ML23046A118
| ML23046A118 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/2023 |
| From: | Aaron Armstrong, Odunayo Ayegbusi NRC/NRR/DRO/IQVB |
| To: | |
| References | |
| Download: ML23046A118 (19) | |
Text
Regulatory Update PEARTS - Procurement Engineering and Related Topics Symposium March 2, 2023 New Orleans, LA Aaron Armstrong and Odunayo Ayegbusi Quality Assurance & Vendor Inspection Branch / Office of Nuclear Reactor Regulation
Topics 2
NRC Vendor Inspection Results Update Summary of Commercial-Grade Dedication Inspections at Licensees sites Reaffirmation of NRCs positions on Part 21, Appendix B, and Commercial Grade Dedication NRC position on Risk-Informed Treatment of Structures, Systems, and Components, ASME code case Questions
NRC Vendor Inspection Results Update 3
Since the August 2022 meeting, the NRC has completed 5 vendor inspections:
SAFER PEICo, Memphis, TN (July 2022)
Energy Steel & Supply Company, Rochester Hills, MI (September 2022)
Schulz Electric Company, East Haven, CT (September 2022)
Flowserve Flow Control Division, Lynchburg, VA (October 2022)
Reuter-Stokes LLC., Twinsburg, OH, (November 2022)
NRC Vendor Inspection Results Update 4
Vendor Inspections completed, but not issued:
Curtiss-Wright, QualTech NP, Cincinnati, OH Curtiss-Wright - EMS - Target Rock, Farmingdale, NY Fluke Biomedical Company, Solon, OH
NRC Vendor Inspection Results Update 5
There were 4 findings of significance identified for the above inspections since the August 2022 meeting:
Criterion XVI, Corrective Action Criterion III, Design Control Criterion IV, Procurement Document Control Criterion XVI, Corrective Action
NRC Vendor Inspection Results Update 6
Energy Steel & Supply Company (ESSC)
Inspection Report 99902104/2022-201-01 :
Criterion XVI, Corrective Action NRC inspection team identified that ESSC was not conducting periodic reviews or issuing the monthly status and trend reports to the President. As a result, NCs and CPAs reports are not being promptly addressed. Because ESSC failed to implement corrective actions to address NRC identified Nonconformance 99901098/2009-201-01, the NRC inspection team identified 2 NC and 13 CPA reports that were past the 30 business days due date required by ESSCs procedures.
ESSC performed an internal audit in July of 2022 and identified an audit finding related to 2 NCs and 4 CPAs reports that were past the 30 business days due date. However, ESSC did not initiate a CPA report to address this issue until 2 months after identification
NRC Vendor Inspection Results Update 7
Flowserve Flow Control Division - Limitorque Inspection Report 99900100/2022-201:
Criterion III, Design Control Flowserve Limitorque implemented a material change from 1144 and 1141 steel bar to 4140 steel bar for several internal components of the Limitorque actuators including the stem nut and the drive sleeve. Flowserve Limitorque concluded that the material change had no adverse effect on the existing environmental qualifications.
However, the NRC inspection team identified that Flowserve Limitorque did not evaluate how the thermal properties of the material, such as the thermal coefficient of expansion, might impact the performance of the internal components.
NRC Vendor Inspection Results Update 8
Flowserve Flow Control Division - Limitorque Inspection Report 99900100/2022-201:
Criterion IV, Procurement Document Control The NRC inspection team identified that Flowserve Limitorque did not issue procurement documents with the applicable technical, quality, and regulatory requirements to the vendors that perform calibration services at Flowserve Limitorques facility for measuring and test equipment that will be used in safety-related activities.
NRC Vendor Inspection Results Update 9
Flowserve Flow Control Division - Limitorque Inspection Report 99900100/2022-201:
Criterion XVI, Corrective Action The NRC inspection team identified that while Flowserve Limitorque performed a commercial-grade survey of the OEMs test facility, Flowserve Limitorques revised documentation did not identify motor torque as a critical characteristic to be measured and did not verify the motor output torque conformed to the associated speed-torque curves for DC motors.
Summary of Commercial-Grade Dedication Inspections at Licensees sites 10 Inspection Procedure IP71111.21N.03 is being revised:
Updating revisions of guidance referenced in the IP (EPRI 3002002982, adding RG 1.250)
Incorporated feedback from first inspections -
Clarity and emphasis for the information request (Appendix B of the Inspection Procedure)
Revision available March 2023
Summary of Commercial-Grade Dedication Inspections at Licensees sites 11 First two inspections completed the week of February 13th at Grand Gulf and Cooper.
NRC will hold cross-regional review panels before the inspection reports are issued.
Technical issues have been observed The final inspection reports for Cooper and Grand Gulf will be in in April 2023 Next inspections are:
March - Hope Creek and Catawba April - Davis Besse
Reaffirmation of NRCs positions on Part 21, Appendix B, and Commercial Grade Dedication 12 NRCs positions on 10 CFR PART 21 reporting:
Available Guidance:
REGULATORY GUIDE 1.234, Evaluating Deviations And Reporting Defects And Noncompliance Under 10 CFR Part 21, Revision 0 (ML17338A072)
NEI 14-09, Guidelines for Implementations of 10 CFR Part 21 Reporting of Defects and Noncompliance, REVISION 1 (ML16054A825)
NRC staff has determined that NEI 14-09 provides an adequate basis for complying with the requirements of 10 CFR Part 21 with the following clarifications:
For design certification rule (DCR) applicants and combined operator license (COL) holders, the DCR applicant is considered the supplier and the COL holder the purchaser while using the guidance of NEI 14-09.
Reaffirmation of NRCs positions on Part 21, Appendix B, and Commercial Grade Dedication 13 NRCs positions on 10 CFR PART 21 reporting requirements in conjunction with 10 CFR 50.72, 10 CFR 50.73 and 10 CFR 73.71 10 CFR Part 21 states:
(c) For persons licensed to operate a nuclear power plant under part 50 or part 52 of this chapter, evaluation of potential defects and appropriate reporting of defects under
§§ 50.72, 50.73, or § 73.71 of this chapter, satisfies each persons evaluation, notification, and reporting obligation to report defects under this part, and the responsibility of individual directors and responsible officers of these licensees to report defects under Section 206 of the Energy Reorganization Act of 1974.
NUREG-1022, Event Report Guidelines 10 CFR 50.72 and 50.73, REV 2 states:
the only case where a defect in a basic component of an operating reactor might be reportable under Part 21, but not under §§ 50.72, 50.73, or 73.71 would involve Part(s) on the shelf. This type of defect, if it does not represent a condition reportable under §§ 50.72 or 50.73, might still represent a condition reportable under 10 CFR Part 21.
Reaffirmation of NRCs positions on Part 21, Appendix B, and Commercial Grade Dedication 14 What should be in the 10 CFR 50.72 and10 CFR 50.73 to meet Part 21 requirements:
Part 21(d)(4) requires the written report required by this paragraph shall include, but need not be limited to, the following information, to the extent known:
(i) Name and address of the individual or individuals informing the Commission.
(ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.
(iii) Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a defect.
(iv) Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.
(v) The date on which the information of such defect or failure to comply was obtained.
(vi) In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be supplied for, manufactured, or being manufactured for one or more facilities or activities subject to the regulations in this part.
(vii) The corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been or will be taken to complete the action.
(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees (ix) In the case of an early site permit, the entities to whom an early site permit was transferred.
Reaffirmation of NRCs positions on Part 21, Appendix B, and Commercial Grade Dedication 15 NRCs positions on 10 CFR PART 21 reporting requirements in conjunction with 10 CFR 50.72, 10 CFR 50.73 and 10 CFR 73.71 In summary If the evaluation of a deviation in a basic component under the guidance for §§ 50.72 and 50.73 results in a report, the obligations under Part 21 for evaluation and reporting have been met.
In the event the evaluation of a deviation under the guidance for §§ 50.72 and 50.73 does not result in a report, licensees must ensure that the evaluation also meets Part 21 and its associated guidance to ensure Part 21 reporting is completely satisfied.
Reaffirmation of NRCs positions on Part 21, Appendix B, and Commercial Grade Dedication 16 NRCs positions on Commercial Grade Dedication Available Guidance:
Regulatory Guide 1.164, Dedication Of Commercial-grade Items For Use In Nuclear Power Plants, Revision 0 (ML17041A206)
Electric Power Research Institute (EPRI) 3002002982, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications, Revision 1 to EPRI NP-5652 and TR-102260 , Revision (ML18199A161)
EPRI 3002002982 is acceptable to the NRC staff in providing an adequate basis for dedication as defined in 10 CFR Part 21, and fulfills the QA requirement in Appendix B to 10 CFR Part 50, subject to the following exceptions or clarifications:
NP-7484 and TR 105849 have not been reviewed or approved by the NRC as an acceptable approach for meeting certain NRC requirements on qualification is found in RG 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants.
EPRI 3002002982, Revision 1 of EPRI NP-5652 and TR-102260, Section 14.1, Digital Equipment and Computer Programs Integral to Plant SSCs, lists six EPRI guidance documents for accepting digital devices. Only TR-106439 Guideline on Evaluation and Acceptance of Commercial-Grade Digital Equipment for Nuclear Safety Applications and TR-107330 Generic Requirements Specification for Qualifying a Commercially Available PLC for Safety-Related Applications in Nuclear Power Plants, have been reviewed and endorsed by the NRC There are four guidance documents referenced in EPRI 3002002982 that have not been reviewed or approved by the NRC as an acceptable approach for meeting an NRC requirement:
NRC Position on Risk-Informed Treatment of Structures, Systems, and Components, ASME code case 17 Code Case N-752, Risk-Informed Categorization & Treatment for Repair and Replacement Activities In 2006, the ASME Section XI Code Committee began working on Code Case N-752. The Code Case was never approved by the ASME Committee.
In April 2007, ANO-2 submitted relief request ANO2-R&R-004, Rev. 1 based on draft Code Case N-752. The ANO-2 relief request was approved by the NRC in April 2009 but never implemented.
In early 2018, the ASME Section XI Committee restarted work on Code Case N-752. The Code Case was approved by ASME in July 2019.
NRC Position on Risk-Informed Treatment of Structures, Systems, and Components, ASME code case 18 Code Case N-752, Risk-Informed Categorization &
Treatment for Repair and Replacement Activities N-752 has NOT been generically approved by the NRC [RG 1.147 Rev.
20 (12/2021)]
In May 2021, N-752 was approved for a plant-specific use through a license amendment request (ML21118B039)
ANO-2 was approved for this code case based on its PRA quality Licensees that have implemented 10 CFR 50.69, may specify alternative treatment for Risk-Informed Safety Class (RISC)-3 and RISC-4 SSCs to the requirements for ASME Class 2 and Class 3 SSCs in 10 CFR 50.55a(g)
NRC is currently reviewing submittals from 2 licensees
Questions 19