ML18102B171
| ML18102B171 | |
| Person / Time | |
|---|---|
| Site: | 99900905 |
| Issue date: | 04/27/2018 |
| From: | Kavanaugh K NRC/NRO/DCIP/QVIB2 |
| To: | Loucks E National Technical Systems |
| Patel R | |
| References | |
| IR 2015201, IR 2015202 | |
| Download: ML18102B171 (5) | |
Text
April 27, 2018 Eric Loucks, General Manager National Technical Systems 7800 HWY 20 West Huntsville, AL 35806
SUBJECT:
CLOSURE OF ITAAC-RELATED FINDINGS FOR NATIONAL TECHNICAL SYSTEMS INSPECTION REPORT NOs.99900905/2015-201 AND 99900905/2015-202
Dear Mr. Loucks:
On December 15-17, 2014, February 11, 2015, and May 11-14, 2015, the U.S. Nuclear Regulatory Commission (NRC) staff completed inspections at the National Technical Systems (here after referred to as NTS) facility in Huntsville, AL. The purpose of these technically-focused, limited-scope routine inspections was to evaluate NTSs implementation of quality activities associated with the qualification testing of the 8-inch high pressure and low pressure squib valves of the passive core cooling system for the Westinghouse Electric Companys AP1000 reactor design for the Vogtle Electric Generating Plant, Units 3 and 4, currently under construction.
The vendor inspection activities are documented in inspection report (IR) No. 99900905/2015-201, dated March 26, 2015 (Agencywide Document Access and Management System (ADAMS)
Accession No. ML15078A3379) and IR No. 99900905/2015-202, dated June 25, 2015 (ADAMS Accession No. ML15152A080) respectively.
Based on the NRC staff review of the inspection findings, the staff identified that Notice of Nonconformance (NON) 99900905/2015-201-01 documented in IR No. 99900905/2015-201, and NON 99900905/2015-202-01 documented in IR No. 99900905/2015-202 were material to the acceptance criteria of inspections, tests, analyses, and acceptance criteria (ITAAC) No.
2.2.03.12a.i (214), from Revision 19 of the certified AP1000 Design Control Document. To close out NON 99900905/2015-201-01 and NON 99900905/2015-202-01, the staff has performed a review of NTSs corrective actions taken to verify the adequacy and effectiveness of corrective actions, the results of which are documented below.
Corrective Actions associated with NON 99900905/2015-201-01 NON 99900905/2015-201-01, documents a finding against Criterion III, Design Control, and Criterion V, Instructions, Procedures, and Drawings, of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Processing Plants, to Title to 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, for NTSs failure to take sufficient measures to validate the accuracy of the commercial vendors irradiation system as applied to the squib valve cartridges sent for irradiation to a commercial facility by NTS. Also, NTS in its procedure NEQ 409, The Wyle
E. Loucks 2 Third-Party Dedication Process, failed to provide sufficient guidance on the dedication of commercial-grade services.
In a letter dated April 14, 2015 (ADAMS Accession No. ML15113A338), NTS, in their corrective actions to address the issues identified in NON 99900905/2015-201-01, stated that they issued NTPQ-001, a third-party qualification dedication plan for commercial-grade services that is based on EPRI-5652 and TR-102260 guidance and scheduled a commercial-grade survey of White Sands, a commercial facility, to verify proper implementation of ASTM E668-10 for radiation compliance. Further, NTS stated that they would collect samples of Thermoluminescent dosimeters (TLDs) during the commercial-grade survey and subject the TLD samples to material testing to verify compliance with ASTM E668-10 specification.
The NRC staff reviewed NTSs corrective actions taken to address the issues identified in NON 99900905/2015-201-01. Based on this review, the NRC staff determined the corrective actions taken by NTS are adequate to address the identified nonconformance.
NON 99900905/2015-201-01 is closed and no additional inspection follow-up is required to verify completion/adequacy of the corrective actions.
Corrective Action Associated with NON 99900905/2015-202-01 NON 99900905/2015-202-01, documents a findings against Criterion XI, Test Control, and Criterion V, Instructions, Procedures, and Drawings, of Appendix B to 10 CFR Part 50 for NTSs failure to establish a procedure in its test program for verifying that the data acquisition system (DAS) functioned as designed. NTS performed both pre-and post-test verification and validation of the DAS to verify that the DAS software was accurately calculating and reporting those temperature and pressure values that would be used to determine the qualification of the safety-related AP1000 8-inch low pressure squib valves. However, NTS activities to validate the proper function of the DAS, a testing activity affecting quality, were not performed in accordance with written procedures containing the requirements and acceptance limits of the design documents to assure that all prerequisites for the given test had been met.
In a letter dated July 27, 2015 (ADAMS Accession No. ML15229A302), NTS, in their corrective actions to address the issues identified in NON 99900905/2015-202-01, stated that they would develop a formal written procedure with data sheets for the performance of the routine pre-test and post-test verification check (spanning) of the testing equipment and retrain appropriate personnel on the specific Criterion XI, Test Control, and Criterion V, Instructions, Procedures, and Drawings, of Appendix B to 10 CFR Part 50, to ensure future processes are properly documented no later than August 31, 2015.
The NRC staff reviewed NTSs corrective actions taken to address the issue identified in NON 99900905/2015-202-01. Based on review, the NRC staff has determined the corrective actions taken by NTS are adequate to address the identified nonconformance.
NON 99900905/2015-202-01 is closed and no additional inspection follow-up is required to verify completion/adequacy of the corrective actions.
E. Loucks 3 Sincerely, Kerri. A. Kavanagh, Branch Chief /RA/
Quality Assurance Vendor Inspection Branch-2 Division of Construction Inspection and Operational Programs
Enclosure:
Summary of NRC Inspection of National Technical Systems Affecting ITAAC
E. Loucks 4
SUBJECT:
CLOSURE OF ITAAC RELATED-FINDING FOR NATIONAL TECHNICAL SYSTEMS INSPECTION REPORT NOs. 99900905/2015-201 AND 99900905/2015-202 Dated: April 27, 2018 DISTRIBUTION:
Public Brenda.morse@nts.com KKavanagh TJackson ASakadales POBryan VHall NRO_DCIP_QVIB-1 NRO_DCIP_QVIB-2 ADAMS ACCESSION NO: ML18102B171 NRO 002 OFFICE NRO/DCIP/QVIB-2 NRO/DCIP/QVIB-2 NAME RPatel KKavanagh DATE: 04/26/2018 04/27/2018 OFFICIAL RECORD COPY
Summary of NRC Inspection of National Technical Systems Affecting ITAAC
- 1. AFFECTED INSPECTIONS, TESTS, ANALYSES, AND ACCEPTANCE CRITERIA The U.S. Nuclear Regulatory Commission (NRC) inspectors identified the following inspections, tests, analyses, and acceptance criteria (ITAAC) related to components being tested by National Technical Systems (here after referred to as NTS) Huntsville facility. For the ITAAC listed below, the NRC staff reviewed NTSs corrective actions in response to Notice of Nonconformance (NON) 99900905/2015-201-01 and NON 99900905/2015-202-01. The ITAACs design commitments referenced below are for future use by the NRC staff during the ITAAC closure process; the listing of these ITAAC design commitments does not constitute that they have been met and/or are closed. The NRC staff did identified two findings associated with the ITAAC identified below.
Source Document ITAAC Index No. ITAAC Acceptance Criteria Appendix C from the i) A test report exists and Combined License concludes that each squib for Vogtle Units 3 and No. 214 2.2.03.12a.i valve changes position as 4 and V.C. Summer indicated in Table 2.2.3-1 Units 2 and 3 under design conditions.
- 2. FINDINGS AND OBSERVATIONS Based on a review of additional information, the NRC staff has determined that the corrective actions taken by NTS in response to NON 99900905/2015-201-01 and NON 99900905/2015-202-01, are adequate to address the identified nonconformance. NON 99900905/2015-201-01 and NON 99900905/2015-202-01 are closed and no additional inspection follow-up is required to verify completion/adequacy of the corrective actions.
- 3. ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description Applicable ITAAC 99900905/2015-201-01 CLOSED NON Criterion III & V 2.2.03.12a.i 99900905/2015-202-01 CLOSED NON Criterion XI & V 2.2.03.12a.i Enclosure