July 25, 2001

Mr. Ronald A. Milner, Chief Operating Officer

Office of Civilian Radioactive Waste Management

U. S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSIONíS OBSERVATION AUDIT

REPORT NO. OAR-01-07, ìOBSERVATION AUDIT OF THE BECHTEL SAIC

COMPANY, LLC, AUDIT NO. BSC-SA-01-021 OF FRAMATOME ANP, INC.î

Dear Mr. Milner:

I am transmitting the U.S. Nuclear Regulatory Commissionís (NRCís) Observation Audit Report

(No. OAR-01-07) of the U.S. Department of Energyís (DOEís), Office of Civilian Radioactive

Waste Management (OCRWM), Management and Operating Contractor, Bechtel SAIC

Company, LLC (BSC), Quality Assurance (QA), audit of Framatome ANP, Inc. (Framatome).

This audit was conducted on June 19 through 21, 2001, at various Framatome facilities in

Lynchburg, Virginia. 

The purpose of this audit was to evaluate the effectiveness of the implementation of

Framatomeís QA Program (QAP), as approved by BSC, and to determine if applicable

requirements of the OCRWM Quality Assurance Program Description (QARD) were being met. 

The scope of the audit included evaluating the implementation of the QARD and QAP for the

welding and nondestructive examination of samples supporting the design of the high-level

waste containers for the proposed repository at Yucca Mountain, Nevada.

The NRC observers (observers) determined that this audit was effective in identifying potential

deficiencies and recommending improvements for the Framatome activities reviewed. During

the conduct of the audit, both the BSC audit team (audit team) and the observers independently

reviewed applicable documents, procedures, and activities within the auditís scope. 

Also, the audit team and observers reviewed and observed welding and nondestructive

activities for the production of welded samples that will be used for corrosion testing and

analysis of the stresses in the waste container closure weld. The audit team identified some

minor problems in the areas of documenting and processing nonconforming conditions and

identifying the status of measuring and test equipment. These problems were corrected during

the audit. Additionally, the audit team identified a potential deficiency in the area of

procurement. The staff believes that this BSC audit was well-planned, thorough, and

adequately evaluated Framatomeís welding and nondestructive examination activities. 

The observers agreed with the audit teamís conclusions, findings, and recommendations

presented at the audit exit. Notwithstanding the audit teamís findings, the staff believes that

Framatome is properly controlling welding and nondestructive examination activities within the
R. Milner -2-

scope of the audit. The staff will continue to interface with OCRWM and follow the progress

that Framatome is making to address the issues identified during this audit. 

A written response to this letter and the enclosed report is not required; however, we do request

that you respond to the open Audit Observer Inquiries from the previous NRC observations

identified in Section 5.3 of the attached report. If you have any questions, please contact 

Larry L. Campbell at (301) 415-5000.

Sincerely,

/RA/

C. William Reamer, Chief

High-Level Waste Branch

Division of Waste Management

Office of Nuclear Material Safety

 and Safeguards

Enclosure: NRC Observation Audit Report

 No. OAR-01-07, ìObservation Audit

of the Bechtel SAIC Company, LLC, 

Audit No. BSC-SA-01-21 of Framatome ANP, Inc.î

CC: See attached list
R. Milner -2-

scope of the audit. The staff will continue to interface with OCRWM and follow the progress

that Framatome is making to address the issues identified during this audit. 

A written response to this letter and the enclosed report is not required; however, we do request

that you respond to the open Audit Observer Inquiries from the previous NRC observations

identified in Section 5.3 of the attached report. If you have any questions, please contact 

Larry L. Campbell at (301) 415-5000.

Sincerely,

/RA/

C. William Reamer, Chief

High-Level Waste Branch

Division of Waste Management

Office of Nuclear Material Safety

 and Safeguards

Enclosure: NRC Observation Audit Report

 No. OAR-01-07, ìObservation Audit

of the Bechtel SAIC Company, LLC, 

Audit No. BSC-SA-01-21 of Framatome ANP, Inc.î

CC: See attached list

DISTRIBUTION:

File Center PUBLIC ACNW LSS CNWRA NMSS r/f HLWB r/f

SWastler CGlenn BMabrito WBelke RLatta DWMr/f

JCiocco TCarter DBrooks TMatula BSpitzberg BNeuberger

BMabrito TTrbovich

ADAMS Accession No. ML012070159 

DOCUMENT NAME: S/DWM/HLWB/llc/Framatome Audit Observation Report.wpd

*See Previous concurrence

OFC HLWB Tech Editor HLWB HLWB

NAME LLCampbell llc *EKraus ek NKStablein nks CWReamer cwr

DATE 07/20/01 0 7/21/01 07/23/01 07/25/01 

OFFICIAL COPY

ACNW: YES X NO Delete file after distribution: Yes No 

1) This document should be made available to the PUBLIC. Yes - llc3 

2) This document is related to the HLW program. It should be placed in the LSS. Yes - llc3

This document is Non-Sensitive 
Letter to R. Milner from C.W. Reamer dated: July 25, 2001 

cc:

R. Loux, State of Nevada R. Massey, Lander County, NV

S. Frishman, State of Nevada J. Pitts, Lincoln County, NV

L. Barrett, DOE/Washington, DC M. Baughman, Lincoln County, NV

A. Brownstein, DOE/Washington, DC A. Funk, Mineral County, NV

S. Hanauer, DOE/Washington, DC J. Shankle, Mineral County, NV

C. Einberg, DOE/Washington, DC L. Bradshaw, Nye County, NV

J. Carlson, DOE/Washington, DC M. Murphy, Nye County, NV

N. Slater, DOE/Washington, DC J. McKnight, Nye County, NV

A. Gil, YMPO D. Weigel, GAO

R. Dyer, YMPO W. Barnard, NWTRB

S. Brocoum, YMPO R. Holden, NCAI

R. Clark, YMPO A. Collins, NIEC

S. Mellington, YMPO R. Arnold, Pahrump County, NV

C. Hanlon, YMPO J. Larson, White Pine County

T. Gunter, YMPO R. Clark, EPA

K. Hess, BSC F. Marcinowski, EPA

D. Krisha, BSC R. Anderson, NEI

S. Cereghina, BSC R. McCullum, NEI

N. Williams, BSC R. Henning, BSC

M. Voegele, BSC/SAIC S. Kraft, NEI

S. Echols, Winston & Strawn J. Kessler, EPRI

B. Price, Nevada Legislative Committee D. Duncan, USGS

J. Meder, Nevada Legislative Counsel Bureau R. Craig, USGS

D. Bechtel, Clark County, NV W. Booth, Engineering Svcs, LTD

E. von Tiesenhausen, Clark County, NV J. Curtiss, Winston & Strawn

A. Kalt, Churchill County, NV N. Rice, NV Congressional Delegation

G. McCorkell, Esmeralda County, NV T. Story, NV Congressional Delegation

L. Fiorenzi, Eureka County, NV J. Reynoldson, NV Congressional Delegation

A. Johnson, Eureka County, NV S. Joya, NV Congressional Delegation

A. Remus, Inyo County, CA J. Pegues, City of Las Vegas, NV

M. Yarbro, Lander County, NV L. Lehman, T-REG, Inc.

I. Zabarte, W.S.N.C.
-1-

U.S. NUCLEAR REGULATORY COMMISSION 

OBSERVATION AUDIT REPORT NO. OAR-01-07

ìOBSERVATION AUDIT OF THE 

BECHTEL SAIC COMPANY, LLC

AUDIT NO. BSC-SA-01-21 OF FRAMATOME ANP, INC.î

 /R/ 07/17/01 /R/ 07/17/01

Larry L. Campbell Brett Neuberger 

Projects and Engineering Section Projects and Engineering Section

High-Level Waste Branch High-Level Waste Branch

Division of Waste Management Division of Waste Management

 /R/ 07/17/01 

Tomas C. Trbovich 

Center for Nuclear Waste Regulatory

 Analyses

Reviewed and Approved by:

 /RA/ llc for nks 07/ /01

N. King Stablein, Chief

Projects and Engineering Section

High-Level Waste Branch 

Division of Waste Management
-2-

1.0 INTRODUCTION

1.1 Framatome ANP, Inc.(Background)

The current statement of work agreement between the U.S. Department of Energy (DOE)

Office of Civilian Radioactive Waste Management (OCRWM), Management and Operating

Contractor (M&O) and Framatome ANP, Inc (Framatome) is Subcontract Change Notice No.

10, dated February 23, 2001, to Subcontract No. BSC SOW #FCF-LV.STR.REV.02/01-006 for

Master Subcontract No. A06607GN8S. Framatome has been contracted to provide

engineering and technical services as directed by the M&O Waste Package Project Manager. 

The overall scope of Framatomeís work includes the development of fabrication and closure

welding processes and systems for the waste package. This scope includes investigating and

developing the fabrication process and verification techniques necessary to implement the highlevel waste container design for the proposed repository at Yucca Mountain, Nevada. Also, the

scope includes providing samples for the materials testing program for further study which

includes activities such as the following: evaluating and developing an alternate weld

processes for process optimization; weld groove design and weld closure sequence, and the

weld system; performing residual stress comparative (process) studies; determining weld filler

metal composition range(s); and providing the minimum weld defect size, the annealing

procedure and specification, and the welded and non-welded engineered barrier materials for

the materials testing program.

The observers note that the base metal material used for welding the samples was American

Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME), Section II,

ìMaterials,î Specification SB-575 (C-22). 

1.2 Performance of the Audit 

Staff from the U.S. Nuclear Regulatory Commission (NRC), Division of Waste Management,

and the Center for Nuclear Waste Regulatory Analyses Center (CNWRA) observed the M&O,

Bechtel, SAIC Company, LLC (BSC) audit of activities regarding the implementation of

Framatomeís Quality Assurance Program (QAP). This audit was conducted on June 19

through 21, 2001, at various Framatomeís facilities in Lynchburg, Virginia. 

The purpose of this audit was to evaluate the effectiveness of the implementation of

Framatomeís QAP, as approved by BSC, and to determine if applicable requirements of the

OCRWM Quality Assurance Program Description (QARD) were being met. The scope of the

audit included evaluating the implementation of the QARD and QAP for the welding and

nondestructive examination of samples supporting the design of the high-level waste containers

for the proposed repository at Yucca Mountain, Nevada.

The NRC observersí (observersí) objective was to assess whether BSC Quality Assurance

(QA), Product Quality Engineering/Supplier Audits and Evaluation Section, audit team (audit

team) and Framatome were properly implementing the requirements contained in Subpart G,

ìQuality Assurance,î to Part 60, of Title 10 of the U.S. Code of Federal Regulations (10 CFR

Part 60) and the provisions contained in the QARD. Prior to the start of the audit, the audit

team and observers were provided a tour of the Framatome facility.
-3-

This report presents the observersí determination of how effective the BSC audit was, and

whether Framatome implemented adequate QARD and QAP controls in the audited areas.

2.0 MANAGEMENT SUMMARY 

Within the areas evaluated, the audit team identified several minor potential deficiencies. 

These deficiencies did not appear to impact the quality and technical adequacy of the

Framatome products being supplied to BSC. During the audit, Framatome took action to

correct the following three deficiencies: 1) a procedure change was initiated for a liquid

penetrant procedure to indicate specific penetrant material to be used for examinations

performed at the Framatomeís facilities; 2) a nonconformance was initiated to correct a

calibration due date discrepancy; and 3) a nonconformance report was revised to identify

specific items that were rejected. The audit team identified the following potential deficiencies

during the audit against a purchase order (PO) to one supplier, Spec/American Technical

Services, Inc.: 1) Framatome failed to specify, on one purchase order, the specific QA program

for the supplier to use; and 2) applicable procurement documents did not address the

restrictions noted on the Framatome Approved Supplier List (ASL). 

The audit team identified the following as an open item that it would be discussing with BSC

management: Framatomeís practice is for its QA personnel to independently review purchase

requisitions (PRs) containing the quality and technical requirements to be followed by the

supplier. However, the POs, incorporating the QA and technical requirements from the PR, are

not required to be reviewed by Framatomeís QA personnel. The audit team questioned why

Framatomeís QA personnel were not reviewing the completed POs. 

The observers determined that BSC Audit No. BSC-SA-01-21 was well-planned and effectively

executed. The audit team members were independent of the activities they audited and were

knowledgeable in the QA and technical disciplines within the scope of the audit. The audit team

membersí qualifications were reviewed and were found acceptable. 

With the exceptions of the potential deficiencies, the audit team concluded that the QARD and

QAP had been satisfactorily implemented in the areas evaluated. The observers agreed with

the audit teamís conclusions, findings, and recommendations presented at the audit exit. The

staff will continue to interface with OCRWM and follow the progress that Framatome is making

to address the issues identified during this audit. 

3.0 AUDIT PARTICIPANTS

3.1 Observers

Larry L. Campbell Team Leader NRC

Brett Neuberger Technical Specialist NRC

Tomas C. Trbovich QA Specialist CNWRA
-4-

3.2 BSC Audit Team

Robert D. Habbe Audit Team Leader BSC QA 

Richard L. Hand Auditor BSC QA

4.0 REVIEW OF THE AUDIT AND AUDITED ORGANIZATION

This BSC QA audit of Framatome was conducted in accordance with OCRWM Quality

Assurance Procedure (QAP) 18.2, ìInternal Audit Program,î and QAP 16.1Q,

ìPerformance/Deficiency Reporting.î The NRC staffís observation of this audit was based on

NRC Manual Chapter 2410, ìConduct of Observation Audits,î dated July 12, 2000.

4.1 Scope of the Audit

The scope of the audit included evaluating the implementation of the QARD and QAP for the

welding and nondestructive examination of samples supporting the design of the high-level

waste containers for the proposed repository at Yucca Mountain, Nevada.

4.2 Conduct and Timing of the Audit

The audit was performed effectively and the audit team demonstrated a sound knowledge of

the applicable Framatome programs and procedures. The audit checklist was developed using

the QARD and the Framatome QAP. Applicable Framatome implementing procedures were

used during the audit. Audit team members conducted thorough interviews; they challenged

responses, when appropriate; and they effectively employed their detailed audit checklists. The

observers concluded that the timing of the audit was appropriate for the auditors to evaluate

ongoing Framatome welding and nondestructive examination activities. The audit team and the

observers caucused at the end of each day. Meetings between the audit team and Framatome

(with the observers present) were held, as necessary, to discuss the current audit status and

preliminary findings.

4.3 Audit Team Qualification and Independence 

The qualifications of the audit team were reviewed for accuracy and completeness in

accordance with the requirements of DOE Procedure QAP 18.1, ìAuditor Qualification.î The

observersí review included an examination of the training, education, and experience of the

audit team members. The observers concluded that the audit team members had the

necessary expertise to perform the audit and were qualified to audit Framatomeís activities.

The observers reviewed organizational information and determined that the audit team

members were independent of any direct responsibility for performing audited activities. The

observers concluded that the auditors had sufficient authority and organizational freedom to

make the audit process meaningful and effective.
-5-

4.4 Examination of QA Elements

4.4.1 QA Program, Procedures, and Training

The audit team reviewed the Framatome organization structure and determined that it provided

adequate organization freedom for the Framatome QA organization to perform its independent

functions. The audit team determined that adequate policies, procedures, and instructions

were available and properly controlled for performing quality related activities supporting the

manufacture of DOEís welded samples. 

Also, the audit team reviewed several indoctrination, training, and qualification records for

Framatome personnel engaged in the activities covered by the QAP and found them

acceptable. Specifically, the audit team reviewed several records for personnel performing

welding, nondestructive examination, inspection, auditing, and engineering activities related to

the welded samples and found them acceptable. 

The observers agreed with the audit teamís findings in this area.

4.4.2 Document Control

The audit team reviewed the document control process for several Framatome documents

including the QAP, procedures controlling the manufacture of the welded samples, master

document lists, document control logs, and changes to these documents. Although, the audit

team found no deficiencies in this area, the audit team questioned Framatomeís practice of not

documenting the satisfactory resolution of the comments provided for procedure changes. The

audit team recommended that administrative procedure be clarified with respect to documenting

the resolution of comments. 

The observers agreed with the audit teamís findings in this area. 

4.4.3 Procurement

The audit team reviewed the following two POs for compliance with procedural requirements. 

PO No. 88855 was issued to Nooter Fabricators, Inc. for the Waste Package Mock-up

Fabrication. The audit team found that the restrictions identified on the ASL for this

supplier was noted on the PO and the PO had received the necessary internal reviews 

prior to order placement. 

 

PO No. 101028 was issued to Spec/American Technical Services, Inc. for

nondestructive examination services. The audit team found that this PO failed to meet

the requirements of the QARD and DOEís contractual Yucca Mountain Technical

Requirements Document because it did not specifically identify a requirement for the

use of the approved QA program. Further, the audit team found that this PO did not

incorporate the restrictions identified on the ASL for Spec/American Technical Services,

Inc. During the audit exit, the audit team identified these findings as potential

deficiencies.

Further, the audit team questioned Framatomeís practice of having its QA personnel review the

PR rather than the completed PO. The audit team indicated that this on-going Framatome
-6-

practice will be discussed with BSC management and the previous BSC audit team leader

before any determination is made on the issuance of a deficiency.

The observers agreed with the audit teamís findings in this area.

4.4.4 Identification & Control of Items and Materials

During the review of fabrication practices, the audit team and observers found that the

restrained weld mock-ups and welded corrosion sample plates had proper piece identification

(heat/lot number; assembly number). The audit team found that the processing of these

samples was properly controlled throughout the various operations, by the use of a shop

traveler, in accordance with Framatome Working Instruction 8, Rev. 10. The audit team

identified no deficiencies in this area.

The audit team and observers questioned Framatomeís procedure controlling the identification

of nonconforming items. During the audit, a piece of a welded sample, previously found to be

unacceptable, had no identification on it, such as a tag, indicating that it was unacceptable for

use and had been formally rejected. The audit team and observers found that Framatomeís

procedure and practice for controlling nonconforming items does not specifically require that

rejected items be identified as rejected by the use of tags or other identification methods. The

audit team recommended that Framatome review its current practice regarding when

nonconforming items need to be identified as nonconforming by tagging the item and that

Framatome tag all nonconforming items, when practical. This recommendation is discussed

further in Section 4.4.10 of this report.

The observers agreed with the audit teamís findings in this area.

4.4.5 Control of Special Processes

The audit team reviewed the control of special processes including the qualification of

procedures and personnel used for welding and nondestructive examination. The qualification

of welding and nondestructive examination personnel and procedures are performed by

Framatome in accordance with Working Instruction 23, Rev 3, and specific manuals. 

The audit team reviewed several Framatome nondestructive examination procedures and found

them acceptable except for Liquid Penetrant (PT) Procedure No. 54-PT-6-07. Framatomeís PT

Procedure No. 54-PT-6-07 identified qualified materials from two suppliers (Magnaflux and

Androx) for use. However, the audit team found that only Magnaflux materials were identified

and qualified in Procedure Qualification (PQ) 240-06 for this procedure. Framatome personnel

stated that there were no Androx materials in house and that these materials were only used at

a client facility when supplied by the client. During the audit, Framatome initialed corrective

action to have the PT procedure revised by removing the Androx materials. Since Magnaflux

materials were used on the weld mock-ups and C-22 corrosion plates, as witnessed during

corrosion plate weld test performance, this procedural error does not invalidate any PT

examinations performed under the BSC contract. 
-7-

A review of Framatomeís welding and nondestructive examination personnel qualification

records and weld procedure qualification records revealed no discrepancies.

The observers agreed with the audit teamís findings in this area.

4.4.6 Inspection (and Inspection, Test and Operating Status)

The audit team found that required independent inspections were identified in the shop traveler

package by two methods: the use of a specific procedure placed in the shop traveler package

or specific inspection instructions are identified in the shop traveler. The inspection activities

reviewed were performed by qualified personnel and recorded on an inspection report or on a

specific sequence step of the shop traveler. The audit team found no discrepancies in this area

and concluded that inspections were performed in accordance with Framatome Working

Instruction Nos. 13 and 14.

The audit team found that the inspection, test, and operating status for items were being

properly controlled through the use of shop travelers. The audit team found that the status of

inspection and test activities were identified either on the shop traveler or on a separate

inspection report. No discrepancies were noted with this element.

The observers agreed with the audit teamís findings in this area.

4.4.7 Control of Measuring and Test Equipment

The audit team checked several dimensional inspection tools used during receiving inspections,

and recorded their serial numbers. Next, the audit team traced the corresponding serial

numbers to the calibration records. 

The audit team found that calibration stickers were recorded for a welding station positioning

device, power supply, and thermometer. The audit team reviewed the calibration records for

these items. The audit team identified a discrepancy with the due date for calibration of the

weld positioning head calibration sticker and corresponding calibration record. During the audit,

Framatome initiated a nonconformance report to document this discrepancy and to correct the

calibration sticker on the device to agree with the calibration record. 

During the audit, Framatome informed the audit team that it was in process of establishing a

new system for recording calibrated equipment usage to make it easier to track should the

equipment be identified as being out of calibration. The audit team identified no other

discrepancies in this area.

The observers agreed with the audit teamís findings in this area.

4.4.9 Handling, Storage, and Shipping

The audit team reviewed and examined four restrained weld mock-up assemblies prepared for

shipment. The audit team found that packaging was completed in accordance with applicable

instructions noted in the shop traveler and approved shipping authorization. The audit team

identified no discrepancies in this area. 

The observers agreed with the audit teamís findings in this area.

4.4.10 Control of Nonconforming Items
-8-

The audit team found that accepted materials and completed products, such as the completed

C-22 welded samples, requiring adherence to quality requirements, were stored in an area

clearly identified as a ìsafety requiredî control zone. During the audit, the audit team and

observers found a rejected piece of C-22 corrosion plate placed in this control zone. The audit

team followed up on this item and found that Framatome had issued a nonconformance report

to document rejected C-22 welded sample plates because the radiographic examination of the

plates revealed unacceptable indications in the sampleís weld. The audit team found that a

subsequent Nondestructive Examination Level III evaluation report identified eight assemblies

evaluated for linear inclusions. The original Nonconformance Report (NCR) No. 6008476

identified only two C-22 welded sample plate assemblies (C-9 and D-18) rejected for linear

inclusions. Framatome informed the audit team that subsequent radiographic film evaluation

and metallographic analysis determined that the identified indications, previously identified as

inclusions, were actually porosity. Framatome indicated that its personnel were initiating

another revision to the NCR for a complete and total listing of plate assembly identifications. 

Framatome explained that its Working Instruction No. 9, Revision 6, requires items to be

tagged when practical. The audit team and observers found that the form used to document

the nonconforming condition appears to give an option for tagging. Framatomeís practice is not

to use tags and to indicate in the tag use box on the NCR form, that no tag was used by

checking the ënoí tag used box on the NCR form. The audit team expressed a concern about

Framatomeís practice of not tagging nonconforming items. 

In another situation, a two inch piece of welded plate from the weld defect analysis was moved

from the controlled zone to a non-safety unidentified stack of material that was verbally

identified as ëscrapí without the completion of a nonconformance or other controlling paperwork. 

Again, the audit team expressed a concern to Framatome because the rejected piece of C-22

material had no identification on it to indicated to indicate that it was rejected. As previously

discussed in this report, the audit team recommended that Framatome review its current

practice regarding when nonconforming items need to be identified as nonconforming by

tagging the item and that Framatome tag all nonconforming items, when practical.

The observers agreed with the audit teamís findings in this area.

4.4.11 Corrective Action

Framatome Procedure No. AP-1703-01 provides requirements for controlling corrective action.

No Corrective Action Requests, identifying significant conditions adverse to quality, have been

initiated for the BSC contract and therefore this element was judged to be not applicable by the

auditors. 

The observers agreed with the audit teamís findings in this area.

4.4.13 Records

The audit team reviewed several types of records during the audit including, but not limited to,

those for: personnel training and qualification; procedure qualifications; audits; QAP and

procedure change control; inspection; nondestructive examination; welding; and shop

fabrication. The audit team identified no discrepancies were in this area.

The observers agreed with the audit teamís findings in this area.

4.4.14 Audits
-9-

The audit team reviewed several audit reports including suppliers supporting the work that

Framatome performed for BSC. The audit team identified no discrepancies in this area. 

The observers agreed with the audit teamís findings in this area.

4.4.5 Technical Review

During the audit, the observers discussed the welded C-22 sample plates with the BSC Waste

Package Project Manager. Table 1, ìWelded C-22 Samples,î of this report provides a

summary of the information obtained from these discussions and the observersí review of

Framatome technical documents. 

Sample Type Welding

Process

Used

Plate Length,

Width,

Thickness

Root

Pass

Depth

Weld Joint

Type

Nondestructive

Examination for

Sample Weld

Corrosion

Test

Samples

NarrowGroove

 GTAW 

37.9"x4"x1.5" 0.050"

each

Double-U

Groove

PT on backside

of root pass

Remainder 10%

RT & PT

Strain Test

Samples

Optimized

 GTAW

12"x4"x0.75" 0.047" Single-U

Groove

PT

UT

Strain Test

Samples

Narrowgroove

 GTAW

12"x4"x0.75" 0.090" Single-U

Groove

PT

UT

Strain Test

Samples

PAW 12"x4"x0.75" 0.4375" Single-U 

Groove

PT

UT

 TABLE 1- WELDED C-22 SAMPLES

Table 1 Acronyms: Liquid Penetrant Examination (PT); Radiographic Examination (RT);

Ultrasonic Examination (UT); Gas Tungsten Arc Welding (GTAW); Plasma Arc Welding (PAW)

Notes for Table 1:

1. All welded samples were fabricated using C-22 base metal material and welded using

ER-Ni-Cr-Mo-Sn weld filler material.

2. All base metal weld preparations were machined and subjected to a visual inspection

and cleaned using acetone.

3. Plate dimensions (length, width, and thickness) are for one plate. Two plates were

welded together for final product.

4. A visual inspection was performed on the completed weldment prior to nondestructive

examination to ensure the surface was acceptable for the examination.

5. Strain test samples were welded in a box that provided restraint in all 6 degrees of

freedom. Bolts were torqued to specified initial value, securing and restraining the

plates, prior to welding.
-10-

6. Strain test samples were sent to a supplier for determination of residual stresses. 

However, the torqued bolts were not locked into a permanent position by any means

such as locking tabs or lockwire. Therefore, there was no guarantee that the bolts

would not loosen during transportation process.

7. Requirements for the corrosion test samples were an even heat effected zone and a

straight plate. The test process was not specified.

8. Approximately 15 to 20 weld passes, on each side of the plates, were used to produce 

the corrosion test samples.

9. Materials Testing, Inc. will cut and prepare specimens from the welded samples. The

samples will be forwarded to Lawrence Livermore National Laboratory for the

coordination of specimen testing at other facilities. 

10. PAW is accomplished in 2 passes.

11. The plate thickness for the strain test samples was determined by thickness capable of

being produced by PAW process. The plates used for this test were machined down

from an original of thickness of 1.5 inches.

5.0 NRC STAFF FINDINGS

The observers determined that Audit No. BSC-SA-01-21 was effective in determining the level

of compliance of Framatomeís activities associated with the manufacturing of welded C-22

samples. The observers agreed with the audit teamís conclusion that the QARD and QAP had

been satisfactorily implemented except for the identified potential deficiencies. 

5.1 NRC Audit Exit Summary

During the audit exit, the observers expressed appreciation for the excellent cooperation and

responsiveness provided to them during their observation activities. In addition, the observers

stated that they agreed with the audit team findings and recommendations, as presented at the

audit exit. Also, during the audit exit, the observers stated that they will continue to interface

with DOE and BSC and follow the progress that Framatome is making to address the issues

identified during this audit. 

5.2 NRC Audit Observer Inquiries

There were no Audit Observer Inquires (AOIs) written during this audit.

5.3 Open NRC AOIs from Previous NRC Observations

The following AOIs remain open from previous NRC audits:

a) AOI No. M&O-APR-01-02-4, dated February 9, 2001, was written to identify an observer

inquiry for ANL-NBS-HS-00032. The AOI states: ìThe work upon which this model is

based (Flint, et al., 1996, ìConceptual and Numerical Model of Infiltration at Yucca

Mountainî) is unqualified. (See OCRWM QA Audit Report M&O APR-00-04)(p. 9). Was

information used to support the conclusions made in the Infiltration AMR? If yes,

describe how the Flint, et al. (1996) data were qualified and assumptions verified. NRC

requests additional information and details. (Refer to U.S. NRCís Observation Audit

Report No. OAR-00-04).î 
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b) AOI No. M&O-APR-01-01-01, February 2001, was written to identify an observer inquiry

for ANL-EBS-MD-000033. Several agreements made at the NRC/DOE Technical

Exchange (January 9-12, 2001, Pleasanton, CA) on Evolution of the near Field

Environment (EMFE) indicate that new data and analysis will be presented in the ìEBS:

Physical and Chemical Environment Model AMR (ANL-EBS-MD-000033),î expected to

be available in FY 02. The following NRC/DOE agreements point specifically to the FY

02 revision of this AMR: ENFE 2.04; ENFE 2.06; ENFE 2.08; ENFE 2.11; ENFE 2.13,

and ENFE 2.18. ENFE 2.05 and ENFE 2.17 also point to this AMR, although they state

the information can be provided in other documents as appropriate. During the M&OARP-01 audit of ANL-EBS-MD-000033, Rev. 01, in Las Vegas, NV (February 20-23,

2001), however, audit team members questioned the usefulness of producing additional

revisions of this AMR. If data and analyses required to fulfill NRC/DOE agreements

listed above are not presented in a FY 02 revision of the ANL-EBS-MD-000033 AMR,

where will this information be presented?î (Refer to U.S. NRCís Observation Audit

Report No. QAR-01-03).