ML23166A368
| ML23166A368 | |
| Person / Time | |
|---|---|
| Site: | 99900728 |
| Issue date: | 06/21/2023 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Swirad M Valcor Engineering Corp |
| References | |
| EPID I-2023-201-0025 IR 2023201 | |
| Download: ML23166A368 (22) | |
Text
Michael Swirad Quality Assurance Director Valcor Engineering 2 Lawrence Road Springfield, NJ 07081
SUBJECT:
NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF VALCOR ENGINEERING NO. 99900728/2023-201
Dear Mr. Swirad:
On May 8 - 12, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at Valcor Engineering (hereafter referred to as Valcor) facility in Springfield, NJ. The purpose of this limited-scope routine inspection was to assess Valcors 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 Valcors implementation of quality activities associated with the design, manufacture, and testing of safety-related valves and components for U.S. nuclear power plants. The enclosed report presents the results of the inspection. This NRC inspection report does not constitute NRC endorsement of Valcors overall quality assurance (QA) or 10 CFR Part 21 programs. In addition, the NRC inspection team evaluated Valcors closure of the inspection findings documented in inspection report No.
99900728/2017-201, dated November 16, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17311A267).
Within the scope of this inspection, no violations or nonconformances were identified.
In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding and the NRCs Rule of Practice, a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRCs Public Document Room or from the NRCs document system (ADAMS), accessible at http://www.nrc.gov/reading-rm/adams.html.
June 21, 2023
M. Swirad 2
Sincerely, Kerri Kavanagh, Chief Quality Assurance Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99900728 EPID No.:
I-2023-201-0025
Enclosure:
Inspection Report No. 99900728/2023-201 and Attachment Signed by Kavanagh, Kerri on 06/21/23
ML23166A368 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME AArmstrong DPark YLaw RRomero-Devore DATE 06/20/2023 06/20/2023 06/20/2023 06/20/2023 OFFICE NRR/DEX/EMIB NRR/DEX/EMIB NRR/DRO/IQVB NAME CBasavaraju NHansing KKavanagh DATE 06/20/2023 06/20/2023 06/21/2023
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99900728 Report No.:
99900728/2023-201 Vendor:
Valcor Engineering Corporation 501 South 11th Street Springfield, NJ 62864 Vendor
Contact:
Michael Swirad Quality Assurance Director Phone: 973-467-8400 x 7223 Email: mikeswirad@valcor.com Nuclear Industry Activity:
Valcor Engineering Corporations scope of supply includes safety-related valves and components and related services for U.S.
nuclear power plants.
Inspection Dates:
May 8 - 12, 2023 Inspectors:
Aaron Armstrong NRR/DRO/IQVB, Team Leader Dong Park NRR/DRO/IQVB Yiu Law NRR/DRO/IQVB (Remote)
Rebecca Romero-Devore NRR/DRO/IQVB, In-Training Chakrapani Basavaraju NRR/DEX/EMIB (Remote)
Nicholas Hansing NRR/DEX/EMIB Approved by:
Kerri Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
Valcor Engineering 99900728/2023-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a limited-scope routine vendor inspection at the Valcor Engineering Corporation (hereafter referred to as Valcor) facility in Springfield, NJ, 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 May 8 - 12, 2023. The last inspection at this facility was conducted in October 2017.
This technically-focused inspection specifically evaluated Valcors implementation of the quality activities associated with the design, manufacture, and testing of safety-related valves and components being supplied to U.S. nuclear power plants. In addition, the NRC inspection team evaluated Valcors closure of the inspection findings documented in inspection report No.
99900728/2017-201, dated November 16, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17311A267).
The following regulations served as the bases for the NRC inspection:
Appendix B to 10 CFR Part 50
10 CFR Part 21 The NRC inspection team observed the following specific activities:
Commercial Grade Dedication of O-rings Part #S101Y22 and Stop Part #V52617-6040-5
Walkdown of the receipt inspection and quality control inspection area
Inspection of the calibration laboratory and nonconformance storage locker
Liquid penetrant examination of a safety-related part for the US nuclear industry During this inspection, the NRC inspection team implemented Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023, IP 43003, Reactive Inspections of Nuclear Vendors, dated April 08, 2020, IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023; and IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated February 10, 2023.
The results of this inspection are summarized below.
10 CFR Part 21 Program The NRC inspection team concluded that Valcor 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 also determined that Valcor is adequately implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.
3 Nonconforming Materials, Parts, or Components and Corrective Action The NRC inspection team reviewed the corrective actions that Valcor took to address Nonconformance No. 99900728/2017-201-02, documented in inspection report No.
99900728/2017-201, dated November 16, 2017 (ADAMS Accession No. ML17311A267). The NRC inspection team reviewed the documentation that provided the objective evidence that all the corrective actions were completed and adequately implemented. Based on this review, the NRC inspection team closed Nonconformance No. 99900728/2017-201-02.
Inspection Areas The NRC inspection team determined that Valcor established its programs for nonconforming material, parts, or components, corrective action, design control and qualification, CGD, procurement document control and oversight of contracted activities, measuring and test equipment, and internal audits, in accordance with the applicable regulatory requirements of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and activities observed, the NRC inspection team also determined that Valcor is implementing its policies and procedures associated with these programs. No findings of significance were identified in these areas.
4 REPORT DETAILS 1.
10 CFR Part 21 Program a.
Inspection Scope The U.S. Nuclear Regulatory Commission (NRC) inspection team reviewed Valcor Engineerings (hereafter referred to as Valcor) 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 evaluated the 10 CFR Part 21 postings and a sample of Valcors 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. The NRC inspection team also verified that Valcors nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program.
Furthermore, for a sample of 10 CFR Part 21 evaluations performed by Valcor, the NRC inspection team verified that Valcor had effectively implemented the requirements for evaluating deviations and failures to comply. The NRC inspection team verified that the notifications were performed in accordance with the requirements of 10 CFR 21.21, as applicable.
The NRC inspection team also discussed the 10 CFR Part 21 program with Valcors 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 Valcor 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 also determined that Valcor is adequately implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.
2.
Nonconforming Materials, Parts, or Components and Corrective Action a.
Inspection Scope The NRC inspection team reviewed Valcors 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, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
5 The NRC inspection team verified that Valcors processes and procedures provide for the identification, documentation, segregation, evaluation, and disposition of nonconforming items. These processes also apply the principles of rework/repair, use-as-is, scrap/salvage, return to vendor, or no defect found.
The NRC inspection team reviewed a sample of Nonconformance Reports (NCRs) and confirmed that Valcor: (1) dispositioned the NCRs 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.
The NRC inspection team also reviewed a sample of Corrective Action Reports (CARs) and confirmed that the CARs contain, as applicable: (1) adequate documentation and 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 actions taken to verify timely and effective implementation of the corrective actions. In addition, the NRC inspection team verified that the corrective action process provides a link to the 10 CFR Part 21 program.
The NRC inspection team discussed the nonconformance and corrective action programs with Valcors management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
In addition, the NRC inspection team reviewed Valcors corrective actions in response to the inspection findings identified in NRC inspection report (IR) No. 99900728/2017-201, dated November 16, 2017 (ADAMS Accession No. ML17311A267).
b.
Observations and Findings b1. Corrective Action Associated with Nonconformances 99900728/2017-201-02 Following the August 2017 inspection at Valcor as documented in NRC Inspection Report (IR) No. 99900728/2017-201, the NRC issued three Nonconformances: 99900728/2017-201-01, 99900728/2017-201-02 and 99900728/2017-201-03. Nonconformances 99900728/2017-201-01 and 99900728/2017-201-03 were closed in an August 2020 inspection as documented in IP No. 99900728/2020-201 (ADAMS Accession No. ML20216A590).
Nonconformance 99900728/2017-201-02 was cited for Valcors failures to ensure the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of solenoid valves. In addition, Valcor failed to establish appropriate measures for source evaluation or inspection at the contractor or subcontractors. Specifically, Valcor 1) did not identify an appropriate set of critical characteristics for the voltage controller and the specified production testing was not adequate to fully verify the performance of the controller; 2) did not establish the technical basis to verify the suitability of the materials for the selection of the sample population for nondestructive and destructive testing of O-rings, helical springs, and stop springs and other commercial-grade items; 3) did not use the correct sample size to verify the suitability of the material of O-rings by a durometer and Fourier-transform infrared spectroscopy (FTIR) analysis; 4) did not establish the acceptance criteria for the verification of material hardness properties of the O-rings to ensure that they met the material specification; and 5) did not perform a commercial-grade survey or source surveillance of the commercial suppliers of
6 helical springs and top springs to verify the validity of the Certificates of Conformance provided by these suppliers for critical characteristics heat treatment and tensile strength.
In its response dated December 15, 2017 (ADAMS Accession No. ML17355A114), Valcor stated that it had initiated Corrective Action (CA) No. 2017-028 to address this issue. To address issue 1), Valcor stated in its response that critical characteristics were established in Q Drawings S1140-23-23Q and S1140-23-25Q. The 180 VDC plus minus 10% tolerance is justified in Engineering Document ER 045. In addition, Acceptance Test Reports TR1140 23 and TR1140-23-25 would be revised to add tests to fully verify the initial VCB output voltage as well as the holding voltage throughout the entire range of input voltages. The VCB would be tested under worst-case load condition to verify satisfactory operability.
To address issue 2), Valcor stated in its response that the procedure for dedication of commercial-grade items, S2002, had been revised to include tables identifying normal, reduced, and tightened plan sample size and destructive test sampling requirements. In addition, Valcor added fields to all Q-Drawings to document the sample plan and justification for each purchased lot.
To address issue 3), Valcor stated in its response that it had immediately stopped using only one sample for Durometer destructive testing and FTIR analysis. Inspectors were trained to follow the new sampling plan in S2002 regardless of if the suppliers documentation indicates that all of the parts are from the same heat number, production lot number, or batch number.
In addition, 10 CFR Part 21 evaluation was initiated to evaluate the extent of the condition.
To address issue 4), Valcor stated in its response that the commercial-grade dedication plan, S101Q, was revised to include acceptance criteria for the material compounds based on critical characteristics defined by Valcor. In addition, an extent of condition was evaluated by reviewing all the receiving inspection records.
To address issue 5), Valcor stated in its response that one of the three spring suppliers utilized by Valcor had commercial grade survey performed in October 2017. In December 2017, Valcor obtained a NIAC audit and validated the second spring supplier as 10 CFR Appendix B compliant. Valcor would perform a commercial grade survey on the third spring supplier. In addition, an extent of condition was performed and concluded that all springs installed and supplied to Valcors customers meet design drawing and will perform as designed.
The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions. The NRC inspection team verified that Q Drawings S1140-23-23Q and S1140-23-25Q have been revised to include critical characteristics of 180V plus minus 10% output voltage, Acceptance Test Reports TR1140-23-23 and TR1140-23-25 have been revised to include tests to verify output voltage. The NRC inspection team verified that the procedure for dedication of commercial-grade items, S2002, has been revised to include tables identifying normal, reduced, and tightened plan sample size and destructive test sampling requirements, and Valcor personnels have been trained to use the latest sampling plan in S2002. The NRC inspection also reviewed a sample of receipt inspection records that showed that the new sampling plan was implemented. The NRC inspection team verified that the commercial grade dedication plan, S101Q, has been reviewed to include acceptance criteria for material compounds. In addition, the NRC inspection team reviewed the audit reports of the three spring suppliers and the extent of
7 condition evaluation Valcor performed to ensure the springs supplied and installed to Valcors customers would perform as designed.
The NRC inspection team reviewed Valcors objective evidence and determined that Valcors corrective actions were adequately implemented to address Nonconformance 99900728/2017-201-02. Based on its review, the NRC inspection team closed Nonconformance 99900728/2017-201-02. No findings of significance were identified.
c. Conclusion
The NRC inspection team concluded that Valcor is implementing its nonconformance and corrective action programs in accordance with the regulatory requirements of Criterion XV and Criterion XVI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that Valcor is implementing its policies and procedures associated with its nonconformance and corrective action programs. No findings of significance were identified.
3.
Design Control and Qualification a.
Inspection Scope The NRC inspection team reviewed Valcors policies and procedures that govern the implementation of its design control program to verify compliance with the requirements of Criterion III, Design Control of Appendix B to 10 CFR Part 50. The NRC inspection team selected a sample of Valcors design packages for safety-related components provided to U.S. nuclear power plants and reviewed relevant design reports, customer specifications, drawings, test procedures, test reports, and qualification reports. The NRC inspection team verified that these documents contained the required technical information in accordance with Valcors procedures and the applicable American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel (BPV) Code requirements.
The NRC inspection team reviewed design packages for two solenoid valves, ensuring that the documents included the correct technical information per the customer specifications, Valcors procedures, and the applicable ASME BPV Code requirements. The NRC inspection team reviewed a design change evaluation to qualify a replacement material for a discontinued O-ring material and verified that the design change was properly evaluated.
The NRC inspection team also observed a liquid penetrant examination of a safety-related part and verified that the testing and associated inspections were performed in accordance with Valcors procedures. The NRC inspection team confirmed that the non-destructive examination (NDE) personnel were qualified in accordance with the applicable Valcor procedures. The NRC inspection team reviewed the test report associated with the observed activity and confirmed that the report recorded the required information in accordance with Valcors procedures.
The NRC inspection team also discussed the design control program with Valcors 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
8 No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that Valcor 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 Valcor is implementing its policies and procedures associated with the design control program. No findings of significance were identified.
4.
Commercial-Grade Dedication a.
Inspection Scope The NRC inspection team reviewed Valcors 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, 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.
Valors CGD process consists of developing CGD plans that include: (1) technical evaluation; (2) identification number; (3) intended environment; (4) safety functions; (5) credible failure mechanisms; (6) critical characteristics and verification methods for acceptance; and (7) supplier/manufacturer identification. The NRC inspection team reviewed a sample of CGD plans and commercial-grade surveys of commercial vendors on Valors commercial approved vendors list. The sample of CGD plans included the following items: solenoid coil, O-rings, packing rings, guide clamps, MGT plates, cylinders. Within these CGD plans, the NRC inspection team reviewed: (1) purchase orders (POs); (2) technical evaluations; (3) checklists; (4) inspection and test reports; and (5) Certificates of Conformance and Certified Material Test Reports (CMTRs). The NRC inspection team evaluated the criteria for the identification of item functions, credible failure mechanisms and modes, selection of critical characteristics and acceptance criteria, identification of verification methods, and justification of the sampling methodologies, as applicable, to verify the effective implementation of Valors CGD process In addition, the NRC inspection team verified that commercial-grade surveys contained the objective evidence necessary to demonstrate the commercial vendors adequately controls the critical characteristics during the service activities.
The NRC inspection team witnessed the verification of a sample of critical characteristics as part of the CGD for a batch of O-rings on PO 282005 and Stops for PO 281702. The NRC inspection team verified that Valors test technician was adequately following the CGD plan and documenting the inspection results. In addition, the NRC inspection team confirmed the test technician was using calibrated measuring and testing equipment (M&TE) to take the appropriate measurements. Furthermore, the NRC inspection team reviewed the training records of the test technician and confirmed that he was adequately trained and qualified in accordance with Valors policies and procedures.
The NRC inspection team also discussed the CGD programs with Valcors management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
9 b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that Valcor 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 determined that Valcor is implementing its policies and procedures associated with the CGD program. No findings of significance were identified.
5.
Procurement Document Control and Supplier Oversight a.
Inspection Scope The NRC inspection team reviewed Valcors policies and implementing procedures that govern the implementation of its procurement document control and supplier oversight programs 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 Valcors approved vendor list (AVL), and a sample of POs, supplier audits, job travelers, and receipt inspection records. For the sample of POs reviewed, the NRC inspection team verified that the POs included, as appropriate: scope of work, right of access to the suppliers facilities, and conditions and restrictions imposed to sub-suppliers. The NRC inspection team confirmed that the POs adequately invoked the applicable technical, regulatory, and quality requirements. In addition, the NRC inspection team verified that for the sample of receipt inspection records reviewed (e.g., receipt inspection reports, Certificates of Compliance, and Certificate of Calibration), these records were (1) reviewed by Valcor for compliance with the requirements of the POs, (2) the records were approved by qualified individuals, and (3) the records contained the applicable technical and regulatory information. The NRC inspection team performed a walkdown of the receipt inspection and quality control inspection area.
The NRC inspection team selected a sample of suppliers from the AVL to review the methodology for conducting and documenting audits to verify adequate evaluation of the suppliers controls for meeting the applicable requirements of Appendix B to 10 CFR Part 50.
For the sample of supplier audits reviewed, the NRC inspection team verified the following:
the audit reports included an audit plan; audits were performed according to established frequency; audit reports included adequate documented objective evidence of compliance with the applicable requirements; and audit documentation was reviewed by Valcors responsible management.
The NRC inspection team also discussed the procurement document control and supplier oversight programs with Valcors 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.
10 c.
Conclusion The NRC inspection team concluded that Valcor is implementing its procurement document control and supplier oversight programs 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 Valcor is adequately implementing its policies and procedures associated with the procurement document control and supplier oversight programs. No findings of significance were identified.
6.
Control of Measuring and Test Equipment a.
Inspection Scope The NRC inspection team reviewed Valcors policies and implementing procedures that govern the implementation of its Measuring and Test 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.
For a sample of M&TE, the NRC inspection team determined that the M&TE had the appropriate calibration stickers and current calibration dates, including the calibration due date. 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 calibration records reviewed by the NRC inspection team 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 used in CGD for a batch order of O-rings was calibrated and labeled, and the associated certificate of calibration stated the traceability to a nationally recognized standard.
The NRC inspection team confirmed that when M&TE equipment is found to be out of calibration, a material rejection report (MRR) is initiated, and an evaluation is performed to determine if the M&TE was previously used. The NRC inspection team performed a walk-down of Valcors calibration laboratory to observe that 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 discussed the control of M&TE with Valcors 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 Valcor 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 Valcor is implementing its policies and procedures associated with the M&TE program. No findings of significance were identified.
11 7.
Internal Audits a.
Inspection Scope The NRC inspection team reviewed Valcors policies and implementing procedures that govern its internal audit program to verify compliance with the requirements of Criterion XVIII, Audits of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed Valcors internal audit plans, internal audit reports, and corrective actions generated during internal audits.
The NRC inspection team verified that the audit documents reviewed were adequately completed and that Valcor adequately corrected the conditions identified in CARs generated during internal audits. The NRC inspection team verified that Valcors procedures described the scope and purpose of audits to be performed, the frequency, audit criteria, and corrective actions when required. The NRC inspection team verified that the audit teams were selected using qualified auditors and that they were not auditing their own work. The NRC inspection team verified that internal audits were performed using checklists.
The NRC inspection team discussed the internal audits program with Valcors 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 Valcor is implementing its internal audits program in accordance with the regulatory requirements of Criterion XVIII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that Valcor is adequately implementing its policies and procedures associated with the internal audit program. No findings of significance were identified.
8.
Entrance and Exit Meetings On May 8, 2023, the NRC inspection team presented the inspection scope during an entrance meeting with Mr. John Trezza, Valcors President, and other members of Valcors management and technical staff. On May 12, 2023, the NRC inspection team presented the inspection results to Mr. Trezza and other members of Valcors 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.
12 ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Position Affiliation Entrance Exit Interviewed Michael Swirad Quality Assurance Director Valcor Engineering Corporation (Valcor)
X X
X John Trezza CEO / President Valcor X
X Tara Kolankoski Senior Quality Assurance Engineer Valcor X
X X
David Baarck Junior Quality Assurance Engineer Valcor X
X X
Christopher Lewis Purchasing Manager Valcor X
Thien Nguyen Director Sales &
Marketing Valcor X
Al Lamastra VP/ General Manager Valcor X
Yesica Wong Inventory Control Manager Valcor X*
X*
Jim Phillips Director of Operations and Supply Chain Valcor X
Ashok Idiculla QC Manager Valcor Oza Rajuash QC Inspector Valcor Mona Patel QC Inspector Valcor X
Wilfredo Zavala Metrology Quality Control Inspector Valcor X
13 Barrett Matiez Staff Engineer Valcor X
Michael Spressler NDE Inspector Valcor X
Hemang Dave Chief
- Engineer, Nuclear Valcor X
X Patti Kemps Valcor X
Paul Conforme Valcor X
Aaron Armstrong Inspection Team Leader Nuclear Regulatory Commission (NRC)
X X
Dong Park Inspector NRC X
X Yiu Law Inspector NRC X*
X*
Rebecca Romero-Devore Inspector NRC X
X Chakrapani Basavaraju Mechanical Engineer NRC X*
X*
Nicholas Hansing Mechanical Engineer NRC X
X Ami Agrawal Deputy Director NRC X
Kerri Kavanagh Branch Chief NRC X
14 2.
INSPECTION PROCEDURES USED:
Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023
Inspection Procedure (IP) 43003, Reactive Inspections of Nuclear Vendors, dated April 8, 2020
IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023
IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated February 10, 2023 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description 99900728/2017-201-01 CLOSED Nonconformance Criterion III 4.
DOCUMENTS REVIEWED Quality Assurance Procedures (QAP):
Nuclear Quality Assurance Manual, Fifth Edition, Revision 30, dated April 14, 2023
S517, Standard Procedure for Design Planning & Control, Nuclear Engineering, Revision D, dated April 12, 2023
S1120, Liquid Penetrant Examination Procedure - Nuclear, Revision AH, dated February 27, 2020
S1477, Acceptance and Burn-In Test Procedures for AC and DC Voltage Control Boxes
& AC and DC Printed Circuit Boards, Revision K, dated July 15, 2021
S1519, Inspection, Test Personnel Qualification Requirement, Revision K, dated March 10, 2020
S1559, Audit Personnel Qualification Procedure - Nuclear, Revision L, dated October 26, 2021
S1613, Qualification Procedure for Certifying Engineers, Revision P, dated March 24, 2023
S1843, Procedure to Prepare, Check and Certify Nuclear Valve Design Specifications, Revision D, dated February 22, 2022
S1303, Engineering Change Order (ECO) Procedure, Revision W, dated July 27, 2022
S2002, Dedication of Commercial Grade Items for Nuclear Safety Related Applications, Revision Y, dated February 22, 2022
S2110, 10CFR21 Defects and Non-Compliance Reporting Procedure, Revision N, dated May 5, 2023
SOP-QA-0001, Training, Revision D, dated April 4, 2023
SOP-QC-0001, Calibration, Revision F, dated December 3, 2022
SOP-QC-0002, Incoming Inspection, Revision B, dated May 13, 2020
WI-SC-0001, Quality Clauses for Suppliers, Revision D, dated February 24, 2022
WI-QA-0002, Control of Nonconforming Items, Revision I, dated January 12, 2023
WI-QA-0003, Corrective Action, Revision G, dated January 15, 2023
WI-QA-0007, Internal Audit, Revision I, dated December 14, 2020
WI-QA-0008, Liquid Penetrant Material Testing & Verification, Revision K, dated
15 February 12, 2020
WI-QA-0022, Valcor Counterfeit Parts Material Prevention Plan, Revision B, dated August 5, 2019
WI-QA-0027, Procurement of Calibration Services, Revision B, dated April 30, 2023
WI-QC-0012, Calibration: Vernier, Revision F, dated December 7, 2020 Design Documents:
QR SKC26022-1, Delta Qualification Report for E0515-80 O-Ring Material Replacement, Revision A, dated January 7, 2020
MR526-5631-45-1, Design Report on Valve Solenoid, Class 150, 2 Inch, Sch. 40, N.C.,
A.C., Nuclear Service, Model V526-5631-45, P/N: 413175201, Revision B, dated January 15, 2019
MR526-5688-26-18, Design Report on Valve Solenoid, Class 1792, 1/4 in. x 0.065 Wall Thk., N.C., D.C., Nuclear Service, Model #V526-5688-26 and P/N: 208865325, Revision D, dated December 7, 2020
Valcor Memo for Review of Westinghouse design specification for MR526-5688-26-18
Design Verification Sheet for MR526-5688-26-18
Valcor Memo for Review of Duke Energy design specification for MR526-5631-45-1
Design Verification Sheet for MR526-5631-45-1
PeneCert Testing Service Report for PT Emulsifier water content, dated May 8, 2023
PeneCert Testing Service Report for PT Penetrant ZL-27A fluorescent brightness, dated April 13, 2023
0177-LTR-0038, INR Engineering Ltd Technical Letter, dated May 3, 2021
ASME QME-1 EQ Qualification Report for Solenoid Valve Model V526-5688-26 APP-PV13-Z0D-104 & 107, Revision G, dated October 18, 2016
Drawing 208865325, Revision C, dated April 20, 2017
Drawing 413175201, Revision D, dated March 18, 2021
Penetrant Examination Record for Part Number V52602-5292-21 Seal
ER 45, Engineering Report for Westinghouse AP1000 Voltage Control Box P/Ns S1140-23-23 and S1140-23-25 Output Voltage Design Analysis, Revision D, dated May 15, 2018 Commercial Grade Dedication Packages (CGD) and Critical Characteristics Attribute and Verification sheets:
Commercial Grade Item Dedication Technical Evaluation
S101Q, O-Ring Standard, Revision C, dated October 16, 2017
S1140-23-23Q, Solenoid Control Box, Revision B, dated July 22, 2020
S1140-23-25Q, Solenoid Control Box AC, Revision B, dated July 22, 2020
Engineering Order 6539, Revision A, dated October 31, 2017
Sales order 402322-001, O-ring, dated March 17, 2023
PO Number 282005, O-ring, dated May,9 2023
CGD S101Q, O-ring, Revision C, dated October 16, 2017
Valcor Standard Procedure, S101-TAB S102-TAB, O-Ring Standard Size and Compound, dated March 1, 2023
CGI Test and Inspection Record, O-Ring Part S101Y22, dated May 9, 2023
Certificate of Conformance for Order number 669916, dated November 14, 2008
16
Job Traveler 318720, V52617-6040-5 Stop, dated February 27, 2023
PO 281702, V52617-6040-5 Stop, dated March 9, 2023
Dwg V52617-6040-5, Stop, Revision B, dated October 1, 2009
CGID Test and Inspection Record for, Stop V52617-6040-5, dated May 9, 2023
CGD Plan No. V52617Q, dated January 2, 2018
Engineering Report for Coil Shell Assembly Failure Investigation for V52653-6040-7, date August 24, 2022
PO for Material Analysis and Verification for S101CB12 O-Ring, dated April 14, 2023
Test report for Material Analysis and Verification for S101CB12 O-Ring, dated May 1, 2023
PO No.270128 for Material Analysis and Verification, dated May 2023
Job order 308829 for 107175201 V526-5295-187 Valve Solenoid, dated February 23, 2022
Job order 308831 for V105-295-25-14 Solenoid Assembly, dated September 20, 2022
Job order 308832 for S1140-11-73 Bracket Term Block Assembly, date August 2, 2022
Job order 310297 for S1140-51-2 Guide Clamp, dated March 8, 2022
CGID Test and Inspection Record for Guide Clamp Part number S1140-51-2, date June 7, 2022
PO 2431487, Valve, solenoid 3/8, 300 class, 3/8 tube ends SA-213 TP 316, Body SA182 GR F316, dated September 10, 2021
PO 274109, Guide Clamp, dated May 10. 2023
Dwg S1140-15-2, Guide Clamp, dated March 16, 1990
CGD Plan No S1140-51-2, Guide Clamp, October 1, 2018
Job Traveler 315370, V52630-554 Solenoid Assembly, dated January 25, 2023
Job Traveler 315370, V52630-555 Plate, dated November 21, 2023
CGID Test and Inspection Record for Plate MGT V52629-555, dated January 12, 2023
PO 4500789853 for V52630-554 Solenoid 120VDC, 3way, dated August 9, 2023
PO 278881 for V52629-55 Plate dated May 3, 2023
Dwg V52629-555, Plate MTG, Revision C, dated February 17, 2021 Internal Audit:
IA-22-001, Assessment (Audit) Plan, dated November 29, 2022
IA-22-001, Internal Audit Report, dated December 7, 2022
Valcor 2021 Internal Nuclear QA Audit Plan, Revision 1
2021 Internal Audit Report, dated December 5, 2021 Supplier Oversight:
Copy of Supplier Audit Survey List.xlsx
Current Approved Vendor List, dated April 11, 2023
2023-Supplier Audit, dated January 18, 2023
Supplier Performance Assessment Record, dated October 25, 2021
Laboratory Testing, Inc. Supplier Audit Report, dated September 6, 2022
Piping Inc. Audit Summary Report, dated August 2, 2021
Inspection Report for Part Number 2618-6031 (PO #280445)
Inspection Report for Part Number 2618-6042 (PO #281906)
Inspection Report for Part Number 2195-0057 (PO #278664)
Material Receiving Report for PO #280445
17
Material Receiving Report for PO #281906
Job Traveler 315323 for Inventory Number 2195-0057
Quality Survey Report for a spring manufacturer, dated February 14, 2019
Audit for a spring manufacturer, dated May 18, 2016
Audit for a spring manufacturer, dated May 23, 2019
Audit for a spring manufacturer, dated January 4, 2018 Purchase Orders:
Purchase Order (PO) #276573
PO #73776
PO #281702
PO #282005
PO #280445
PO #281906
PO #278664 Measuring and Test Equipment Documents:
Certificate of Calibration, HHG029, 23.0 /.00005 Digital Height Gage, Model No. V 602+,
dated September 20, 2022
Certificate of Calibration, KRW007, Wilson, Model/Serial No. R54-00-1072, dated June 2, 2022
Certificate of Calibration, KRW009-V, Durometer, Model/Serial No. Type M-1442 /
1128616, dated March 8, 2023
Certificate of Calibration, VER329, 0-6 /.0005 Digital Caliper, Model/Serial No. 200-196-30 / A18237564, dated October 27, 2022
Certificate of Calibration, VEC0001-22-04-01652-1, WGB001, Gage Blocks, 88 PCS.,
Serial No. R6517, dated April 22, 2022
Certificate of Calibration, VEC0001-21-05-02001-5, WRG073, Plain Ring Gage Master, Serial No. 7E09, dated June 17, 2021
Certificate of Calibration, XOR001, Parker Size Gauge for O-Rings, dated June 4, 2021
Certificate of Calibration, UXR006, Thermo Scientific Portable XRF Analyzers X-Ray Tube Radiation Survey Certificate, Survey Date: December 1, 2022
Certificate of Calibration, UXR006, Thermo Scientific Portable XRF Analyzers X-Ray Tube Radiation Survey Certificate, Survey Date: March 21, 2023
Service Report, SE-2207348011, dated February 7, 2023
Service Report, SE-2303367333, dated April 5, 2023
CGID Test & Inspection Record, 47879 S101Y113, dated December 22, 2021
CGID Test & Inspection Record, 48407 S101CS48, dated January 4, 2023
CGID Test & Inspection Record, 48409 S101Y112, dated January 6, 2023
Test Report for P/N S1140-23-23, dated April 24, 2013
Test Report for P/N S1140-23-25, dated August 10, 2016 NCRs:
MRR 0796-2021
MRR 1299-2021
MRR 0069-2022
MRR 0262-2022
18
MRR 0331-2022
MRR 0497-2022
MRR 0626-2022
MRR 0699-2022
MRR 0711-2022
MRR-0714-2022 Corrective Action Reports (CARs) Reviewed During the NRC Inspection:
CA-2017-028
CA-2019-045
129-2020-8D
144-2020-8D
191-2020-8D
362-2021-SCAR
367-2021-SCAR
369-2021-SCAR
399-2022-3D
400-2022-3D
401-2022-8D
402-2022-3D
403-2022-3D
404-2022-8D
405-2022-8D
445-2022-SCAR
446-2022-SCAR
464-2022-SCAR
497-2023-SCAR
510-2023-3D
533-2023-3D 10 CFR Part 21 Records
S2110-2019-5
S2110-2021-QA-1
S2110-2021-QA-2
S2110-2021-QA-3
S2110 2021-QA-3, O-Ring Sampling, dated May 25, 2021 Training Records:
Lead Auditor Qualifications and Certification Record of John Salasky
Qualification Record of Michael Swirad
Qualification Record of Mona Patel
Qualification Record of Barrett W. Matiez
Qualification Record of Mahfuja Begum
Qualification Record of Michael Spressler
S2002 Revision N and CFSI Training
S2002 Revision R Training
19
S2002 Revision U Training
S2002 Revision V Training