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NRC Inspection Le Creusot 2009
From an NRC Report, October 6 – 8, 2009, by Kerri Kavanagh

In the US, nuclear reactors having potentially defective Le Creusot-Areva parts include (but are not necessarily limited to): Nuclear Reactor Pressure Vessels at Prairie Island 1 and 2; Replacement Reactor Pressure Vessel Closure Heads (replacement lids) at North Anna, Surry, Three Mile Island, Crystal River 3, Arkansas One, Turkey Point, Salem, St Lucie, DC Cook); (Replacement) Steam Generators at Prairie Island 1, Callaway, Arkansas One, Salem, St Lucie, Three Mile Island and (Replacement) Pressurizers at St Lucie, Millstone (See Greenpeace France, Briefing http://grnpc.org/IgNdG and “AREVA – Société Générale / Investor day Burgundy – April 9, 2009“)

Kerri Kavanagh, on behalf of the US NRC, belatedly issued a statement on June 20th entitled: “Quality Assurance Issues in France: Implications for U.S. Plants?” Kerri Kavanagh pretends to not know what parts or types of parts are involved, nor their ages. And yet, the NRC’s own documentation states:
The designer/manufacturer of the reactor vessels for Prairie Island is Creusot-Loire (formerly called SFAC)… The replacement reactor vessel closure heads and CRDM pressure housings were manufactured by Mitsubishi Heavy Industries Ltd (MHI) in Futami, Japan under their ASME Section III code program.http://pbadupws.nrc.gov/docs/ML0712/ML071290663.pdf Thus, at least for this example Kerri should know the age, and the catastrophic consequences of a ruptured nuclear reactor pressure vessel. It also appears that the initial reactor vessel closure heads, almost surely Creusot made, had to be replaced.

Prairie Island Nuclear Power Station was built within a few years of the Swiss Beznau Nuclear Power Station, which also has Le Creusot (at the time called Schneider Forge) reactor pressure vessels. And, in fact, Beznau 1 has been offline for almost a year due to almost 1000 defects in its reactor pressure vessel. Last weekend 6,000 people walked in mud, in the rain, demanding the prompt closure of Beznau nuclear power station. The Swiss regulator claims that the reactor pressure vessel for Beznau 2 is ok. Prairie Island is located on the extreme upper Mississippi River, and Beznau on the Aare River shortly before it feeds into the upper Rhine. Both of these rivers are essential economically and environmentally.

The US NRC had concerns over Areva testing and documentation at least as early as 2009, and the French Nuclear Safety Authority (ASN) was aware of these concerns. In fact, Kerri Kavanagh, who responded Monday for the NRC, did a presentation almost 7 years ago saying: “July 2009 – French Regulator Autorité de Sûrete Nucléaire (ASN) observed NRC inspection at Creusot Forge, Le Creusot, France… Summary of Findings • 10 CFR Part 21 Program – NOV for failure to meet the requirements for implementing a procedure to evaluate deviations and failures to comply, and for imposing Part 21 in procurement documents • Control of Measuring and Test Equipment – Failure to require the calibration of the temperature measuring thermocouples for the temperature baths for the impact tests to conform to ASME Code, Section III, Subsection NB-2360…” “NRC Report October 6 – 8, 2009, Kerri Kavanagh, Sr. Reactor Engineer Office of New Reactorshttps://web.archive.org/web/20160617220431/http://www.nrc.gov/docs/ML0928/ML092800118.pdf
(Greenpeace says that the French Safety Authority raised concerns to Areva as early as 2006.)

This is very similar to what the French Regulator ASN (June 17, 20 2016) just said: “These extremely varied irregularities comprise inconsistencies, modifications or omissions in the production files, concerning manufacturing parameters or test results. Some information concerning forging, heat treatment, mechanical testing or chemical analyses were thus not sent to the Creusot Forge customer or to ASN. Nineteen of these irregularities concern compliance with the customer’s specifications and the manufacturing rules for nuclear pressure equipment1.https://web.archive.org/web/20160622025033/http://www.french-nuclear-safety.fr/Information/News-releases/Irregularities-detected-in-Areva-s-Creusot-Forge-plant

From Kerri’s presentation:
NRC Vendor Inspection Le Creusot summary of findings
US NRC visit to Le Creusot shadowed by ASN
NRC report Kavanaugh 2009

ASN further states that “With regard to the components intended for other countries, Areva has informed the customers concerned./ Investigations are continuing and could well bring further irregularities to light. ASN is ensuring that the review process will be seen through to completion, more specifically through inspections, in order to assess all the anomalies which may have affected past manufacturing operations and draw any relevant conclusions regarding the safety of the facilities.” See entire news release here: https://web.archive.org/web/20160622025033/http://www.french-nuclear-safety.fr/Information/News-releases/Irregularities-detected-in-Areva-s-Creusot-Forge-plant (It is the same in English as in French which isn’t always the case).

Kerri Kavanagh says that Areva “pledged to provide us with a list of U.S. plants affected by these paperwork irregularities when the investigation is completed around the end of July. We’ll continue to engage with ASN and AREVA to make sure we have a complete picture of how these irregularities may affect any components provided to U.S. nuclear power plants“. [If Kerri is willing to believe Areva then Kerri can also buy some land in Bayou Corne (Louisiana Sinkhole) or in Fukushima, for that matter.]

Why is the US NRC depending on French State owned Areva? The liability falls on Areva, even though some of these parts were made prior to state takeover. The UK appears to get different responses depending on whether Areva answers them or EDF (the utility, also French state owned) or the regulator ASN (apparently also a French state entity). For that matter, why is the British regulator depending on the French state-owned vendor (AREVA), the French regulator, ASN, and the French state owned utility EDF rather than doing their jobs and regulating?

According to the British regulator:
In May: “Areva has confirmed that the reactor components supplied to Sizewell B by its Le Creusot forge facility are not implicated as a result of its recent review of historical records…
Updated 3 June 2016
ONR has been advised by the French nuclear regulator, Autorite de Surete Nucleaire (ASN), and EDF, of possible inconsistencies, modifications or omissions in the quality documentation associated with forged components manufactured by Areva at Le Creusot Forge in France. ONR is engaged with ASN and EDF concerning the reports of anomalies and inconsistencies in quality documentation.
http://news.onr.org.uk/2016/05/irregularities-in-documention-of-areva-made-components/ [Currently French state-owned EDF is owner-operator of Sizewell Nuclear Power Station.]

At least 400 of the 10,000 quality documents (technical compliance slips) reviewed by Areva – concerning around 4% of all manufactured parts – contained defects. Problems concern the concentration levels of carbon and other elements contained in metallic parts, which determine the mechanical strength of machined components. These levels were incorrectly reported or not reported at all. Figures which did not comply with regulatory safety requirements may have been masked using this process.

If non-nuclear equipment such as turbine rotors are affected, over half of the 400 identified components are parts used in heavy equipment that is essential to operating reactors: components in vessels, which contain nuclear fuel, in lids, in pressurisers, which maintain pressure in the primary system, and in shells and heads in steam generators, which evacuate heat to a secondary circuit, among others.

This equipment must be extremely robust and operate to the highest mechanical standard to ensure total safety.” ( Greenpeace France, Read the entire Briefing here: http://grnpc.org/IgNdG )

NRC statement, with our comments in brackets:
Quality Assurance Issues in France: Implications for U.S. Plants?
3 Comments Posted by Moderator on June 20, 2016
Kerri Kavanagh
 Chief, Quality Assurance and Vending Inspection Branch

The NRC doesn’t just oversee how nuclear power plants operate. We also oversee the quality of the important components that go into the reactors. [They can’t just look but need to act on findings in a serious way.] “That’s why NRC staffers are working with the French Nuclear Safety Authority and AREVA, a manufacturer of reactor components, to determine if a quality assurance investigation underway in France has implications for U.S. plants. [As we’ve already seen, Kerri knows that this is almost certainly the case, and really all Le Creusot parts are potentially at risk.]

ASN – the acronym for the French regulator — requested the probe in early May after a flaw was discovered in the vessel of a reactor under construction at Flamanville in France. So AREVA checked the manufacturing records of the Le Creusot Forge, in central France. They found anomalies in the records of about 400 parts manufactured there since the plant opened in 1965. (Le Creusot Forge was purchased by AREVA in 2006.)” [Why is Areva doing the checking? Who could trust them? They are in serious financial trouble and are liable for any defective parts found.]

ASN says these are paperwork irregularities – inconsistencies, modifications or omissions in production files concerning manufacturing parameters or test results. The irregularities are troubling because complete documentation provides assurance the components were forged to the proper procedures and specifications.” [Even complete documentation provides no guarantees as it could be faked. However, these paperwork irregularities, changes and omissions in testing results and manufacturing parameters suggest either sloppiness which could lead to errors or intentional deceit. Why would there be modifications of test results other than because they didn’t like the true results?]

They do not mean, however, that any parts or components manufactured at Le Creusot are defective” [The opposite is also true. And, the fact that modifcations or omissions are found in test results points to almost certain defects.]

AREVA announced at the end of May that it had completed two-thirds of its review and found no indications of safety issues“. [Of course they won’t find safety issue! They would have to pay for them, whereas the nuclear liability laws mean they don’t pay much, if anything, in the event of an accident. The economic stakes are high for Areva-Le Creusot.] “The company told the NRC about 10,000 documents are still under review. The company pledged to provide us with a list of U.S. plants affected by these paperwork irregularities when the investigation is completed around the end of July.” [How about getting a copy of all 10,000 documents? Why does the ASN appear more interested in regulating French State owned Areva than the US NRC does? Does Areva have something on the NRC?] “We’ll continue to engage with ASN and AREVA to make sure we have a complete picture of how these irregularities may affect any components provided to U.S. nuclear power plants.

NRC’s regulations in 10 CFR Part 21, “Reporting of Defects and Noncompliance,” require any entity that identifies reportable issues to evaluate them and inform the users of any impacted components. The users then have 60 days to do their own safety evaluations. If the users identify significant safety hazards, they must report these to the NRC by phone within two days, and in writing within 30 days.
AREVA and Le Creusot Forge are under contractual obligations to their U.S. customers (who are NRC licensees) to follow these reporting requirements. We’ll take appropriate regulatory and enforcement action if we find issues of safety significance. At this time, there is no indication of a safety issue with any components from Le Creusot covered by this quality assurance audit.
[But, there appears no evidence that there is NOT a safety issue – on the contrary, evidence points to potential safety issues.]

Regarding new reactors, Westinghouse Electrical Co., the architectural engineering firm for the AP1000 reactors under construction at Vogtle and V.C. Summer, has confirmed that no components at these plants were supplied by Le Creusot Forge.

Once AREVA completes its audit and we have a complete picture of the situation, the NRC has several options. We may issue a generic communication to keep the broader nuclear industry informed. We may also perform inspections to ensure conformance and compliance with our regulations.” [They need to perform inspections, but chances are they will issue a “generic communication”, knowing them as we now do.]

More information will be coming on this issue. If the NRC determines that Le Creusot Forge has provided components to U.S. nuclear power plants, we’ll make sure those components are fully evaluated to determine any impact the documentation irregularities might have on their safety-related functions.” [THEY KNOW THAT LE CREUSOT FORGE PROVIDED COMPONENTS SO WHY AREN’T THEY EVALUATING THEM!]
Comment 1:
steamshovel2002 June 21, 2016 at 10:24 am Is the NRC record keeping so poor they can’t tell if any components came from the Le Creusot Forge? This is nothing but industry protection. If the NRC has faith in their paperwork, they would immediately release a list of components. 
Why are the French and the Belgium getting so nervous over reactor component paperwork? 
I am the guy who recently ask the NRC to ultrasonically test all vessels. This was exactly the reason why I asked, can you really ever trust the aging paperwork?”
Comment 2:
Donna Gilmore June 20, 2016 at 10:25 am How long have these components been installed in U.S. reactors? If these components were defective or degraded what would the possible safety implications be? Are all the components in question inspectable once they are installed? I understand from NRC technical staff and the nuclear industry that not all nuclear plant critical component are inspectable once installed. This is a current unresolved issue for aging management in reactor license renewals.“

Kerri Kavanagh-NRC Response:
Moderator June 20, 2016 at 4:23 pm
How long have these components been installed in U.S. reactors? Le Creusot Forge and AREVA Inc are still in the process of determining the extent of condition.
” [Kerri didn’t answer the question. Kerri has to know how long the reactor pressure vessels have been at Prairie Island – over 40 years.] “This evaluation will inform them of the components affected, the plants affected, and how long they have been installed. AREVA has informed NRC staff that they are looking at approximately 10,000 documents. The company informed the NRC that they will provide us with a list of components and plants affected when the evaluation is completed (expected to be by end of July).

If these components were defective or degraded what would the possible safety implications be? The safety implications will not be known until the vendor evaluations are completed. [Kerri knows very well the impacts of a ruptured nuclear reactor pressure vessel, and failed steam generators and they aren’t good.] “However, if significant safety hazards are identified as part of the evaluation, Le Creusot Forge and/or AREVA must report these to the NRC within two days. During our ongoing discussions with AREVA, they have informed the NRC that there is currently no indication of safety issues with the components at U.S. plants and that the issues they are evaluating deal mostly with the reconciliation of paperwork from the manufacturing/fabrication of the components.
” [Oh, great, they will try to reconcile omissions and modifications to test results? That will help a lot! Just add reconciliation to modifications and omissions?]
Are all the components in question inspectable once they are installed? I understand from NRC technical staff and the nuclear industry that not all nuclear plant critical component are inspectable once installed. This is a current unresolved issue for aging management in reactor license renewals. The inspectability of components will depend on where they are installed in the plant. However, even if a component is not easily inspectable, tests and/or evaluations can usually be performed on similar/surrogate components to verify whether a component will perform as originally designed and licensed.
Kerri Kavanaghhttps://web.archive.org/web/20160621220544/https://public-blog.nrc-gateway.gov/2016/06/20/quality-assurance-issues-in-france-implications-for-u-s-plants/


From the NRC’s own documentation:
The designer/manufacturer of the reactor vessels for Prairie Island is Creusot-Loire (formerly called SFAC) whose manufacturing facility is located in Southern France near the city of Creusot… Creusot-Loire had met all the latest code requirements for qualification with the one exception being that they were unable to obtain an ASME Code stamp since ASME did not have provisions for issuance of Code Stamps to foreign suppliers. However, their quality assurance program was in strict conformance with ASME Section III requirements./ The replacement reactor vessel closure heads and CRDM pressure housings were manufactured by Mitsubishi Heavy Industries Ltd (MHI) in Futami, Japan under their ASME Section III code program.http://pbadupws.nrc.gov/docs/ML0712/ML071290663.pdf

Le Creusot Response to US NRC in 2009 – almost 7 years ago
ML092800003 NRC visit to Le Creusot p. 1
ML092800003, US NRC at Le Creusot p. 2
document number: ML092800003

AREVA – Société Générale / Investor day Burgundy – April 9, 2009
https://web.archive.org/web/20160617201548/http://www.asn.fr/Informer/Actualites/Irregularites-detectees-dans-l-usine-d-Areva-de-Creusot-Forge-l-ASN-fait-un-point-d-etape

One of the best articles written on Creusot Forge. It’s in German but you can put it in google translate if you don’t read German.
Zermürbter Juwel
Auch die Franzosen haben ihren Fall AEG: Die Traditionsfirma Creusot-Loire kämpft ums Überleben.
http://www.spiegel.de/spiegel/print/d-13507981.html

Creusot Forge has had viability issues since the 1960s, perhaps due to the end of the Algerian War. Under Schneider ownership it had long been part of France’s military industrial complex. Later it was part of the French nuclear industry. Even a small country would require more tanks than nuclear reactors. The period when it was owned by the Empain family-Baron Empain, of Belgium, is discussed a bit here: https://en.wikipedia.org/wiki/Schneider-Empain

NUPIC General Membership Meeting, Chattanooga, TN
NRC Report October 6 – 8, 2009, Kerri Kavanagh, Sr. Reactor Engineer Office of New Reactors
https://web.archive.org/web/20160617220431/http://www.nrc.gov/docs/ML0928/ML092800118.pdf

Greenpeace France Briefing:
http://grnpc.org/IgNdG
http://www.greenpeace.org/france/PageFiles/266171/Briefing_Greenpeace%20France_Anomalies%20and%20suspected%20falsifications%20at%20Areva’s%20site.pdf?utm_source=internal&utm_medium=post&utm_term=possible%20falsifications,Areva,Greenpeace%20France,brief&utm_campaign=Climate&__surl__=IgNdG&__ots__=1466197900782&__step__=1
http://www.greenpeace.org/international/en/press/releases/2016/Anomalies-suspected-falsifications-Areva/

EMPHASIS ADDED THROUGHOUT THIS BLOG POST