IR 05000390/2023011
| ML23202A171 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 07/24/2023 |
| From: | James Baptist Division of Reactor Safety II |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2023011 | |
| Download: ML23202A171 (1) | |
Text
SUBJECT:
WATTS BAR NUCLEAR PLANT - QUADRENNIAL FOCUSED ENGINEERING INSPECTION (FEI) COMMERCIAL GRADE DEDICATION REPORT 05000390/2023011 AND 05000391/2023011
Dear James Barstow:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Watts Bar Nuclear Plant and discussed the results of this inspection with Mr. Tony Williams Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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 II; the Director, Office of Enforcement; and the NRC Resident Inspector at Watts Bar Nuclear Plant.
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.
July 24, 2023
Sincerely, James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000390 and 05000391 License Nos. NPF-90 and NPF-96
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000390 and 05000391
License Numbers:
Report Numbers:
05000390/2023011 and 05000391/2023011
Enterprise Identifier:
I-2023-011-0020
Licensee:
Tennessee Valley Authority
Facility:
Watts Bar Nuclear Plant
Location:
Spring City, TN 37381
Inspection Dates:
June 12, 2023 to June 30, 2023
Inspectors:
T. Fanelli, Senior Reactor Inspector
R. Fanner, Reactor Inspector
C. Franklin, Reactor Inspector
Approved By:
James B. Baptist, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication at Watts Bar Nuclear 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 Control Embedded Digital Devices Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000390,05000391/2023011-01 Open/Closed None 71111.21N.
The NRC identified a Green Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) 50, Appendix B, Criterion IV, Procurement Document Control, with two examples, for the failure to ensure that purchase order requirements controlled unidentified embedded digital devices for safety related components, including commercial grade dedicated (CGD) components.
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) PEG PKG NO. CKG876A, WO 120191302,
Description:
80-9210836-90 PCB 1 PH VOLT SENSE 120VAC SCI, (125V VITAL BATTERY CHARGER)
- (2) PEG PKG NO. CRE458A, WO 120277323,
Description:
80-9215501-90 PCB ASSY UPS TROUBLE 140VDC, (DG 2A-A BATTERY CHARGER 1, NORMAL)
- (3) PEG PKG NO. DAP056L, WO 121461932,
Description:
HOSE, #4 HYDRAULIC.
AQP, (DIESEL GENERATOR 1B-B)
- (4) PEG PKG NO. BWJ668N, WO 116534761,
Description:
Guide Spring Item# BWJ668N for
.5,.75, & 1" Series 1500 Globe VLV, (CCP 1B-B DISCHARGE VENT)
- (5) PEG PKG NO. CAP374N, WO 119191200,
Description:
INDUSTRY GRADE ISO VG-46, TURBINE OIL, (SAFETY INJECTION PMP 2A-A)
- (6) PEG PKG NO. CKF478V, WO 122663423,
Description:
PHILLIPS66, MULTIPLEX 220 #2 GREASE, 1/14oz TUBE/CARTRIDGE, (RHR HEAT EXCHANGER 2A INLET ISOLATION)
- (7) PEG PKG NO. CWM252Fx`, WO 119909145,
Description:
BREAKER, CIRCUIT, THERMAL MAGNETIC, 480, 80, 3, 60, 3, 125 A, (125V DC Vital Power System)
- (8) PEG PKG NO. CWM252Fx`, WO 117648487,
Description:
BREAKER, CIRCUIT, MAGNETIC, 600, 5, 3, 25000-480, 125 A, (Safety Injection System)
- (9) PEG PKG NO. CXV589N, WO 121842856,
Description:
PUMP, AC CIRCULATING OIL PUMP, ASSEMBLY, W/ELECTRIC MOTOR, (Standby Diesel Generator System)
- (10) PEG PKG NO. AEQ777G, WO119145014,
Description:
CAPACITOR, FIXED (Solid State Protection System)
- (11) PEG PKG NO. CAY920W, WO122554382,
Description:
CAPACITOR, ELECTRICAL DEVICE, (Aux Feedwater)
- (12) PEG PKG NO. CDT158T, WO121998756,
Description:
Resistor, Variable (EDG-1B-B)
- (13) PEG PKG NO. CRE546B, WO120463676,
Description:
CAPACITOR, ELECTRICAL DEVICE, Q LEVEL (Battery Charger)
- (14) PEG PKG NO. DAJ426G, WO121041296,
Description:
SCR, Q LEVEL (125V Vital Battery Charger 8-S)
INSPECTION RESULTS
Failure to Control Embedded Digital Devices Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000390,05000391/2023011-01 Open/Closed None 71111.21N.0 The NRC identified a Green Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) 50, Appendix B, Criterion IV, Procurement Document Control, with two examples, for the failure to ensure that purchase order requirements controlled unidentified embedded digital devices for safety related components, including commercial grade dedicated (CGD) components.
Description:
The inspectors reviewed TVA-NQA-PLN89-A, Nuclear Quality Assurance Plan (NQAP), Rev 41, to determine the quality requirements for purchasing safety related components. The inspectors noted that Section 8, Procurement and Material Control, required in part, that procurement documents shall specify or reference design basis technical requirements and inspection and test requirements (including acceptance criteria)that shall be prepared under the requirements of Section 7, Design Control. Section 7, specified, in part, that Measures shall be established and implemented to provide test requirements in design output documents for the following tests as appropriate:
1. Design qualification.
2. Product acceptance (proof).
1. The licensee purchased commercial grade replacement parts for AMETEK battery
chargers and inverters as basic components from AMETEK. In approximately 2015, AMETEK changed their sub-vendor (Carlo Gavazzi) for commercial grade timing relays to be CGD as basic components. Neither the licensee, AMETEK nor the sub-vendor documentation identified embedded digital devices associated with the timing relay functions. Based on a walkdown observation and review of the relay capabilities, the team identified that these timing relays contained unidentified embedded digital devices that controlled the timer functionality. The licensee and AMETEK substantiated the condition. The licensee purchase order for these timing relays did not include requirements to assure that any embedded digital devices were identified and controlled as criteria for qualification and acceptance. As a result, uncontrolled Carlo Gavazzi timing relays with unidentified embedded digital devices have been installed in the plant since approximately 2015.
2. In 2016, the site received Information Notice (IN) 2016-01, Recent Issues Related to
the Commercial Grade Dedication of Allen Bradley 700-RTC Relays, ML15295A173.
The site review of IN 2016-01 failed to ensure that established purchase order requirements included specifications to assure that any unidentified embedded digital devices were identified and controlled. The IN 2016-01 identified that embedded digital devices went unidentified during the CGD of Allen Bradley timing relays which was causing anomalous behavior, under certain conditions, in safety related equipment. The Allen Bradley model number did not change to reflect a design change that embedded the digital device to control the timing circuits. The site screening (CR 1163578) addressed the specific make and model of relay identified in IN 2016-01, but not the issue implications that unidentified embedded digital devices could affect any number of commercial grade manufacturers. The screening of IN 2016-01 was a failure to identify purchase order requirements were necessary to address unidentified embedded digital devices and thus was a condition adverse to quality. As a result, the site has received new orders of Carlo Gavazzi relays with unidentified digital devices. In addition, the licensee purchase orders for other control devices did not include requirements to assure that any unidentified embedded digital devices were identified and controlled as criteria for qualification and acceptance, which have not been screened for embedded digital devices.
Corrective Actions: The licensee entered the issue into the corrective action program and perform an operability evaluation.
Corrective Action References: CR 1864898-unidentified embedded device, CR 1865139-part 21 tracker, and CR 1864568-CR 1163578 did not address all concerns. (IN2016-01 and Part 21)
Performance Assessment:
Performance Deficiency: The failure to ensure that purchase order requirements controlled unidentified embedded digital devices for safety related components, including CGD components was a performance deficiency.
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 failure to control embedded digital devices through commercial grade dedication adversely affected the reliability and capability of basic components.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 2
- Mitigating Systems Screening Questions, Item A. Mitigating SSCs and PRA Functionality (except Reactivity Control Systems), specified that if the finding affected the design or qualification of a mitigating SSC, but it maintained its operability or PRA functionality then it screens to GREEN.
Cross-Cutting Aspect: None
Enforcement:
Violation: Title 10 Code of Federal Regulations (CFR) Part 50 Appendix B, Criterion IV, Procurement Document Control, required in part, measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcontractors.
Contrary to the above, since 2015, the date of installation, the licensee failed to assure measures that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material such as measures to ensure the control of unidentified embedded digital devices in the design and testing of commercial grade basic components.
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 June 30, 2023, the inspectors presented the Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication results to Mr. Tony Williams Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
1860913,
1860914
CR 1857481
Motors stored in warehouse from info gathering
05/18/2023
CR 1857483
Circuit boards from info gathering
05/18/2023
CR 1860913
WO Issue ticket missing
06/14/2023
CR 1860914
WO 116534761 does not contain an issue ticket
06/06/2023
CR 1860915
WO 120463676 does not contain an issue ticket for
CRE546B
06/06/2023
CR 1862619
Update to TVA-NQA-PLN89-A, Update Reference to NP-
5652
06/14/2023
CR 1862808
NESSD DOC Only Discrepancy
06/15/2023
CR 1863460
Capacitor Shelf Life Discrepancy
06/20/2023
CR 1864568
CR 1163578 did not address all concerns.(IN2016-01 and
Part 21)
06/26/2023
CR 1864854
AMETEK Relay Unidentified Embedded Digital Device
06/27/2023
CR 1864898
AMETEK Relay Unidentified Embedded Digital Device
06/27/2023
CR 1865139
Part 21 tracker
06/28/2023
CR 1865502
23 NRC Commercial Grade Dedication Inspection -
Green NCV: PEG Procedures
06/29/2023
CR 1865505 Rev
23 NRC Commercial Grade Dedication Inspection -
Minor Violation - Shelf Life
06/29/2023
CR 1865507
23 NRC Commercial Grade Dedication Inspection -
Observation - ASL restrictions
06/29/2023
CR 1865510 Rev
23 NRC Commercial Grade Dedication Inspection -
Observation - Shelf Life notes
06/29/2023
Corrective Action
Documents
Resulting from
Inspection
CR 1865512
Rev1
23 NRC Commercial Grade Dedication Inspection -
Observation - Shelf Life guidance
06/29/2023
1-45W709-2
CWM252F
Wiring Diagrams, Charger, Inverter and Misc. Equipment
Sheet 2
Rev 0
1-45W760-211-
Wiring Diagram 6900 Shutdown Power-Train A&B
Schematic Diagram
R21
71111.21N.03
Drawings
1-45W760-63-6
Wiring Diagrams, Safety Injection System Schematic
Rev 10
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
BVB012C
BVB012C
Wiring Diagrams,480V Reactor MOV Board 1A1-A
Connection Diagram Sheet 2
Rev 11
WBN-1-45W751-
BVB012C
Wiring Diagrams,480V Reactor MOV Board 1A1-A Single
Line Sheet 2
Rev 37
WBN-1-45W751-
5-CC CWM252F
Wiring Diagrams,480V Reactor MOV Board 1A2-A Single
Line Sheet 2
Rev 38
WBN-45B1767-
004296917
CWM252F
Wiring Diagrams,480V Reactor MOV Board 1A2-A,
Connection Diagram Compartment 13B
Rev 3
WBN-TVDD9954
3/4 Series Y Type Globe Valve
Rev. 11
2016N-72 VAS
NUPIC JOINT UTILTIES AUDIT of AMETEK
SOLIDSTATE CONTROLS AUE # VA16-003 / NUPIC #
24149 COLUMBUS, OH, 11/06/2016
11/06/2016
PO 2234885
GE Industrial Solutions Inc., Lubricant, Oil, QA 2, Drum
Rev. 1
PO 3140696
Flowserve Corp., Guide, Valve, QA 1, SS
Rev. 1
PO 4895928
Ametek Solidstate Controls, Board, Circuit, QA 1, Voltage
Sensing, 120, 1 PH
Rev. 1
PO 5573688
Ametek Solidstate Controls, Board, Circuit, QA 1,
Assembly
Rev. 1
PO 6673375
Engine Systems Inc., Fitting, Connection, QA 1
Rev. 1
PO 6929387
GE Industrial Solutions Inc., Lubricant, grease, QA 2,
Lithium complex, NLGI grade 2, 14oz, paste, tube
Rev. 0
TVA Receiving
Report PO
27610 - 2
Vendor QUAL TECH NP, Gould Inc, Circuit Breaker
9/29/2017
TVA Receiving
Report PO
200052 - 1
Vendor QUAL TECH NP, Siemens Energy & Automation,
Circuit Breaker
4/22/2020
TVA Receiving
Report PO
6679142 - 1
Vendor Engine Systems Inc, Circulating Oil Pump
Assembly 1 NPT, W/Electric Motor TEFC 460V, 3 phase,
Hz
4/13/2021
Miscellaneous
TVA Supply
BREAKER,CIRCUIT, QA 1, THERMAL MAGNETIC, 480,
4/29/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Chain Review
(SCR) 102990
80, 3, 60, 3, 125 A
WBN-VTD-A998-
0040
AMETEK SOLIDSTATE CONTROLS INSTRUCTION &
OPERATING MANUAL WITH DRAWINGS DUAL 20 AMP
BATTERY CHARGERS IN SINGLE ENCLOSURE
Rev. 1
0-MI-57.034
Agastat Time Delay Relays
Rev 4
0-SI-236-63
25V DC Vital Battery Charger III Test
Rev. 13
CEB-SS-5.10
Seismic Qualification of Electrical, Mechanical, and I&C
Devices
Rev. 3
CEB-SS-5.10
Seismic Qualification of Electrical, Mechanical, and I&C
Devices
Rev. 4
DS-M18.2.18
Std Procurement Notes
Rev 30
DS-M18.2.18
Standardized Procurement Notes
Rev 30
NEDP-8.0
Evaluations for Procurement of Materials, Items, and
Services
Rev. 8
NEDP-8.0
Evaluations for Procurement of Materials, Items, and
Services
Rev. 0
NEDP-8.2
Technical Evaluation for Procurement of Safety Related
and Quality Related Materials, Items, and Services
Rev 1
NEDP-8.3
Supplier Submittals
Rev. 4
NEDP-8.3
Supplier Submittals
Rev. 4
NEDP-8.4
Equivalency Evaluation for Procurement and Use of
Replacement Materials and Items
Rev. 0007
NEDP-8.4
Equivalency Evaluation for Procurement and Use of
Replacement Materials and Items
Rev. 7
NEDP-8.5
Other Evaluations
Rev. 7
NEDP-8.5
Other Evaluations
Rev. 0007
NEDP-8.5
Other Evaluations
Rev 7
NPG-SPP-03.16
Supplier Audits, Surveys, Source Surveillances and ASL
Maintenance
Rev. 16
Procedures
NPG-SPP-
04.001
Procurement of Material, Labor and Services
Rev. 0014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NPG-SPP-
04.001
Procurement of Material, Labor, and Services,
Rev 14
NPG-SPP-
04.002
Material Receipt and Inspection
Rev. 4
NPG-SPP-
04.002
Material Receipt and Inspection
Rev. 0
NPG-SPP-
04.004
Material Issue, Control and Return
Rev. 1
NPG-SPP-09.3
Plant Modifications and Engineering Change Control
Rev. 0038
P.S.4.M.1.5
CLASSIFICATION, PROCUREMENT, RECEIPT AND
USE OF LUBRICANTS
Rev. 5
Work Orders
119909145,
117648487,
21842856,
119684290,
20277320,
119190332,
2663418,
21461932,
115700387