ML22109A217
| ML22109A217 | |
| Person / Time | |
|---|---|
| Site: | 99902102 |
| Issue date: | 04/27/2022 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Workoff M Curtiss-Wright, Steam & Air Solutions |
| Galletti G | |
| References | |
| IR 2022201 | |
| Download: ML22109A217 (27) | |
Text
April 27, 2022 Mary Workoff, General Manager Curtiss-Wright Steam and Air Solutions 585 Trade Center Parkway, Summerville, SC 29483
SUBJECT:
NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF CURTIS WRIGHT STEAM AND AIR SOLUTIONS NO. 99902102/2022-201
Dear Ms. Workoff,
On March 14-18, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Curtiss-Wright Steam and Air Solutions (CW-SAS) facility in Summerville, South Carolina. The purpose of this limited-scope inspection was to assess CW-SAS compliance with the provisions of selected portions of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 21, Reporting of Defects and Noncompliance.
This technically-focused inspection specifically evaluated CW-SAS implementation of the quality activities associated with design, fabrication, and testing of safety-related components being supplied to the U.S. operating nuclear power plants. The enclosed report presents the results of the inspection. This NRC inspection report does not constitute NRC endorsement of CW-SAS overall quality assurance (QA) or 10 CFR Part 21 programs.
Based on the results of this inspection, the NRC inspection team found the implementation of your QA program met the applicable technical and regulatory requirements imposed on you by your customers or NRC licensees. No findings of significance were identified.
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, the NRC will make available electronically for public inspection a copy of this letter and its enclosure through the NRCs Public Document Room or from the NRCs Agencywide Documents Access and Management System, which is accessible at http://www.nrc.gov/reading-rm/adams.html.
M. Workoff 2
If you have any questions concerning this matter, please contact Mr. Greg Galletti of my staff at (301) 415-1831.
Sincerely, Kerri Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99902102
Enclosure:
Inspection Report No. 99902102/2022-201 and Attachment Signed by Kavanagh, Kerri on 04/27/22
ML22109A217 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME GGalletti YDiaz-Castillo FVega DATE 04/22/2022 04/25/2022 04/25/2022 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NAME AKeim KKavanagh DATE 04/25/2022 04/27/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99902102 Report No.:
99902102/2022-201 Vendor:
Curtiss-Wright Steam and Air Solutions (CW-SAS)
Vendor
Contact:
Scott Rennick Phone: +1 (843) 486-6056 Email: srennick@curtisswright.com Nuclear Industry Activity:
CW-SAS provides Terry Turbine pumps, spare parts, and services to the commercial nuclear industry.
Inspection Dates:
March 14-18, 2022 Vendor Location:
585 Trade Center Parkway Summerville, SC 29483 Inspection Team Leader:
Greg Galletti NRR/DRO/IQVB Inspectors:
Andrea Keim NRR/DRO/IQVB Yamir Diaz-Castillo NRR/DRO/IQVB Frankie Vega NRR/DRO/IQVB Approved by:
Kerri Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
Curtiss-Wright Steam and Air Solutions 99902102/2022-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a routine vendor inspection at the Curtiss-Wright Steam and Air Solutions (hereafter referred to as (CW-SAS) facility in Summerville, SC, to verify it had implemented an adequate quality assurance (QA) program that complies with the requirements of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR)
Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 21, Reporting of Defects and Noncompliance. The NRC inspection team conducted this inspection on-site from March 14 - 18, 2022.
This technically-focused inspection specifically evaluated CW-SAS implementation of the quality activities associated with the design, fabrication, and testing of safety-related Terry Turbine pump components and replacement parts being supplied to U.S. nuclear power plants.
The following regulations served as the bases for the NRC inspection:
Appendix B to 10 CFR Part 50
10 CFR Part 21 During the course of this inspection, the NRC inspection team implemented Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017, IP 43004, Inspection of Commercial-Grade Dedication Programs, dated January 27, 2017; and IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated May 16, 2019.
The NRC inspection team observed the following specific activities:
Shop area walkdown and work practices of CW-SAS implementation for identification of parts and materials, areas of nonconforming materials, welding, and non-destructive examination.
Commercial-grade dedication (CGD) of a stainless steel Grade 440C guide bushing.
The NRC inspection team concluded that CW-SAS QA policies and procedures comply with the applicable requirements of Appendix B to 10 CFR Part 50 and 10 CFR Part 21, and that CW-SAS personnel are implementing these policies and procedures effectively. The information below summarizes the results of this inspection.
10 CFR Part 21 Program The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its 10 CFR Part 21 program to verify compliance with the requirements of 10 CFR Part 21. The NRC inspection team: 1) reviewed the 10 CFR Part 21 postings; 2) reviewed a sample of safety-related purchase orders (POs) to ensure 10 CFR Part 21 was specified; 3) verified that CW-SAS nonconformance and correction action programs
3 provide a link to the 10 CFR Part 21 program; and 4) reviewed CW-SAS process for Part 21 evaluations. No findings of significance were identified.
Design Control and Commercial Grade Dedication The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its design control and CGD programs to verify compliance with the requirements of Criterion III, Design Control, and Criterion VII, Control of Purchase Material, Equipment, and Services, of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed a sample of CW-SAS implementation processes, including on-line access systems and databases associated with the design information for Terry Turbine replacement parts.
The NRC inspection team identified that commercial-grade surveys did not consistently provide objective evidence to validate the adequate implementation of the commercial suppliers quality controls over the critical characteristics, rather they were more broadly programmatic in nature, and the POs did not specifically address the commercial suppliers processes credited for controlling critical characteristics in quality or technical requirements. The NRC inspection team determined this issue to be minor because CW-SAS performs additional tests and inspections as part of the CGD process, and the results of these tests and inspections demonstrate that the critical characteristics were adequately controlled. CW-SAS initiated corrective action report CAR No. 2022-0046 to address this issue.
Supplier Oversight The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its supplier oversight program to verify compliance with the regulatory requirements of Criterion IV, Procurement Document Control, and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50.
The NRC inspection team CW-SAS program for the development and maintenance of its approved suppliers list. The NRC inspection team selected a sample of suppliers to review the methodology for conducting and documenting audits and the review of third-party audits to verify adequate evaluation of the suppliers controls for meeting the applicable requirements of Appendix B to 10 CFR Part 50.
The NRC inspection team noted that CW-SAS had not performed annual evaluations for five suppliers that had recent POs issued. CW-SAS procedure does have adequate guidance for the conduct of annual evaluations. The NRC inspection team determined this issue to be minor because CW-SAS performs additional tests and inspections as part of the receipt inspection process, and the results of these tests and inspections provide reasonable assurance that the suppliers are providing products that meet the applicable requirements. CW-SAS initiated CAR No. 2022-0047 to address this issue.
Identification and Control of Materials, Parts, and Components The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its materials identification and control program to verify compliance with the requirements of Criterion VIII, Identification and Control of Materials, Parts, and Components, of Appendix B to 10 CFR Part 50. The NRC inspection team also observed implementation of the material identification and control program by CW-SAS employees during in-process fabrication activities including receipt inspection, special testing, storage and inventory control, and machining. No findings of significance were identified.
4 Manufacturing Control and Special Processes The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its manufacturing control program to verify compliance with the regulatory requirements of Criterion IX, Control of Special Processes, of Appendix B to 10 CFR Part 50 and the American Society for Nondestructive Testing (ASNT) SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing. The NRC inspection team reviewed CW-SAS process for controlling weld filler metal. The NRC inspection team also performed a walk-down of the weld storage area and confirmed that weld filler materials were adequately controlled to prevent degradation, inadvertent use, or loss of traceability. The NRC inspection team reviewed a sample of procedures and test reports associated with magnetic particle testing and visual testing for a bracket actuator and a valve bonnet, as applicable. No findings of significance were identified.
Control of Measuring and Test Equipment The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its measuring and testing equipment (M&TE) program to verify compliance with the requirements of Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50. The NRC inspection team performed a walkdown of CW-SAS M&TE area and selected a sample of M&TE for review. The NRC inspection team verified the M&TE were labeled, handled, and stored in a manner that indicated the calibration status of the instrument and ensured its traceability to calibration test data. The NRC inspection team also verified that the M&TE had been calibrated, adjusted, and maintained at prescribed intervals prior to use. The NRC inspection team performed a walkdown of the area assigned to their main calibration supplier.
The NRC inspection team identified that contrary to CW-SAS calibration procedures, two calibration certificates from one of CW-SAS calibration suppliers did not include a statement that the calibration was provided in accordance with PO requirements. The NRC inspection team determined this issue to be minor because the calibration laboratory is accredited to the 2017 edition of the International Standard Organization /International Electrotechnical Commission standard No. 17025 (2017 edition ISO/IEC 17025), General Requirements for the Competence of Testing and Calibration Laboratories, and all the other conditions included in Revision 1 of NEI 14-05A were met. CW-SAS initiated CAR No. 2022-0048 to address this issue.
Test Control The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its test control program to verify compliance with the regulatory requirements of Criterion XI, Test Control, of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed a sample of completed hydrostatic test reports for a packing assembly and gland assembly cases. The NRC inspection team verified that the hydrostatic test reports included the acceptance range and documented the equipment used to document the results.
The NRC inspection team reviewed CW-SAS process for pre-testing and set-up of hydrostatic testing. The NRC inspection team also performed a walk-down of the test set-up area for hydrostatic testing and other equipment expected to be operational at the CW-SAS facility. No findings of significance were identified.
5 Nonconforming Materials, Parts, or Components and Corrective Action The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its nonconforming materials, parts, or components and corrective action programs to verify compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed a sample of CW-SAS nonconformance and corrective action reports and confirmed the sample was documented, evaluated, and dispositioned in accordance with CW-SAS program requirements. No findings of significance were identified.
6 REPORT DETAILS 1.
10 CFR Part 21 Program a.
Inspection Scope The U.S. Nuclear Regulatory Commission (NRC) inspection team reviewed Curtiss-Wright Steam and Air Solutions (CW-SAS) policies and implementing procedures that govern the implementation of its Title 10 of the Code of Federal Regulations (10 CFR)
Part 21, Reporting of Defects and Noncompliance, program to verify compliance with the regulatory requirements. The NRC inspection team also evaluated the 10 CFR Part 21 postings and a sample of CW-SAS purchase orders (POs) to verify compliance with the requirements of 10 CFR 21.21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, and 10 CFR 21.31, Procurement Documents.
In addition, the NRC inspection team reviewed a sample of CW-SAS nonconformance and corrective action reports to verify that CW-SAS adequately considered issues for evaluation under their 10 CFR Part 21 program. The NRC inspection team also verified that CW-SAS nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program.
The NRC inspection team discussed the 10 CFR Part 21 program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
- c. Conclusion The NRC inspection team concluded that CW-SAS was implementing its 10 CFR Part 21 program in accordance with the regulatory requirements of 10 CFR Part 21. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CW-SAS was adequately implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.
2.
Design Control
- a. Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its design control program to verify compliance with the regulatory requirements of Criterion III, Design Control, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. CW-SAS scope of supply is limited to replacement parts and repair work for the existing Terry Turbines used in operating US nuclear power plants. CW-SAS owns the design of the Terry Turbines and there hasnt been any significant design changes.
7 The NRC inspection team reviewed CW-SAS processes for performing design and configuration control, including design reviews and design changes. The NRC inspection team reviewed design documentation (e.g. drawings, parts qualification and design records, engineering change notices) associated with a sample of replacement/spare parts (i.e., washer, valve bonnet, guide bushings) and a complete valve bonnet assembly. CW-SAS explained how the design control process is implemented electronically using a product lifecycle management system. Specifically, CW-SAS uses this electronic system to manage design control activities such as design reviews, design interface, engineering changes, verification, validation, and maintaining design records.
The NRC inspection team verified that CW-SAS design review process includes the purpose of each design change, method of conduct, and documentation of the results.
Design changes resulting from design reviews are implemented through the Engineering Change Review and Notification Process with the results of the design review documented in the Engineering Part Qualification and Design Record. The NRC inspection team confirmed that the design review process was conducted in accordance with CW-SAS implementing procedures, and the results of design reviews were adequately documented.
The NRC inspection team also discussed the design control program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
- b. Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its design control program in accordance with the regulatory requirements of Criterion III of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CW-SAS is implementing its policies and procedures associated with the design control program. No findings of significance were identified.
3.
Commercial-Grade Dedication
- a. Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its commercial-grade dedication (CGD) program to verify compliance with the regulatory requirements of Criterion III and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50. In addition, the NRC inspection team conducted interviews with CW-SAS personnel, observed of dedication activities in-process, and review of related CGD documentation.
Specifically, the NRC inspection team reviewed dedication packages to assess the different elements of the CGD program, including the technical evaluation process, design drawings, commercial-grade surveys, and test and inspection reports.
8 The sample of CGD packages included the following items: spring, packing ring stop, guide bushing, carbon ring, sliding nut, and a hydraulic cylinder. The CGD packages included: 1) POs; 2) the technical evaluation for the identification and documentation of the basis and justification for the selection of the critical characteristics; 3) acceptance methods and acceptance criteria; 4) receiving inspection records; and 5) Certificates of Conformance. The NRC inspection team evaluated the criteria for the identification of item functions, credible failure mechanisms/modes, selection of critical characteristics and acceptance criteria, and the identification of verification methods to verify the effective implementation of CW-SAS CGD process.
The NRC inspection team also witnessed the verification of the critical characteristics as part of the CGD of a sample of guide bushing. The NRC inspection team verified that CW-SAS quality control (QC) inspector was adequately following the applicable procedures and documenting the inspection results. In addition, the NRC inspection team confirmed that CW-SAS QC inspector was using calibrated equipment to take the appropriate measurements.
The NRC inspection team also discussed CGD program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
- b. Observations and Findings During the review of a sample of commercial-grade surveys, the NRC inspection team noted that the commercial-grade surveys did not consistently provide objective evidence to validate the adequate implementation of the commercial suppliers quality controls over the critical characteristics. The NRC inspection team also noted that the commercial-grade surveys included the review of other areas from the commercial suppliers quality program unrelated to the control of the critical characteristics. During discussions with CW-SAS staff, the NRC inspection team learned that CW-SAS reviews other areas of their commercial suppliers quality program during commercial-grade surveys as they also purchase other components for use in non-nuclear projects. The NRC inspection team discussed with CW-SAS staff that the purpose of a commercial-grade survey is to verify one or more critical characteristics based on the merits of a commercial suppliers quality controls. This verification is accomplished by reviewing the suppliers quality program and procedures that control the critical characteristics and observing the actual implementation of these controls in the manufacturing of items identical or similar to the items being purchased. In addition, a commercial-grade survey should be critical characteristic and item specific. Furthermore, during the review of a sample of POs issued to these commercial suppliers, the NRC inspection team noted that the POs did not invoke the applicable quality manual, procedures, and/or controls applicable to the critical characteristics identified during the commercial-grade survey that should be implemented during the manufacturing process.
The NRC inspection team determined these issues to be minor because CW-SAS performs additional tests and inspections as part of the CGD process, and the results of these tests and inspections demonstrate that the critical characteristics were adequately controlled. CW-SAS initiated Corrective Action Report (CAR) No. 2022-0046 to address this issue.
9 c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its CGD program in accordance with the regulatory requirements of Criterion III and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CW-SAS is implementing its policies and procedures associated with the CGD program. No findings of significance were identified.
4.
Supplier Oversight a.
Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its supplier oversight program to verify compliance with the regulatory requirements of Criterion IV, Procurement Document Control, and Criterion VII of Appendix B to 10 CFR Part 50.
The NRC inspection team reviewed CW-SAS program for the development and maintenance of its approved suppliers list (ASL). The NRC inspection team selected a sample of suppliers to review the methodology for conducting and documenting audits and the review of third-party audits to verify adequate evaluation of the suppliers controls for meeting the applicable requirements of Appendix B to 10 CFR Part 50. The NRC inspection team verified that for a sample of POs, CW-SAS adequately invoked the applicable technical, regulatory, and quality requirements. The NRC inspection team also reviewed CW-SAS process for conducting audits at an established frequency and verified that the audit reports provided adequate objective evidence of compliance with the applicable requirements. Audit findings were documented and resolved in the CW-SAS and the suppliers corrective action programs. In addition, the NRC inspection team verified that the audits were performed by qualified personnel.
The NRC inspection team also discussed the supplier oversight program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings During the review of a sample of supplier audits and the ASL, the NRC inspection team noted that CW-SAS had not performed annual evaluations for five suppliers that had recent POs issued. CW-SAS procedure SASINST 4200.1a, Management of the Approved Suppliers List, Supplier Audits, and Supplier Selection, dated December 22, 2022, requires suppliers to be evaluated on an annual basis using the template in Appendix A, Supplier Annual Evaluation, of the procedure.
The NRC inspection team determined this issue to be minor because CW-SAS performs additional tests and inspections as part of the receipt inspection process, and the results of these tests and inspections provide reasonable assurance that the suppliers are providing products that meet the applicable requirements. CW-SAS initiated CAR No.
2022-0047 to address this issue.
10 c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its supplier oversight program in accordance with the regulatory requirements of Criterion IV and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that CW-SAS is adequately implementing its policies and procedures associated with the supplier oversight program. No findings of significance were identified.
5.
Identification and Control of Materials, Parts, and Components
- a. Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its material identification and control program to verify compliance with the regulatory requirements of Criterion VIII, Identification and Control of Materials, Parts, and Components, of Appendix B to 10 CFR Part 50. The NRC inspection team also observed implementation of the material identification and control program by CW-SAS employees during in-process fabrication activities including receipt inspection, special testing, storage and inventory control, and machining. The NRC inspection team verified that all materials inspected were adequately marked with appropriate lot, batch and/or heat numbers using the markings and labeling conventions in accordance with written procedures and instructions.
The NRC inspection team discussed the material identification and control program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its material identification and control program in accordance with the regulatory requirements of Criterion VIII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and direct observation of material control practices in the manufacturing facility, the NRC inspection team also determined that CW-SAS is adequately implementing its policies and procedures associated with the material identification and control program. No findings of significance were identified.
6.
Manufacturing Control and Special Processes
- a. Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its manufacturing control program to verify compliance with the regulatory requirements of Criterion IX, Control of Special Processes, of Appendix B to 10 CFR Part 50 and the American Society for Nondestructive Testing (ASNT) SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing.
11 During the week of the inspection, there were no safety-related welding or non-destructive examination (NDE) activities being performed. As such, the NRC inspection team reviewed a completed weld procedure specification (WPS) and supporting procedure qualification record (PQR) for a bracket actuator. This is the only safety-related welding performed by CW-SAS since the facility started operating in 2020. The NRC inspection team verified that the applicable welding data was adequately recorded in the WPS and PQR (e.g., procedures used, type of weld filler material, etc.).
The NRC inspection team reviewed CW-SAS process for controlling weld filler metal.
The NRC inspection team also performed a walk-down of the weld storage area and confirmed that weld filler materials were adequately controlled to prevent degradation, inadvertent use, or loss of traceability. The weld filler materials were kept in containers and ovens at specified temperatures to control moisture, as applicable, and the environmental condition of the weld filler material storage facility was adequately controlled. In addition, the NRC inspection team reviewed the associated welder performance qualification records and confirmed the welder had completed the required training and had maintained his qualification in accordance with CW-SAS procedures.
The NRC inspection team reviewed a sample of procedures and test reports associated with magnetic particle testing (MT) and visual testing (VT) for a bracket actuator and a valve bonnet, as applicable. The NRC inspection team confirmed that the NDE reports contained the required information in accordance with CW-SAS NDE procedures. In addition, the NRC inspection team reviewed the qualification records for the Level II inspector who performed the MT and VT and confirmed that she was qualified in accordance with the requirements of ASNT SNT-TC-1A.
The NRC inspection team also discussed the manufacturing control program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its manufacturing control program in accordance with the regulatory requirements of Criterion IX of Appendix B to 10 CFR Part 50 and the requirements of ASNT SNT-TC-1A. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CW-SAS is implementing its policies and procedures associated with the manufacturing control program. No findings of significance were identified.
7.
Control of Measuring and Test Equipment a.
Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its measuring and testing equipment (M&TE) program to verify compliance with the requirements of Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50.
12 Most of CW-SAS calibration services are performed by a single calibration supplier.
This supplier has a full-time staff at the CW-SAS facility. The NRC inspection team noted that this supplier is included in CW-SAS ASL for calibration services and is accredited to the 2017 edition of the International Standard Organization (ISO)/
International Electrotechnical Commission (IEC) Standard 17025, General Requirements for the Competence of Testing and Calibration Laboratories. In addition to this main supplier, CW-SAS maintains other calibration suppliers in their ASL that are also accredited to ISO/IEC 17025-2017. The NRC inspection team confirmed that CW-SAS performs CGD of calibration services in accordance with the requirements of the Nuclear Energy Institute (NEI)14-05A, Guidelines for the use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated September 11, 2020.
The NRC inspection team performed a walkdown of CW-SAS M&TE area and selected a sample of M&TE for review. The NRC inspection team verified the M&TE were labeled, handled, and stored in a manner that indicated the calibration status of the instrument and ensured its traceability to calibration test data. The NRC inspection team also verified that the M&TE had been calibrated, adjusted, and maintained at prescribed intervals prior to use. In addition, the NRC inspection team confirmed that for the calibration records reviewed, the records indicated the as-found or as-left conditions, accuracy required, calibration results, calibration dates, and the due date for recalibration. Furthermore, the NRC inspection team also verified that the selected M&TE was calibrated using procedures traceable to known industry standards.
The NRC inspection team performed a walkdown of the area assigned to their main calibration supplier. The NRC inspection team selected a micrometer that was placed on a rack labeled Out of Calibration for further evaluation. The NRC inspection team noted that this item was tagged, segregated, and separated from the rest of the calibrated equipment. CW-SAS explained the process followed when items are found out of calibration, how these issues are documented, tracked, and items are segregated.
CW-SAS issues corrective actions and performs an extent of condition to identify items that have been accepted using this equipment since the last valid calibration date.
The NRC inspection team also discussed the M&TE program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings During the review of a sample of POs issued to a commercial calibration laboratory, the NRC inspection team noted that, contrary to CW-SAS calibration procedures and the requirements of NEI 14-05A Revision 1, two calibration certificates from one of CW-SAS calibration suppliers did not include a statement that the calibration was provided in accordance with PO requirements. The NRC inspection team considered this issue to be minor since the calibration laboratory is accredited to ISO/IEC-17025:2017 and all the other conditions from Revision 1 of NEI 14-05A were met. CW-SAS initiated CAR No.
2022-0048 to address this issue.
13 c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its M&TE program in accordance with the regulatory requirements of Criterion XII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CW-SAS is implementing its policies and procedures associated with the M&TE program. No findings of significance were identified.
8.
Test Control
- a. Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its test control program to verify compliance with the regulatory requirements of Criterion XI, Test Control, of Appendix B to 10 CFR Part 50.
During the week of the inspection, there were no safety-related testing activities being performed. The CW-SAS facility started operation in 2020 and is still setting up some larger testing operations. As such, the NRC inspection team reviewed a sample of completed hydrostatic test reports for a packing assembly and gland assembly cases.
The NRC inspection team verified that the hydrostatic test reports included the acceptance range and documented the equipment used to document the results.
The NRC inspection team reviewed CW-SAS process for pre-testing and setup of hydrostatic testing. The NRC inspection team also performed a walk-down of the test setup for hydrostatic testing and other equipment expected to be operational at the facility. In addition, the NRC inspection team discussed the qualification of personnel performing testing.
The NRC inspection team also discussed the test control program with CW-SAS management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
- b. Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its test control program in accordance with the regulatory requirements of Criterion XI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that CW-SAS is implementing its policies and procedures associated with the test control program. No findings of significance were identified.
14 9.
Nonconforming Materials, Parts, or Components and Corrective Action Program a.
Inspection Scope The NRC inspection team reviewed CW-SAS policies and implementing procedures that govern the implementation of its nonconformances and corrective action programs to verify compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50. The NRC inspection team verified that CW-SAS processes and procedures provide for the identification, documentation, segregation, evaluation, and disposition of nonconforming items. These processes also apply the principles of rework/repair, scrap, return to vendor, or use as-is.
The NRC inspection team observed CW-SAS assembly floor operations and verified that nonconforming materials, parts or components were properly identified, marked, and segregated, when practical, to ensure that they were not reintroduced into the production processes. The NRC inspection team reviewed a sample of nonconforming reports (NCRs) associated with the production of safety-related parts and confirmed that CW-SAS: (1) dispositioned the nonconforming materials in accordance with the applicable procedures; (2) documented an appropriate technical justification for the dispositions; and (3) took adequate corrective action regarding the nonconforming items to prevent recurrence, as appropriate.
Additionally, the NRC inspection team discussed the nonconformance program with CW-SAS personnel to verify they were cognizant of program requirements, designated areas to segregate and control nonconforming materials, parts, or components, and that they actively used the nonconforming materials reporting process to identify and document any nonconforming conditions.
The NRC inspection team also reviewed a sample of CARs and confirmed: (1) there was adequate documentation and a description of conditions adverse to quality; (2) an appropriate analysis of the cause of these conditions and the corrective actions taken to prevent recurrence; (3) direction for review and approval by the responsible authority; (4) a description of the current status of the corrective actions; and (5) the follow-up actions taken were verified to be timely and that effective implementation of the corrective actions had been implemented. In addition, the NRC inspection team confirmed that there was adequate connection between the nonconformance, corrective action, and CW-SAS 10 CFR Part 21 program to assure conditions adverse to quality were appropriately considered for 10 CFR Part 21 applicability.
The NRC inspection team also discussed the nonconformance and corrective action programs with CW-SAS management and technical personnel. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
15 c.
Conclusion The NRC inspection team concluded that CW-SAS is implementing its nonconformance and corrective action programs in accordance with the regulatory requirements of Criterion XV and XVI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that CW-SAS is implementing its policies and procedures associated with the nonconformance and corrective action programs. No findings of significance were identified.
- 10. Entrance and Exit Meetings On March 14, 2022, the NRC inspection team presented the inspection scope during an entrance meeting with Ms. Mary Workoff, CW-SAS General Manager, and other members of CW-SAS management and technical staff. On March 18, 2022, the NRC inspection team presented the inspection results to Ms. Workoff and other members of CW-SAS management and technical staff. The attachment to this report lists the attendees of the entrance and exit meetings, as well as those individuals whom the NRC inspection team interviewed.
Att-1 ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Position Affiliation Entrance Exit Interviewed Mary Workoff General Manager Curtis-Wright Steam and Air Solutions (CW-SAS)
X X
Bob Shepard Director New Equipment CW-SAS X
X Adriana Welsh Director of After Market CW-SAS X
Shane Sablotsky Quality Assurance (QA) Manager CW-SAS X
X X
Tom Frost Director of Operations CW-SAS X
TJ Hines Manager of QA and Testing CW-SAS X
X Brian Fogarty Sr. QA Engineer CW-SAS X
Ron Burdick Senior Nuclear Quality Engineer CW-SAS X
X X
Todd Johnson Product Engineer CW-SAS X
X Caitlin Burley Lead Quality Control (QC)
Inspector CW-SAS X
Sean Pexton Welding Engineer CW-SAS X
Scott Rennick Regulatory Compliance Engineer CW-SAS X
X X
Joe Cabaup QC Supervisor CW-SAS X
Eric Cotton Purchasing CW-SAS X
X X
Greg Galletti Inspector NRC X
X Yamir Diaz-Castillo Inspector NRC X
X Frankie Vega Inspector NRC X
X Andrea Keim Inspector NRC X
X
Att-2 Name Position Affiliation Entrance Exit Interviewed Kerri Kavanagh Branch Chief NRC X
2.
INSPECTION PROCEDURES USED:
Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated January 27, 2017 IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated May 16, 2019
- 3. DOCUMENTS REVIEWED
Curtis-Wright Steam and Air Solutions (CW-SAS) Quality Management System Manual, Revision D, dated September 30, 2021
Document No. 004-120-501, Qualification and Certification of Nondestructive Testing Personnel Steam and Air Solutions, Revision 13, dated December 8, 2021
Document No. 004-161-300, Inspection to Nonconformance, Revision C, dated January 14, 2022
Document No. EA-001, Engineering Design Control, Revision R, dated September 15, 2020
Document No. NNSOP-1-1-008, Control and Dispersal of Welding Filler/Electrode, Revision R, dated January 19, 2022
Document No. NNSOP-1-1-010, Welding Procedure and Welder Qualification Control, Revision L, dated November 30, 2021
Document No. NNSOP-1-1-011, Commercial Grade Dedication, Revision 6, dated September 20, 2007
Document No. NNSOP-1-1015, Visual Acuity Requirements and Testing, Revision 11, dated October 7, 2020
Document No. NNSOP-1-1025, Part Dedication and Inspection Record Control, Revision 11, dated May 15, 2018
Document No. NNSOP-1-2-002, Engineering Change Notice Navy and Nuclear Products, Revision 14, dated November 29, 2012
Document No. NNSOP-1-2-003, Engineering Change Request Commercial Navy and Nuclear Products, Revision 7, dated October 14, 2014
Att-3
Document No. NNSOP-1-2-016, Part Configuration Review, Revision 5, dated March 8, 2017
Document No. NNSOP-1-2-018, Part Qualification and Design Documentation, Revision 8, dated December 1, 2009
Document No. NNSOP-1-2-019, Generation and Control of Engineering Design Documents, Revision 6, dated May 15, 2018
Document No. NNSOP-1-3-004, Welding Quality Record Instructions, Revision 6, dated September 1, 2021
Document No. NNSOP-1-6-001, Order Entry and Processing for Nuclear Parts Marketing Orders, Revision 17, dated March 2, 2018
Document No. NNSOP-4-009, Design Basis Qualification Report Index, Nuclear CCS-CS, ZS, GS Frames, Revision 2, dated February 4, 2008
Document No. NNSOP-1-2-001, Reporting Defects and Noncompliance 10CFR21 Part 21 of Title 10 of the Code of Federal Regulations for Nuclear Turbines, Revision 20, dated November 17, 2017
Document No. PS-0701, Post Weld Heat Treatment of Ferrous Weldments and Stress Relief of Material Stock and Semi-Finished Components, Revision H, dated June 29, 2018
Document No. QA5-25.SC0340050, Calibration Program - Curtis-Wright Corporation SAS - SC0340050, Revision 3, dated June 2021
Document No. SASINST 4200.1a, Management of the Approved Supplier List, Supplier Audits, and Supplier Selection, Revision A, dated December 22, 2020
Document No. SASINST 4122.2a, Guidelines for Processing Purchase Orders, dated August 24, 2020
Document No. SASINST 4122.20b, Supplier Selection and Proposal Evaluation, dated April 12, 2021
Document No. SASINST 4734.1d, Measuring and Test Calibration, Revision D, dated March 8, 2022
Document No. SASINST 7520.1e, Audits and Surveillances, Revision E, dated May 13, 2021
Document No. SS-3072, Magnetic Particle Inspection of Plate Edges, Revision J, dated September 24, 2021
Document No. SS-9307, Hydrostatic Testing Procedure, Revision R, dated March 14, 2022
Att-4
Document No. SASINT 0288.1b, Quality Event System, dated August 23, 2021
Document No. 004-161-300, Inspection to Nonconformance, Revision C, dated January 14, 2022
Document No. IPM-005-024, Fraudulent Product - Document and Material Inspection, Revision 0, dated July 16, 2009
Document No. SS-3040, Traceability and Material Control, Revision T, dated November 22, 2021
Document No. 6050823, Parts Marking Spec, Revision L, dated July 6, 2021
Purchase Order (PO) No. 906124 for a spring compression, Revision 3, dated October 18, 2021
PO No. 907298 for a guide bushing, Revision 2, dated January 14, 2022
PO No. 906242 for a carbon ring, Revision 1, dated January 14, 2022
PO No. 906760 for a relay AC or DC, Revision 3, dated January 28, 2022
PO No. 907218 for calibration services, dated January 6, 2022
PO No. 906028 multiple items including Woodward Governor 505 Digital, EMC Filter and Power Supply, Change Notice 5, dated January 19, 2022
PO No. 906028 for Filter, Revision 4, dated February 3, 2022
PO No. 905702 for a waldron coupling, Revision 3, dated August 24, 2021
PO No. 907621for an element filter schroeder, dated February 9, 2022
PO No. 905348 for a solenoid valve, Revision 4, dated August 23, 2021
PO No. 906760 for a relay, Revision 3, dated January 28, 2022
PO No.907231 for repair PQ005682, Revision 1, dated March 3, 2022
PO No. 908082 for repair PQ005597, Revision 1, dated March 18, 2022
CW-SAS Approved Suppliers List, dated February 7, 2022
Certification of Conformance/Compliance (CoC) for a spring compression, Part No.
105594A02, dated December 8, 2021
CoC for a carbon ring, Part No. 6894, dated January 26, 2022
CoC for a hydraulic cylinder, Part No. 890412-001, dated September 30, 2020
Att-5
CoC for a stop packing ring, Part No.12887, dated March 31, 2021
CoC for a relay AC or DC, Part No. 75899A02, dated February 16, 2022
Certified Material Test Report for a guide bushing, material specification N4264, Revision B (ASTM A276 - Grade 440C), Heat No. 430612, dated January 27, 2022
Hydrostatic Test Report for Order No. C2362333 (AAB2395), dated March 10, 2021
Hydrostatic Test Report for Order No. C2362333 (AAB2396), dated March 10, 2021
Hydrostatic Test Safety Checklist for Job No. 1173941, dated February 21, 2022
Hydrostatic Test Report for Order No 1173941, dated February 21, 2022
Hydrostatic Test Safety Checklist for Job No. 1174005, dated February 21, 2022
Hydrostatic Test Report for Order Number 1174005, Case Gland Assembly, dated February 21, 2022
Part Inspection Record for a spring compression, Part No. 105594A02, dated December 9, 2021
Part Inspection Record for a carbon packing ring stop, Part No. 12887, dated March 8, 2021
Part Inspection Record for a guide bushing, Part No. 79344A01, dated March 15, 2021
Part Inspection Record for a carbon ring, Part No. 6894, dated December 16, 2021
Part Inspection Record for a sliding nut, Part No. 108017A19, dated December 3, 2020
Part Inspection Record for a hydraulic cylinder, Part No. 890412-001, dated September 12, 2020
Part Inspection Record for a stop packing ring, Part No. 12887, dated March 9, 2021
Part Inspection Record for a relay AC or DC, Part No. 75899A02, dated February 15, 2022
Positive Material Identification Record for a carbon packing stop, Part No. 12887, dated March 8, 2021
Positive Material Identification Record for a guide bushing, Part No. 79344A01, dated February 25, 2022
Commercial-grade survey report No. SAS 21-04 of a supplier of springs, dated May 5, 2021
Att-6
Commercial-grade survey report No. CW-SAS 20-02 of a supplier of guide bushings, dated July 2, 2020
Commercial-grade survey report No. SAS 21-09 of a supplier of sliding nut, dated June 10, 2021
Commercial-grade survey report No. DR 18-17 of a supplier of carbon rings, dated July 27, 2018
Engineering Part Qualification and Design Record for a guide bushing, Part No.
79344A01, Revision G, dated November 11, 2021
Engineering Part Qualification and Design Record for a carbon ring, Part No. 6894, Revision L, dated December 7, 2020
Engineering Part Qualification and Design Record for a sliding nut, Part No. 108017A19, Revision F, dated April 18, 2006
Engineering Part Qualification and Design Record for a hydraulic cylinder, Part No.
890412-001, Revision 00, dated January 31, 2012
Engineering Part Qualification and Design Record for a spring compression, Part No.
105594A02, Revision U, dated April 17, 2020
Engineering Part Qualification and Design Record for a carbon packing ring stop, Part No. 12887, Revision D, dated February 9, 2021
Engineering Part Qualification and Design Record for a drive shaft, Part No.58179
Engineering Part Qualification and Design Record for a valve bonnet, Part No.57878
Engineering Part Qualification and Design Record for a washer, Part No.800738-001
Engineering Part Qualification and Design Record, valve bonnet assembly, Part No.800491-709
Engineering Part Qualification and Design Record for a packing retainer plate, Part No.800820-001
Engineering Part Qualification and Design Record for a cap screw, Part No. 75234A03
Engineering Part Qualification and Design Record for a carbon spacer, Part No. 800714-002
Engineering Part Qualification and Design Record for an internal retaining ring, Part No.890352-001
Engineering Part Qualification and Design Record for a valve bonnet, Part No.800825-003
Att-7
Engineering Part Qualification and Design Record, valve bonnet sleeve, Part No.800408D02
Valve Bonnet Assembly Drawing No. 801518
Valve Bonnet Assembly Drawing No. 800491
Hardness Exam Report for a guide bushing, Part No. 79344A01, dated March 15, 2022
Drawing No. F-1881, Stop, Packing Ring, Revision E, dated March 12, 2021
Lead Auditor Qualification Record, dated December 30, 2019
Document No. NNSOP-1-1-002 CERT, Level 2B Inspection Certification, Revision 1, dated April 8, 2020, qualification as a Level II B Quality Inspector, date of the Certificate of Qualification is July 16, 2020
Visual Acuity Examination Record, dated August 6, 2021
Magnetic Particle Testing Level II Qualification and Certification Record, Certification Date May 4, 2021
Visual Testing Level II Qualification and Certification Record, Certification Date April 19, 2021
Magnetic Particle Examination Record for a valve bonnet, item No. 57878, Revision AB, dated July 12, 2021
Magnetic Particle Examination Record for a bracket actuator, item No. 801363-701, Revision B, dated August 9, 2021
Visual Examination Record for a bracket actuator, item No. item No. 801363-701, Revision B, dated August 9, 2021
Penetrant Testing Level II Qualification and Certification Record, Certification Date April 19, 2021
Welder Performance Qualification (WPQ) Record, WPQ No. W10.1-10 W005, dated April 16, 2021
Technical Evaluation for ISO17025:2017 Accredited Calibration Service Providers, Documented Accreditation Certificate Review for Acceptance of Calibration and Testing Services, dated October 12, 2020
Calibration Supplier Program - CW Corporation SAS - SC0340050, dated June 2021
Certificate of Calibration No. 20228410, dated February 25,2022
Certificate of Calibration No. 316798-659961, Revision 1, dated May 28, 2021Certificate of Calibration No. 332202-545069, Revision 1, dated December 21, 2021
Att-8
Certificate of Calibration No.1026586-202140229, dated August 25, 2021
Certificate of Calibration No.1 20225476, dated February 8, 2022
Certificate of Calibration No.1030113-2022869, dated January 10, 2022
Certificate of Calibration No. 202210431, dated March 9, 2022
Certificate of Calibration No. 333173-812564, dated January 11, 2022
Certificate of Calibration No. 321437-6999048, dated August 11, 2021
Certificate of Calibration No. 3315028-639333, dated May 6, 2021
Certificate of Calibration No. 314585-633780, dated May 3, 2021
Certificate of Calibration No. 314585-633779, Revision 1, dated May 3, 2021
Audit Plan DR 19-09, dated July 1, 2019
Audit Checklist Audit No. 19-09, dated July 10, 2019
Audit Report No. DR 19-09, dated September 30, 2019
Nuclear Industry Assessment Corporation (NIAC) Audit No. 27008, dated January 28, 2022
CW-SAS Evaluation of NIAC Audit No. 27008, dated February 7, 2022
NIAC Audit No. 24034, dated March 20, 2019
CW-SAS Evaluation of NIAC Audit No. 24034, dated May 28, 2021
NIAC Audit No. 26004, dated June 30, 2021
CW-SAS Evaluation of NIAC Audit No. 26004, dated March 11, 2022 Corrective Action Reports (CARs) Opened During the NRC Inspection
Att-9 CARS Reviewed During the NRC Inspection
CAR 2021-0130, dated September 14, 2021
CAR-2020-0152, dated October 16, 2020
CAR-2021-0014, dated January 20, 2021
CAR-2021-0038, dated March 11, 2021
CAR-2021-0084, dated June 21, 2021
CAR-2021-0091, dated July 1, 2021
CAR-2021-0104, dated August 6, 2021
CAR-2021-0126, dated September 7, 2021
CAR-2021-0171, dated December 9, 2021
CAR-2022-0010, dated January 14, 2021