ML24317A118
| ML24317A118 | |
| Person / Time | |
|---|---|
| Site: | 99902049 |
| Issue date: | 11/13/2024 |
| From: | Nicole Coovert Division of Operating Reactors |
| To: | Brenner A Holtec |
| References | |
| Download: ML24317A118 (1) | |
Text
Andrew Brenner Director of Licensing, SMR Holtec International 1 Holtec Boulevard Camden, NJ 08104
SUBJECT:
NRC AUDIT OF SUBSURFACE INVESTIGATION ACTIVITIES AT THE PALISADES ENERGY CENTER PROJECT SITE
Dear Andrew Brenner:
This letter provides a summary of an U.S. Nuclear Regulatory Commission (NRC) audit of subsurface investigation work performed for the Holtec Palisades SMR-300 (Palisades SMR) plant located at the Palisades Energy Center project site. This audit was conducted from October 1-2, 2024, in accordance with Inspection Procedure (IP) 45052, Review of Geotechnical and Site Characterization Activities.1 As described in the audit summary (Enclosure 1), NRC staff examined the quality assurance (QA) programs of the applicant, and their contractors, agents, and consultants, as applied to geotechnical activities, to verify if the programs are being implemented in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
Based on the results of this audit, the NRC staff determined that QA program requirements were being adequately implemented as required by the applicant and their contractors, agents, or consultants. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Should you have any questions concerning this letter, please contact me at 404-997-4510.
Sincerely, Nicole Coovert, Chief Engineering Branch 3 Division of Operating Reactor Safety Docket No.:
99902049
Enclosure:
NRC Audit Report w/attachment: Supplemental Information 1 Agencywide Documents Access and Management System (ADAMS) Accession Number ML22019A083.
November 13, 2024 Signed by Coovert, Nicole on 11/13/24
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE RII/DORS RII/DORS RII/DORS NAME L. Colon Fuentes A. Ponko N. Coovert DATE 11/12/24 11/12/24 11/13/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION (NRC)
Region II Docket Number: 99902049 Applicant:
SMR, LLC. A Holtec International Company Facility:
Holtec SMR located at the Palisades Energy Center Location:
Covert, Michigan (MI)
Inspection Dates:
October 1 through October 2, 2024 NRC Auditors:
A. Ponko, Senior Construction Project Inspector, Region II, Division of Operating Reactor Safety (DORS)
L. Colon Fuentes, Construction Project Inspector, Region II, DORS NRC Accompanying Personnel:
None Approved by:
Nicole Coovert, Chief Engineering Branch 3 Division of Operating Reactor Safety
2 Audit Summary Palisades SMR Subsurface Investigation Activities October 1-2, 2024 INSPECTION PROCEDURE 45052, REVIEW OF GEOTECHNICAL AND SITE CHARACTERIZATION ACTIVITIES Project safety-related geotechnical sampling and data collection field activities were being performed by Fugro Great Lakes, LLC (FUGRO) in accordance with a project plan prepared by Enercon Services, INC. (ENERCON) for Holtec SMR, LLC (HOLTEC). These activities were being performed under the FUGRO quality assurance program. Oversight of FUGRO field activities was being performed by ENERCON and HOLTEC.
The staff reviewed documents prepared by HOLTEC, ENERCON, and FUGRO describing the quality assurance (QA) measures applicable to geotechnical and site characterization activities being performed to support development of a construction permit application (CPA). These documents included the Topical Report on the Quality Assurance Program for Holtec Internationals Small Modular Reactor (SMR) Design and Construction, (Holtec Report HI-2230815, Revision 2); the ENERCON Quality Assurance Manual, Revision 14; and the FUGRO Quality Assurance Manual. The staff also reviewed the FUGRO project planning document, as well as, project and work instructions applicable to geotechnical and site characterization activities being performed to support the CPA. The staff reviewed if adequate measures for performing field exploration and data collection activities had been established and were being implemented in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. Specifically, the staff verified that procedures and instructions prescribing site exploration and testing activities had been established and were being adequately implemented for geotechnical drilling and sampling, borehole geophysical logging, well drilling and sampling, calibration of measuring and test equipment (M&TE), handling and storage of core samples, personnel training and qualifications, corrective actions, and contractor oversight.
The staff observed in process soil sampling and/or core boring at boreholes B24-001, B24-002, B24-017, and B24-028 to verify that geotechnical drilling and sampling was being conducted in accordance with the ENERCON project plan, FUGRO project planning document, and implementing work plans, procedures, and instructions. The staff also observed the handling and care of newly completed rock core samples and performed a walk down of the core storage facility to verify that the handling, care, and storage of completed rock core samples was in accordance with project requirements. Additionally, the staff observed in process borehole geophysical logging at borehole B24-001.
The staff verified that appropriate training and qualification requirements had been identified and specified for personnel associated with safety-related geotechnical and site characterization activities and reviewed certificates of qualification for personnel performing activities affecting quality to verify that measures were being adequately implemented for the training of personnel to ensure that suitable proficiency was achieved and maintained.
The staff reviewed procedures associated with the control of M&TE and verified that measures were established to ensure that M&TE used in site characterization activities are of the proper range, type, and accuracy and provide for inspection, calibration, adjustment, and maintenance of M&TE at prescribed intervals, using national standards as a basis for calibration. The staff
3 also reviewed the M&TE log and a sampled M&TE issued for use to determine that controls for calibration were being adequately implemented and to verify that in-use M&TE was in good working order, properly calibrated, and uniquely identifiable.
The staff reviewed the audit reports that HOLTEC and ENERCON relied upon to qualify ENERCON and FUGRO, respectively, to perform work associated with safety-related geotechnical and site characterization activities. The staff also reviewed the FUGRO oversight plan prepared by ENERCON, as well as three project surveillances conducted by ENERCON to verify that work being performed by FUGRO in support of the Palisades SMR CPA conformed to the procurement documents and applicable technical and QA program requirements. The staff also reviewed two QA surveillances completed by the independent FUGRO QA organization to verify prerequisites were met prior to performing safety-related work and one QA surveillance performed by the same QA organization to verify that safety-related work conformed to the applicable procedures, instructions and quality assurance requirements. The staff verified that HOLTEC was performing adequate oversight of ENERCON and FUGRO in accordance with the requirements of 10 CFR Part 50, Appendix B.
The staff reviewed a sample of eight corrective action documents (CADs) initiated by HOLTEC and two CADs opened by FUGRO to verify that measures were being adequately implemented to promptly identify, classify, and resolve deficiencies, nonconformances, and conditions adverse to quality in a timely manner. The staff also verified that project quality records were being stored in accordance with applicable requirements.
Based on the results of this audit, the staff determined that QA program requirements, as applicable to CPA geotechnical activities, were being adequately implemented in accordance with the requirements of Appendix B to 10 CFR Part 50.
On October 2, 2024, the NRC staff discussed the results of this audit with Mr. Andrew Brenner Director of Licensing, Palisades SMR, Holtec International, LLC and other members of your staff. Proprietary and copyright information was reviewed during the audit period but was not included in the audit report.
4 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Applicant and Contractor Personnel A. Brenner, Holtec, Director of Licensing S. Mitchell, Holtec, SMR-Licensing/Site Lead J. Dolecki, Holtec, Operations Manager, SMR 300 B. Hatiopoglu, Enercon, Senior Geotechnical Engineer O. El Menchawi, Fugro, V.P Nuclear Services, Project Manager J. Sowers, Fugro, Lead Geologist D. Valintine, Fugro, Lead Geophysicist L. Ferreira, Fugro, Field Coordinator C. Eldridge, Fugro, Quality Assurance Manager LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Type Status Description None LIST OF DOCUMENTS REVIEWED Plans, Procedures, and Instructions Enercon Document No. ESEPC-HOLTEC-00077, Project Plan for Construction Permit Application Support for Two New Holtec SRM-300 Units at Palisades Nuclear Plant Site Covert Township, Van Buren County, Michigan, Revision 0 Enercon Project Instruction No. ESEPC-HOLTEC-00077-PI-001, HOLTEC Small Modular Reactor (SMR) Construction Permit Application (CPA) Aquifer Testing, Revision 0 Enercon Project Instruction No. ESEPC-HOLTEC-00077-PI-004, Groundwater and Surface Water Data Collection, Revision 0 Enercon Project Instruction No. ESEPC-HOLTEC-00077-PI-006, Meteorological Data Management, Revision 0 Enercon Project Instruction No. ESEPC-HOLTEC-00077-PI-008, Field Hydrological Data Collection, Revision 0 Enercon Project Instruction No. ESEPC-HOLTEC-00117, Fugro Oversight Plan for Palisades SMR CPA, Revision 3 Enercon Attachment 12-13, Quality Assurance Requirements (Limitations and Hold Points) for Fugro, Revision 0 Fugro Project Instruction No. PSMR-PI-01, Data Collection Plan, Revision 1 Fugro Project Instruction No. PSMR-PI-02, Geotechnical Work Plan, Revision 3 Fugro Project Instruction No. PSMR-PI-03, Geotechnical Laboratory Testing Plan, Revision 0 Fugro Project Instruction No. PSMR-PI-04, Ground Control Survey, Revision 2 Fugro Project Instruction No. PSMR-PI-05, Borehole Geophysical Logging, Revision 0 Fugro Project Instruction No. PSMR-PI-06, Pressuremeter Methodology, Revision 0 Fugro Project Instruction No. PSMR-PI-07, SPT Hammer Calibration, Revision 0 Fugro Project Instruction No. PSMR-PI-08, Geoscience Data Review, Revision 0 Fugro Project Instruction No. PSMR-PI-09, Geoscience Analysis, Revision 0 Fugro Work Instruction No. 11, Revision 0 Fugro Work Instruction No. 12, Revision 0
5 Fugro Work Instruction No. 13, Revision 0 Fugro Work Instruction No. 15, Revision 0 Fugro Work Instruction No. 16, Revision 0 Audits & Surveillance Reports Independent Assessment Report Number (from SIEIMS): IA-24-011 (NIAC Audit Number 31498) of Enercon Services, Inc.
Enercon Supplier Audit of Fugro USA Land, Inc. - 2024 FCL-AUD-03 Enercon Services, Inc. Surveillance of Fugro USA Land, Inc. - Surveillance No. FCL-SURV-2024-01 Enercon Services, Inc. Surveillance of Fugro USA Land, Inc. - Surveillance No. FCL-SURV-2024-02 Enercon Services, Inc. Surveillance of FUGRO USA Land, Inc. - Surveillance No. FCL-SURV-2024-03 Fugro QA Surveillance Report PSMR-SR-2024-03 Fugro QA Surveillance Report PSMR-SR-2024-04 Fugro QA Surveillance Report PSMR-SR-2024-06 Corrective Action Documents Holtec SMR-00001 Holtec SMR-00002 Holtec SMR-00003 Holtec SMR-00004 Holtec SMR-00005 Holtec SMR-00006 Holtec SMR-00007 Holtec SMR-00010 Fugro PSMR-CAR-2024-01 Fugro PSMR-CAR-2024-02 Calibration Records ABI40 Equipment Verification Scout-MXA 20240910, Revision 0 QL40-CAL Equipment Verification Scout-MXA 20240917, Revision 0 QL40-OBI-2G Equipment Verification Scout-MXA 20240911, Revision 0