ML24169A203
| ML24169A203 | |
| Person / Time | |
|---|---|
| Site: | 99900404 |
| Issue date: | 06/18/2024 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Zozula C Westinghouse |
| References | |
| EPID I-2024-201-0001 IR 2024201 | |
| Download: ML24169A203 (1) | |
Text
Camille T. Zozula, Manager Global Nuclear Regulatory Affairs Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066
SUBJECT:
NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF WESTINGHOUSE ELECTRIC COMPANY NO.
99900404/2024-201 AND NOTICE OF NONCONFORMANCES
Dear Ms. Zozula:
On May 6-10, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Westinghouse Electric Company (WEC) facilities in Warrendale, PA. The purpose of this limited-scope routine inspection was to assess 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 evaluated WECs implementation of the quality activities as they pertain to WECs development of the digital Plant Protection System (PPS) for Limerick Generating Station (LGS) Units 1 and 2. This inspection specifically focused on the design outputs related to the Requirements Phase, and completed portions of the Design Phase, of the digital PPS development lifecycle for LGS Units 1 and 2. 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 program.
Based on the results of this inspection, the NRC inspection team found that the implementation of your QA program did not meet certain regulatory requirements contractually imposed on you by NRC licensees. Specifically, the NRC inspection team determined that WEC was not fully implementing its QA program in the area of Criterion VII, Control of Purchased Material, Equipment, and Services, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part
- 50. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter. In response to the enclosed notice of nonconformance (NON), WEC should document the results of the extent of condition review for these findings and determine if there are any effects on other safety-related components.
Please provide a written statement or explanation within 30 days of this letter in accordance with the instructions specified in the enclosed NON. We will consider extending the response time if you show good cause for us to do so.
June 18, 2024
C. Zozula 2
In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, of the NRCs Rules of Practice, a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, (if applicable), should not include any personal privacy, proprietary, or safeguards information (SGI) so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request that such material is withheld from public disclosure, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, Protection of safeguards information:
performance requirements.
Sincerely, Kerri Kavanagh, Chief Quality Assurance Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99900404 EPID No.:
I-2024-201-0001
Enclosures:
- 1. Notice of Nonconformance
- 2. Inspection Report No. 99900404/2024-201 and Attachment Signed by Kavanagh, Kerri on 06/18/24
ML24169A203 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB R-I/DORS/EB2 NAME DZhang OAyegbusi LDumont DATE 6/17/2024 6/17/2024 6/18/2024 OFFICE NRR/DEX/EICB NRR/DRO/IRAB NRR/DRO/IQVB NAME SDarbali BHughes KKavanagh DATE 6/18/2024 6/17/2024 6/18/2024 NOTICE OF NONCONFORMANCE Westinghouse Electric Company Docket No. 99900404 1000 Westinghouse Drive Report No. 2024-201 Cranberry Township, PA 16066 Based on the results of a U.S. Nuclear Regulatory Commission (NRC) inspection conducted at the Westinghouse Electric Company (WEC) facility in Warrendale, PA from May 6, 2024, through May 10, 2024, WEC did not conduct certain activities in accordance with NRC requirements that were contractually imposed on WEC by its customers or NRC licensees:
A. Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B,
Quality Assurance Program 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, states in part, that Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery.
W2-9.4-101, Control of Purchased Items and Services, Revision 8.1, Section 4.5.3, states, in part, that Westinghouse methods to accept an item or service from a supplier shall be a supplier certificate of conformance, source verification, receiving activities, receipt inspection, or post-installation test at the nuclear facility site, or a combination of these methods. Section 4.5.3.1 of W2-9.4-101, states that where required by code, regulation, or contract requirement, documentary evidence that items conform to procurement requirements (e.g., certificate of conformance) shall be available at the nuclear facility site prior to installation or use.
Contrary to the above, as of May 10, 2024, WEC failed to ensure that purchased material, equipment, and services from Liberty Electronics conform to the purchase order (PO) requirements. Specifically, WEC did not provide sufficient objective evidence to demonstrate that the requirements imposed in PO 4500858963 for procured calibration services and recording of inspection, measurement and test equipment used were satisfied.
This issue has been identified as Nonconformance 99900404/2024-201-01.
B. Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50, states in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
W3-5.1-101, Westinghouse Corrective Action Program Procedure, Revision 10.0, Section 4.1.3 states, that Condition Adverse to Quality (CAQ) shall be promptly identified and corrected.
2 Contrary to the above, as of May 10, 2024, WEC failed to correct conditions adverse to quality. Specifically, WEC closed Corrective Action Program-Issue Report (CAP-IR)-
2023-3864 and CAP-IR-2023-11754 without adequately correcting the conditions adverse to quality identified in these CAP-IRs.
This issue has been identified as Nonconformance 99900404/2024-201-02.
Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Chief, Quality Assurance and Vendor Inspection Branch, Division of Reactor Oversight, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a Reply to a Notice of Nonconformance and should include for each noncompliance: (1) the reason for the noncompliance or, if contested, the basis for disputing the noncompliance; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further noncompliance; and (4) the date when the corrective action will be completed. Where good cause is shown, the NRC will consider extending the response time.
In accordance with the requirements of 10 CFR 2.390, Public inspections, exemptions, requests for withholding, of the NRCs Rule of Practice, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated this 18th day of June 2024.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99900404 Report No.:
99900404/2024-201 Vendor:
Westinghouse Electric Company Camille Zozula zozulact@westinghouse.com Nuclear Industry Activity:
Westinghouse Electric Company supplies and supports development of the digital Plant Protection System for Limerick Generating Station Units 1 and 2.
Inspection Dates:
May 6 - 10, 2024 Vendor Location:
5000 Ericsson Drive Warrendale, PA 15086 Inspection Team Leader:
Deanna Zhang NRR/DRO/IQVB Inspectors:
Odunayo Ayegbusi NRR/DRO/IQVB Louis Dumont R-I/DORS/EB2 Samir Darbali NRR/DEX/EICB, Technical Specialist Approved by:
Kerri Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
Westinghouse Electric Company 99900404/2024-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a routine vendor inspection at the Westinghouse Electric Company (WEC) facility in Warrendale, PA, to verify WEC 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 6 - 10, 2024.
This technically-focused inspection specifically evaluated WECs implementation of its QA and 10 CFR Part 21 programs as applied to WECs activities to support the development of the digital Plant Protection System (PPS) for Limerick Generating Station (LGS) Units 1 and 2. This inspection specifically focused on the development activities and design outputs related to the Requirements Phase, and completed portions of the Design Phase, of the digital PPS development lifecycle for LGS Units 1 and 2.
The following regulations served 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 implemented Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023; IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated February 10, 2023; IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2024, and IP 35710, Quality Assurance Inspection of Software Used in Digital Instrumentation and Control Nuclear Applications, dated April 18, 2024.
The results of this inspection are summarized below.
Control of Purchased Material, Equipment, and Services The NRC inspection team issued Notice of Nonconformance (NON) 99900404/2024-201-01.
NON 99900404/2024-201-01 cites WECs failure to ensure that purchased material, equipment, and services from Liberty Electronics conform to the purchase order (PO) requirements.
Specifically, WEC did not provide sufficient objective evidence to demonstrate that that requirements imposed in PO 4500858963 for procured calibration services and recording of inspection, measurement and test equipment used were satisfied.
Nonconforming Materials, Parts, or Components and Corrective Actions The NRC inspection team issued NON 99900404/2024-201-02. NON 99900404/2024-201-02 cites WECs failure to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected. Specifically, WEC closed Corrective Action Program-Issue Report
3 (CAP-IR)-2023-3864 and CAP-IR-2023-11754 without adequately correcting the conditions adverse to quality identified in these CAP-IRs.
Other Inspection Areas Based on the limited sample of documents reviewed and activities observed, the NRC inspection team determined that WEC is implementing its policies and procedures for design control, procurement document control, and nonconforming material, parts, and components in accordance with the applicable regulatory requirements of Appendix B to 10 CFR Part 50. In addition, the NRC inspection team reviewed WECs policies and procedures governing its 10 CFR Part 21 program and determined that WEC is implementing its policies and procedure for posting and reporting defects requirements. 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 Westinghouse Electric Companys (WECs) 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 WECs purchase orders (POs) to verify compliance with the requirements of 10 CFR 21.6, Posting Requirements, and 10 CFR 21.31, Procurement Documents, respectively. The NRC inspection team also verified that WECs nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program.
The NRC inspection team also discussed WECs 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.
Conclusion 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.
2.
Commercial Grade Dedication and Control of Purchased Material, Equipment and Services a.
Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern its commercial grade dedication program and control of purchased material, equipment, and services to verify compliance with the requirements of Criterion III, Design Control 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 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
The NRC inspection team reviewed WECs quality supplier list (QSL) and selected a sample of suppliers from the QSL to review the methodology for conducting and documenting audits/commercial grade surveys 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/commercial grade surveys reviewed, the NRC inspection team verified the following: the audit/commercial grade survey reports included an audit/survey plan; audits/commercial grade surveys were performed according to established frequency;
5 audit/commercial grade survey reports included adequate documented objective evidence of compliance with the applicable requirements; and audit/commercial grade survey documentation was reviewed by WECs responsible management.
The NRC inspection team selected a sample of receipt inspection records to verify that these records (1) were reviewed by WEC for compliance with the requirements of the POs, (2) were approved by qualified individuals, and (3) 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 observed the receipt inspection of a Limerick Generating Station (LGS) Unit 2 Plant Protection System (PPS) Integrated Logic Controller (ILC)-G10 cabinet.
Additionally, the NRC inspection team discussed WECs program for commercial grade dedication and control of purchased material, equipment, and services 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 The NRC inspection team reviewed PO 4500858963 to Liberty Electronics (hereafter referred to as Liberty) for the manufacturing of LGS Unit 1 and 2 PPS ILC Assemblies. The PO stated that the items and services included in the PO are to be commercially dedicated by WEC for nuclear safety-related use. PO 4500858963 imposed requirements for Liberty to (1) impose use of International Organization for Standardization (ISO)/International Electrotechnical Commission (IEC) 17025, General requirements for the competence of testing and calibration laboratories accredited laboratories on Libertys POs for calibration services; and (2) record all inspection, measurement, and test equipment (IM&TE) utilized during inspections and tests for WEC products. These requirements were necessary to satisfy the commercial grade dedication of the ILC assemblies per Commercial Dedication Instruction (CDI) - 4057, Services Associated with Build to Print Electro-Mechanical Parts &
Assemblies, Revision 13.
The NRC inspection team observed that WEC did not verify that the requirements specified in PO 4500858963 were satisfied. Specifically, WEC did not provide sufficient objective evidence to demonstrate that Liberty had included in its quality program requirements to (1) use ISO/IEC 17025 accredited laboratories for procured calibration services, and (2) record IM&TE used for all inspection and tests for WEC products. In addition, WEC did not provide sufficient objective evidence that documents the basis to allow certain procurement restrictions imposed on procurements from Liberty as documented in CAP-IR-2020-4474 to be removed.
This issue has been identified as Nonconformance 99900404/2024-201-01.
c.
Conclusion The NRC inspection team issued Nonconformance 99900404/2024-201-01 in association with WECs failure to implement the regulatory requirements in Criterion VII of Appendix B to 10 CFR Part 50. Nonconformance 99900404/2024-201-01 cites WEC for failing to ensure that purchased material, equipment, and services from Liberty Electronics conform to the purchase order (PO) requirements.
6 3.
Nonconforming Materials, Parts, or Components, and Corrective Action Program a.
Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its control of 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, respectively.
The NRC inspection team verified that WECs processes and procedures provide for the identification, documentation, segregation, evaluation, and disposition of nonconforming items. These processes also apply the principles of rework, repair, reject, use-as-is.
The NRC inspection team observed WECs 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 material reports (i.e., Quality Notifications (QNs)) and automation issues tracking system (RITS) associated with the production of the Limerick digital modernization project to confirm that WEC dispositioned the nonconforming materials in accordance with the applicable procedures, documented an appropriate technical justification for various dispositions, and took adequate corrective action regarding the nonconforming items to prevent recurrence, as appropriate.
The NRC inspection team also reviewed a sample of CAP-IRs to verify: (1) adequate documentation and description of conditions adverse to quality; (2) 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) actions taken to verify timely and effective implementation of the corrective actions. In addition, the NRC inspection team confirmed 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 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 The NRC inspection team observed that WEC closed CAP-IR-2023-3864 and CAP-IR-2023-11754 without adequately correcting the conditions adverse to quality identified in these CAP-IRs. CAP-IR-2023-3864 stated that Diode IL-3000440791 went through test and quality control (QC) inspection and got posted to stock without being flagged on a QN for the forward bias voltage being out-of-tolerance. The NRC inspection team observed that the identified corrective action and the objective evidence of the actions implemented did not address the issue identified (i.e., deficiencies in the QA program that led to both the testing personnel and QC inspector to not identify the forward bias voltage as being out-of-tolerance).
CAP-IR-2023-11754 stated that WEC has lost configuration control of ILC cabinets that were being built by Liberty under PO 4500858963 for the LGS Units 1 and 2 digital
7 modernization project. The identified cause of this issue was that WEC unintentionally issued change notices (CNs) to PO 4500858963, which directed Liberty Electronics to build the ILC cabinets to a new design baseline while Liberty Electronics were amid manufacturing activities for the cabinets. These CNs resulted in loss of configuration controls for these cabinets. The corrective actions implemented did not adequately address the issue identified in this CAP-IR (i.e., WEC unintentionally issuing PO CNs with a new baseline). Further, objective evidence for completion of corrective actions was not documented in the CAP-IR. WEC created CAP-IR-2024-5058 to address these issues.
These issues are documented as Nonconformance 99900404/2024-201-02.
c.
Conclusion The NRC inspection team concluded that WEC is implementing its controls for nonconforming materials, parts, or components in accordance with the regulatory requirements of Criterion XV 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 its controls for nonconforming parts, materials, and components.
No findings of significance were identified.
The NRC inspection team issued NON 99900404/2024-201-02 in association with WECs failure to implement the regulatory requirements of Criterion XVI of Appendix B to 10 CFR Part 50. This NON cites WEC for failing to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material, and equipment, and nonconformances are promptly identified and corrected. Specifically, WEC closed CAP-IR-2023-3864 and CAP-IR-2023-11754 without adequately correcting the conditions adverse to quality identified in these CAP-IRs.
4.
Design Control a.
Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its design control program to verify compliance with the regulatory requirements of Criterion III of Appendix B to 10 CFR Part 50. The NRC inspection team sampled system requirements for the LGS Units 1 and 2 PPS, which encompassed design attributes related to system response time, system loading, secure operational environment, electrical and data isolation, and equipment qualification. The inspection team also sampled a Limerick PPS functional requirement related to the main steam isolation valve position contact inputs. The NRC inspection team confirmed that there was traceability of these system requirements to lower-level documents (e.g., software requirements and software design descriptions). The NRC inspection team also sampled priority logic requirements for the component interface module (CIM) and confirmed that the priority logic requirements were adequately translated into design descriptions, hardware specifications, and verified through independent verification and validation (IV&V).
In addition, the NRC inspection team discussed WECs program for design control with WECs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
8 b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that WEC is implementing its design control program in accordance with the regulatory requirements of Criterion III 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 its design control program. No findings of significance were identified.
5.
Procurement Document Control a.
Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its activities for procurement document control to verify compliance with the regulatory requirements of Criterion IV, Procurement Document Control, of Appendix B to 10 CFR Part 50.
The NRC inspection team reviewed a sample of POs to verify 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.
The NRC inspection team also discussed WECs procurement document controls 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 procurement document controls in accordance with the regulatory requirements of Criterion IV 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 procurement document controls. No findings of significance were identified.
9 6.
Entrance and Exit Meetings On May 6, 2024, the NRC inspection team presented the inspection scope during an entrance meeting with Ms. Camille Zozula, Manager of Global Nuclear Regulatory Affairs, and other members of WEC management and technical staff. On May 10, 2024, the NRC inspection team presented the inspection results to Ms. Zozula 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.
10 ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Position Affiliation Entrance Exit Interviewed Matthew Shakun Principal Licensing Engineer WEC X
X Michael Bednar Senior Quality Engineer WEC X*
X*
X*
Baylie Mook Quality Assurance Engineer WEC X*
Daniel Martin Qualification Operations, Principal Engineer WEC X*
Stephen Packard QA Manager WEC X*
X*
Boyan Setchenski Project Portfolio, Program Manager WEC X*
Dante Mincin Qualification Operations, Manager WEC X*
Matthew Wierzchowski Production Engineer WEC X*
Camille Zozula Global Nuclear Regulatory Affairs, Manager WEC X*
Warren Odess-Gillet Licensing I&C Engineer WEC X*
X*
Kasey Corbin Safety Systems Software Engineering, Manager WEC X*
X*
Anandi Balakumar IV&V Principal Engineer WEC X*
Matthew Thompson Quality Control Supervisor WEC X*
X*
Darryl Muetzel Hardware Engineering &
Draft, Principal Engineer WEC X*
11 Christopher Srock Global Instrumental and Control, Director WEC X*
Zachery Harper Licensing, Senior Manager WEC X*
Robert Beasley Hardware Engineering &
Draft, Principal Engineer WEC X*
X*
Steven Merkiel Functional &
Systems Engineering Principal Engineer WEC X
X X
Brian Domitrovich Energy System and I&C Senior PPM WEC X
X X
Stephen Seaman Safety & Reactor Systems Consulting Engineer WEC X
X Chris Crefeld Director, Safety &
Reactor Systems WEC X
X Murat Uzman Manager IV&V WEC X
X X
Angela Zubroski Quality Engineer WEC X
Miguel Vallarata Safety HW Engineering &
Drafting, Manager WEC X
X Andrew Lutz Principal Project Manager WEC X
Patrick Combes Hardware Engineering and Drafting WEC X
X*
Nick Moore Safety Software Engineering, Principal Engineer WEC X
X Roger Costantino Manager, System Testing and IV&V WEC X
X*
Brandon Neef GICP System Testing, Principal Test Engineer WEC X
X
12 Steve Billman Functional &
Systems Engineering, Senior Manager WEC X
X*
Courtney Frank Project Portfolio, Senior Director WEC X
Parastoo Muse Project Portfolio, Program Manager WEC X
X Hasan Serdar Uyar Principal Engineer, IV&V WEC X
Mart Uzman Manager, IV&V WEC X
Suresh Channarasap Consulting Engineer WEC X*
Jeremy Sawyer WEC X
X Eugene Frioni Lead Auditor WEC X*
Veronica Alberino Senior Quality Control Inspector WEC X
John Light WEC X
James McComiskey WEC X
Kaitlyn Elyard WEC X
Francis Mascitelli Licensing Lead Constellation X*
Gerald Segner Principal Project Manager Constellation X*
Mark Samselski Senior Staff Engineer Constellation X*
13 Deanna Zhang Inspector, Team Leader NRC X
X Odunayo Ayegbusi Inspector NRC X
X Louis Dumont Inspector NRC X
X Samir Darbali Subject Matter Expert NRC X
X Kerri Kavanagh Branch Chief NRC X*
- - Attended virtually
14 2.
INSPECTION PROCEDURES USED:
Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023 IP 35710, Quality Assurance Inspection of Software Used in Digital Instrumentation and Control Nuclear Applications, dated January April 18, 2024 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 99900404/2024-201-01 Opened Notice of Nonconformance (NON)
Criterion VII of Appendix B to 10 CFR Part 50 99900404/2024-201-02 Opened NON Criterion XVI of Appendix B to 10 CFR Part 50 4.
DOCUMENTS REVIEWED Quality Assurance and Work Procedures Westinghouse Electric Company Quality Management System-A, Revision 8.1, dated April 12, 2024 NA 4.19.9, Issue Reporting and Resolution, Revision 3.2, dated August 17, 2022 NA 15.1, Control of Nonconformances, Revision 21.1, dated August 11, 2021 W2-5.1-101, Westinghouse Corrective Action Program Procedure, Revision 10.0, dated September 27, 2023 W2-5.1-201, Identification and Reporting of Conditions Adverse to Nuclear Safety, Revision 3.0, dated March 27, 2024 W2-5.1-101.W01, Corrective Action Program Issue Identification, Screening, and Classification, Revision 4.0 W2-5.1-101.W11, Corrective Action program Issue Evaluation, Analysis, Resolution, and Trending, Revision 3.2 W2-5.1-201.W02, 10 CFR 21 Posting, Revision 1.0, dated March 27, 2024 W2-6.1-101, Document Control, Revision 1.2, dated July 27, 2022 W2-9.4-101, Control of Purchased Items and Services, Revision 8.1, dated August 24, 2022 W2-9.4-101, Control of Purchased Items and Services, Revision 8.1, dated August 24, 2022 W2-9.5-101, Supplier QA Program Qualification and Assessment, Revision 3.0, dated November 11, 2020
15 W2-9.5-104, Supplier Oversight, Revision 2.0, dated June 5, 2018 W2-9.5-105, Control of Suppliers on the ASL and QSL, Revision 3.0, dated October 10, 2018 W2-9.5-106, Supplier Corrective Action Request Process, Revision 3.0, dated May 27, 2020 W2-9.14-200, Counterfeit, Fraudulent, and Suspect Items, Revision 0.2, dated July 5, 2022 CDI-4057, Services Associated with Build to Print Electro-Mechanical Parts & Assemblies, Revision 13, dated August 23, 2022 CDI-5087, AC160 Module Manufacturing, Revision 06, dated October 18, 2023 QCI-308, Work Instruction for Receiving Inspection of Item(s) Controlled on a Westinghouse Commercial Dedication Instruction, Revision 7, dated March 2017 Limerick Plant Protection System Design Documents WNA-DS-04899-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System: System Requirement Specification, Revision 4 WNA-DS-04900-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System: System Design Specification, Revision 6 WNA-DS-05075-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Requirement Specification, Revision 0 WNA-DS-05101-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Component Functional Logic Specification, Revision 1 WNA-DS-05129-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Functional Logic Specification, Revision 1 WNA-SD-00746-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Bistable Processor Logic and Regulatory Guide 1.97 Processor, Revision B WNA-SD-00747-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Local Coincidence Logic Processor, Revision B WNA-SD-00748-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Integrated Logic Processor, Revision B WNA-SD-00749-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Software Design Description for the Interface and Test Processor, Revision B WNA-SD-00750-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Maintenance and Test Panel, Revision B WNA-SD-00751-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Safety Display, Revision A
WNA-J3-00024-GLIM, Limerick Generating Station Units 1&2 Detailed Functional Diagram
16 Reactor Protection System Main Steamline Isolation Valve Closure, Revision 1 LTR-GIC-23-052, Documentation of PPS Functional and System Design J3/J5 tracing up to SyRS, FLS and CFL Spec requirements, Revision 0 Limerick Plant Protection System and Component Interface Module (CIM) Design Documents WNA-PC-00071-GLIM, Limerick Generating Station (LGS) Digital Modernization Project (DMP) Units 1&2, Configuration Management Plan, Revision 1 6105-20010, Component Interface Module Requirement Traceability Matrix, Revision 20 6105-20004, CIM FPGA Software Requirements Specification, Revision 17 6105-00021, CIM SRNC IV&V Simulation Environment Specification, Revision 5 6105-20032, ATB-CIM Test Case Specification, Revision 5 6105-00005, Operating Plants Business Independent Verification and Validation: CIM-SRNC Test Plan Revision 11 6105-20014, CIM FPGA Software Design Description, Revision 5 6105-00013, CIM-SRNC IV&V Plan, Revision 14 6105-60135, CIM-SRNC IV&V Task Report Implementation Phase Component Test Procedure Generation & Verification, Revision 0 6105-00092, CIM-SRNC IV&V Summary Report, Revision 11 WNA-DS-02331-GEN, Component Interface Module Logic Specification, Revision 2 WNA-TP-04019-GEN, CIM SRNC Subsystem Test Procedure, Revision 2 WNA-DS-02904-GEN, CIM SRNC Subsystem Test Tool Design Specification, Revision 0 WNA-VR-00365-GEN, Synopsys VCS D-2010.06-4 Software Validation Report, Revision 0 WAAP-12879, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Revision 0 WNA-TR-02718-GEN CIM SRNC Subsystem Test Report, Revision 4 Purchase Orders (PO) 4500439371 4500428578 4500858963 4500885816 Corrective Action Program - Issue Report (CAP-IR) Reviewed During the NRC Inspection CAP IR-2020-4474 CAP IR-2022-10020
17 CAP IR-2023-2884 CAP IR-2023-3834 CAP IR-2023-3864 CAP IR-2023-6619 CAP IR-2023-8261 CAP IR-2023-9684 CAP IR-2023-9913 CAP IR-2023-11608 CAP IR-2023-10638 CAP IR-2023-11641 CAP IR-2023-11754 CAP IR-2023-12161 CAP IR-2024-3 CAP IR-2024-48 CAP IR-2024-416 CAP IR-2024-795 CAP IR-2024-1956 CAP IR-2024-2116 CAP IR-2024-2567 CAP IR-2024-4672 CAP-IR Created During NRC Inspection CAP-IR-2024-5058 Nonconforming Report Quality Notifications (QNs) 60104583 60105885 60106098 60106186 60106649 Automation Issues Tracking System (RITS) 77259 77547 78039 79232 79925 Training Records and Reports Limerick Design Modernization Project Training Report, dated May 9, 2024 Supplier Audits WES-2020-015, Supplier Commercial Grade Survey Report of Liberty Electronics Inc, dated April 9, 2020
18 WES-2023-102, Supplier Commercial Grade Survey Report of Liberty Electronics, dated April 4, 2023 Supplier Audit / Evaluation Summary (SAES) ID 51958 Liberty Electronics PO Restriction Update