ML22199A043

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Vendor Inspection Report of Westinghouses Quality Assurance Program and 10 CFR Part 21 Program Implementation in Cranberry Township, PA
ML22199A043
Person / Time
Site: 99900404
Issue date: 07/22/2022
From: Kerri Kavanagh
NRC/NRR/DRO/IQVB
To: Glenn G
Westinghouse, Global Operations Services
A. Keim, 301-415-1671
References
EPID I-2022-201-0027 IR 2022201
Download: ML22199A043 (14)


Text

Greg T. Glenn Licensing Engineering Westinghouse Electric Company Global Operations Services 1000 Westinghouse Drive Cranberry Township, PA 16066

SUBJECT:

NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF WESTINGHOUSE ELECTRIC COMPANY, NO. 99900404/2022-201

Dear Mr. Glenn:

On June 6 - 10, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Westinghouse Electric Company (WEC) facility in Cranberry Township, PA.

This limited-scope routine inspection assessed WECs compliance with provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and selected portions of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

This technically-focused inspection specifically evaluated WECs implementation of the quality activities associated with the design, testing and analysis of safety-related fuel assemblies being supplied to U.S. nuclear power plants. The enclosed report presents the results of the inspection. This NRC inspection report does not constitute NRC endorsement of WECs 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 NRC's "Rules of Practice," a copy of this letter, and its enclosure(s), will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs July 22, 2022

G. Glenn Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions concerning this matter, please contact Ms. Andrea Keim of my staff at (301) 415-1671.

Sincerely, Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99900404 EPID: I-2022-201-0027

Enclosure:

Inspection Report No. 99900404/2022-201 and Attachment Signed by Kavanagh, Kerri on 07/22/22

ML22199A043 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DSS/SFNB NRR/DRO/IQVB NAME AKeim PPrescott JKaizer Kkavanagh DATE 07/19/2022 07/20/2022 07/21/2022 07/22/2022 Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NEW REACTORS DIVISION OF CONSTRUCTION INSPECTION AND OPERATIONAL PROGRAMS VENDOR INSPECTION REPORT Docket No.:

99900404 Report No.:

99900404/2022-201 Vendor:

Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066 Vendor

Contact:

Mr. Greg T. Glenn Email: glenngt@westinghouse.com Phone: (412) 374-6974 Nuclear Industry Activity:

Westinghouse Electric Company (WEC) provides nuclear fuel and fuel analyses as well as other engineering and design services for new and operating nuclear reactors.

Inspection Dates:

June 6 - 9, 2022 Inspectors:

Andrea Keim NRR/DRO/IQVB, Team Leader Paul Prescott NRR/DRO/IQVB*

Joshua Kaizer NRR/DSS/SFNB Reed Anzalone NRR/DANU/UTB2*

  • Performed inspection remotely Approved by:

Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation EXECUTIVE

SUMMARY

Westinghouse Electric Company 99900404/2022-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a vendor inspection at the Westinghouse Electric Company (WEC) facility in Cranberry Township, PA, to verify that 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, 10 CFR Part 21, Reporting of Defects and Noncompliance.

This technically-focused inspection specifically evaluated WECs implementation of the quality activities associated with the design, testing and analysis of safety-related fuel assemblies being supplied to U.S. nuclear power plants.

The following regulations serve as the bases for the NRC inspection:

Appendix B to 10 CFR Part 50

10 CFR Part 21 During this inspection, the NRC inspection team used the following Inspection Procedures (Ips):

IP 43002, Routine Inspections of Nuclear Vendors, dated April 5, 2022; and IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated May 16, 2019.

The NRC inspection team concluded that WECs QA policies and procedures comply with the applicable requirements of Appendix B to 10 CFR Part 50 and 10 CFR Part 21, and that WECs personnel are implementing these policies and procedures effectively. The results of this inspection are summarized below.

Design Control and Test Control The NRC inspection team reviewed a sample of WECs calculation notes, guidance, issue reports, and internal correspondence associated with assessing critical heat flux (CHF) correlations to verify compliance with the regulatory requirements of Criterion III, Design Control, and Criterion XI, Test Control, of Appendix B to 10 CFR Part 50. The NRC inspection team verified the technical adequacy of the identification, impact, and safety assessment of the ODEN 12 test data on WEC critical heat flux correlations. No findings of significance were identified.

10 CFR Part 21 The NRC inspection team reviewed WECs 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) verified that WECs nonconformance and corrective action programs provide a link to the 10 CFR Part 21 program; and (2) reviewed a sample of 10 CFR Part 21 evaluations that also included Significant Condition Adverse to Quality [SCAQ] of High Significance in Quality Impact evaluations and Significant Condition Adverse to Quality of High Significance in Nuclear Regulatory Impact, performed by WEC. The NRC inspection team also verified that WECs nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program. No findings of significance were identified.

Corrective Action The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its corrective action program to verify compliance with the requirements of Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50. The NRC inspection team also reviewed a sample of corrective action issue reports (Irs) and confirmed the corrective action Irs were adequately reviewed, implemented, and approved by appropriate personnel in a timely manner. No findings of significance were identified.

REPORT DETAILS 1.

Design Control and Test Control a.

Inspection Scope The U.S. Nuclear Regulatory Commission (NRC) inspection team reviewed WECs policies and implementing procedures that govern the implementation of its design control program to verify compliance with the requirements of Criterion III, Design Control, and Criterion XI, Test Control, of Appendix B to 10 CFR Part 50, 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. The NRC inspection team reviewed and evaluated a sample of design documentation associated with the evaluation of critical heat flux (CHF) data from the ODEN 12 tests. Specifically, the NRC inspection team reviewed WECs calculation notes, guidance, issue reports, and correspondence associated with the identification, impact, and safety assessment of specific critical heat flux correlations.

WEC issued a Nuclear Safety Advisory Letter (NSAL) 14-5, Lower Than Expected Critical Heat Flux Results Obtained During Departure from Nucleate Boiling Testing, on June 17, 2014, to inform customers about the discovery of a potential non-conservative sub-region in applicable ranges of some WEC CHF correlations. As discussed in a letter to the NRC from WEC dated June 6, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML17159A439)), WEC performed the ODEN 12 tests to obtain data in this sub-region where experimental data was lacking.

The NRC inspection team, reviewed WEC engineering documentation on their CHFs correlations uncertainty in this sub-region. In addition, the NRC inspection team reviewed, the WEC 2016 assessment demonstrating that even under the most severe assumptions about the CHF correlations performance, there was sufficient margin to CHF. The NRC inspection team reviewed new ODEN test data that would be used to quantify the correlations uncertainty in that sub-region.

The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings The NRC inspection team reviewed WECs analysis of the new ODEN data. The NRC inspection team found that WEC appropriately dispositioned the data in an appropriate time frame. Even though the new data revealed that the estimate of the CHF correlations uncertainties were initially underpredicted in 2016, that 2016 analysis showed that there was still sufficient margin to account for the new higher uncertainties and the use of the CHF correlation would remain acceptable.

The NRC inspection team also reviewed corrective action reports related to the ODEN 12 data, CHF correlations developed with this data, and their future application. These corrective actions reports are still in-process, therefore, the NRC inspection team could not review the resolution. However, the NRC inspection team did review the actions taken and the steps to resolve the item. The NRC inspection team found that WEC is taking appropriate action to incorporate the test data and address the CHF correlations in the sub-region.

c.

Conclusion The NRC inspection team concluded that WEC is implementing its design control and test control 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 and activities observed, the NRC inspection team determined that WEC is implementing its policies and procedures associated with design control and test control. WEC is in the process of analyzing the ODEN 12 test data and updating of CHF correlations; therefore, the NRC inspection team was unable to review the final resolution. However, the NRC inspection team determined WEC is taking appropriate action to incorporate the test data and address the CHF correlations. No findings of significance were identified.

2.

10 CFR Part 21 a.

Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its 10 CFR Part 21, Reporting of Defects and Noncompliance, program to verify compliance with the regulatory requirements. The NRC inspection team: (1) verified that WECs nonconformance and corrective action programs provide a link to the 10 CFR Part 21 program; and (2) reviewed a sample of 10 CFR Part 21 evaluations that also included Significant Condition Adverse to Quality of High Significance in Quality Impact and Significant Condition Adverse to Quality of High Significance in Nuclear Regulatory Impact, evaluations performed by WEC. The NRC inspection team also verified that WECs nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program.

In addition, for a sample of 10 CFR Part 21 evaluations performed by WEC, the NRC inspection team verified that WEC had effectively implemented the requirements for evaluating deviations and failures to comply. The NRC inspection team verified that notifications were issued to customers in accordance with the requirements of 10 CFR 21.21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, as applicable.

The NRC inspection team also discussed the 10 CFR Part 21 program with WECs 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.

Conclusions The NRC inspection team concluded that WEC is 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 determined that WEC is implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.

3.

Corrective Action Program a.

Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its corrective action program to verify compliance with the requirements of Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed WECs processes and implementing procedures that provide for the identification, documentation, segregation, evaluation, and disposition of items that are addressed through the corrective action program.

The NRC inspection team reviewed a sample of corrective action issue reports and safety evaluations associated with potential issues related to analytical software to confirm that WECs disposition of the identified issues was in accordance with the applicable procedures and took adequate corrective action to prevent recurrence, as appropriate.

The NRC inspection team also discussed the corrective action program with WECs 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 WEC is implementing its corrective action program in accordance with the regulatory requirements of Criterion XVI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that WEC is implementing its policies and procedures associated with the corrective action. No findings of significance were identified.

4.

Entrance and Exit Meetings On June 6, 2022, the NRC inspection team discussed the scope of the inspection with Jill Redmon, Executive Vice-President, Quality, Environment, Health and Safety, and other members of WECs management and technical staff. On June 9, 2022, the NRC inspection team presented the inspection results and observations during an exit meeting with Jill Redmon, and other members of WECs 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.

Attachment 1.

ENTRANCE/EXIT MEETING ATTENDEES Name Title Affiliation Entrance Exit Interviewed Ken Altemus Vice President, NFE Westinghouse Electric Company (WEC)

X*

X Doug Weaver Vice-President Global Nuclear Regulatory Affairs WEC X*

Greg Glenn Licensing Principal Engineer WEC X

X X

Mathew Symanski Licensing Intern WEC X

X X

Yixing Sung Consulting Engineer WEC X

X X

Brian Beebe CF & SD Director WEC X

X X

Zack Harper Licensing Manger WEC X

X X

Kent Bonadio Manager, Transient Analysis WEC X

X Peter Hilton Fellow Engineer WEC X

X Greg Williams Manager, Fuel Rod &

Thermohydraulic Design (FRTHD)

WEC X*

X Parvez Khambatta Licensing Engineer WEC X*

X X

Mathew Cerrone Manager, Software &

System Technology WEC X

X*

Michael Connor Fellow Engineer WEC X*

X*

Guireng Pan Fellow Engineer WEC X*

Lori Lubic Advanced Project Manager WEC X*

X*

Darrin Smith

Manager, Design & Support WEC X*

X*

Andrew Atwood Manager, Materials &

Fuel Rod Design WEC X*

X*

Camille Zozula Manager/Interim Director Management Systems and Regulatory Comp WEC X*

Name Title Affiliation Entrance Exit Interviewed Michael Anness Director Fuel Innovation WEC X

X*

Brent Jeffcoat Principle Engineer WEC X*

X*

Fredrik Waldemarsson Development Engineer WEC -

Sweden X

Henrik Tejne Manager, Mechanical Construction WEC -

Sweden X

Greg Williams Manager, FRTHD WEC X

X*

Zeses Karoutas Chief Engineer, Nuclear Fuel WEC X*

Olin McRae, III Manager, Innovation PWR Fuel Technology WEC X*

X*

Andrea Sterdis Contract Engineer WEC X*

Michael Corletti Sr Director, Advanced Analysis and Risk Application WEC X*

David Huegel Fellow Engineer WEC X*

X*

Jill Redmon Exec. Vice-President Quality, Environment, Health & Safety WEC X*

X*

John R. Lovre Technician WEC X*

X*

Peter Chan Vice-President, Global Quality WEC X*

Byron Frank Fellow Engineer WEC X*

X*

Sukhwans Singh Principal Engineer WEC X

X*

X Carrie Wood Principal Engineer WEC X*

X*

X*

Dustin Staub Principle Engineer WEC X*

X*

Vincent Penkrot Fellow Engineer WEC X

X*

Paul Evans Fellow Engineer WEC X*

Bill Bordogw Technician WEC X

Dena Litwiler Sr. Manager, D&I WEC X

Kerri Kavanagh Branch Chief Nuclear Regulatory Commission (NRC)

X*

Andrea Keim Inspector NRC X

X Name Title Affiliation Entrance Exit Interviewed Paul Prescott Inspector NRC X*

X*

Joshua Kaizer Inspector/Technical Expert NRC X

X Reed Anzalone Inspector/Technical Expert NRC X*

X*

  • Present via telephone 2.

INSPECTION PROCEDURES USED Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 13, 2012 IP 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017 3.

DOCUMENTS REVIEWED Procedures and Instructions

Westinghouse Quality Management System -A, Revision 8.0, dated May 22, 2020

W2-5.1-101, Westinghouse Corrective Action Program Procedure, Revision 8, dated September 1, 2021

W2-5.1-101.W01, Submitting a Corrective Action Program Issue Report, Revision 2.3, dated January 3, 2022

W2-5.1-101.W02, Screening a Corrective Action Program Issue Report, Revision 3.1, dated January 3, 2022

W2-5.1-101.W03, Issue Review Committee Work Instruction, Revision 4.2, dated January 3, 2022

W2-5.1-101.W08, Corrective Action Review Board Work Instruction, Revision 2.0, dated February 28, 2020

W2-5.1-101.W09, CAP Issue Management Work Instruction, Revision 2.0, dated January 3, 2022

W2-5.1-101.W10, CAP Trending Program Work Instruction, Revision 3.0, dated April 13, 2022

W2-5.1-101.W11, Causal Analysis Work Instruction, Revision 1.1, dated June 30, 2021

W2-5.1-101.W12, CAP Planned Aging Process, Revision 0.1, dated September 1, 2021

W2-5.1-201, Identification and Reporting of Conditions Adverse to Nuclear Safety, Revision 2.1, dated October 6, 2021

W2-5.1-201.W01, Nuclear Safety Review Staff Work Instruction, Revision 2.1, dated April 22, 2020

W2-5.1-201.W02, 10 CFR 21 and 10 CFR 50.55(e) Posting, Revision 0.0, October 6, 2021

W2-8.1-100, Design and Development Process, Revision 0.1, dated February 29, 2016

W2-8.1-101, Design and Development, Revision 3.1, February 27, 2018

W2-8.3-100, Design Analysis and Outputs Process, Revision 0.0, August 15, 2016

W2-8.3-101, Design Analysis, Revision 3.0, dated June 12, 2018 W2-8.4-103, Design Testing, Revision 1.0, dated November 6, 2018

W2-8.5-100, Design Change Control Process, Revision 0.0, dated August 15, 2016

W2-8.6-100, Software and Computer Systems Control Processes, Revision 1.0, dated September 4, 2018

W2-8.6-104, Software Problem Reporting, Revision 1, September 4, 2018

W2-9.14-100, Control of Nonconforming Process Outputs, Products and Services, Revision 2, dated February 27, 2018

W2-9.4-102, Deviation Notices, Revision 2.2, dated March 7, 2022

EP-116, Issue Reporting, Revision 25.0, dated October 30, 2019

EP-201, Test Prospectus and Test Report, Revision 27.4, dated October 30, 2019 Safety Reports, Calculation Notes, Test Data

LTR-SRC-21-18, Nuclear Safety Evaluation for IR 2021-5074, Watts Bar Unit 2 Shield Wall Restraint Shims not Installed, dated July 1, 2021

LTR-SRC-21-25, Nuclear Safety Evaluation for IR 2021-9154, Pellet Lot Nitrogen Exceeds Limit, dated November 5, 2021

LTR-SRC-21-26, Nuclear Safety Evaluation for IR 2021-9812, Cat A STI-29575 STAV7 Calculates the Hot Free Volume Incorrectly, dated December 2, 2021

MT-16-37, Input to Nuclear Safety Assessment - Potential Risk of WRB-2 Over-Prediction of DNBR Margin in 17x17OFA/IFM Thimble Subchannel (CAPAL#

100362765), dated March 8, 2016

ODEN Temperature Traces for 12.2 Runs

BTK-19-0272, ODEN Data Report - CHF Testing of VANTAGE 5 Fuel with IFM Thimble Cell Configuration and Cosine Axial Power Shape ODEN 12.0 and ODEN 12.2, dated June 3, 2019

CF-NF-PE-19-23, VIPRE-W Assessment of Oden 12.0 and 12.2 Test Data with the WRB-2 DNB Correlation - Typical 14-Channel (Plant) and 36-Channel ODEN (5x5 Test)

Models, dated February 19, 2020

CN-GEN-THD-305, Evaluation of ODEN 12 DNB Test Data Using WRB-2 Correlation, dated April 21, 2020

CN-GEN-THD-324 - Draft, Comparison of Rector 14-Channel Correlation Predicted Uniform Critical Heat Flux to Measured Test Data for VANTAGE 5 fuel, dated November 18, 2020

PFT-21-51, Rev 1. Regression results for Local Quality (linear) and the HZb term (Power) for the WOFA and WNG-2 correlation database, dated September 3, 2021

Power Point Presentation, Challenge Points, dated January 2022

Power Point Presentation, Input Uncertainty in PWR CHF Model Development, dated January 2022

CN-GEN-THD-328 - Draft, WOFA DNB Correlation Sensitivity Study for Vantage 5 fuel, dated February 2, 2021

PFT-22-10, Calculation of WTDP DNBR Limits for Correlations with HZb term including WOFA, dated March 17, 2022 Corrective Action Issue Report Opened During the NRC Inspection None Software Technology Issues

Software Technology Issue (STI)-29284/CE-21-046, BYPASS Code Wall Temperature in Pressure Drop Calculation for Non-Isothermal cases dated January 27, 2021

STI-29323/CE-21-119, WARP 1.2.0 Does not allow for Xenon Feedback to be Removed while using the Feedback Input Structure, dated March 2, 2022

STI-29339/CE-21-127, Error in THSCRN Pin Swap Technique when Swapping Pin from Assembly Peripheral to Interior Locations, dated March 9, 2021

STI-29551/CE-21-449, Inconsistent Radial Peak Usage in THSCRNH VIPRE-W Model Setup for Assemblies on the Line of Symmetry, dated August 23, 2021 Corrective Action Reports

Issue Report (IR) 2021-5074, Licensing Basis Analysis for Short Term LOCA Mass and Energy for the Cold Leg Break Area of 127 sq. inches in the DBA Incorrect, dated May 3, 2021

IR 2021-9154, Rejectable Nitrogen Result Recorded for Pellet Lot, dated August 23, 2021

IR 2021-9812, Cat A STI-29575 STAV7 seems to Calculate the Hot Free Volume Incorrectly, dated September 10, 2021

IR 2021-10857, VVER Mid Grid Outer Strap Seam - Unsupported Edge, dated October 5, 2021

IR 2021-3141, Unexplained CFFF LOCA Burst Test Results, dated August 3, 2022

IR 2021-3330, Wolf Creek unable to Implement Updated BEACON nocolr File due to Software Error, dated April 11, 2022

IR 2021-6281, Wrong Placement of Fuel Rods According to Assembling Record, dated June 1, 2021

IR 2022-2866, Non-conservative Critical Heat Flux Predictions with WRB-2 and WRB-2M Correlations for 10-inch Spacing at high inlet temperature and nominal flow conditions, dated March 28, 2022

IR-2022-2365, Non-conservative Critical Heat Flux Predictions at High Inlet Temperatures and Nominal Flow - WSSV, dated March 28, 2022