ML25189A437
| ML25189A437 | |
| Person / Time | |
|---|---|
| Site: | 99900003 |
| Issue date: | 07/24/2025 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Griffin S GE Hitachi Nuclear Energy |
| References | |
| EPID I-2025-201-0025 IR 2025201 | |
| Download: ML25189A437 (1) | |
Text
Mr. Stanley Griffin Nuclear Programs Quality Leader GE Hitachi Nuclear Energy 3901 Castle Hayne Road Wilmington, NC 28401
SUBJECT:
NUCLEAR REGULATORY COMMISSION INSPECTION REPORT OF GE HITACHI NUCLEAR ENERGY NO. 99900003/2025-201, AND NOTICE OF NONCONFORMANCE
Dear Mr. Griffin:
On June 2 - 6, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the GE Hitachi Nuclear Energys facility (hereafter referred to as GEH) in Wilmington, NC. On July 2, 2025, the NRC staff conducted a re-exit to present inspection results and observations to Mr. Curtis VanCleve, Executive Nuclear Quality Leader, and other members of GEHs management and technical staff. The purpose of this limited-scope routine inspection was to assess GEHs compliance with the 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 limited-scope inspection also verified GEHs compliance with the requirements of 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements, 10 CFR 73.22, Protection of Safeguards Information: Specific Requirements, and the Commissions Order No. EA-07-231, Order Imposing Safeguards Information Protection Requirements and Fingerprinting and Criminal History Records Check Requirements for Access to Safeguards Information, for handling Safeguards Information (SGI) related to new reactor designs.
This technically-focused inspection specifically evaluated GEHs implementation of the quality activities associated with the supply of safety-related and balance-of-plant equipment and services (e.g., commercial-grade dedication of electrical and mechanical components, engineering services, etc.) for U.S nuclear power plants and the SGI program to determine its effectiveness in protecting SGI. The enclosed report presents the results of this inspection.
This NRC inspection report does not constitute NRCs endorsement of GEHs overall quality assurance (QA) or 10 CFR Part 21 programs.
During this inspection, the NRC inspection team found that the implementation of your QA program failed to meet certain NRC requirements imposed on you by your customers or NRC licensees. Specifically, the NRC inspection team determined that GEH was not fully July 24, 2025
S. Griffin 2
implementing its QA program in the areas of test control and nonconforming materials, parts, or components. 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),
GEH 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.
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 NRCs Public Document Room or from the NRCs document system (ADAMS), accessible at http://www.nrc.gov/readingrm/
adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or 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, 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 be 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 would 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 SGI 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 A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.:
99900003 EPID No.:
I-2025-201-0025
Enclosures:
- 1. Notice of Nonconformance
- 2. Inspection Report No. 99900003/2025
-201 and Attachment Signed by Kavanagh, Kerri on 07/24/25
ML25189A437 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME YDiaz-Castillo FVega TLee DATE 7/10/2025 7/9/2025 7/9/2025 OFFICE NRR/DRO/IQVB NRR/DNRL/NPHP NRR/DNRL/NPHP NAME CRuley OKhan JHoncharik DATE 7/11/2025 7/10/2025 7/11/2025 OFFICE NRR/DRO/IRAB NRR/DRO/IQVB NAME CSmith KKavanagh DATE 7/15/2025 7/24/2025 NOTICE OF NONCONFORMANCE GE Hitachi Nuclear Energy Docket No. 99900003 3901 Castle Hayne Road Report No. 2025-201 Wilmington, NC 28401 Based on the results of a U.S. Nuclear Regulatory Commission (NRC) inspection conducted at the GE Hitachi Nuclear Energys (hereafter referred to as GEH) facility in Wilmington, NC, from June 2, 2025, through June 6, 2025, GEH did not conduct certain activities in accordance with NRC requirements that were contractually imposed on GEH by its customers or NRC licensees:
A. Criterion XI, Test Control, 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, states, in part, that A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Paragraph 5.3.5 of Quality Control Test Instruction (QCTI) No. 715, Cylinder, Tube &
Flange, Drawing 919D258 All Groups, Revision 14, dated January 22, 2020, states that After holding pressure for 10 minutes, check for leakages at all exposed surfaces with special attention to the following areas: [.1] The two plug-to-flange welds on the OD
[outside diameter] of the flange. In addition, paragraph 3.5 of QCTI-715 states that All hydrostatic tests shall be performed using site demineralized water. Conductivity is to be monitored and is not to exceed 3 micromho/cm max. Verify conductivity meter before and after testing.
Subparagraph NB-6224, Examination for Leakage After Application of Pressure, of Section III, Rules for Construction of Nuclear Facility Components, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, 2015 Edition, states, in part, that Following the application of the hydrostatic test pressure for the required time (see NB-6223), all joints, connections, and regions of high stress, such as regions around openings and thickness transition sections, shall be examined for leakage.
Contrary to the above, as of June 6, 2025, GEH failed to ensure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is performed in accordance with written procedures. Specifically, after performing the hydrostatic pressure test on four cylinder and tube flange assemblies, the GEH inspector: (1) did not examine for leakage the two plug welds on each of the four cylinder tube and flange assemblies; and (2) did not verify the conductivity of the demineralized water after the hydrostatic pressure test was completed.
This issue has been identified as Nonconformance 99900003/2025-201-01.
B. Criterion XV, Nonconforming Materials, Parts, or Components, of Appendix B to 10 CFR Part 50, states that Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for
2 identification, documentation, segregation, disposition, and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.
Section 4.2.14 of procedure No. CP-15-300, Material Review Board, Revision 1, dated August 21, 2018, states, in part, that If there is a pending disposition situation, and a
[Material Review Board] member determines that further processing or information is needed before a final disposition can be made, then document any of the following special instructions on the nonconformance record: how far to process, what dimensions to hold, what inspection results are required, other pertinent information.
Section 4 of procedure No. CP-15-100, Control of Nonconforming Items, Revision 5, dated October 28, 2024, states, in part, that All nonconforming items must be reviewed and accepted, or dispositioned as: rejected, repaired, reworked, scrapped, or used-as-is in accordance with established procedures. Section 4.2.2 of CP-15-100 also states, in part, that All tags and/or the use of markings must be legible and not be detrimental to the item or its packaging. In addition, Section 4.3.3 of CP-15-100 states, in part, that During periods of disposition activities, Quality shall maintain status and control of all nonconforming items.
Contrary to the above, as of July 2, 2025, GEH failed to review and accept, reject, repair, or rework nonconforming items in accordance with documented procedures. The NRC inspection team identified 186 nonconformance reports (NCRs) that remain open without a documented disposition. The oldest NCR that remains open without any documented disposition is from August 10, 2023. Specifically, for the limited sample reviewed, (1)
GEH could not locate a collet finger associated with NCR No. S-1054; and (2) GEH could not confirm that a retainer (NCR No. S-1007) and a spacer (NCR No. S-1031) were associated with these NCR Nos. because the serial numbers that provide traceability were not legible.
This issue has been identified as Nonconformance 99900003/2025-201-02.
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 noncompliance; and (4) the date when your corrective actions will be completed.
Where good cause is shown, consideration will be given to 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 NRCs Public Document Room or from the NRCs document system (ADAMS), accessible from the NRCs Web site at http://www.nrc.gov/reading-rm/ adams.html. To the extent possible, your response 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
3 information that should be protected and a redacted copy of your response that deletes such information.
If you request that such material be withheld from public disclosure, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the basis 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 SGI 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.
Dated this 24th day of July 2025.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99900003 Report No.:
99900003/2025-201 Vendor:
GE Hitachi Nuclear Energy 3901 Castle Hayne Road Wilmington, NC 28401 Vendor
Contact:
Mr. Stanley Griffin Nuclear Programs Quality Leader Email: stanley.griffin@ge.com Phone: (910) 616-4019 Nuclear Industry Activity:
GE Hitachi Nuclear Energy (hereafter referred to as GEH) provides manufacturing and commercial-grade dedication of electrical and mechanical power plant components, as well as engineering services, to U.S. nuclear power plants. In addition, as part of its nuclear work, GEH implements a program for the management and protection of safeguards information.
Inspection Dates:
June 2 - 6, 2025 Re-exit Date:
July 2, 2025 Inspectors:
Yamir Diaz-Castillo NRR/DRO/IQVB Team Leader Frankie Vega NRR/DRO/IQVB Inspector Tiffany Lee NRR/DRO/IQVB Trainee Charlotte Ruley NRR/DRO/IQVB Trainee John Honcharik NRR/DNRL/NPHP Technical Specialist Omar Khan NRR/DNRL/NPHP Trainee Approved by:
Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
GE Hitachi Nuclear Energy Report No. 99900003/2025-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a limited-scope routine vendor inspection at the GE Hitachi Nuclear Energys (hereafter referred to as GEH) facility in Wilmington, NC, to verify that 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. In addition, the NRC inspection team verified that GEH had implemented a program in accordance with the applicable requirements of Section III, Rules for Construction of Nuclear Facility Components,Section V, Nondestructive Examination, and Section IX, Welding and Brazing Qualification, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, and the American Society for Nondestructive Testing (ASNT) SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing. Furthermore, the NRC inspection team verified that GEH had implemented a program to protect Safeguards Information (SGI) in accordance with the requirements of 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements, 10 CFR 73.22, Protection of Safeguards Information: Specific Requirements, and the Commissions Order No. EA-07-231, Order Imposing Safeguards Information Protection Requirements and Fingerprinting and Criminal History Records Check Requirements for Access to Safeguards Information. The NRC inspection team conducted this inspection on-site during the week of June 2 - 6, 2025. On July 2, 2025, the NRC staff conducted a re-exit to present inspection results and observations to Mr. Curtis VanCleve, Executive Nuclear Quality Leader, and other members of GEHs management and technical staff. This was the fourth NRC inspection of GEH at this facility.
This technically focused inspection specifically evaluated GEHs implementation of quality activities associated with the safety-related and balance-of-plant equipment and services being supplied for U.S. nuclear power plants.
Specific activities observed by the NRC inspection team included:
Dimensional and material properties inspections as part of the commercial-grade dedication activities of an electrical contactor Calibration of a ring gage Condition Report and Corrective Action Program meetings Hydrostatic pressure testing of plug welds on four cylinder tube and flange assemblies for a control rod Tack welding of a blade to a velocity limiter assembly Welding of the velocity limiter assembly and fins Liquid Penetrant examination of a velocity limiter assembly after fin welding
3 Eddy current examination of an absorber section blade of the laser welds Dimensional inspection of an extension tube Bath cleaning of several control rod components Helium leak testing of an absorber blade Welding of an outer tube assembly to a flange of a control rod These regulations served as the basis for the NRC inspection:
Appendix B to 10 CFR Part 50 10 CFR Part 21 10 CFR Part 73 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; IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 10, 2023, and IP 81811, Protection of Safeguards Information by Design Certification Applicants and Vendors, dated April 8, 2020.
With the exception of the nonconformances described below, the NRC inspection team concluded that GEHs QA policies and procedures comply with the applicable requirements of Appendix B to 10 CFR Part 50, 10 CFR Part 21, and 10 CFR Part 73, and that GEHs personnel are implementing these policies and procedures effectively. The results of this inspection are summarized below.
Test Control The NRC inspection team issued Nonconformance 99900003/2025-201-01 in association with GEHs failure to implement the regulatory requirements of Criterion XI, Test Control, of Appendix B to 10 CFR Part 50. Nonconformance 99900003/2025-201-01 cites GEH for failing to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service was performed in accordance with written procedures.
Specifically, the GEH inspector did not examine the two plug welds on each of the four cylinder tube and flange assemblies and did not verify the conductivity of the demineralized water after hydrostatic pressure testing.
Nonconforming Material, Parts, or Components The NRC inspection team issued Nonconformance 99900003/2025-201-02 in association with GEHs failure to implement the regulatory requirements of Criterion XV, Nonconforming Materials, Parts, or Components, of Appendix B to 10 CFR Part 50. Nonconformance 99900003/2025-201-02 cites GEH for failing to review and accept, reject, repair, or rework nonconforming items in accordance with documented procedures. Specifically, for the limited sample reviewed, (1) GEH could not locate a collet finger associated with NCR No. S-1054; and (2) GEH could not confirm that a retainer (NCR No. S-1007) and a spacer (NCR No. S-1031)
4 associated with these NCR Nos. because the serial numbers that provide traceability were not legible.
Safety Conscious Work Environment The NRC inspection team concluded that GEHs Safety Conscious Work Environment program and implementation were consistent with the NRCs guidance in Appendix 1, Guidance for Gathering SCWE and PI&R Insights, of IP 71152, Problem Identification and Resolution, dated October 31, 2023. Based on the outcome of the limited number of interviews conducted of selected individuals within the GEH organization, the NRC inspection team determined that GEH staff are willing to raise nuclear safety concerns and the individuals perception of their managements responsiveness to these concerns were positive. The GEH staff also indicated that they felt comfortable raising concerns to their supervisor and management, and elevating issues up through supervision or management if not appropriately addressed. The GEH staff can enter issues directly into the corrective action program or nonconformance program.
Other Inspection Areas The NRC inspection team determined that GEH established its programs for design control, commercial-grade dedication, procurement document control, supplier oversight, material traceability, control of special processes, control of measuring and test equipment, corrective actions, 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 GEH is implementing its policies and procedures associated with these programs. In addition, the NRC inspection team determined that GEH is implementing its 10 CFR Part 21 program for evaluating deviations and reporting defects that could create a substantial safety hazard in accordance with the applicable regulatory requirements. No findings of significance were identified in these areas.
Furthermore, the NRC inspection team concluded that GEHs SGI protection polices and implementing procedures comply with the applicable requirements of 10 CFR Part 73 and the Commissions Order, and that GEHs personnel are implementing these policies and procedures effectively. No findings of significance were identified.
5 REPORT DETAILS 1.
Test Control a.
Inspection Scope The NRC inspection team reviewed GE Hitachi Nuclear Energys (hereafter referred to as GEH) policies and implementing procedures that govern the implementation of its test control program to verify compliance with the requirements of Criterion XI, Test Control, 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.
The NRC inspection team observed a hydrostatic pressure test of plug welds on four cylinder tube and flange assemblies for control rods associated with traveler No. SCO-3470254 using Quality Control Test Instruction (QCTI)-715, Cylinder, Tube & Flange, Drawing 919D258 All Groups, Revision 14, dated January 22, 2020.
The NRC inspection team discussed the test control program with GEHs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observation and Findings While observing safety-related hydrostatic pressure testing of four cylinder tube and flange assemblies (Serial Nos. SE2352, SE2354, SE3257 and SE2360), the NRC inspection team noted that the GEH inspector did not examine the two plug welds on each of the four cylinder tube and flange assemblies being tested and did not verify the conductivity of the demineralized water after the hydrostatic pressure testing was completed. The NRC inspection team noted that two of the four assemblies were at a height that the welds were not easily accessible for examination by the GEH inspector.
Further, the conductivity meter was in a congested area that was also not easily accessible for verification. During discussions with the GEH inspector, the GEH inspector stated that his responsibility was limited to performing the hydrostatic pressure test, and that the weld examination was not included in their scope of work. The NRC inspection team noted that the Authorized Nuclear Inspector (ANI) witnessed the hydrostatic pressure test and signed off on the hydrostatic test report.
Paragraph 5.3.5 of QCTI-715 states that, in part, that After holding pressure for 10 minutes, check for leakages at all exposed surfaces with special attention to the following areas: [.1] The two plug-to-flange welds on the OD [outside diameter] of the flange. In addition, paragraph 3.5 of QCTI-715, Revision 14 states that All hydrostatic tests shall be performed using site demineralized water. Conductivity is to be monitored and is not to exceed 3 micromho/cm max. Verify conductivity meter before and after testing.
In addition, Subparagraph NB-6224, Examination of Leakage After Application of Pressure, of Section III, Rules for Construction of Nuclear Facility Components, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)
Code states, in part, that Following the application of the hydrostatic test pressure for the required time (NB-6223), all joints, connections, and regions of high stress, such as
6 regions around openings and thickness transition sections, shall be examined for leakage.
Checking the welds for leakage after hydrostatic pressure testing is necessary to ensure the leak integrity of the welds. Similarly, ensuring the demineralized waters conductivity is within the required parameter is significant because if out of specification it could be detrimental to the components ability to perform its safety-related function during all plant operating conditions.
The NRC inspection team identified this issue as Nonconformance 99900003/2025-201-01 for GEHs failure to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service was performed in accordance with written procedures. GEH initiated condition report (CR) No. 49494 to address this issue.
c.
Conclusion The NRC inspection team issued Nonconformance 99900003/2025-201-01 in association with GEHs failure to implement the regulatory requirements of Criterion XI of Appendix B to 10 CFR Part 50. Nonconformance 99900003/2025-201-01 cites GEH for failing to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service was performed in accordance with written procedures. Specifically, the GEH inspector did not examine the two plug welds on each of the four cylinder tube and flange assemblies and did not verify the conductivity of the demineralized water after hydrostatic pressure testing.
2.
Nonconforming Materials, Parts, or Components and Corrective Action a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the control of nonconformances 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 observed three meetings overseeing GEHs Corrective Action Program (CAP) and CRs: (1) the Condition Review Group meeting, (2) the CAP Leadership Oversight Group meeting, and (3) the Corrective Action Review Board meeting.
The NRC inspection team reviewed a sample of GEHs CRs 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. GEH classifies CRs pertaining to significant conditions adverse to quality as Priority A CRs, which require either a Root Cause Analysis or a Nonconformance Assessment.
The NRC inspection team reviewed a sample of GEHs nonconformance reports (NCRs) to verify that GEH has implemented a program that ensures that nonconforming items
7 are being adequately dispositioned, documented appropriate technical justification for various dispositions, and took adequate corrective action with regards to the nonconforming items. Nonconformances can be dispositioned as rework, repair, use-as-is, accept-as-is meets specification, or scrap.
The NRC inspection team also discussed the nonconforming materials, parts, or components and corrective action programs with GEHs 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 a code hydrostatic pressure test of two cylinder tube and flange assemblies with open NCRs dispositioned as conditionally released for further processing. These two assemblies did not have the required NCR tag and the copy of the Conditional Material Release (CMR) form with the traveler, as required per GEH procedure WI-08-104-02, Conditional Material Release, Revision 2, dated December 26, 2024. The NRC inspection team determined this issue to be minor because GEH maintained traceability of the components through the components heat numbers and corresponding work travelers. GEH initiated CR No. 49485 to address this issue.
The NRC inspection team observed that there were 186 NCRs that remain open without documented dispositions from the appropriate Material Review Board members. Section 4 of CP-15-100, Control of Nonconforming Items, Revision 5, dated October 28, 2024, states, in part, that All nonconforming items must be reviewed and accepted, or dispositioned as: rejected, repaired, reworked, scrapped, or used-as-is in accordance with established procedures. Section 4.2.14 of procedure No. CP-15-300, Material Review Board, Revision 1, dated August 21, 2018, states, in part, that If there is a pending disposition situation, and a [Material Review Board] member determines that further processing or information is needed before a final disposition can be made, then document any of the following special instructions on the nonconformance record: how far to process, what dimensions to hold, what inspection results are required, other pertinent information. The NRC inspection team observed that the NCRs did not contain dispositions nor special instructions.
The NRC inspection team selected three of GEHs oldest NCRs without dispositions and asked GEHs staff to locate the nonconforming items and ensure that the components are still adequately segregated and have not been inadvertently used or installed. The NCRs selected were NCR No. S-1054 (collet finger); NCR No. S-1007 (retainer), and NCR No. S-1031 (spacer). GEH was not able to locate the collet finger as it was missing from the designated nonconforming material segregation area. While GEH was able to find what it suspected were the retainer and spacer, these two items could not be properly identified due to the illegibility of the serial number markings denoting their traceability. The NRC inspection team identified this issue as Nonconformance 99900003/2025-201-02 for GEHs failure to review and accept, reject, repair, or rework nonconforming items in accordance with documented procedures. GEH initiated CR No.
49526 to address this issue.
8 c.
Conclusion The NRC inspection team issued Nonconformance 99900003/2025-201-02 in association with GEHs failure to implement the regulatory requirements of Criterion XV of Appendix B to 10 CFR Part 50. Nonconformance 99900003/2025-201-02 cites GEH for failing to review and accept, reject, repair, or rework nonconforming items in accordance with documented procedures. Specifically, GEH could not locate a collet finger associated with NCR No. S-1054; and (2) GEH could not confirm a retainer (NCR No. S-1007) and a spacer (NCR No. S-1031) associated with these NCR Nos. because the serial numbers that provide traceability were not legible.
The NRC inspection team concluded that GEH is implementing its corrective action programs in accordance with the regulatory requirements of 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 GEH is implementing its policies and procedures associated with the corrective action program. No findings of significance were identified.
3.
Design Control a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the implementation of its design control program to verify compliance with the regulatory requirements of Criterion III, Design Control, of Appendix B to 10 CFR Part 50. The NRC inspection team confirmed that GEHs procedures provide adequate instructions for the controls of design inputs, outputs, design analyses, records, and organizational interfaces.
The NRC inspection team reviewed a sample of design reports, design specifications, engineering drawings, structural evaluations, and engineering changes for the following safety-related projects: (1) access hole cover modifications on the Browns Ferry Reactor Pressure Vessel Shroud; and (2) Electric Power Research Institutes integrated surveillance package capsule holder assembly for the supplemental subsequent license renewal for Peach Bottom.
The NRC inspection team confirmed that GEHs design control process: (1) was being adequately implemented in accordance with the applicable technical and regulatory requirements; (2) adequately translated technical and quality requirements into applicable specifications, procedures and instructions; (3) effectively controlled design activities by documented instructions and procedures; and (4) accomplished design changes in accordance with the approved procedures.
The NRC inspection team reviewed and discussed GEHs design activities associated with the work being performed in support of advanced reactors and small modular reactors (SMRs). The NRC inspection team reviewed two Statements of Work (SOW) referenced in purchase orders (POs) issued by TerraPower to GEH for the supply of design reports, calculations, and engineering analyses associated with the Natrium reactor design. GEH stated that the design is still considered preliminary and that most of the deliverables referenced in the SOWs had open items that GEH is actively working to resolve. The only deliverable finalized by GEH associated with the Natrium reactor design is a technical report titled Qualification of Noble Gas Compressibility Data,
9 Revision 0, dated March 27, 2025. For the work associated with the Natrium reactor design, GEH is implementing Natrium Advanced Reactor Demonstration Project Quality Plan (PQP), Revision 7, dated November 2024.
Similarly, GEH is starting to do some preliminary work on the BWRX-300 SMR design for the Tennessee Valley Authoritys Clinch River Nuclear Site. At the time of the inspection, GEH only issued one safety-related PO for engineering calculations and services related to this project.
The NRC inspection team also discussed the design control program with GEHs 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 GEH 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 GEH 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 GEHs policies and implementing procedures that govern the implementation of its commercial-grade dedication (CGD) program to verify their 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 CGD packages for a limit switch, a timer, and a solenoid valve. Within these CGD packages, the NRC inspection team reviewed the following documents: (1) POs; (2) dedication specifications (DSs); (3) technical evaluations; (4) checklists; (5) inspection reports; and (6) Product Quality certificates.
GEHs CGD process consists of developing DSs that include: (1) technical evaluation; (2) part identification; (3) safety functions; (4) credible failure mechanisms; (5) critical characteristics; (6) acceptance criteria and verification methods. The NRC inspection team evaluated the criteria for the identification of item functions, credible failure mechanisms/modes, selection of critical characteristics and acceptance criteria, and the identification of verification methods to verify effective implementation of GEHs CGD process. The NRC inspection team also reviewed two commercial-grade surveys (CGSs) and confirmed that the CGSs contained the objective evidence necessary to demonstrate that the commercial vendors are implementing adequate controls for the critical characteristics identified by GEH.
10 The NRC inspection team also observed GEHs technicians perform CGD activities associated with an electrical contractor (part No. DJ188C8872P007) for the Browns Ferry Nuclear Plant in accordance with DS No. 004N4740 Revision 2, dated June 24, 2024. The NRC inspection team verified that: (1) the critical characteristics and acceptance methods were adequately specified; (2) the drawings and material specifications contained the associated acceptance criteria for each critical characteristic; and (3) the inspection reports adequately documented the acceptance of the critical characteristics. In addition, the NRC inspection team confirmed that 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 GEHs policies and procedures.
The NRC inspection team reviewed GEHs measures for using the International Laboratory Accreditation Cooperation accreditation process in lieu of performing commercial-grade surveys for the procurement of calibration and testing services as part of the CGD process. GEH implements this process as described in the Nuclear Energy Institute document No.14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated September 2020, which was recognized for use by the NRC in a safety evaluation dated November 23, 2020 (Agencywide Documents Access Management System Accession (ADAMS) No. ML20322A019).
The NRC inspection team also discussed the commercial-grade dedication program with GEHs 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 During the review of a dedication package for a timer, the NRC inspection team noted that an NCR was created when performing inspection activities associated with this dedication. The NCR noted that the recorded spring force values were outside the allowable range included in the DS. The spring force was identified as a critical characteristic in the DS. The NCR resolution was to update and expand the allowable range for the spring force without further justification or rational on the basis for acceptability. The NRC inspection team noted that the DS acceptance criteria was updated with this expanded range; however, the revised DS did not include the basis for the change. The NRC inspection team discussed this issue with the DS engineer, and he explained the basis for the change which used qualified seismic levels of 3.0gs, per the DS technical evaluation, to justify the modification to the spring force allowable range. The NRC inspection team determined this issue to be minor because the item was re-inspected using the updated revision of the DS and no issues were identified with the dedicated timer. GEH initiated CR No. 49525 to address this issue.
During the review of a PO for calibration services that were dedicated using a commercial-grade survey of the laboratory, the NRC inspection team noted that the PO did not invoke the QA manual that was reviewed during the commercial-grade survey to ensure appropriate control of the critical characteristics. The PO did include a requirement that the calibration certificate or the Certificate of Conformance include a statement that the PO requirements were met. The NRC inspection team identified that none of the documentation provided by the laboratory included such statement as
11 required by the PO. The NRC inspection team determined this issue to be minor because it is a documentation issue and there was no impact on the calibration of the equipment. GEH initiated CR No. 49515 to address this issue.
c.
Conclusion With the exception of the two minor issues identified above, the NRC inspection team concluded that GEH 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 also determined that GEH is implementing its policies and procedures associated with the commercial-grade dedication program. No findings of significance were identified.
4.
Supplier Oversight a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the implementation of its supplier oversight program to verify compliance with the requirements of Criterion IV, Procurement Document Control, and Criterion VII of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed a sample of POs, GEHs Approved Vendors List (AVL), supplier audit reports, and annual evaluations.
For the review of the sample of POs, the NRC inspection team verified the POs included, as applicable: (1) the scope of work; (2) right of access to the suppliers facilities; (3) extension of contractual requirements to sub-suppliers; (4) and the applicable technical, regulatory, and quality requirements.
The NRC inspection team also reviewed a sample of audit reports and verified that the audits reports included, as applicable: (1) an audit plan; (2) any findings identified and the associated corrective actions; (3) adequate documented objective evidence of compliance with the applicable requirements; and (4) a documented review by GEHs responsible management. For the review of the annual evaluations, the NRC inspection team confirmed they included the information required by GEHs policies and procedures. In addition, the NRC inspection team also verified that the audits were performed in accordance with the established frequency and by qualified lead auditors and auditors. Furthermore, the NRC inspection team reviewed the training and qualification records of lead auditors and auditors and confirmed that auditing personnel had completed all the required training and had maintained the applicable qualification and certification in accordance with GEHs policies and procedures.
The NRC inspection team also discussed the supplier oversight program with GEHs 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 During the review of an audit report, the NRC inspection team noted the report stated that part of the audit was done remotely. Upon further discussion with GEH, they clarify that while the vast majority of the audit was done on-site, more time was needed to review additional documentation and this was done remotely. The NRC inspection team
12 reminded GEH that the COVID-19 public health emergency expired on May 11, 2023; therefore, the QA alternatives approved by the NRC for audit extension and remote auditing and/or source verification under exigent conditions can no longer be used unless new exigent conditions exist. The NRC inspection team determined this issue to be minor because GEH had not issued any safety-related POs to the supplier (the audit was done to add the supplier to the AVL. GEH initiated CR No. 49517 to address this issue.
c.
Conclusion With the exception of the minor issue identified above, the NRC inspection team concluded that GEH is implementing its supplier oversight program 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 also determined that GEH is implementing its policies and procedures associated with the supplier oversight program. No findings of significance were identified.
5.
Material Traceability a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the implementation of its material traceability 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 GEHs fabrication shop and observed that the shop travelers identified the heats for the material, and that all materials were marked with unique identifiers traceable to procurement records and certified material test reports. For a sample of material selected, the NRC inspection team observed that identification markings were: (1) traceable to design and shop drawings; (2) remained legible through the manufacturing process; and (3) were applied using materials and methods that provided a clear and legible identification and did not adversely affect the function or service life of structure systems or components observed.
The NRC inspection team discussed the material traceability program with GEHs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observation and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that GEH is implementing its material traceability 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, the NRC inspection team also determined that GEH is implementing its policies and procedures
13 associated with the material traceability program. No findings of significance were identified.
6.
Control of Special Processes a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the implementation of its control of special processes program to verify compliance with the regulatory requirements of Criterion IX, Control of Special Processes, of Appendix B to 10 CFR Part 50, and with the applicable requirements of Section III, Rules for Construction of Nuclear Facility Components,Section V, Nondestructive Examination, and Section IX, Welding and Brazing Qualification, of the ASME B&PV Code, and the American Society for Nondestructive Testing (ASNT)
SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing.
For manufacturing activities, the NRC inspection team reviewed a sample of shop travelers, work instructions, and the calibration certificates of the M&TE. For non-destructive examination (NDE) activities, the NRC inspection team reviewed the procedures for helium leak testing (HL), eddy current testing (ECT), and liquid penetrant testing (PT), as well as HL, ECT and PT reports, HL, ECT and PT inspector qualifications, and Level III inspector qualifications, and the calibration certificates of the welding equipment.
Welding The NRC inspection team observed the following safety-related welding activities:
Manual tack gas tungsten arc welding (GTAW) welding of the blade to the velocity limiter assembly using weld procedure No. WPS003, GTAW Stainless Steel P No. 8 304L, 316L, CF3, XM-19, Revision 4, dated April 9, 2007and work instruction (WI)
No. WSI-5418D, Weld Control Rod Blade, Revision 47, dated August 18, 2022 Welding of the outer tube assembly to the flange of a control rod using weld procedure No. 107, GTAW Stainless Steel P No. 8 XM-19 to 304L or 316L, Revision 0, dated September 12, 2013, and WI No. WSI-3715H, Outer Tube to Flange Weld, and, Manual GTAW of the velocity limiter assembly and fins using weld procedure No.
107, GTAW Stainless Steel P No. 8 XM-19 to 304L or 316L, Revision 0, dated September 12, 2013.
The NRC inspection team verified that the welding procedure specifications above were qualified in accordance with the applicable requirements of Sections III and IX of the ASME B&PV Code, using the supporting procedure qualification records (PQRs) and the applicable GEHs procedures. The NRC inspection team also verified that the welders were qualified to perform the work on the ASME B&PV Code parts.
14 Control of Weld Material The NRC inspection team observed the weld material storage and each weld area control station and verified that weld material was adequately controlled in accordance with the applicable GEHs procedures. The weld material is stored in a locked and controlled material storage area and weld material is transferred to a locked and controlled cabinet in the welding area that can only be accessed by qualified welders.
The NRC inspection team also verified that calibrated welding machines and associated equipment such as infrared contact pyrometers were used and had valid calibration documentation in accordance with the applicable GEH procedures.
Nondestructive Examination (NDE)
The NRC inspection team observed the following safety-related NDE activities:
Helium leak test of an absorber blade using procedures QCII-50224, Quality Control Inspection Instruction for Ultra HD Control Rod Top Level Assembly, Revision 1, and QCEI-704, Quality Control Examination Instruction for Helium Leak Detection (SCO), Revision 18 Dimensional inspection of an extension tube using procedure No. CI-50604, Extension F3 Visual, Revision 3, dated February 26, 2025 Liquid Penetrant examination of a velocity limiter assembly and fin welding using QCI-50506, Quality Control Instruction for Velocity Limiter (after welding), Revision 0, dated May 9, 2017, and WCEI-676, Examination Instructions for PT, Revision 28, dated November 6, 2013 Eddy current examination of an absorber section blade of the laser welds using QCEI-718, Eddy Current Examination Using an Array Probe-Ultra Control Blade and Tube to Tube to Tie Rod, Revision 10, and QCI-293, General Inspection Criteria for Laser Welds, Revision 20.
The NRC inspection reviewed verified that the above examinations were performed by qualified personnel and qualified procedures in accordance with the applicable requirements of Section III and Section V of the ASME B&PV Code and ASNT SNT-TC-1A. The NRC inspection team also verified that the NDE test reports included all inspection results with the associated inspector and inspection procedures.
Qualification and Training of Welding and NDE Personnel The NRC inspection team reviewed the associated welder qualification records and confirmed that the welders had completed the required training and had maintained their qualifications in accordance with GEHs procedures. The NRC inspection team also verified that the applicable procedure for welder qualification meets the requirements of Sections III and IX of the ASME B&PV Code.
The NRC inspection team reviewed the non-destructive Level II inspector and Level III examiner qualification records and confirmed they were qualified in accordance with the requirements in ASNT SNT-TC-1A and GEHs implementing procedures. The NRC
15 inspection team also verified that the applicable implementing procedure for NDE inspector qualification meets the requirements of Sections V of the ASME B&PV Code and ASNT SNT-TC-1A.
The NRC inspection team discussed the control of special processes program with GEHs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observation and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that GEH is implementing its 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 also determined that GEH is implementing its policies and procedures associated with the control of special processes program. No findings of significance were identified.
7.
Control of Measuring and Test Equipment a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the 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 walk-through of GEHs gage laboratory and interviewed the on-site calibration technician. For a sample of M&TE, the NRC inspection team verified 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 NRC inspection team verified that the calibration certificates contained the following information: (1) as-found or as-left conditions; (2) accuracy required; (3) calibration results; (4) calibration dates; and (5) the due date for recalibration. Further, the NRC inspection team also verified that the selected M&TE was calibrated using procedures traceable to known industry standards. In addition, the NRC inspection team confirmed that when M&TE is found to be out of calibration, GEH initiates a nonconformance report and performs an evaluation to determine the extent of condition.
The NRC inspection team observed the calibration of a ring gage and reviewed the records for the standard used for this calibration. The NRC inspection team confirmed that the calibration was done in accordance with GEHs applicable calibration procedures and that the ring cage was adequately calibrated.
The NRC inspection team also discussed the M&TE program with GEHs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
16 b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that GEH 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 GEH is implementing its policies and procedures associated with the M&TE program. No findings of significance were identified.
8.
Internal Audits a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the internal audits program to verify compliance with the requirements of Criterion XVIII, Audits, of Appendix B to 10 CFR Part 50.
The NRC inspection team reviewed a sample of internal audit reports from 2023 and 2024 and verified that: (1) internal audits were performed by qualified auditors; (2) lead auditors prepared and approved plans that identified the audit scope and checklist criteria prior to the audit; (3) internal audits contained adequate documented objective evidence; and (4) internal audits were performed by personnel not having direct responsibilities in the areas being audited. In addition, the NRC inspection team confirmed that audit findings were dispositioned, and corrective actions were implemented to correct the issues identified.
The NRC inspection team also discussed the internal audits program with GEHs 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 GEH is implementing its internal audits program in accordance with the regulatory requirements of Criterion XVII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that GEH is implementing its policies and procedures associated with the internal audits program. No findings of significance were identified.
9.
10 CFR Part 21 Program a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures that govern the implementation of its 10 CFR Part 21, Reporting of Defects and
17 Noncompliance, program to verify compliance with the regulatory requirements. In addition, the NRC inspection team evaluated the 10 CFR Part 21 postings and a sample of GEHs POs for compliance with the requirements of 10 CFR 21.6, Posting Requirements, and 10 CFR 21.31, Procurement Documents. The NRC inspection team also verified that GEHs nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program. For a sample of 10 CFR Part 21 evaluations performed by GEH, the NRC inspection team verified that GEH 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 observed a meeting where GEH discussed the screening of 10 CFR Part 21 Potential Reportable Conditions (PRCs) and their process of evaluating deviations or failures that could be potentially associated with a substantial safety hazard. GEH has had one PRC that has escalated to an official 10 CFR Part 21 Report within the past five years.
The NRC inspection team also discussed the 10 CFR Part 21 program with GEHs 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 GEH 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 GEH is implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.
- 10. Safeguards Information Program a.
Inspection Scope The NRC inspection team reviewed GEHs policies and implementing procedures to verify that GEHs information protection system effectively protects Safeguards Information (SGI), as defined in 10 CFR 73.21, Protection of Safeguards Information:
Performance Requirements, and 10 CFR 73.22, Protection of Safeguards Information:
Specific Requirements, and prevents unauthorized disclosure. This is inclusive of control of SGI information provided to applicants and vendors by the NRC.
b.
Observations and Findings No findings of significance were identified.
18 c.
Conclusion The NRC inspection team concluded that GEH established its SGI protection program in accordance with the applicable requirements of 10 CFR 73.21, 10 CFR 73.22, and the Commissions Order No. EA-07-231. Based on the limited sample of documents reviewed and activities observed, the NRC inspection team determined that GEH is implementing its policies and procedures associated with the SGI program in accordance with the regulatory requirements of 10 CFR 73.21 and 10 CFR 73.22. No findings of significance were identified.
- 11. Safety Conscious Work Environment a.
Inspection Scope The NRC inspection team reviewed GEHs policy that governs the implementation of its safety conscious work environment (SCWE) program. The NRC inspection team interviewed a total of 12 personnel from different departments regarding the SCWE at GEH. Across the board, all GEH personnel interviewed feel free to raise nuclear or industrial safety concerns through all avenues.
The NRC inspection team also discussed the SCWE program with GEHs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that GEHs staff appear to be comfortable raising and pursuing issues with their supervisors and GEHs upper management. As such, the NRC inspection team determined that the SCWE at GEH was adequate.
- 12. Entrance and Exit Meetings On June 2, 2025, the NRC inspection team discussed the scope of the inspection with Curtis VanCleve, Executive Nuclear Quality Leader, and other members of GEHs management and technical staff. On June 6, 2025, the NRC inspection team presented the inspection results and observations during an exit meeting with Mr. VanCleve and other members of GEHs management and technical staff. On July 2, 2025, the NRC inspection team conducted a re-exit to present inspection results and observations to Mr. VanCleve and other members of GEHs 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.
Att1-1 ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Title Affiliation Entrance Exit Interviewed Curtis VanCleve+
Executive Nuclear Quality Leader GE Hitachi Nuclear Energy (GEH)
X X
Michelle Catts Executive Nuclear Programs and Licensing GEH X
X William Knopfel Executive Nuclear Services GEH X
X Stanley Griffin+
Nuclear Quality Oversight Leader GEH X
X X
David Ethington Quality Program Leader GEH X
X X
Lindsay Arnold Services Performance Improvement Leader GEH X
X X
Mark Gerdes+
Services Quality Leader GEH X
X X
Clark Burger Quality Leader GEH X
X X
Kendall Sanders Access Program Leader GEH X*
X Lynn Cook Supplier Quality Manager GEH X*
X*
X Brian Bellamy Security Director GEH X*
X*
X Paul Dubrouillet Engineering Manager GEH X
X X
Devon Harris Production Control Manager GEH X
David Donavan Engineer Technical Lead GEH X
Mark Sumner Engineer Technical Lead GEH X
Sara Jalali Senior Engineer GEH X
Att1-2 Name Title Affiliation Entrance Exit Interviewed Austin Harding Engineer GEH X
Cory Shores Engineer GEH X
Ronny York Laboratory Technician GEH X
Jack Moonaan Project Manager GEH X
John Bartleman Quality Engineer GEH X
X X
Eddie Smith Quality Coordinator GEH X
Greg Riehs Quality Control (QC) Inspector GEH X
Cody Kennedy QC Inspector GEH X
Eli Gutierrez QC Inspector GEH X
Joe Calderazzo Cleaner GEH X
Brandon Miller Purchased Material Quality Controls GEH X
Justin Shortt Production Control GEH X
Keith Ehrenfeld Welder GEH X
Blake Allen Welder GEH X
Larry Barefoot Authorized Nuclear Inspector Hartford Steam Boiler X
Yamir Diaz-Castillo Inspection Team Leader Nuclear Regulatory Commission (NRC)
X X
Frankie Vega Inspector NRC X
X Tiffany Lee Inspector in Training NRC X
X Charlotte Ruley Inspector in Training NRC X
X John Honcharik Technical Specialist NRC X
X
Att1-3 Name Title Affiliation Entrance Exit Interviewed Omar Khan Technical Specialist in Training NRC X
Kerri Kavanagh+
Branch Chief NRC X
- Participated remotely.
+Participated in the re-exit meeting.
2.
INSPECTION PROCEDURES USED Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 10, 2023 IP 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023 IP 81811, Protection of Safeguards Information by Design Certification Applicants and Vendors, dated April 8, 2020 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description 99900003/2025-201-01 OPENED NON Criterion X 99900003/2025-201-02 OPENED NON Criterion XV 4.
DOCUMENTS REVIEWED Policies and Procedures NEDO-11209-A, GE Hitachi Nuclear Energy Quality Assurance Program Description, Revision 17, dated December 8, 2022 MA-001, GEH ASME Quality Assurance Program Manual for ASME Boiler and Pressure Vessel Code Section III, Division 1 and Division 5, and ASME Boiler and Pressure Vessel Code Section VIII, Division 1, Revision 19, dated December 28, 2023 BP-16-02, Nuclear Safety Culture, Revision 4, dated June 30, 2022 CP-03-100 Design Control, Revision 11, dated April 15, 2024 CP-03-100-G400, Design Release, Revision 11, dated April 8, 2025
Att1-4 CP-06-104, Protection of Safeguards Information, Revision 9, dated April 3, 2025 CP-07-02-F01, Supplier Quality Program Evaluation, Revision 37, dated February 5, 2025 CP-07-104 Customer Purchase order technical evaluation and dedication of commercial grade items and services, Revision 7, dated June 24, 2024 CP-07-106 Receiving Inspection Procedure and Routines, Revision 2, dated November 8, 2023 CP-07-202 Supplier Source Inspections for Product Release, Revision 20, dated April 21, 2025 CP-08-107, FCO Shop Traveler Control, Revision 3, dated May 10, 2024 CP-08-108, Identification and Traceability Control of Material, Revision 3, dated May 5, 2025 CP-08-109, Identification, Traceability and Control of Materials, Parts and Components, Revision 2, dated May 5, 2025 CP-08-110, Foreign Material Control Program, Revision 2, dated January 2, 2024 CP-08-113, WFSC Traveler Control, Revision 2, dated May 14, 2025 CP-08-114, Identification and Control of Material at WFSC, Revision 3, dated September 27,2023 CP-08-115, Material and Equipment Traceability Requirements, Revision 2, dated June 16, 2023 CP-09-103, Process Qualification, Revision 4, dated October 25, 2024 CP-09-104, Material Reconciliation, Revision 2, dated April 25, 2025 CP-10-105, Inspection Requirements for Procured Items, Revision 21, dated December 12, 2023 CP-12-101 Calibration Control Program Revision 10, Dated August 11, 2021 CP-12-102 Calibration Program for Instrumentation and Controls, Revision 3, dated August 11, 2023 CP-12-104 Scale and Balance Program, Revision 3, dated July 20, 2023 CP-15-100, Control of Nonconforming Items, Revision 5, dated October 28, 2024 CP-15-300, Material Review Board, Revision 1, dated August 21, 2018
Att1-5 CP-16-108, Corrective Action Program, Revision 20, dated April 23, 2025 CP-20-05, Qualifications of NDE Examination Personnel, Revision 9.2, dated April 21, 2022 CP-20-10, Certification of Manufacturing NDE Examination Personnel, Revision 2, dated April 30, 2025 CP-20-217, Vision Acuity Examination Instruction, Revision 1.4, dated December 8, 2020 OP No. 1010.98, Deionized Water System Operating Procedure.
QAR-017, QA Requirements for Procurement of Calibration and Testing Services, Revision 15, dated September 29, 2022 QA-0008-6690, Quality Assurance Requirements for Electrical/Electro-Mechanical Assemblies, Revision 3, dated May 20, 2016 QA-0006-8029, Quality Records List, Revision 0, dated May 24, 2016 QAR-01, QA Requirements for Safety-Related and ASME Code Items, Revision 16, dated February 21, 2021 QCTI-715, Cylinder, Tube & Flange, Drawing 919D258 All Groups, Revision 14, dated January 22, 2020, QCI-50506, Velocity Limiter (after welding), Revision 0, dated May 9, 2017, QCEI-676, Examination Instructions, Revision 28, dated November 6, 2013 QCEI-704, Helium Leak Detection (SCO), Revision 18 QCII-50170, Control Rod Eddy Current Inspection Instructions, Revision 3 QCII-50224, Ultra HD Control Rod Top Level Assembly, Revision 1 QCIS-293, General Inspection Criteria for Laser Welds, Revision 20 QS-103, Standard Liquid Penetrant Acceptance Criteria, Revision 18, dated November 6, 2013 QCEI-718, Eddy Current Examination Using an Array Probe-Ultra Control Blade and Tube to Tube to Tie Rod, Revision 10 QCI-293, General Inspection Criteria for Laser Welds,, Revision 20 QCI-50604, Extension F3 Visual, Revision 3, February 26, 2025
Att1-6 Quality Control Plan No. A-196, Safety Related/ASME Code Suppliers - Quality Assurance System Requirements, Revision 16, June 9, 2023 WI-03-100-10 Safety Classification of Equipment and Services, Revision 9, dated December 26, 2024 WI-03-100-22 Materials and Process Engineering Control, Revision.1, dated June 04, 2023 WI-03-100-30 Design Verification, Revision 6, dated December 12, 2024 WI-03-100-30-G300 Guidelines for Design Verification, Revision 3, dated April 25, 2025 WI-03-100-30-G303 Guidelines for Design Verification When using Preliminary Design Inputs, Revision 2, dated February 10, 2025 WI-03-100-32 Engineering Tests, Revision 2, dated June 26, 2024 WI-06-100-23-F02, Receiving Inspection Quality Control Inspection Instruction, Revision 1, dated October 10, 2019 WI-07-104-02 Dedication Specification Generation, Revision 6.2, dated December 02, 2021 WI-08-114-01, B03 Shelf Life Program, Revision 3, dated March 3, 2025 WI-08-209-02, Material Handling, Inspection, Storage and Shipping, Revision 8, dated August 7, 2023 WI-09-103-01, SCO Weld Process and Performance Qualifications, Revision 3, dated November 18, 2022 WI-10-105-04, Operation of Infrared Spectrometers, Revision 8, dated August 5, 2024 WI-10-105-02 Commercial Grade Dedication, Revision 15, dated January 14, 2025 WI-15-100-01, SCO Nonconforming Material Control, Revision 6, dated March 18, 2025 WI-16-108-07, Reporting of Defects and Noncompliance under 10 CFR Part 21, Revision 17, dated May 17, 2025 WI-16-109-01, Condition Review Process, Revision 16, dated November 20, 2024 WSI-5418, Weld Control Rod Blade, Revision 47, dated August 18, 2022 WSI-43013, Clean Room Cylinder, Tube and Flange, Revision 4, dated August 29, 2019
Att1-7 WSI-9001, Assembly, Test, Polish OD, Disassemble and Clean, Revision 5, December 15, 2023 WSI-4200, Standardized Cleaning Cycles Cleaning Fixtures and Components, Revision 48, dated March 21, 2023 Design and Commercial-Grade Dedication Design Specification No. 006N7652 for Access Hole Cover Repair, Revision 1 Drawing No. 267B6409, Capsule Body Tube, Revision 1, dated May 19, 2010 Drawing No. 007N5199, Revision 2, dated March 14, 2023 Drawing No. 006N7842, AHA Assembly, Revision 0, dated January 24, 2022 Drawing No. 007N1527, SSLR Capsule Holder, dated May 12, 2023 Drawing No. 006N8084, Reactor Modification, Revision 1, dated January 26, 2022 Document No. 002N4117, Dedication Specification for M&TE Calibrated from Suppliers Providing Calibration Services Classified as Commercial Grade, Revision 10, dated July 21, 2022 Document No. i006N4956, Design Specification for EPRI Integrated Surveillance Program Capsule Holder Assembly for Secondary License Renewal, Revision 1 (no date provided)
Commercial Grade Calibration Services Receiving Inspection and Dedication Checklist for GEH Asset No. WG003259, GEH PO No. 437154295, dated November 18, 2024 Commercial Grade Calibration Services Receiving Inspection and Dedication Checklist for GEH Asset No. W18762, GEH PO No. 437150616, dated June 12, 2024 Commercial Grade Calibration Services Receiving Inspection and Dedication Checklist for GEH Asset No. W19050, GEH PO No. 437158018, dated April 9, 2025 Dedication Specification No. 007N1853, Revision 1, dated January 30, 2025 Dedication specification No. 001N8014, Revision 2, dated January 16, 2025 Dedication Specification No. 003N2934, Revision 6, dated February 27, 2025 Dedication Specification No. 004N4740, Revision 2, dated June 24, 2024 Dedication Specification No. 004N2916, Revision 0, dated April 12, 2016 Dedication Specification No. DD242D5417, Revision 5, dated October 25, 2021 Dedication Specification No. DD105E5260, Revision 4, dated November 15, 2021
Att1-8 Dedication specification No. 003N0577, Revision 1, dated February 22, 2017 Dedication Specification No. 003N0341, Revision 3, dated November 4, 2015 Document No. 007N2608, EPRI Surveillance Sample Holder Structural Evaluation Summary Report, Revision 1, dated May 2023 Document No. 006N4017, Natrium Advanced Reactor Demonstration Project Quality Plan, Revision 7, November 2024 Document No. 007N7291, EPRI SSLR Sample Holder Technical Safety Evaluation Report (TSER), Revision 0, dated August 2023 Document No. PLM 006N4182 PWP, EPRI Supplemental SSLR Capsule Holder, Revision 0, dated January 15, 2021 Document No. 007N5214, Installation Specification for EPRI Integrated Surveillance Program Capsule Holder, Revision 2 Document No. 009N5772, Qualification of Noble Gas Compressibility Data, Revision 0, dated March 27, 2025 Document No. PLM 006N6790 Reactor Modification TVA Unit 2 & 3 AHC Repair Services Project Work Plan, Revision 0, dated June 30, 2021 Interface Control Drawing 007N5292 for EPRI Sample Holder, Revision 1, dated March 14, 2023 Supplier Commercial Grade Survey Report for a supplier of calibration services, dated December 29, 2022 Supplier Commercial Grade Survey Plan for a supplier of machining services, dated January 2, 2025 Supplier Commercial Grade Survey Plan for a supplier of chrome plating, dated August 21, 2024 Access Hole Cover Permanent Repair Installation Specification No. 006N8085, Revision 0
Technical Safety Evaluation Report for AHC Permanent Report, Browns Ferry Unit 2 and 3, 006N8723 Revision 1, dated February 2022 CA-00036579 for Release of 006N4956 Revision 1 and DBR-0059952, Revision 1, dated December 22, 2022 Statement of Work - Natrium Demonstration Project: GE-Hitachi SOW for Budget Period 3
Att1-9 Statement of Work - Natrium Demonstration Project: GE-Hitachi SOW for Budget Period:
Effective Date: March 28, 2023 Welding and Nondestructive Examination Records Traveler No. SCO-5470254, Cylinder, Tube and Flange-Hydrostatic Test Traveler No. SCO-5473353, Velocity Limer Assembly 5S Traveler No. SCO-5472670, UHD Section Lattice Traveler No. SCO-5456253, Extension F3 Dimensional Traveler No. SCO-5468950, Absorber Blade Leak Test Traveler No. SCO-5449479, Cylinder, Tube and Flange Outer Tube Assembly to Flange Welding Procedure Specification No. 107 GTAW Stainless Steel P No. 8 XM-19 to 304L or 316L, Revision 0, dated September 12, 2013 Welding Procedure Specification No. 003 GTAW Stainless Steel P No. 8 304L, 316L, CF3, XM-19, Revision 4, dated April 9, 2007 Welding Operator Qualification Tests (initial) - Welder ID No. 35018 - GTAW WPS 003 &
WPS 007, dated June 26, 2018 Welding Operator Qualification Tests (retest) - Welder ID No. 35018 - GTAW WPS 003
& WPS 007, dated August 5, 2020 Welding Operator Qualification Tests (initial) Welder ID No. 35018 - GTAW WPS 107 -
July 16, 2018 Welding Operator Qualification Tests (initial) - Welder ID No. 31327 - GTAW WPS W003M, W007M - February 20, 2012 Welder Continuity Log for Welder ID Nos. 35018 and 31327 Level III Certification Records for Jason L. Schoneweis:
Dimensional Examination, dated January 12, 2024
Liquid Penetrant, dated December 16, 2021
Ultrasonic Test, dated March 11, 2022
Magnetic Particle, dated October 15, 2021
Radiography, dated August 3, 2021 Level II Certification Records for Basil E. Smith:
Visual, dated December 13, 2023
Helium Leak Detection, dated August 9, 2024
Att1-10 Level II Certification Records for Eliborio Gutierrez:
Liquid Penetrant, dated April 3, 2025
Eddy Current, dated July 26, 2024 Level II Certification Records for Aaron (Cody) Kennedy:
Liquid Penetrant, dated June 28, 2023
Dimensional Examination, dated January 8, 2024
Visual, dated January 8, 2024 Level II Certification Records for Greg A. Riehs, Liquid Penetrant, dated February 12, 2025 Calibration, Inspection, and Test Records Product Quality Certificate (PQC) for a Slip Joint Clamp Assembly, Revision 0, dated May 5, 2025 PQC for a 2500 High Pressure Core Spray Pump Motor, Revision 0, dated May 31, 2023 PQC for two Small Display Control Modules, Revision 0, dated March 12, 2025 Certificate of Compliance for Purchase Order (PO) No. 437158442, Revision 0, Part No.
124D1539G003, Revision 4, Serial No. SN001-437155942, Slip Joint Clamp Assembly, dated May 5, 2025 Certificate of Conformance for PO No. 437149944, Heat No. 215985, Certification No.
40685, Ultra High Density Body Tube, dated August 26, 2024 Certificate of Conformance for PO No. 437148945, Revision 1, Manufacturing Lot No.
BJ-106B6.#m22, Boron Carbide Nuclear Grade Material Specification 200-Finer, dated June 7, 2024 Certificate of Conformance for PO No. 437140296 for repair services of a 2500 High Pressure Core Spray Pump Motor, dated May 30, 2023 Certificate of Conformance for PO No. 437155061, Revision 2, Part No. 005N0015P001, for a Machined Centrifugal Casting, dated February 2, 2025 Certificate of Conformance for PO No. 437153350, Revision 3, Heat No. 324641, for an Ultra High Density Body Tube, dated April 22, 2025 Certificate of Calibration No. 1-H69GM-3-1 for a digital pressure gage, calibrated on November 13, 2024 Certificate of Calibration No. 10543228 for a digital oscilloscope, calibrated on May 9, 2024 Certificate of Calibration No. F021725R1 for a measuring machine, calibrated on March 3, 2025
Att1-11 Record of Calibration for a micrometer, asset No. WG002771, calibrated on February 6, 2025 Record of Calibration for a micrometer, asset No. W05370, calibrated on September 13, 2024 Record of Calibration for a caliper, asset No. W05235, calibrated on September 16, 2024 Hydrostatic Test Reports for Cylinder, Tube and Flange (SE2352, SE2354, SE3257 and SE2360) for Control Rods, dated June 3, 2025 Liquid Penetrant Report, Fabricast Velocity Limiter Assembly 5S, dated June 4, 2025 GEH Test Report No. 24A5968, Heat 203832, Lot No. VT7159, Revision 1, dated June 15, 2000 Purchase Orders, Audit Reports, and Annual Evaluations Audit Report Nos. 2022-01, 28012, 31495, 31508, 31519, 31570, 31881, EMC-2022-01, GAVIAL-2024-01, UKA-2022-01, TSI-2022-01, Veridiam-2022-01, WID-2024-01 AUDIT-2024-SA-01, NIAC Scheduling and Assessment Concurrence Letter, dated February 21, 2024 GEH Internal Audit Checklist No. NQA-2024-01 of Service Components Operation, dated April 22, 2024 GEH Internal Audit Plan No. NQA-2024-01 of Service Components Operation, dated February 16, 2024 GEH Internal Audit Report No. NQA-2024-01 of Service Components Operation, dated April 22, 2024 GEH Internal Audit Checklist No. NQA-2023-03 of Service Components Operation, dated May 23, 2023 GEH Internal Audit Plan No. NQA-2023-03 of Service Components Operation, dated March 17, 2023 GEH Internal Audit Report No. NQA-2023-03 of Service Components Operation, dated May 23, 2023 Internal Audit Report No. NQA-2025-01, Safeguards Information (SGI) Program, dated February 12, 2025 Purchase Order (PO) No. 437144909 for equipment and diving services, Revision 3, dated May 23, 2023 PO No. 437148945 for boron carbide, Revision 1, dated December 12, 2023
Att1-12 PO No. 437158442 for reactor services, Revision 0, dated April 24, 2025 PO No. 437149944 for a body tube capsule, Revision 3, dated August 28, 2024 PO No. 437159129 for a power supply, Revision 0, dated June 2, 2025 PO No. 437158266 for a connector casting, Revision 0, dated May 16, 2025 PO No. 437140926 for repair services, Revision 5, dated May 31, 2023 PO No. 437155061 for a machined centrifugal casting, Revision 2, dated February 20, 2025 PO No. 43756022 for a small control display mod, Revision 2, dated March 12, 2025 PO No. 437157663 for the BWRX-300 Aircraft Impact Assessment, Revision 0, dated May 20, 2025 PO No. 437154295 for calibration services, Revision 0, dated September 6, 2024 PO No. 7308152 from Tennessee Valley Authority (TVA) for engineering services, Revision 7, dated November 7, 2023 PO No. 437153350 for a body tube capsule, Revision 5, dated May 6, 2025 PO No. 437158018 for calibration services, Revision 0, dated March 31, 2025 PO No. 437150616 for calibration services, Revision 2, dated January 27, 2025 PO No. 7688804 from TVA for engineering services, Revision 2, dated April 9, 2025 PO No. P3059219SR, Revision 0, dated November 18, 2024 PO No. 437155622 Revision 0, Dated December 20, 2024 PO No. 437155602, dated November 21, 2024 PO No. 62108139, dated November 13, 2024 PO No. 437154880, Revision 1, dated October 11, 2024 PO No. 01465251, Revision 1, dated October 1, 2024 PO No. 7745458, dated April 21, 2025 PO No. 437152403, Revision 2, dated May 9, 2024 PO No. 6886156, Revision 1, dated June 30, 2021
Att1-13 Supplier Quality Program Evaluation dated January 9, 2025 Supplier Quality Program Evaluation dated December 7, 2024 Supplier Quality Program Evaluation dated February 28, 2024 Supplier Quality Program Evaluation dated March 27, 2025 Supplier Quality Program Evaluation dated October 9, 2024 Supplier Quality Program Evaluation dated February 20, 2025 Nonconformance Reports S-1007, S-1103, S-1290, S-1527, S-1551, S-1588, S-1613, S-2027, S-3409, S-3689, 31728, 31814, 32432, 32976, 33102, 33094, 33132, 32974, 32976, 33074, 33078, and 33076 Condition Reports Condition Report (CR) Nos. 39284, 39979, 41708, 42656, 46088, 47938, 48214, 48983, 49000, and 49076 Corrective Action Reports Opened During the NRC Inspection CR Nos. 49485, 49508, 49515, 49517, 49518, 49525, 49526, and 49580 Training and Qualification Records Lead Auditor Qualifications for Mark Soler, Christopher J. Morin, Samuel P. Vanderslic, Jim Vorhees, Mark Gerdes, Joseph Campbell, R. Taylor Blake, and Michael Torbit Laboratory Technician Qualifications for Ronny H. York Auditor and Technical Specialist Qualifications for Jesse Rutter Auditor Qualifications for Mark Svajger and Maria Pfeffer Product Quality Certificates (PQC)
PQC for PO No. P3059219SR, dated February 3, 2025 PQC for PO No. 62108139, dated January 28, 2025 PQC for PO No. 01465251, dated March 5, 2025 PQC for PO No. 7745458, dated June 6, 2025
Att1-14 Miscellaneous GE Hitachi Nuclear Energy, Safeguards Information (SGI) Basic Awareness Training, dated June 3, 2025 Potential Reportable Condition Nos. 22-01, 22-02, 22-03, 23-01, 23-04, 23-11, 24-07, 25-03 10 CFR Part 21 Communication for Reportable Condition: SC 23-01, dated July 26, 2023