of ITS polyurethane foam.

Because this issue was identified on a recent previous inspection, no violation will be issued in this inspection report.

No findings of significant were identified.

1.5.3 Conclusions

Overall, the team determined that, materials and components procured and received by TNF met procurement specification, as applicable, and that the specifications conformed

9 to the design commitments and requirements contained in the SARP and CoC. No issues were identified.

1.6 Nonconformance and Corrective Actions

1.6.1 Inspection Scope

The team reviewed selected records and interviewed selected personnel to verify that a nonconformance control program is effectively implemented, and that corrective actions for identified deficiencies are technically sound and completed in a timely manner. The team reviewed the following implementing procedures for TNFs nonconformance and corrective action programs:

  • TIP 7.13, Supplier Findings and Corrective Actions, revision 13
  • 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 22
  • TIP 15.4, Control of Fabrication of Nonconforming Items, revision 5
  • TIP 16.1, Corrective Action, revision 33
  • TIP 16.3, Corrective Action Review Board, revision 18

The team reviewed TNFs nonconformance program to assess the effectiveness of controls established for the processing of nonconforming materials, parts, and components. The team reviewed a sample of eight NCRs for the MAP-12 packages. The review focused on NCRs that were dispositioned as Use-As-Is" and Repair, to determine if TNF had justified their dispositions of the NCRs adequately.

The team also reviewed TNFs corrective action program (CAP) and reviewed a sample of seven CARs generated from 2021 to 2024. The CARs were reviewed to determine whether TNF completed corrective actions for identified deficiencies in a technically sound and timely manner. The review focused on the processing of Level 1 CARs which involved significant conditions adverse to quality, as well as Level 2 and Level 3 CARs which were considered less significant.

1.6.2 Observation and Findings

Overall, the team assessed that TNF had adequate nonconformance controls and CAP in place to identify, track, and resolve quality related deficiencies and deviations.

Nonconformances and corrective actions reviewed were appropriately dispositioned and resolved in a timely manner and in accordance with implementing procedures.

No findings of significance were identified.

1.6.3 Conclusions

The team determined that TNF effectively implemented its nonconformance program and CAP and has adequate procedures in place to ensure compliance with the applicable regulations and QA requirements.

10 1.7 Personnel Training and Oversight

1.7.1 Inspection Scope

The team reviewed selected records and procedures and interviewed selected personnel to verify that individuals performing activities affecting quality are properly trained and qualified, and to verify that management and QA staff are cognizant and provide appropriate oversight.

Specifically, the team reviewed the indoctrination and training records for three (3) TNF employees that have performed quality control inspection activities to verify the training was adequate. The team reviewed records for two employees that have performed quality related welding and one nondestructive examination inspector for the MAP-12 package. The review also included audit personnel.

1.7.2 Observation and Findings

Overall, the team, identified TNF personnel were adequately qualified and training to program and procedures and their qualification and training records were maintained.

No findings of significance were identified.

1.7.3 Conclusions

The team determined that TNF had trained and qualified individuals performing activities affecting quality and that TNF management provided appropriate oversight of quality related activities, as applicable.

1.8 Audit Program

1.8.1 Inspection Scope

The team verified that audits of the QAP and activities affecting the safety aspects of the packaging are scheduled, have been performed as scheduled, and that identified deficiencies have been satisfactorily resolved in a timely manner. The team reviewed the audit program to verify that TNF scheduled, planned, and performed audits in accordance with their NRC-approved QAP and implementing procedures. The team reviewed the audit results to determine if TNF identified deficiencies and addressed these deficiencies within their CAP.

The team selected a sample of internal audits and interviewed personnel to verify that TN effectively implemented their audit program. This sample included a review of lead auditor certifications and qualifications. In addition, the team reviewed the 2022, and 2023 TNF internal audits. The team reviewed the following TIPs:

  • TIP 18.1, Internal Audits, revision 18
  • TIP 18.2, Surveillances, revision 2

11 1.8.2 Observation and Findings

Overall, the team assessed that for the audits sampled TNF generally conducted audits with qualified and certified personnel, scheduled and evaluated applicable elements of their QA program. The team noted that TNF identified observations and findings as applicable within the audits and documented as necessary in accordance with the approved quality procedures. Additionally, the team noted that TNF addressed the observations and findings identified within their CAP.

No findings of significance were identified.

1.8.3 Conclusions

The team determined, for the items selected for review that TNF was performing internal audits in accordance with their QAP.

2.0 Entrance and Exit Meeting

On September 10, 2024, the NRC inspection team discussed the scope of the inspection during an entrance meeting with Framatome and TNF representatives. On September 12, 2024, the NRC inspection team discussed the preliminary results and observations during an onsite meeting with both representatives. Section 1 of the attachment to this report shows the attendance for the meetings.

12 ATTACHMENT

1. MEETING ATTENDEES AND INDIVIDUALS INTERVIEWED

Name Title Affiliation Earl Love Team Leader NRC Raju Patel Safety Inspector NRC Azmi Djapari Safety Inspector NRC Andres Rowe Inspector in-Training NRC Bryan Flanagan Licensing and Compliance Framatome Dan Talmadge Engineer Framatome Scott Robinson Engineer Framatome Paul Garcia IMS Manager Framatome Shaleen Severson Corporate Quality Manager Framatome Louis Cataisson Project Manager TNF Steve Simao Project Manager TNF Michael Cameron Plant Manager TNF John Burchfield Quality Manager TNF Brian Ocampos Senior Quality Manager TN Americas Tammy Johnson Quality Manager TN Americas

2. INSPECTION PROCEDURES USED

IP 86001 Design, Fabrication, Testing, and Maintenance of Transportation Packagings 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 ADAMS Agencywide Documents Access and Management System ASME American Society of Mechanical Engineers ASL Approved Suppliers List CAP Corrective Action Program CoC Certificate of Compliance ITS Important to Safety M&TE Measuring and Test Equipment NCR Nonconformance Report NCV Non-Cited Violation NDE Nondestructive Examination

Attachment NRC U.S. Nuclear Regulatory Commission PO Purchase Order PDR Public Document Room QA Quality Assurance QAP Quality Assurance Program QAPD Quality Assurance Program Description Manual QA Quality Assurance QAP Quality Assurance Program RIR Receipt Inspection Report SARP Safety Analysis Report for Packaging TIP Transnuclear Implementing Procedure TNF Transnuclear Fabrication

5. DOCUMENTS REVIEWED

Certificate holder documents reviewed during the inspection were specifically identified in the Report Details above.

2