ML24261B891
| ML24261B891 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/2024 |
| From: | Yamir Diaz-Castillo, Fitzgerald M NRC/NRR/DRO/IQVB |
| To: | |
| References | |
| Download: ML24261B891 (16) | |
Text
NRC Update NUPIC General Membership Meeting June 10 - 11, 2024 Baltimore, MD Yamir Diaz-Castillo & Michael Fitzgerald Quality Assurance & Vendor Inspection Branch Office of Nuclear Reactor Regulation
Recent & Upcoming NRC Inspections 2
Recent (since the last update):
Korea Hydro & Nuclear Power Consolidated Power Supply NuScale Power, LLC Westinghouse Electric Company (WEC) (Columbia, SC)
Integrated Power Services TE Connectivity WEC (Warrendale, PA)
ASCO L.P.
Doosan Enerbility (South Korea)
Fairbanks Morse Engine (NUPIC Observation)
Upcoming:
Energy Steel Paragon Energy Solutions
NRC Inspections & Findings 3
Hanna Cylinders Criterion II, Quality Assurance Program
Failed to provide objective evidence that personnel performing activities affecting quality were adequately trained (no training records available since 2020 to present).
Criterion VII, Control of Purchased Material, Equipment, and Services
Failed to provide objective evidence that a supplier of safety-related services (internal audits) was audited prior to adding it to the Approved Suppliers List (ASL).
Failed to perform a commercial-grade survey of three commercial suppliers that were added to the ASL.
Failed to take measures to control parts procured from at least two suppliers not listed on the ASL.
NRC Inspections & Findings 4
Hanna Cylinders (cont.)
Criterion XII, Control of Measuring and Test Equipment Failed to adequately control measuring and test equipment (M&TE) and perform an extent of condition:
Two ring gages found out of tolerance in June 2023 but did not perform an extent of condition review (one ring gage used for a safety-related job in July 2022).
One vernier caliper could not be found and did not perform an extent of condition review.
Another vernier caliper past its calibration due date was in the segregation area but not tagged.
Two plug gages not controlled in the M&TE log.
NRC Inspections & Findings 5
Hanna Cylinders (cont.)
Criterion XVI, Corrective Action Failed to promptly identify and correct conditions adverse to quality:
Three corrective action reports (CARs) remained open past the due date imposed by procedures.
One CAR was closed without completing the corrective action.
The effectiveness review for several CARs was not performed as required by procedures.
NRC Inspections & Findings 6
Consolidated Power Supply Criterion III, Design Control, and Criterion VII Failed to verify several dimensional critical characteristics met the applicable requirements.
NuScale Criterion V, Instructions, Procedures, and Drawings Failed to classify an engineering calculation as safety-related.
Failed to screen an error under 10 CFR 50.46.
NRC Inspections & Findings 7
TE Connectivity Criterion VII Failed to perform commercial-grade surveys to verify that the commercial suppliers had established and adequately implemented homogeneity and traceability controls to support the selected sample plans.
Criterion XVI Failed to promptly identify and correct conditions adverse to quality:
Five CARs opened and closed; however, the corrective actions were not adequately implemented (identified reoccurrence).
NRCs Engagement with NUPIC 8
NRC observed the 1st NUPIC joint utility audit in 2004 (B&W Canada).
Other countries are looking to emulate the NUPIC organization.
Why do we observe NUPIC audits?
To verify, by direct observation, the effectiveness of the independent oversight activities performed by 3rd party organizations to qualify vendors.
Ensure the NUPIC audit process remains an acceptable alternative to the NRCs vendor inspection program.
Revisions to RG 1.164 & RG 1.234 9
Revision 1 to Regulatory Guide (RG) 1.164, Dedication of Commercial-Grade Items for Use in Nuclear Power Plant, was issued in April 2024.
2 updates related to Counterfeit, Fraudulent, or Suspect Items (CFSI):
Definition of CFSI.
Reference to EPRI 3002002276, Plant Support Engineering: Counterfeit and Fraudulent Items Mitigating the Increasing Risk.
Revisions to RG 1.164 & RG 1.234 10 Revision 1 to RG 1.234, Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR Part 21, was issued in March 2024.
3 updates on postings, training, and CFSI:
Postings can be digital copies, hard copies, or a combination of both. May be met through electronic postings, regardless of the physical location of the workplace. Moved from the Background to the Regulatory Position section.
Revisions to RG 1.164 & RG 1.234 11 3 updates on postings, training, and CFSI (cont.):
Training of personnel involved in 10 CFR Part 21 activities is covered under 10 CFR 50.120, Training and qualification of nuclear power plant personnel.
Does not contradict guidance in NEI 14-09. Moved from the Background to the Regulatory Position section.
Definition of CFSI.
Public Meeting on ASME Code Case (CC) N-883 12 Code Case (CC) N-883 allows ASME Certificate Holders to build items prior to the establishment of an Owner.
The NRC does not have regulatory jurisdiction over ASME Certificate Holders and cannot authorize them to construct items using CC N-883.
NRC conditioned the use of CC N-883 in Revision 9 of RG 1.84 (can only be used by holders of construction permit, operating license, or combined license).
Virtual public meetings held on May 8, 2024, and June 11, 2024, to discuss the industrys needs.
Collaboration with NMSS 13 Joint observation by NRR and NMSS of the NUPIC audit of ORANO, TN Americas in December 2023.
An NMSS staff member participated in the vendor inspection of Consolidated Power Supply in Birmingham, AL and of Doosan Enerbility in Changwon, Korea.
Conduct joint Branch meetings every 6 weeks.
Allows for the efficient and maximum use of resources.
Revision to Inspection Procedure 43005 14 Two key changes:
If the NRC staff disagrees with the audit teams assessment of the issue(s), the NRC staff will have a debrief meeting with the audit team leader after the exit meeting.
The NRC will wait to get the audit report before issuing the NRCs trip report (within 30 days of getting the audit report) and the NRC staff will document the disagreements discussed with the audit team leader in the trip report.
Friendly Reminder 15 To allow the continued operation of nuclear reactors during the COVID-19 pandemic, the NRC issued several safety evaluations allowing licensees to perform remote audits, commercial-grade surveys, and source verifications during exigent conditions.
The COVID-19 public health emergency was terminated on May 11, 2023, therefore, the ability to conduct remote audits, commercial-grade surveys, and source verifications, is no longer applicable unless new exigent conditions exist.
16 Michael Fitzgerald Reactor Operations Engineer (301) 415-0420 Michael.Fitzgerald@nrc.gov Yamir Diaz-Castillo Reactor Operations Engineer (301) 415-2228 Yamir.Diaz-Castillo@nrc.gov