ML20318A294
| ML20318A294 | |
| Person / Time | |
|---|---|
| Site: | 07201042 |
| Issue date: | 11/03/2020 |
| From: | Earl Love Division of Fuel Management |
| To: | Ocampos B Orano TN Americas |
| ECLove - NMSS/DFM/IOB - 860.614.4332 | |
| Shared Package | |
| ML20318A292 | List: |
| References | |
| IR 2020202 | |
| Download: ML20318A294 (8) | |
Text
INSPECTOR NOTES COVER SHEET Licensee/Certificate Holder ORANO/TN Americas LLC (TN) 7160 Riverwood Road, Suite 200 Columbia, Maryland 21046 Licensee/Certificate Holder Brian Ocampos, Director of Quality Assurance and Safety Contact Kevin OConnor, Quality Assurance Engineer Docket No. 72-1042 Inspection Report No. 72-1042/2020-202 Inspection Date(s) September 22-24, 2020 and November 2, 2020 Inspection Location(s)
Wolf Creek Generating Station, Burlington, KS Inspectors Earl Love, Team Leader, Senior Transportation &
Storage Safety Inspector Marlone Davis, Senior Transportation & Storage Safety Inspector Summary of Findings and Actions The purpose of this inspection was to determine whether TN fabricated the NUHOMS EOS MATRIX-MX Horizontal Storage Modules (HSM-MX) at the Wolf Creek Generating Station (WCGS) in accordance with the NUHOMS EOS Updated Final Safety Analysis Report (UFSAR), Safety Evaluation Report (SER),
Certificate of Compliance (CoC) No. 1042, Amendment 1 and Title 10 of the Code of Federal Regulations (CFR) Part 72, subpart G requirements.
The team assessed TN's management of the project, and fabrication controls to determine if TN conducted these activities in accordance with their Quality Assurance (QA) Program and if WCGS reviewed these activities to determine that there was no adverse impact on the site operations or Technical Specifications (TS).
The team observed selected activities; reviewed procedures and instructions; examined documents, records, and drawings; verified personnel training and qualifications; and interviewed personnel responsible for various activities.
Based on the results of this inspection, the NRC determined that no violations of significance occurred.
The team held an inspection debrief meeting on September 24, 2020 and a final inspection meeting on November 2, 2020. Overall, there were no issues or violations identified.
Lead Inspector Signature/Date 11/03/2020 Inspector Notes Approval Branch Chief Signature/Date Leira Y. Cuadrado- Digitally signed by Leira Y. Cuadrado-Caraballo Caraballo Date: 2020.11.09 16:22:05 -05'00' Page 1 of 8
Inspector Notes During the week of September 22-24, 2020, a team of NRC inspectors conducted inspection activities in accordance with NRC Inspection Procedure 60853, "On-site Fabrication of Components and Construction of an ISFSI." The purpose of the inspection was to determine whether TN performed on-site fabrication activities at the WCGS in accordance with the NUHOMS EOS UFSAR, SER, CoC and Title 10 of the CFR Part 72, Subpart G requirements.
The team assessed TNs management and fabrication controls to determine if TN conducted these activities in accordance with their Quality Assurance (QA) Program. The team observed selected activities; reviewed procedures and instructions; examined documents, records, and drawings; verified personnel training and qualifications; and interviewed personnel responsible for various activities.
The team performed a preliminary exit briefing on September 24, 2020. During the briefing, there was one outstanding request that the team needed to complete the inspection (refer to inspection requirement 2.02). In response the outstanding item, on October 30, 2020, TN provided additional information (e.g., 72.48 license review, and corrective action plan and extent of condition associated with CAR 2020-333). On November 2, 2020, the team completed its review of the submittal and conducted a final telephone exit with TNs QA Director. Overall, no issues or violations were identified.
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INSPECTOR NOTES: THE TEAM PERFORMED AND DOCUMENTED APPLICABLE PORTIONS OF SECTION 02.01 THROUGH 02.06 OF INSPECTION PROCEDURE 60853 On September 22-24, 2020, the team observed construction activities and performed reviews of fabrication QA records and activities related to the NUHOMS EOS HSM-MX at WCGS. The inspection focus was to determine whether the HSM-MXs would perform their intended function as stated in the UFSAR and CoC, as applicable following fabrication.
Additionally, the team assessed how WCGS reviewed these activities to determine that there was no adverse impact on site operations and TSs.
WCGS has built two concrete pads, each of which is designed to hold 32 NUHOMS EOS dry shielded canisters (DSC), each of which can store up to 37 PWR spent fuel assemblies, inside the HSM-MX overpack/module. The HSM-MX design is a two-tiered, staggered, high-density module, which contains multiple compartments to accommodate multiple DSCs. TN is constructing, at WCGS, eleven (11) Cast-In-Place Array HSM-MXs to CoC No. 1042, Amendment 1. This is a first-time inspection of fabrication/construction of HSM-MXs at WCGS.
The following components form a single array at the WCGS ISFSI: One (1) Main Structure, for 5 upper compartments and 6 lower compartments; 12 Outlet Vent Covers; 4 End Shield Walls; and 11 Doors, plus 1 partial Door. The team noted the Door, Wall and Outlet Vent Cover are concrete components cast separately for assembly at WCGS and that the door was fabricated with a steel backing plate.
02.01 Determine whether materials, components, and other equipment and services received by the fabricator meet DCSS design procurement specifications; procurement specifications conform to the design commitments and requirements contained in the SAR and, as applicable, the CoC or the site-specific license and TS; and provisions of 10 CFR Part 21, Reporting of Defects and Noncompliance, for reporting defects that could cause a substantial safety hazard have been implemented.
The team reviewed TNs project and QA plans for the WCGS HSM-MX construction and assembly. The scope of the QA plan established the QA requirements for the level of testing, inspection, and documentation in accordance with their approved NRC QA program description as defined in Title 10 of the CFR Part 72, subpart G, paragraph 72.140. This also included the review of TNs approved QA implementing procedures and Services Procedure Manuals (SPM)s.
In addition, the team noted that materials testing, and inspections were compliant to TN specification No. EOS-01-0213, Revision 1, Concrete Construction of NUHOMS HSM-MX and that the specification established the requirements for materials, construction, inspection, testing, QA and documentation for the precast reinforced concrete portions of the NUHOMS HSM-MX and the cast in place Matrix Array. The team verified that the fabrication procedures, drawings, and purchase orders of the HSMs were consistent with design commitments and requirements contained in the final SAR. Overall, the team verified that implementing procedures were in place and effective in controlling activities in accordance with licensing and design documents.
The team reviewed TIP No. 15.2, "Control of Nonconforming Items," Revision 18, used to document, track, and resolve nonconforming conditions, as well as TN site specific procedure Page 3 of 8
SPM No. 5.20.9, Revision 1, "Control of Nonconforming Items during Onsite Fabrication and Assembly of HSM." In addition, the team assessed all of TNs Nonconformance Reports (NCR)s since the start of the HSM-MX construction and assembly. The review consisted of NCRs with dispositions of use as is to evaluate if the NCR and supporting documents contain enough information to justify why the nonconforming condition does not compromise the ability of the component to perform its intended function. The team reviewed how TN resolved these deficiencies in a technically sound and timely manner.
02.02 With regard to on-site DCSS fabrication activities, determine whether the licensee, vendor, and fabricator personnel have established an effective method for tracking, evaluating, and dispositioning changes or modifications to the DCSS component design; for selected design changes, the applicable documentation is complete and accurate, including relevant 72.48 evaluations; Individuals performing quality-related activities are trained and certified where required; and on-site fabricators personnel are familiar with the specified design, designated fabrication techniques, testing requirements, and quality controls (QC) associated with the construction of the DCSS.
The team assessed that implementing quality procedures provided adequate guidance for the processing of nonconforming items associated with the HSM-MX construction and assembly.
The team noted that one NCR dispositioned as use-as-is did not meet the TN EOS TS Code alternative for specified concrete compressive strength of 7,000 pound per square inch (psi) related to the 28-day test. The team reviewed TN NCR No. 2020-118, Revision 0 and Licensing Review No. 721042-230, Revision 0 for the shield block inlet (lower compartment) to evaluate how TN dispositioned the use-as-is NCR. TN subject NCR reported that two 28-day cylinder tests for the compressive strengths were 5,770 psi and 5,960 psi, respectively. Section 4.4 of the TN EOS TS takes an alternative to the American Concrete Institute (ACI) 349-06 Code.
Specifically, the TS alternatively (per ACI 349-13, Code Requirements for Nuclear Safety-Related Concrete Structures and Commentary, Section RE.4) increases the specified 28-day compressive strength from 5,000 psi to 7,000 psi for HSM fabrication so that any losses in properties (e.g., compressive strength) resulting from long-term thermal exposure will not affect the safety margins based on the specified 5,000 psi compressive strength used in the design calculations.
The team noted TNs NCR 2020-118 technical basis to allow for a limit of 5,000 psi compressive strength was because the concrete temperatures in the general and local areas of the shield block inlet would fall below 200 degrees Fahrenheit for normal and off-normal conditions.
However, the team noted the EOS UFSAR and TS bases was unclear as to which components in the HSM require an acceptance limit of 5,000 psi (vs. 7,000 psi) compressive strength.
The team inquired with TN as to whether they needed to submit to the NRC a new alternative or if the current TS captured both alternative compressive strength code requirements. The team asked the question based on section 4.4.1 of the EOS TS, in that, it appeared the load combinations for the reinforced concrete of the HSM combined normal, off-normal, and accident loads. In addition, the team noted TNs commitment to not certify and/or load the HSM array with DSCs until the specified compressive strength of 7000 psi is achieved. TN addressed the teams questions and observations in corrective action report (CAR) No. 2020-333 and subsequently completed Licensing Review 721042-244 to add a section to CoC 721042 UFSAR Revision 3 Chapter 13.A, Technical Specification Bases, to provide the bases for the TS 4.4.4 code alternatives for the HSM concrete specifications. In addition, TN supplemented its response to a Request for Additional Information related to Amendment 2, planned for submittal on October 29, Page 4 of 8
2020, revise TS 4.4.4 to clarify the applicable ACI 349-06 section and paragraph, and the associated code requirement, applicable to the proposed alternatives.
The team noted that TNs change to UFSAR provides an adequate technical basis for the Code alternatives for the HSM concrete specifications which specify the use of NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility, Section 8.4.14.2 for the concrete temperature limit criteria for normal and off-normal conditions in lieu of ACI 349-06, Appendix E, Section E.4, Concrete Temperatures, and the Code alternative to utilize ACI 349-13 Section RE.4 in lieu of ACI 349-06 for testing up to 56 days at increased compressive strength where such temperature limit criteria of NUREG-1536 are exceeded (refer to ADAMS No. ML20262H086). Overall, the team noted TNs Bases statement adequately provides the technical basis behind the alternatives and explains how the Code alternatives are applied within the licensing framework for the NUHOMS EOS system. No additional concerns were noted.
The team verified that trained and certified individuals performed quality-related activities, and that on-site fabricators were familiar with the specified design, fabrication techniques, and quality control requirements associated with the Matrix HSM construction. The team reviewed TN approved procedure SPM 5.20.1, Revision 1, "Conduct of Site - Onsite Fabrication and Installation." In addition, the team verified that WCGS personnel performed appropriate oversight of the construction activities and documented results of surveillances and adverse conditions, where applicable. The team determined that TN was conducting on-site fabrication activities of the WCGS HSM-MX under an NRC approved QA program.
02.03 With regard to on-site DCSS fabrication quality assurance (QA) activities, determine whether they are conducted under an U.S. Nuclear Regulatory Commission- (NRC-) approved QAP (10 CFR 72.140); DCSS components are being fabricated per approved QA and 10 CFR Part 21 implementing procedures and fabrication specifications; fabricators personnel are familiar with the reporting requirements of 10 CFR Part 21; and fabricator has complied with 10 CFR 21.6, Posting requirements:
The team verified design, construction and assembly activities were in accordance with TNs NUHOMS EOS, UFSAR, Revision 2, as well as, TNs NRC approved QA program, including associated site implementation procedures. The team reviewed TN implementing procedure (TIP) No. 15.1, "Reportability Determinations and Postings," to evaluate if provisions were in place for evaluating deviations that could cause a substantial safety hazard and if TN could implement the requirements of the regulation in a timely manner. The team requested a list of Part 21 evaluations and notifications associated with the fabrication of the NUHOMS HSM-MX and interviewed personnel to verify if they were familiar with TIP No.15.1. The team also verified that TN was meeting the posting requirements in accordance with the regulations in 10 CFR 21.6, Posting requirements. The team assessed that TN has provisions in place for evaluating deviations and reporting defects, as required by 10 CFR Part 21. The team noted that TN did not have any Part 21 reports since the start of on-site fabrication and construction of the WCGS ISFSI HSM-MX. The team noted that TN posted Part 21 requirements within their ISFSI trailer area.
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02.05 If construction activities are observed, then verify:
Compressive strength samples are collected, cured, and tested, per specifications, and tests indicate whether the concrete meets the specified minimum design strength; The correct size, grade, and spacing of reinforcing steel are installed per the specifications; Concrete is properly placed in adequate forms, consolidated (vibrated), finished, and cured; and slump and air entrainment tests fall within the specified values:
The team noted that the reinforced concrete Matrix HSMs were being fabricated in accordance with ACI-318-2008, Building Code Requirements for Structural Concrete which provides minimum requirements for structural concrete design or construction, and ACI 349-06, Code Requirements for Safety-Related Concrete Structures. In addition, the team noted, quality and testing of materials used in construction were covered by reference to various Standards of the American Society for Testing Materials (ASTM) specifications.
The team reviewed the pre-placement activities for one outlet vent cover (WC-OVC-4) and one door (WC-D-4). The inspectors walked down the fabrication area, examined the rebar and embed installation to verify that the rebar size, spacing, splice length, and concrete coverage on the top and bottom complied with approved drawings and specifications. The team also evaluated the concrete formwork installation for depth, straightness, and horizontal bracing and verified the overall dimensions and orientation for compliance to the approved drawings. The team observed the concrete placement of both the WC-OVC-4 and WC-D-4 to verify that TN properly placed, consolidated, and finished the concrete placement.
Prior to the concrete placement, the team observed the tests conducted for the slump of the concrete, air content, temperature measurements, and the collection and preparation of cylinder samples for compression tests to meet the acceptance criteria in the approved specification. The team reviewed the measuring and test equipment (M&TE) associated with observed tests such as the slump cone, scale, air meter, and thermometer. The team reviewed the calibration reports to verify calibration dates, testing standards, and traceability of the associated M&TE. The team reviewed the concrete truck batch tickets to verify that the concrete delivered to the site met applicable code and specification requirements regarding the concrete batch composition and time to placement. The team also interviewed TN and licensee personnel to verify that personnel was knowable of the ongoing work and provided appropriate oversight of the HSM construction activities. Additionally, the team performed a documentation review of one completed shield block and one completed end shield wall to verify that TN properly performed QA/QC hold points.
The team assessed that TN conducted the concrete placement and testing within the specified procedures and specifications. The team assessed that TN established controls of M&TE in accordance with standards and regulatory requirements. The team also assessed that TN engineering and construction personnel provided the appropriate information on work travelers in accordance with approved procedures. The team also verified that personnel used M&TE within their capacities and sensitivities as documented in the document work package.
Overall, the team noted concrete forms, reinforcing and embedded items met TNs specification and approved fabrication drawings requirements; specified tests have been performed; and that concrete was properly batched, transported, placed and consolidated into place.
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SUPPLEMENTAL INFORMTION KEY POINTS OF CONTACT Personnel Interviewed Brian Voss, ORANO Field Services Director Steve Bostic, TN Onsite Project Coordinator James Rumen, TN Field Engineer Scott Mawhinney, TN Project Engineer Joseph Patrick, ORANO Supervisor Tim Petit, TN Project Manager Cindy Brown, TN Document Package Coordinator Kevin OConnor, TN Quality Assurance Jason Cabrita, TN Quality Assurance LIST OF DOCUMENTS REVIEWED Procedures SPM 5,20.9, Control of Nonconforming Items during Onsite Fabrication and Assembly of HSM, Revision 1 SPM 5.20.9, Conduct of Site - Onsite Fabrication and Installation, Revision 2 SPM 5.21.1, General Construction Requirements and Methods for Onsite Fabrication of HSM-M, Revision 3 SPM 5.21.8, Concrete Batching and Testing Procedure for Onsite Fabrication of HSM-H, Revision 3 Drawings NUH-03-7103, Base, Revision 5 NUH-03-7105, Walls and Outlet Vent Cover Design Drawing, Revision 2 Corrective Action Report (CAR) 2020-198, dated 6/17/2020: Control of redline fabrication drawings.
2020-250, dated 7/28/2020: Concrete balling 2020-255, dated 7/30/2020: Evaluation of Inspection and Test Personnel Qualifications 2020-305, dated 9/12/2020: Material Control Tagging and Storage 2020-306, dated 9/12/2020: Material Identification and Storage 2020-307, dated 9/12/2020: Calibration Sticker 2020-332, dated 9/24/2020: authorization to proceed to concrete placement pending final acceptance of out of tolerance test result(s) 2020-333, dated 9/24/2020: 72.48 general applicability question of LR 721042-230, which evaluated the licensing impact of TN NCR 2020-118 (refer to inspection requirement 2.02).
Nonconformance Reports (NCR)
NCR 2020-107 dated 7/22/2020: disposition: use-as-is: Aggregates not conforming to ASTM-C33 1/2" sieve requires 95%-100% passing. License Review No.: LR 721042-231 NCR 2020-118 dated 8/11/2020, disposition use-as-is: Shield Block Inlet (lower), compressive Page 7 of 8
test below TN Specification EOS-01-0213(1) requirement of 7,000psi at 28 days. License Review Nos.: LR 721042-230 and LR721042-244 NCR 2020-046 dated 3/4/20, disposition: use-as-is: Wolf Creek Approval Letter. Specification EOS-01-0213, Section 5.2.2 "Aggregates," and ASTM C 33; coarse aggregated failed to meet the required gradation. Gradations represent a concrete sample that was produced for the mix design approval regarding the chloride Ion testing. No HSM components were fabricated.
NCR 2020-132 dated 9/14/2020, disposition: use-as-is: Stage 1 concrete placement for Matrix:
Batch ticket 5037833 and 50217246 exceeded Air Content of specification EOS01-0213(1).
Miscellaneous Batch Ticket 179654 and Supplemental Sheet, dated September 15, 2015 Batch Ticket 179672 and Supplemental Sheet, dated September 15, 2015 Concrete Batching for Onsite Fabrication Signoff Sheet, dated September 15, 2015 HSM Procedure Traveler for Base LGS-B-ES-1, dated August 28, 2015 HSM Procedure Traveler for End Wall LGS-EW-38, dated September 15, 2015 HSM Procedure Traveler for Outlet Vent Cover LGS-OVC-8, dated September 15, 2015 HSM Procedure Traveler for Roof LGS-R-ES-1, dated August 28, 2015 Lab Report 10-132843, Concrete Cylinder Compression Test, dated September 10, 2015 Lab Report 10-132844, Concrete Cylinder Compression Test, dated September 10, 2015 Project Specification NUH-03-0314, AREVA Specification: Concrete Construction of NUHOMS HSM, Revision 4 ORANO Project Plan 30501.FC1, Revision 4 Shield Block Inlet (WC-SB-5), Plastic Concrete Test Results, Batch Ticket 5037582, dated June 16, 2020 End Shield Wall (WC-ESW-1), Compressive Strength of Concrete, Report #CC-000112, dated 8/11/2020 (Specification: Strength 7000psi, Actual: 5230/5430psi) LR721042-230 Generic Final Documentation Package, (9) Batch Ticket Records, dated 9/12/2020 Generic Final Documentation Package, Skyway Cement Company, Chicago, IL, Slag Cement Material Certification Report dated August 17, 2020, Multiple Lots, date range July 1-31, 2020.
Certified Material Test Report Type I/II, Monarch Cement Company, Humboldt, KS dated 7/22/2020 Stage One - End Compartment (WC-1-EC-1), Matrix HSM ID# L1: Front Wall, Shield Block Layout and Forms; Reinforcing Steel; Embedment; Pre-Pour Inspection; Curing; Post-Pour Inspection; and Dimensional Inspections.
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