ML24222A673
| ML24222A673 | |
| Person / Time | |
|---|---|
| Site: | 99902105 |
| Issue date: | 07/31/2024 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Knott R Paragon Energy Solutions |
| References | |
| EPID I-2024-201-0038 IR 2024201 | |
| Download: ML24222A673 (1) | |
Text
Richard Knott, Vice President, Quality Assurance Paragon Energy Solutions, LLC, 7410 Pebble Dr, Fort Worth, TX 76118
SUBJECT:
NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF PARAGON ENERGY SOLUTIONS, LLC NO. 99902105/2024-201
Dear Mr. Knott:
On June 24 - 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at Paragon Energy Solutions, LLCs (hereafter referred to as PES) facility in Fort Worth, TX (formerly owned by AZZ Nuclear l NLI). The purpose of this limited-scope routine inspection was to assess PESs 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 PESs implementation of quality activities associated with the supply of safety-related design, reverse engineering, commercial grade dedication, equipment testing and qualification, repair and replacement services to NRC regulated facilities. In addition, the NRC inspection team evaluated PESs closure of two Notices of Nonconformance NON 99901471/2016-201-04 and NON 99901471/2019-201-01 documented in inspection report No. 99901471/2016-201, dated December 14, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16305A097) and inspection report No. 99901471/2019-201, dated July 3, 2019 (ADAMS Accession No. ML19175A138), respectively. This NRC inspection report does not constitute NRC endorsement of PESs overall quality assurance (QA) or 10 CFR Part 21 programs.
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.
July 31, 2024
R. Knott 2
Sincerely, Kerri Kavanagh, Chief Quality Assurance Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99902105 EPID No.:
I-2024-201-0038
Enclosure:
Inspection Report No. 99902105/2024-201 and Attachment Signed by Kavanagh, Kerri on 07/31/24
ML24205A231 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME MFitzgerald YLaw Deanna Zhang DATE 07/26/2024 07/24/2024 07/29/2024 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME BHughes OAyegbusi KKavanagh DATE 07/25/2024 07/24/2024 07/31/2024 Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99902105 Report No.:
99902105/2024-201 Vendor:
Paragon Energy Solutions, LLC 7410 Pebble Dr, Fort Worth, TX 76118 Vendor
Contact:
Richard Knott Vice President Quality Assurance Phone: 518-450-9706 Email: RKnott@paragones.com Nuclear Industry Activity:
Paragon Energy Solutions, LLC is an American Society of Mechanical Engineers Boiler and Pressure Vessel Code N, NPT, and NS certificate holder. Paragons scope of supply includes safety-related design, reverse engineering, commercial grade dedication, equipment testing and qualification, repair and replacement services for NRC regulated facilities.
Inspection Dates:
June 24 - 28, 2024 Inspectors:
Odunayo Ayegbusi NRR/DRO/IQVB, Team Leader Deanna Zhang NRR/DRO/IQVB Michael Fitzgerald NRR/DRO/IQVB, Trainee Yiu Law NRR/DRO/IQVB, Remote Approved by:
Kerri Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
Paragon Energy Solutions, LLC 99902105/2024-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a limited-scope routine vendor inspection at the Paragon Energy Solutions, LLCs (hereafter referred to as PES) facility in Fort Worth, TX, 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 June 24 - 28, 2024. This was the first NRC inspection of PESs Fort Worth facility, after PES purchased AZZ Nuclear l NLI in 2020.
This technically focused inspection specifically evaluated PESs implementation of the quality activities associated with the supply of safety-related design, reverse engineering, commercial grade dedication, equipment testing and qualification, repair and replacement services for NRC regulated facilities.
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 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 NRC inspection team observed the following specific activities:
Seismic qualification testing of a nuclear instrument assembly Receipt inspection of electrical breakers Walkdown of measuring and test equipment and nonconformance storage lockers Acceptance testing for the commercial grade dedication of a pressure regulator valve Pre-job brief and factory acceptance test for a charge alarm & load sharing assembly The results of this inspection are summarized below.
Corrective Action Program The NRC inspection team reviewed the corrective actions that PES took to address Nonconformance No. 99901471/2016-201-04, documented in inspection report No. 99901471/2016-201, dated December 14, 2016, and Nonconformance No. 99901471/2019-201-01, documented in inspection report No. 99901471/2019-201, dated July 3, 2019. 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. 99901471/2016-201-04 and 99901471/2019-201-01.
3 Inspection Areas The NRC inspection team determined that PES established its programs for 10 CFR Part 21, design control, commercial grade dedication, equipment testing and qualification, procurement document control and oversight of contracted activities, identification and control of materials, parts, and components, special processes, control of measuring and test equipment, nonconforming materials, parts, or components, corrective action, 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 PES 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 Paragon Energy Solutions, LLCs (hereafter referred to as PES) 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 PESs 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 PESs nonconformance and corrective action procedures provide a link to its 10 CFR Part 21 program. Furthermore, for a sample of 10 CFR Part 21 evaluations performed by PES, the NRC inspection team verified that PES had effectively implemented the requirements of 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, Notification of Failure to Comply or Existence of a Defect and its Evaluation, as applicable.
The NRC inspection team discussed the 10 CFR Part 21 program with PESs 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 PES 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 PES is adequately implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.
2.
Design Control and Reverse Engineering a.
Inspection Scope The NRC inspection team reviewed PESs 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, 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 a completed reverse engineering project for an undervoltage auxiliary relay cabinet system control logic board and verified that the design management plans for the control logic board and decoder logic board, acceptance and inspection procedures, and drawings for these boards were completed in accordance with PESs reverse engineering procedures.
5 The NRC inspection team also discussed the design control program with PESs management and technical staff. The attachment to this inspection report lists the procedures 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 PES is implementing its design control program and reverse engineering controls 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 determined that PES is implementing its policies and procedures associated with its design control program and reverse engineering controls. No findings of significance were identified.
3.
Commercial-Grade Dedication a.
Inspection Scope The NRC inspection team reviewed PESs policies and implementing procedures that govern the implementation of its commercial-grade dedication (CGD) program to verify compliance with the regulatory requirements of Criterion III and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50.
The NRC inspection team reviewed a sample of PESs completed CGD project documents, including CGD technical evaluations and plans, inspection and acceptance procedures, dedication and verification and validation reports, and associated POs and receipt inspection forms. The NRC inspection team verified that the technical evaluations identified appropriate (1) critical characteristics to be verified for the item under dedication, and (2) acceptance methods and acceptance criteria for each critical characteristic. The NRC inspection team observed the performance of acceptance testing for the commercial grade dedication of a pressure regulator.
The NRC inspection team also discussed the CGD program with PESs 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 PES 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 and activities observed, the NRC inspection team determined that PES is implementing its policies and procedures associated with the CGD program. No findings of significance were identified.
6 4.
Procurement Document Control and Oversight of Contracted Activities a.
Inspection Scope The NRC inspection team reviewed PESs 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 PESs 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 PES 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 or commercial grade surveys (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 or surveys reviewed, the NRC inspection team verified the following: the audit/survey reports included an audit/survey plan; audits/surveys were performed according to established frequency; audit/survey reports included adequate documented objective evidence of compliance with the applicable requirements; and audit/survey documentation was reviewed by PESs responsible management. The NRC inspection team also verified that audits performed by the Nuclear Industry Assessment Committee were evaluated by PES in accordance with its written procedures for applicability to its scope of activities.
The NRC inspection team also discussed the procurement document control and supplier oversight programs with PESs 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 PES 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 PES is adequately
7 implementing its policies and procedures associated with the procurement document control and supplier oversight programs. No findings of significance were identified.
5.
Test Control and Equipment Qualification a.
Inspection Scope The NRC inspection team reviewed PESs policies and implementing procedures that govern the implementation of its test control program to verify compliance with the regulatory requirements of Criterion XI, Test Control, of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed PESs equipment qualification test procedures and factory acceptance test procedures.
The NRC inspection team reviewed a select sample of PES environmental and seismic test reports for safety-related equipment and verified that the test reports specified applicable standards, test methods, and acceptance criteria. The NRC inspection team also verified that test anomalies identified in these reports were appropriately evaluated and dispositioned.
The NRC inspection team observed the pre-job briefing and performance of a factory acceptance test for a charge alarm and load sharing assembly and verified that the test was completed in accordance with the test procedure.
The NRC inspection team also discussed the test control program with PESs 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 PES is implementing its test control program in accordance with the regulatory requirements of Criterion XI of Appendix B to 10 CFR Part 50.
Based on the limited sample of documents reviewed and activities observed, the NRC inspection team determined that PES is implementing its policies and procedures associated with the test control program. No findings of significance were identified.
6.
Identification and Control of Materials, Parts, and Components a.
Inspection Scope The NRC inspection team reviewed PESs policies and implementing procedures that govern the implementation of its material identification and control program to verify compliance with the regulatory requirements of Criterion VIII, Identification and Control of Materials, Parts, and Components, of Appendix B to 10 CFR Part 50.
The NRC inspection team performed a walk-down of PESs facility and verified that components were identified with a traceability number that is attached with a label to the component. The traceability number is based on PESs job number. The NRC inspection team also noted that the traceability number is included in all the documentation associated with the component, as applicable.
8 The NRC inspection team also discussed the material identification and control program with PESs 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 PES is implementing its material identification and control program in accordance with the regulatory requirements of Criterion VIII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and activities observed, the NRC inspection team determined that PES is adequately implementing its policies and procedures associated with the material identification and control program. No findings of significance were identified.
7.
Control of Special Processes a.
Inspection Scope The NRC inspection team reviewed PESs policies and implementing procedures that govern the implementation of its control of special processes to verify compliance with the regulatory requirements of Criterion IX, Control of Special Processes, of Appendix B to 10 CFR Part 50.
During the week of the inspection, there were no safety-related welding or non-destructive examination activities being performed. The NRC inspection team reviewed completed welding documentation and training records associated with the PES personnel that completed the welding activities.
The NRC inspection team also discussed the control of special processes program with PESs 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 determined that PES has established policies and procedures associated with the control of special processes program in accordance with the regulatory requirements of Criterion IX of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that PES is adequately implementing its policies and procedures associated with the special processes program. No findings of significance were identified.
9 8.
Control of Measuring and Test Equipment a.
Inspection Scope The NRC inspection team reviewed PESs policies and implementing procedures that govern the implementation of its M&TE program to verify compliance with the requirements of Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50.
The NRC inspection team performed a walkdown of the M&TE storage and production areas and selected a sample of M&TE for review. The NRC inspection team verified that the M&TE were labeled, handled, and stored in a manner that indicated the calibration status of the instrument and ensured its traceability to calibration test data, including appropriate calibration stickers and current calibration dates. The NRC inspection team also verified that the M&TE had been calibrated, adjusted, and maintained at prescribed intervals prior to use.
Additionally, the NRC inspection team verified that the certificate of calibration stated the traceability to a nationally recognized standard. The NRC inspection team confirmed that when M&TE is found to be out of calibration, a discrepancy report (DR) is initiated, and an evaluation is performed to determine if the M&TE was previously used. The NRC inspection team reviewed the M&TE log, which included M&TE that were transferred from closed PES facilities.
The NRC inspection team discussed the control of M&TE with PESs 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 PES 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 PES is implementing its policies and procedures associated with the M&TE program. No findings of significance were identified.
9.
Nonconforming Materials, Parts, or Components and Corrective Action a.
Inspection Scope The NRC inspection team reviewed PESs policies and implementing procedures that govern the implementation of its nonconforming materials, parts, or components and corrective action programs to verify compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50.
The NRC inspection team verified that PESs 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.
10 The NRC inspection team observed PESs 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 (NCRs) generated between 2021 to 2024 that were associated with the production of safety-related parts to confirm that PES 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. In addition, the NRC inspection team confirmed that the nonconformance process provides a link to the 10 CFR Part 21 program.
The NRC inspection team also reviewed a sample of corrective action program assessments (CAPAs) to verify: (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 confirmed that the corrective action process provides a link to the 10 CFR Part 21 program.
In addition, the NRC inspection team reviewed the implementation and closure of the corrective actions taken in response to two Notice of Nonconformances (NON) documented in NRC inspection report No. 99901471/2016-201, dated December 14, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16305A097) and inspection report No. 99901471/2019-201, dated July 3, 2019 (ADAMS Accession No. ML19175A138).
The NRC inspection team discussed the nonconformance and corrective action programs with PESs 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 Corrective Action Associated with Notice of Nonconformance 99901471/2016-201-04 Following the December 2016 inspection of PES (formerly AZZ Nuclear l NLI), the NRC issued NON 99901471/2016-201-04 for PESs failure to ensure the suitability of equipment that is essential to the safety-related functions for certain components supplied to the nuclear industry on two occasions. In the first instance, PES failed to verify the critical characteristic of total harmonic distortion and power quality on the output of a repaired Exeltec inverter supplied to an NRC licensee. In the second instance, PES failed to identify and verify the critical characteristic of current interrupting rating for Masterpact circuit breakers supplied to an NRC licensee.
Regarding the first part of the NON, the 2019 NRC inspection of PESs facility verified the corrective actions taken and closed the first part of the NON.
Regarding the second part of the NON, the 2019 NRC inspection team did not consider the corrective action taken to be adequate. Specifically, the 2019 NRC inspection team identified that for circuit breakers and other similar devices supplied by PES as part of motor control centers, PES had not taken sufficient actions to verify that the supplied items were identical
11 in form, fit, and function to those that were previously qualified and tested by PES. PES did not have control of the design process for these commercial devices and did not repeat the qualification testing, which was used to validate the commercial ratings on the original supplied equipment. In addition, PES did not perform inspections, surveys, or other activities that might be sufficient to verify that no changes had occurred to the commercial components that would invalidate their previously established commercial ratings, including interrupting ratings. Based on these concerns, the second part of the NON was left open after the 2019 NRC inspection of PESs facility.
In its response, dated September 26, 2019 (ADAMS Accession No. ML19282A381), PES stated that it initiated NLI-CAPA-534 to address the second part of the NON.
The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions in NLI-CAPA-534. The NRC inspection team verified that 1) procedures were revised to document how the circuit interrupt rating for motor control center devices will be verified; and 2) training was administered to the engineering staff regarding identifying Short Circuit Interrupt (SCI) or Short Circuit Withstand (SCW) when it is determined to be a critical characteristic for the application of a specific safety function.
Based on its review, the NRC inspection team determined that PES adequately corrected the issue. Therefore, the NRC inspection team closed NON 99901471/2016-201-04.
Corrective Action Associated with Notice of Nonconformance 99901471/2019-201-01 Following the July 2019 NRC inspection of PES (formerly AZZ Nuclear l NLI), the NRC issued NON 99901471/2019-201-01 for PESs failure to ensure the suitability of equipment that is essential to the safety-related functions for certain components supplied to the nuclear industry associated with the environmental qualification testing of certain relays. Specifically, as part of its process for performing qualification testing, PES failed to justify the activation energies used in the thermal aging analysis/calculations. Also, PES failed to fully evaluate anomalies that were identified during the functional testing portion of the qualification program.
In its response, dated September 26, 2019 (ADAMS Accession No. ML19282A381), PES stated that it initiated NLI-CAPA-539 and NLI-CAPA-543 to address the NON. As part of the corrective actions, PES performed an extent of condition review, which resulted in additional training to ensure that individuals dispositioning anomalies provide the necessary information to substantiate the decision to accept or reject anomalies.
The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions in NLI-CAPA-539 and NLI-CAPA-543. The NRC inspection team verified that 1) the procedure that governs the qualification process had been revised to include details of the steps and justification that are necessary to be performed before selecting an activation energy for any material; 2) training was conducted for PESs engineering group; 3) anomalies during functional testing are to be well explained, description of the issue and resolution must be clear without the need to interview other stakeholders, decisions to resolve the anomalies must be explained, and resolution must be substantiated. Based on its review, the NRC inspection team determined that PES adequately corrected the issue. Therefore, the NRC inspection team closed NON 99901471/2019-201-01.
12 c.
Conclusion The NRC inspection team concluded that PES 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 PES is implementing its policies and procedures associated with its nonconformance and corrective action programs.
No findings of significance were identified.
- 10. Internal Audits a.
Inspection Scope The NRC inspection team reviewed PESs 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 PESs internal audit plans, internal audit reports, and CAPAs generated during internal audits when applicable. The NRC inspection team verified that the audit documents reviewed were adequately completed and that PES adequately corrected the conditions identified in CAPAs generated during internal audits. The NRC inspection team verified that PESs 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 PESs 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 PES 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 PES is adequately implementing its policies and procedures associated with the internal audit program. No findings of significance were identified.
- 11. Entrance and Exit Meetings On June 24, 2024, the NRC inspection team presented the inspection scope during an entrance meeting with Mr. Doug VanTassell, PESs President/Chief Executive Officer, and other members of PESs management and technical staff. On June 28, 2024, the NRC inspection team presented the inspection results to Mr. Doug VanTassell and other members of PESs 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.
Att1 ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Position Affiliation Entrance Exit Interviewed Doug VanTassell President/Chief Executive Officer Paragon Energy Solutions, LLC (PES)
X X*
Tighe Smith Chief Nuclear Officer PES X*
X Howard LeCompte
- Director, Business Developme nt PES X
X*
X Richard Knott Vice President (VP),
Quality Assurance PES X
X X
Kenny Morrison Supplier Quality Manager PES X
X X
Tracy Muller QA Manager PES X
X X
Chip VanTassell Chief Financial Officer PES X
X John Wisniewski VP, Major Projects PES X
Joe Garguilo VP, Engineering PES X
X X
Daniel Dale Chief Operating Officer PES X
X Leo Lara Director, Lab Operations PES X
X Josh Ricci Training Manager PES X
X
Att1 Kim Tomlinson
- Director, Procurement &
Inventory PES X
X Henry Moana QA Engineering Supervisor PES X
X X
Matt Novotny QC Supervisor PES X
X X
Ross Lorberbaum
- Director, Electrical Engineering PES X*
X*
Brenan Kelley I&C Lab Manager PES X*
X*
James Nguyen Electrical Engineering Manager PES X*
X*
Chad Michaelis Innovation Team Manager PES X*
Michael Norris PMO Manager PES X*
Marcus Oates Mechanical Engineering Manager PES X*
X*
X Nathan Newland I&C Engineering Manager PES X*
Nick Phan ASME Mechanical Engineer PES X*
X*
X
Att1 Tim Lara Mechanical Lab Manager PES X*
X*
X Cole Howard CGD Lab Manager PES X*
X*
Heather Born VP, Human Resources PES X*
X*
Sean Beedy I&C Engineering Manager PES X*
X*
Chris Harrington Chief Innovation Officer PES X*
X Larry Forist Assembly Lab Supervisor PES X*
Chris Medley ASME Quality Engineer PES X*
X Sandra Thompson M&TE Technician PES X
Violet Mowrer Receipt Inspector PES X
Jeff Stubblefield Principal Electrical Engineer PES X
Att1 Bennett Miller Senior Electrical Engineer PES X
Jose Alvarez I&C Engineer PES X
Eric Laise Level II Technician PES X
Ezra Israel Level I Technician PES X
Henry Le Supplier Quality Engineer PES X
X X
Robert Goller Lead Mechanical Engineer PES X
Joshua Brandon Project Engineer PES X
Odunayo Ayegbusi Inspection Team Leader Nuclear Regulatory Commission (NRC)
X X
Deanna Zhang Inspector NRC X
X Michael Fitzgerald Inspector NRC X
X Yiu Law Inspector NRC X*
X*
Aaron Armstrong Acting Branch Chief NRC X*
X*
- Remote
Att1 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 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 99901471/2016-201-04 CLOSED Nonconformance (NON)
Criterion III 99901471/2019-201-01 CLOSED NON Criterion III 4.
DOCUMENTS REVIEWED Quality Assurance Procedures (QAP):
Paragon Energy Solutions, LLC Quality Assurance Manual Second Edition, Revision 1, dated February 27, 2023 ASME Quality Assurance Manual, Revision 28, dated December 2023 QSP-01, ASME Code Program, Scope and Requirements Procedure, Revision 14, dated December 21, 2023 QAP-02, Training, Revision 11, dated April 1, 2024 QAP-03, Design Control, Revision 9 QAP-07, Control of Purchased Items and Services, Revision 16, dated December 21, 2023 QAP-08, Identification & Control of Material, Parts, & Components, Revision 2, dated March 7, 2021 QAP-09, Control of Special Processes, Revision 3, dated November 5, 2020 QAP-12, Control of Measuring and Test Equipment, Revision 6, dated May 8, 2024 QAP-13, Handling, Storage, & Shipping, Revision 6, dated December 7, 2023 QAP-14, Inspection, Test, and Operating Status, Revision 3, dated March 23, 2023 QAP-15, Control of Nonconforming Items, Revision 8, dated July 4, 2024 QAP-16, Corrective and Preventive Actions, Revision 4, dated July 4, 2024 QAP-18, Audits, Revision 5, dated December 21, 2023 QAP-19, 10CFR21 Reporting, Revision 4, dated July 4, 2024 Engineering Procedures (ENG) and Standard Operating Procedures (SOP):
ENG-01, Commercial Grade Dedication, Revision 7 ENG-03, Equipment Qualification, Revision 5, dated July 4, 2024 ENG-04, Welding & Brazing, Revision 4, dated August 21, 2023 ENG-05, Reverse Engineering of Electronic Components and Assemblies Revision 7 ENG-13, Non-Destructive Examination, Revision 3, dated November 14, 2023
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- ENG-16, General Requirements for Painting, Powder Coating, & Plating, Revision 2, dated November 18, 2020 ENG-18, Engineering Change Notice, Revision 4 ENG-20, Factory Acceptance Testing, Revision 4, dated January 19, 2024 SOP-PRD-004, Production Discrepancy Report Process Revision 3 MCC-Cubicle-FMEA-1, Failure Modes and Effects Analysis (FMEA), Equipment: Motor control Center Cubicles, Revision 3, dated April 29, 2020 FMEA-ICP, Failure Modes and Effects Analysis (FMEA), Equipment: Industrial Control Panels, Revision 2, dated April 1, 2020 SVP-101, Revision 11, dated January 31, 2024 Completed Commercial Grade Dedication Packages (CGD) project packages:
Commercial Grade Item Dedication Technical Evaluation, Plan, and Test Data Sheet:
CGD-GFH45AS3204G1, Revision 0, dated July 10, 2024 Commercial Grade Item Dedication Technical Evaluation and Test Plan: CGD-BXXXX-Series Transformer, Revision 0, dated February 2, 2023 Commercial Grade Item Dedication Technical Evaluation, Test Plan, and Test Datasheet:
CGD-MBC-2920-130B-E, Revision 6, dated April 1, 2024 Commercial Grade Item Dedication Technical Evaluation, Test Plan, and Test Datasheet:
CGD-Micrologic-5.0A, Revision 0, dated October 18, 2022 Design Documents and Qualification Reports:
QR-065027-1, Revision 10, dated May 14, 2020 RR-21000772-1, Revision 0, dated November 30, 2022 VVR-042181-1, Revision 19, February 17, 2017 VVR-042181-1, Revision 20, dated April 4, 2022 DMP-22000559-01-01, Revision 0, August 22, 2022 DMP-22000559-02-01, Revision 0, dated May 23, 2023 IEE22000559-01-02, Revision 0, dated September 12, 2023 QR33013-904-1, Revision 0, dated September 12, 2023 QP-21000065-1, Seismic Test Plan, Revision 5, dated May 30, 2024 DWG No 33013-904-PCB-1, Revision 0, dated September 12, 2023 DWG No 33013-904-SD-1, Revision 0, dated September 12, 2023 Audits/Surveys:
QAA-2022-01, Paragon Energy Solutions (PES) 2022 Internal Audit, Revision 0, dated March 3, 2023 QAA-2023-01, Paragon Energy Solutions (PES) 2023 Internal Audit, Revision 0, dated November 8, 2023 APXBR-AVL-129-004, Third Part Audit/Survey Assessment Evaluation, Revision 0, dated January 20, 2023 PAC-AVL-129, Performance Assessment Checklist, dated October 3, 2023 CGSR-AVL-1187-01, Commercial Grade Survey Report, Revision 0, dated April 13, 2023 PAC-AVL-1187-01, Performance Assessment Checklist, dated September 8, 2022 PAC-AVL-1187-02, Performance Assessment Checklist, dated April 2, 2024 APXBR-AVL-1111-03, Third Party Audit/Survey Assessment Evaluation, Revision 1, dated June 1, 2022
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- PAC-AVL-1111-04, Performance Assessment Checklist, dated October 3, 2023 CGSR-AVL-191-11, Commercial Grade Survey Report, Revision 0, dated July 5, 2022 Purchase Orders (PO):
PO 018480, dated January 20, 2023 PO 019179, dated February 21, 2023 PO 027736, dated May 6, 2024 PO 45010255968, dated October 5, 2023 PO 024047, dated October 16, 2023 PO 10657079, dated May 9, 2024 PO NLI-108978, dated April 13, 2020 PO 03172476, dated November 8, 2023 PO 10643889, dated February 3, 2023 PO 4501241844, dated February 29, 2024 PO 01368380, dated September 15, 2023 PO 1384756, dated February 25, 2023 PO 01389979, dated March 29, 2023 Measuring and Test Equipment Documents:
M&TE Records - 3207 Fluke Multimeter, 3120 Fowler 12 Digital Caliper, 2794 Fluke Multimeter, 2613 Pressure Gauge, 1913 Pressure Transducer, 707 Stopwatch, 1896 Pressure Transducer, 3136 Fluke Multimeter, 1604 Signal Conditioner, 1903 Accelerometer, 2475 Digital Manometer, Torque Screwdriver, 2622 Current Probe, 2661 Flowmeter, 3130 Fluke Multimeter, 2017 Oscilloscope, 3129 Digital Multimeter, 1523 Multimeter, 897 Fluke Multimeter Calibration Certificates - 173279, 176790, 0011507813, 0011512456, 176360, 170313, 172077, 173038, 555865, 570109, 0011465025, 176786, 171736, 510456.2024, 172830, 0011456683, 0011522957, 168185, 173837 Material Receipt Forms:
36051 - Breaker 8310 - Electrical, Glass Cloth Type 24983 - Seal Oil, Nitrile 22545 - Seal Oil, Viton 23831 - Gasket, Actuator 13043 - Gasket 31961 - Breaker 26815 - Ferrule 25918 - Cable, 14 AWG 25980 - Power Supply DRs/NCRs:
DR-24845 DR-24847 DR-19974
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- DR-27928 DR-27929 NCR-964 NCR-1057 NCR-1081 NCR-1088 NCR-1089 NCR-1109 NCR-1113 NCR-1133 NCR-1148 NCR-1154 NCR-1169 NCR-1171 NCR-1173 NCR-1179 Corrective and Preventive Actions (CAPAs):
534, 539, 543, 746, 767, 768, 786, 781, 830, 838, 881, 884, 885, 898, 899, 904, 905, 915, 932, 939, 957 CAPAs Opened During the Inspection:
964, 965, 966, 967 Training and Qualification Records:
Lead Auditor Training and Qualification Records for Kevin Buckley, Randy Butz, Kenny Morrison, Henry Le, and Chris Goddard Training Records for Ezra Israel, Tim Lara, Eric Laise, Jose Alvarez, Daniel Maze, Violet Mowrer, and Sandra Thompson Welder Qualification Records for David Flores and Joey Bryan Test Control Documents:
AP-MBC-3720-E, Revision 1, dated March 7, 2024 IP 33013-904-01-01, Material Inspection Procedure for Fuse, Revision 0, dated September 1, 2022 TD-PR22000559, Test Data Associated with IP33013-904-01-01, Revision 0 Receipt Inspection Record:
Receipt Inspection Record for PO NLI-108978 Receipt Inspection Record for PO 015821 Miscellaneous:
CC-PR21000772-1, Revision 0 Job Order PR 23001043