IR 05000263/2023010
| ML23242A192 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 09/07/2023 |
| From: | Jamie Benjamin NRC/RGN-III/DORS/EB1 |
| To: | Hafen S Northern States Power Company, Minnesota |
| References | |
| IR 2023010 | |
| Download: ML23242A192 (1) | |
Text
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT - COMMERCIAL GRADE DEDICATION INSPECTION REPORT 05000263/2023010
Dear Shawn Hafen:
On August 4, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Monticello Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Four findings of very low safety significance (Green) are documented in this report. Four of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Monticello Nuclear Generating Plant.
September 7, 2023 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jamie C. Benjamin, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000263 License No. DPR-22
Enclosure:
As stated
Inspection Report
Docket Number:
05000263
License Number:
Report Number:
Enterprise Identifier:
I-2023-010-0045
Licensee:
Northern States Power Company, Minnesota
Facility:
Monticello Nuclear Generating Plant
Location:
Monticello, MN
Inspection Dates:
July 10, 2023 to August 04, 2023
Inspectors:
K. Barclay, Senior Reactor Inspector
I. Hafeez, Senior Reactor Inspector
A. Shaikh, Senior Reactor Inspector
Approved By:
Jamie C. Benjamin, Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Commercial Grade Dedication Inspection at Monticello Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Perform Critical Characteristics Testing during Commercial Grade Dedication of Battery Charger Lamp Sockets Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000263/2023010-01 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50,
Appendix B, Criteria III, "Design Control," for the licensee's failure to perform critical characteristics testing during commercial grade dedication of battery charger lamp sockets. Specifically, the licensee failed to perform the appropriate testing during commercial grade dedication of the safety related 250Vdc battery charger lamp sockets to demonstrate that the procured lamp sockets had adequate dielectric strength to meet its intended safety function.
Failure to Provide Commercial Grade Surveys for Procured Gaskets Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000263/2023010-02 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50,
Appendix B, Criteria VII, "Control of Purchased Material, Equipment, and Services," for the licensees failure to provide objective evidence of quality during the commercial grade dedication of procured gaskets to be used in safety-related components. Specifically, the licensee failed to provide commercial grade dedication surveys demonstrating that the Flexitallic gaskets procured from a vendor were manufactured to meet the critical characteristics required for the gaskets to maintain their safety function in installed applications.
Failure to Identify and Correct Condition Adverse to Quality for Commercial Grade Dedicated Parts Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000263/2023010-03 Open/Closed None (NPP)71111.21N.03
The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50,
Appendix B, Criteria XVI, "Corrective Action", for the licensees failure to identify and correct conditions adverse to quality. Specifically, the licensee failed to correct non-conformances associated with procedure FP-NO-SAS-0, "Supplier Qualification and Maintenance of the Supplier Qualified List," Rev. 5 deficiency identified in corrective action document 501000031549 and failed to identify other potential non-conformances associated with the same procedure deficiency.
Inadequate Commercial Grade Dedication of Electrical Connectors Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000263/2023010-04 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50,
Appendix B, Criteria III, "Design Control," for the failure to establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs. Specifically, the licensee failed to list all the safety-related design functions and associated critical characteristics for electrical connectors in one procurement evaluation and prescribed the wrong electrical insulation test in a separate procurement evaluation.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.03 - Commercial Grade Dedication Commercial Grade Dedication (section 03.01)
The inspectors reviewed the implementation of the licensees processes for dedicating commercial-grade items/services as basic components and/or for procuring safety-related structures, systems, and components for the following samples:
- (1) IECSCD-2 CAPACITOR:FXD,35VDC,10MFD,RESIN DPPD
- (2) EACSLA-2 ARRESTER:FLM,1-15/16DIA X 2-1/4LG IN (3)262496-2 DIODE:TRNSVOLT SUPPRSSR,190V,5.5A,1500W
- (4) EMESEC-2 GREASE:13.4OZ TUBE
- (5) EAASJW-2 PIN:CTTR:5/64IN,1/2IN,EXTNDD PRNG
- (6) EMGSFK-2 GASKET:SPRLWND:8IN,R4,304 SS.
- (7) EACSKG-2 Electrical Socket
- (8) EMXSKO-2 RTV108: use QL1 - EMXSKO-1 (9)6541781-2 Connector: Terminal 16 to 14 AWG, RNG TONGU (10)220393-2 GASKET:SPRLWND:R-SPECIAL,304 SS (11)100-2678-2 ADAPTER:CMMNCTN:10-32TPI FEM,BNNA JK,RED.
(12)261395-2 VALVE:CHK:1/2IN,10PSI CRCKNG,COMPRSN.
(13)269041-2 GREASE:1PT CAN,NO-OX-ID A-SPECIAL (14)220661-2 PLUG:TUBE:1/2IN,BRS (15)6554744-2 Connector: CMMNCTN:TERMNL STRIP BNNA JK
INSPECTION RESULTS
Failure to Perform Critical Characteristics Testing during Commercial Grade Dedication of Battery Charger Lamp Sockets Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000263/2023010-01 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criteria III, "Design Control," for the licensee's failure to perform critical characteristics testing during commercial grade dedication of battery charger lamp sockets. Specifically, the licensee failed to perform the appropriate testing during commercial grade dedication of the safety related 250Vdc battery charger lamp sockets to demonstrate that the procured lamp sockets had adequate dielectric strength to meet its intended safety function.
Description:
As part of the commercial grade dedication (CGD) inspection, the inspectors reviewed documents associated with the procurement and CGD of Sylvania Pilot Lamp Sockets for use in the Division I and II safety related 250Vdc battery chargers. Fleet procedure FP-SC-PE-01, Dedication of Commercial Grade Items and Services, states the following: Sub-section 5.6.2 "Critical Characteristics for Acceptance" step 2: The critical characteristics for acceptance SHALL be identifiable and measurable attributes/variables of a commercial grade item which, when verified, provide reasonable assurance that the item received is the item specified, and will perform its intended safety function. CGD procurement document CGD-2017-002 and associated document MRE 314, Rev.0, Sylvania Pilot Lamp Socket,Section III.C, identified the safety function of the pilot lamp socket. Specifically,Section III. Appendix A.C of MRE 314, states, The only safety function of this pilot lamp socket is to provide an isolated electrical path. Since this socket assembly is not isolated (protected by fuses) from the internal 1E circuit of the battery charger, it then becomes an integral part of the circuit. The dielectric strength of the socket assembly must be sufficient to not allow short circuits resulting in possible degradation of the 1E circuit.Section III. Appendix A.C, further states, in part, that insulation resistance and dielectric strength can be assumed to be equivalent characteristics.Section III. Appendix B.C, which provides the basis for selection of the critical characteristics for acceptance, states, The critical characteristics selected for acceptance of this pilot lamp socket are insulation resistance, dimensions, and general configuration. The dimensions and general configuration will provide assurance that the socket received is as ordered and will fit the existing mounting hole. The insulation resistance of the socket assembly material shall be verified from terminal to ground to assure it is sufficient to prevent current paths to ground. Insulation resistance and dielectric strength may be assumed to be equivalent in this low power (120VAC, 0.025A) application. Insulation resistance was selected due to the availability of a Megger test set; However, a dielectric voltage withstand test at 1000V plus two times the operating voltage for one minute would provide equivalent assurance that the socket assembly possess the correct insulation properties.
The inspectors determined that the licensee had made an unverified assumption in assuming that dielectric strength testing and insulation resistance testing were equivalent. Specifically, the inspectors noted that insulation resistance testing simply measures the resistance of the insulation material to electrical current for a specified voltage, whereas the dielectric strength test measure the electrical breakdown voltage of insulation materials( measure the reaction of the material) and identifies if the insulator physically degrades with larger than operating voltage applied for some time resulting in a potential short circuit/fire. The inspectors determined that the licensee had failed to provide adequate basis for the electrical equivalency of insulation resistance and dielectric strength in demonstrating that the safety function of the lamp socket would be maintained. In addition, Attachment A of MRE 314 which provides guidance on conducting the insulation resistance test, specifies that 500 Vdc is to be applied across the lamp socket terminals when measuring resistance. However,Section III. Appendix B.C stated that the voltage shall be verified (applied) from terminal to ground. The inspectors noted that the insulation resistance test which was performed by the licensee was with voltage applied across the socket terminals which would measure the electrical insulation resistance medium that is separated by the electrical insulation barrier across the two terminals, whereas terminal to ground test, which was called for in the evaluation would have the voltage applied from terminal to ground of the socket and would have measured how effective the dielectric of the insulation barrier resistance of the socket to ground is in resisting the flow of electrical current to ground. Therefore, the inspectors determined that the licensee incorrectly performed the insulation resistance test. The inspectors also determined that these lamp sockets were more recently issued for installation in September 2022 under work WO 700047450, "Replace Pilot Light/Lens Elec-D53."
Corrective Actions: The licensee noted the applied voltage discrepancy (terminal to terminal vs. terminal to ground) in MRE 314 and issued corrective action document stating that terminal to terminal voltage as stated in Attachment A, is incorrect. The licensee also noted the inspectors concern about the unverified assumption that dielectric strength and insulation resistance are equivalent and issued a corrective action document identifying the need to provide a thorough technical basis for acceptance of insulation resistance in lieu of dielectric strength as a measurable attribute to verify the lamp socket will perform its intended safety function. The licensee initiated immediate actions to quarantine existing lamp sockets dedicated under this CGD-2017-002 and reperform the CGD of these lamp sockets. In addition, the licensee performed a walkdown of the battery chargers and removed the panels to access the pilot light lamp socket. The licensee discovered that the lamp sockets that had been dedicated under CGD-2017-002 and issued for installation in September 2022, under WO 700047450, were not actually installed. In fact, the licensee identified that a different lamp socket that had been procured as safety-related components from an Appendix B qualified vendor was installed. The licensee issued this condition of as-found configuration not matching design and work order information into their corrective action program. The inspectors determined that because no lamp socket dedicated under the deficient CGD-2017-002 had been installed in the 250V battery chargers, there was no operability concern associated with the battery chargers.
Corrective Action References: IRs 501000075187, 501000075306, and 501000075271
Performance Assessment:
Performance Deficiency: Failure to perform critical characteristics testing during commercial grade dedication of battery charger lamp sockets. Specifically, the licensee failed to perform the appropriate testing during commercial grade dedication of the safety related 250Vdc battery charger lamp sockets to demonstrate that the procured lamp sockets had adequate dielectric strength to meet its intended safety function.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform appropriate testing to demonstrate that the required critical characteristic was verified for these battery charger lamp sockets, resulted in potentially adverse effects on the reliability of 250Vdc battery chargers in maintaining the associated Division 1 and 2 safety related batteries fully charged.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered "Yes" to the IMC 0609 Exhibit 2, "Mitigating Systems Screening Questions" discussed in Section A, Does the finding is a deficiency affecting the design or qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality?" Therefore, the finding was screened as having very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criteria III, states in part, that, Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components. The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Procedure FP-SC-PE-01, Dedication of Commercial Grade Items and Services, which states the following: Sub-section 5.6.2 "Critical Characteristics for Acceptance" step 2: The critical characteristics for acceptance SHALL be identifiable and measurable attributes/variables of a commercial grade item which, when verified, provide reasonable assurance that the item received is the item specified, and will perform its intended safety function.Section III. Appendix A.C of MRE 314, Sylvania Pilot Lamp Socket, states, The only safety function of this pilot lamp socket is to provide an isolated electrical path. Since this socket assembly is not isolated (protected by fuses) from the internal 1E circuit of the battery charger, it then becomes an integral part of the circuit. The dielectric strength of the socket assembly must be sufficient to not allow short circuits resulting in possible degradation of the 1E circuit.
Contrary to the above, in 1992, the licensee failed to verify or check the adequacy of the design.. Specifically, the licensee failed to test for dielectric strength of procured lamp sockets that were later issued for installation in a safety related D53 battery charger to verify the safety function will be performed, and without adequate basis, chose to test for insulation resistance that was subsequently incorrectly performed resulting in a potential false reading of the lamp socket resistance.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Provide Commercial Grade Surveys for Procured Gaskets Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000263/2023010-02 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criteria VII, "Control of Purchased Material, Equipment, and Services," for the licensees failure to provide objective evidence of quality during the commercial grade dedication of procured gaskets to be used in safety-related components. Specifically, the licensee failed to provide commercial grade dedication surveys demonstrating that the Flexitallic gaskets procured from a vendor were manufactured to meet the critical characteristics required for the gaskets to maintain their safety function in installed applications.
Description:
As part of the commercial grade dedication (CGD) inspection, the inspectors reviewed documents associated with the procurement and CGD of Flexitallic gaskets for use in the safety-related components such as closed loop piping systems and valves. Fleet procedure FP-SC-PE-01, Dedication of Commercial Grade Items and Services, states the following:
Sub-section 5.6.3 "Critical Characteristic Acceptance Method " step 2: COMMERCIAL GRADE SURVEY OF SUPPLIER (METHOD 2) is used to accept commercial grade items based on the merits of a suppliers commercial quality controls. These controls may include quality programs, procedures, or practices. Commercial grade surveys should be coordinated through and performed by Supplier Assessment. Commercial grade dedication document MRE 251, Flexitallic Gaskets, Section 2B, Quality Assurance Requirements, states, The supplier shall process this order in accordance with Flexitallics Quality Assurance Program as surveyed and accepted by the commercial survey CS 93-11 performed 09/93.
Commercial grade surveys include the critical characteristics attributed to the part being procured to ensure that the fabrication method used by the supplier verifies the critical characteristics attributed to the part so that the part can perform its intended design and safety function. The design function of the Flexitallic gasket is described in the commercial grade dedication document MRE 251, Flexitallic Gaskets, which states, that these gaskets are Used between machined parts or around pipe joints to prevent the escape of fluid. The safety function of the Flexitallic gasket is also described in MRE 251, which states that While the failure of any specific gasket has not been shown to be able to affect the safety related function of its parent component, the conservative approach is to verify the gasket material and dimensions to provide us with the assurance that these items will perform their intended design function. The inspectors requested copies of the commercial grade survey referenced in MRE 251 for the procurement and acceptance of the Flexitallic gaskets. However, the licensee could not locate these surveys and entered the issue into their corrective action program as lost records.
The inspectors determined that the licensee failed to provide objective evidence of quality in the procurement of Flexitallic gaskets due commercial grade survey CS 93-1 that the licensee could not locate. The inspectors also determined that these MRE 251 procured Flexitallic gaskets have been installed in the plant since 1994 and were most recently installed as part of WO 700077103, Replace RHRSW-17 in April 2021 and WO 700057702, "Installation of RPV Head Piping" in May 2021.
Corrective Actions: The licensee documented the inspectors concern in their corrective action program and provided reasonable assurance of operability of the installed Flexitallic gaskets based on operating history. The licensee also initiated actions to perform an extent of condition concerning other gaskets procured referencing the lost survey CS 93-1.
Corrective Action References: IR 501000074729 and 501000075066
Performance Assessment:
Performance Deficiency: Failure to provide evidence of quality for the commercial grade dedication of procured Flexitallic gaskets. Specifically, the licensee failed to provide the commercial grade surveys evaluated for the commercial grade dedication of Flexitallic gaskets procured for use in safety related components, and therefore, failed to demonstrate that the procured gaskets were manufactured to meet the identified critical characteristics required to perform the intended safety function.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, gaskets procured under these missing surveys were installed in the plant in safety related components and could have potentially failed to prevent the escape of fluid from the safety related components, resulting in potential adverse effects on equipment performance that challenges plant stability.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered "No to the question, Did the degraded condition increase the likelihood of a complete loss of a support system that would result in a plant trip? Therefore, the finding was screened as having very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criteria VII, states in part, that, Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery.
Fleet procedure FP-SC-PE-01, Dedication of Commercial Grade Items and Services, states the following: Sub-section 5.6.3 "Critical Characteristic Acceptance Method " step 2:
COMMERCIAL GRADE SURVEY OF SUPPLIER (METHOD 2) is used to accept commercial grade items based on the merits of a suppliers commercial quality controls. Commercial grade dedication document MRE 251, Flexitallic Gaskets, Section 2B, Quality Assurance Requirements, states, The supplier shall process this order in accordance with Flexitallics Quality Assurance Program as surveyed and accepted by the commercial survey CS 93-11 performed on 09/1993.
Contrary to the above, since 1994, the licensee failed to assure that purchased material, conformed to the procurement documents. Specifically, the licensee failed to provide objective evidence of quality for commercial grade dedicated Flexitallic gaskets procured from the contractor because commercial survey CS 93-11 could not be located by the licensee.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Identify and Correct Condition Adverse to Quality for Commercial Grade Dedicated Parts Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000263/2023010-03 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criteria XVI, "Corrective Action," for the licensees failure to identify and correct conditions adverse to quality. Specifically, the licensee failed to correct non-conformances associated with procedure FP-NO-SAS-0, "Supplier Qualification and Maintenance of the Supplier Qualified List," Rev. 5 deficiency identified in corrective action document 501000031549 and failed to identify other potential non-conformances associated with the same procedure deficiency.
Description:
As part of the commercial grade dedication (CGD) inspection, the inspectors requested documentation pertaining to procurement and dedication evaluations for a number of selected components/parts. In response to the inspectors' request for information on the selected components, the licensee identified documentation deficiencies for five of the selected components and documented these deficiencies in its corrective action program (CAP) as document CAP 501000074763. In CAP 501000074763, the licensee stated that "EPRI NP-5652 revision 0, which is a QATR commitment for Commercial Grade Dedication, require purchase orders to invoke the QA Program evaluated during a Commercial Grade Survey, when Commercial Grade Surveys are used as the dedication method. In 2019 a gap was identified with our current PO practices and QIM 501000031549 was initiated which added new requirements to POs to correct this gap. A condition evaluation completed on 10/21/2019 revised FP-NO-SAS-01, "Supplier Qualification and Maintenance of the Supplier Qualified List," to require that Conditions of Approval be added to the QSL regarding Commercial Grade Surveys and a subsequent procedure change was implemented. This CAP is intended to document that five of the NRC selected samples for the NRC CGD Inspection pre-dated these corrective actions in 2019 and did not make reference to the Commercial Grade Survey, instead making a generic statement about implementing a quality management program. The specific NRC Selected Sample Purchase Orders for the Monticello inspection that are not in compliance with the QATR requirement are: Item #2:
PO PL1769CQ dated 1/30/1997 for Gaskets from Flexitallic Item #8: PO 00056175 dated 2/17/2015 for Tube Plug from Swagelok Item #11: PO P502536 dated 12/15/2004 for Cotter Pin from Fastenal Item #13: PO PF5798CQ dated 1/24/1994 for Gaskets from Flexitallic Item #15: PO 4000004168 dated 3/06/2018 for RTV from Momentive & Fastenal."
The inspectors questioned the licensees' corrective actions implemented upon discovery of the procedure deficiency in 2019. Specifically, the inspectors requested the licensee to provide evidence that the conditions adverse to quality identified in their CAP in 2019 were corrected and that potential additional non-conformances associated with procedure FP-NO-SAS-01 deficiency were also identified, particularly for POs predating 2019 identification. The licensee evaluated the inspectors' questions and determined that appropriate corrective actions had not been implemented in 2019 upon discovery of non-conformances. Specifically, the licensee determined that the conditions adverse to quality for having non-conforming parts installed in the plant was not corrected and the licensee failed to identify other potential non-conforming POs, and therefore, failed to correct those non-conforming commercial grade dedicated components. The licensee documented these concerns and into CAP 501000075538. The inspectors determined that the licensee failed to identify and correct conditions adverse to quality in accordance with its corrective action program.
Corrective Actions: The licensee entered the inspectors' concerns into its corrective action program and initiated actions to correct the non-conformance identified in 2019 for the affected POs and perform extent of condition to identify all additional POs predating 2019 that could have been affected due to the procedure deficiency.
Corrective Action References: 501000031549, 501000074763, 50100075417, and 501000075538
Performance Assessment:
Performance Deficiency: Failure to correct non-conformances associated with procedure FP-NO-SAS-0 deficiency identified in corrective action document 501000031549 and failure to identify other potential non-conformances associated with this procedure deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to correct non-conformances identified in corrective action document 501000031549 in 2019 and failure to identify additional potential non-conformances associated with POs predating 2019, could have resulted in components installed in the plant that are potentially non-conforming to the requirements in EPRI NP-5652 revision 0, which is a QATR commitment for commercial grade dedication implemented at the plant.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered "No to the question, Did the degraded condition increase the likelihood of a complete loss of a support system that would result in a plant trip? Therefore, the finding was screened as having very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Appendix B, Criteria XVI, states, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.
Contrary to the above, on October 16, 2019, the licensee failed to identify and correct a condition adverse to quality. Specifically, the licensee failed to correct non-conforming parts identified in the deficient POs associated with the procedure deficiency described in corrective action document 501000031549 and failed to identify other potential non-conforming parts for other POs associated with this same procedure deficiency resulting in additional potential non-conforming parts installed in the plant.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Commercial Grade Dedication of Electrical Connectors Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000263/2023010-04 Open/Closed None (NPP)71111.21N.03 The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criteria III, "Design Control," for the failure to establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs. Specifically, the licensee failed to list all the safety-related design functions and associated critical characteristics for electrical connectors in one procurement evaluation and prescribed the wrong electrical insulation test in a separate procurement evaluation.
Description:
The inspectors reviewed engineering equivalency evaluations, commercial grade dedication plans and purchase orders associated with electrical connector sockets, which the licensee had procured and installed to support safer and more efficient testing and maintenance on systems such as reactor protection. The permanently installed sockets allowed the licensee to connect test equipment more reliably than other test connection methods and, in some cases, reduced the need to lift leads during testing. During their review, the inspectors identified that one of the dedication plans did not contain all the necessary critical characteristics to validate the commercial grade sockets could perform their safety-related design functions.
Material requirement evaluation (MRE) 819, Pomona 5699, 5700, 5701 Series Jacks, Revision 0, which evaluated electrical connector sockets to replace screws on terminal strips, did not list all the safety-related design functions nor the critical characteristics for the missing design functions. The evaluation only listed a single design function of limiting leakage currents to acceptably low values. The inspectors determined that mechanically connecting wires and conductors with low electrical resistance was a significant missing design function because the connectors replaced terminal strip screws and therefore had to maintain the electrical conductivity of safety-related circuits. The licensee agreed that MRE 819 was not adequate and entered the issue into their corrective action program.
The licensee, while answering an NRC question about insulation resistance testing, identified that an incorrect insulation test method was prescribed in CGD 2014-007, Pomona Terminal Strip Banana Jack, which was a newer CGD evaluation of the electrical connector sockets.
The test method used incorrect test points, which effectively measured the insulation resistance of the testing terminal board instead of the electrical connector socket. The licensee also entered this issue into their corrective action program.
The licensees review of the non-conforming electrical connectors concluded that a reasonable assurance of operability remained. They based their conclusions, in part, on licensee work instructions and work orders that install the electrical connectors to a mechanically tight state; successful insulation tests associated with MRE 819; corrective action program reviews that did not identify any historical performance issues and a previous modification example that checked continuity during the installation of similar electrical connectors. The inspectors did not identify any performance deficiencies associated with the licensees basis for continued operability.
Corrective Actions: The licensee's planned corrective actions included performing an evaluation to further understand the issue and create appropriate corrective actions as necessary; performing an extent of condition to determine where the parts are installed in the plant; evaluating the acceptability of the installed parts and quarantining the current inventory.
Corrective Action References:
501000075457 - CGD Critical Characteristic / Banana Jack 501000075506 - Banana Jacks Inadequate Testing
Performance Assessment:
Performance Deficiency: The licensee failed to establish measures for the selection and review of suitability for the application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Two examples were identified where the licensee failed to establish measures for the selection and review of suitability for electrical connector jacks. The first example was found in MRE 819, Pomona 5699, 5700, 5701 Series Jacks, Revision 0, where the licensee failed to list all the safety-related design functions and associated critical characteristics for the electrical connectors. The second example was found in CGD 2014-007, Pomona Terminal Strip Banana Jack, Revisions 0 and 1, where the licensee failed to prescribe the correct test method for a critical characteristic associated with a safety-related design function.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee installed commercial parts in safety-related applications without validating all critical characteristics necessary to dedicate those parts as basic components. The inspectors found this situation similar to example 5.c of IMC 0612 appendix E, "Examples of Minor Issues."
Additionally, the licensee used a different approach to support reasonable assurance of operability. Instead of relying on the commercial grade dedication process, the licensee had to use qualitive evidence such as a lack of historical performance issues documented in the corrective action program for the make and model of the electrical connector; installation instructions that require the jacks to be installed to mechanically tight and a work order example that checked continuity after the installation of electrical connectors. The inspectors found this similar to example 3.e of IMC 0612 appendix E.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as having very low safety significance (Green) because the inspectors answered Yes to the first risk screening question listed in IMC 0609, Appendix A, Exhibit 2, Section A. Specifically, the finding affected the design or qualification of a mitigating SSC and did not result in the loss of operability or functionality. A search of the corrective action program did not identify any historical performance issues associated with the electrical connectors.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.
Contrary to the above, from June 15, 2004 to July 18, 2014, the licensee failed to review for suitability of application of parts and processes essential to the safety-related functions of the Pomona Terminal Strip Banana Jack. Specifically, in MRE 819, Pomona 5699, 5700, 5701 Series Jacks, Revision 0, an evaluation that established the commercial grade dedication plan for terminal strip electrical connectors, the licensee failed to list all the safety-related design functions and the associated critical characteristics necessary to accomplish those safety-related design functions.
Contrary to the above, from July 18, 2014 to August 4, 2023, the licensee failed to review for suitability of application of parts and processes essential to the safety-related functions of the Pomona Terminal Strip Banana Jack. Specifically, in CGD 2014-007, Pomona Terminal Strip Banana Jack," Revisions 0 and 1, an evaluation that established the commercial grade dedication plan for terminal strip electrical connectors, the licensee failed to prescribe the correct test method for the connector insulation integrity, a critical characteristic associated with a safety-related design function.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On August 4, 2023, the inspectors presented the Commercial Grade Dedication Inspection results to Shawn Hafen and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
501000074763
Insufficient PO Requirements
06/23/2023
501000074669
Lost Records WO 7000077103
06/21/2023
501000074729
Missing Documents/Records
06/22/2023
501000074754
Lost Records SCR-03-0223
06/21/2023
501000074763
Insufficient PO Requirements
06/23/2023
501000074839
RFI Response Inadequate
06/26/2023
501000075066
CGD Objective Evidence
06/27/2023
501000075115
NRC CGD Inspection Response Exceeded 24 Hours
07/10/2023
501000075175
Segregation of Material in QC Area - CGD
07/10/2023
501000075187
Insufficient Testing Justification
07/12/2023
501000075191
Lost Records WO 700005486
07/11/2023
501000075262
MRE-770, MID 268756-2 Rebuild Kit
07/14/2023
501000075263
Insufficient CGD Testing
07/13/2023
501000075271
Inaccurate Information Provided to NRC
07/14/2023
501000075306
Incomplete Basis in CGD 2017-002 Rev. 0
07/18/2023
501000075323
Potential Configuration Issue in D10
07/16/2023
501000075331
Inaccurate VTM Revision
07/17/2023
501000075339
CGD Critical Characteristic for P/N
07/19/2023
501000075417
Insufficient PO Requirements
07/23/2023
501000075418
CGD Critical Characteristics for P/N
07/24/2023
501000075457
CGD Critical Characteristics/Banana Jack
07/24/2023
501000075485
Incorrect language in CGD Evaluation
07/26/2023
501000075492
Commercial Grade Dedication Standards
07/26/2023
501000075496
NOS: Supplier QA Manual Revision
07/27/2023
501000075502
CGD revision basis enhancements
07/26/2023
501000075506
Banana Jacks Inadequate Testing
07/26/2023
501000075538
Ineffective Closure of Corrective Actions
07/27/2023
Corrective Action
Documents
Resulting from
Inspection
501000075740
CAP Not Initiated When CAQ Identified
08/03/2023
Vendor Drawing; Swagelok; Plug - Fractional; B-810-P
None
71111.21N.03
Drawings
Vendor Drawing; Swagelok; SS-CHS8-10
None
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
27103385
Pin, Cotter
C
NX-20022-1
1" Crispin Deep Well Air Valve
2Q065
Installation of RPS Test Fixture to Preclude Half Scrams
During Surveillance Testing
1116
EQV To Facilitate the Installation of Banana Jack
Adapters in Place of Screw Terminals.
Engineering
Changes
601000001877
Add Cell and Replace 11 Battery
04/15/2021
CGD-2007-025
RTV Sealants and Adhesives
MRE 251
Flexitallic Gaskets
MRE 314
Sylvania Pilot Lamp Socket
MRE 494
Burndy Lugs
Engineering
Evaluations
MRE 812
Flame Arrestors, CD P/N PV-484, CGE
Vendor Brochure / Specification Sheet; NO-OX-ID
A-Special; Sanchem Inc
None
Vendor Description / Specification Sheet; Brass Plug for
1/2" Swagelok Tube Fitting
None
Vendor Description / Specification Sheet; Stainless Steel
Poppet 6000 PSIG Check Valve, 1/2" Swagelok Tube
Fitting, 10 PSIG; SS-CHS8-10
None
2019-0071
Source Surveillance; Swagelok Minnesota
11/25/2019
22-0047
Vendor Surveillance; Swagelok Minnesota CG
2/15/2023
23148
NUPIC Survey; Swagelok Company; Solon, OH
09/20/2012
24974A
NUPIC Survey; Swagelok Company; Solon, OH
03/05/2021
24974D
NUPIC Survey; Swagelok Company; Solon, OH
03/23/2021
CGD-2006-007
Swagelok Valves, Metal Hose Assemblies, and Brass
Fittings
& 1
CGD-2017-002
NO-OX-ID A-Special Grease
CSM 2009-007-
Classification of Subcomponents and Material; Gaskets -
Spiral Wound, Corrugated Iron, Metal Jacketed and Sheet
Type
03/21/2011
M-CGE-103
Cotter Pin Commercial Grade Application Evaluation
2/26/1991
Miscellaneous
MRE 557
Materials Requirements Evaluation; Seismically
Insensitive Items List
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MRE 733
Materials Requirements Evaluation; Banana Jack
Adapters for HFE Relays
MRE 770
Material Requirement Evaluation; Crispin 1" Model D-10
Air Valve Rebuild Kit
PO 00021458
Purchase Order; Jack, Terminal Strip Banana; Pomona
Electronics
01/02/2008
PO 00036670
Rebuild Kit; Air Vent Valve, 1 in; Crispin Model D-10 Type
S
03/11/2011
PO 00056175
Tube Plug, 1/2 IN Swagelok, Brass; B-810-P
2/17/2015
PO 00066519
Purchase Order; Grease, NO-OX-ID "A-Special"
03/14/2017
PO 4000026635
Purchase Order: Check Valve, Poppet, 1/2 IN Swagelok
09/22/2022
PO P010590
Jack, Type Banana, Pomona P/N E13127-2 & E13127-4
AWI-06.01.04
Materials Requirements Evaluation Process
& 8
CD 8.2
Control of Purchased Items and Services
CGD-2023-004-
AC Pilot Light Socket for 250VDC Chargers
FP-NO-SAS-01
Supplier Qualification and Maintenance of the Qualified
Suppliers List
FP-NO-SAS-01
Supplier Qualification and Maintenance of the Qualified
Suppliers List
FP-NO-SAS-01
Supplier Qualification and Maintenance of the Qualified
Suppliers List
FP-NO-SAS-03
Performance of Commercial Grade Surveys
FP-SC-PE-01
Dedication of Commercial Grade Items and Services
FP-SC-PE-01
Dedication of Commercial Grade Dedication Items and
Services
- 11
FP-SC-PE-05
Shelf Life Program
FP-SC-RSI-02
Quality Receipt
MRE 314
Sylvania Pilot Lamp Socket
MWI-8-M-4.06
Conductor Termination
QF0202
FP-SC-GEN-01 - NSPM - Glossary of Procurement Terms
QF0203
FP-SC-RSI-02 - Quality Inspection Checklist
Procedures
QF0228
FP-SC-PE-01 - Commercial Grade Dedication Evaluation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-
Assessments
606000001737
23 NRC Inspection on CGD Process FSA
01/20/2023
3186-RI-01-1
1N56665A Diode Specification/Receipt Inspection/Testing
Sheet
700006740
97-31 - Install Banana Jacks for 2 Year REL
04/23/2018
700009590
CH B RHR, Core Spray and ADS Control Panel; C-33
Install 8 Banana Jacks
700017331
PM AV-4024 Air Vent Valve
04/06/2018
700025574
Rplc Inverter Capacitors & Fuses
700049605
RV-2-71C - Changeout SRV Per 4280-PM
07/01/2021
70005210
CH B RHR, Core Spray and ADS Control Panel; C-33 DIV
II, Install Banana Jacks
2/27/2021
700067808
Projects RPLC #11 125 VDC Battery
09/07/2021
700081011
Replace 11 ESW Biocide Injection Check Valve
10/12/2022
Work Orders
700115405
CH A RHR, Core Spray and ADS Control Panel; Install
Pomona Jacks C-32
0