ML19056A419

Nuclear Regulatory Commission February 2018 EPRI Joint Utility Task Group Presentation

ML19056A419
Person / Time
Issue date:	02/22/2019
From:	Aaron Armstrong, Paul Prescott Division of Construction Inspection and Operational Programs
To:
Armstrong A
References
Download: ML19056A419 (24)

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NRC UPDATEFebruary 11-14, 2019EPRI JUTGDallas Fort Worth, TexasPaul Prescott and Aaron ArmstrongQuality Assurance Vendor Inspection Branch, Office of New Reactors Topics2Vendor Inspection Findings NRC Reverse Engineering Findings and EPRI GuidanceNRC Vendor Inspection Report Improvement Plan Discussion of Waterford Inspection finding and NRC Vendor Inspection Findings 3 Breakdown of Vendor Inspection Findings 412 inspections -11 NOVs/NONsCriterion III18.18%Criterion XI9.09%Criterion IV9.09%Criterion V9.09%Criterion VII18.18%Criterion XII9.09%Criterion XVI9.09%Criterion IX9.09%Criterion X9.09%

Vendor Inspection Trends Significant FindingsDesign and Test ControlTranslation of Design Requirements and TestingSpecial Processes and InspectionQA Process Oversight5 Design and Testing Requirements6associated with the design, fabrication, and testing of components that comprise the Uninterruptable Power Supply System for the Westinghouse AP1000 reactors being constructed at the Vogtle Units 3 and 4. Inspection ResultsGutor failed to ensure the suitability of materials, parts, equipment, and processes that are essential to the safety-related functions of the inverters being supplied to the Vogtle Units 3 and 4 nuclear power plantsGutor failed to develop acceptance criteria to ensure that the battery chargers acceptance tests meet the design requirements as stated in Westinghouse's purchase orderTake-away: Suppliers need to ensure that design and testing requirements are met and document these design and testing requirements for activities affecting quality. Gutor Electronic, Wettingen, Switzerland Special Processes and Inspection 7Inspection conducted in October 2018 to verify QA activities for design, fabrication, assembly, and testing of U.S. nuclear fuel assemblies. Inspection ResultsWES Filler metal rods were observed to be inadequately controlled in the workshop. Filler metal rods hanging from an air supply pipe in the liquid penetrant inspection booth where there was washing/hosing of penetrant with water, as well as spraying of developer and penetrantWES did not inspect fit-up prior to welding of the absorber cross to the velocity limiter of the control rod blades to verify that the dimension of the root gap was within the drawing specifications by using an appropriate measuring device or gaugeInstead, the welder relied on visual estimation, based on experience only, to determine if the root gap met the required dimensions within necessary limits Westinghouse Electric Sweden (WES) AB, Vsters, Sweden QA Program Oversight8Inspection conducted in July 2018 to assess the design, fabrication, assembly, and testing of ASME B&PV Code Section III, Class 1, 2 & 3 and non-ASME safety-related, repair/replacement of parts and componentsInspections Results HTI failed to establish adequate measures for source evaluation and selection of contractors and subcontractors to ensure that purchased material, equipment, and services conformed to procurement documentsHTI did not impose the requirements of Appendix B to 10 CFR Part 50 in its safety-related procurement documents for materials and services procured as basic components. Procurement documents shall specify compliance with the requirements of Appendix B to 10 CFR Part 50 to ensure that adequate quality assurance is applied and passed down to the sub-suppliersHayward Tyler Inc., Colchester Vermont QA Program Oversight9Inspections Results, Continued failed to establish measures to assure that services, whether purchased directly or through contractors and subcontractors, conform to the procurement documentsthe pressure gauge used during hydrostatic testing of three ASME Section III safety-related diffusers were not calibrated within the tolerance range of 0-400 pounds per square inch gauge (PSIG) using a standard dead weight tester and calibration procedureInspection were ineffective as previous issues were identified in the 2018 inspection Hayward Tyler Inc., Colchester Vermont NRC Reverse Engineering Findings and EPRI Guidance10 NRC Reverse Engineering Findings and EPRI Guidance11NRC Information Notice 2016-09 highlighted three examples of licensee and vendor issues regarding inadequate reverse engineering EPRI Revision 1(issued 2018) of TR-107372 (EPRI 3002011678) provided guidance on reverse engineering techniques NRC has not specifically endorsed 3002011678However, NQA-1 ballot in process to add guidance on reverse engineering, referencing 3002011678 NRC Reverse Engineering Findings and EPRI Guidance12Licensee did not establish suitable subsystem interface requirements.1. Callaway, AFW controller cards (2015)Licensee did not verify adequacy by either design reviewor sufficient testing3002011678 step 4.2.6: Evaluate the interfaces, fit, tolerances, inputs, and outputs; and 4.3.4: Determine if interfacesare addressed3002011678 step 4.2.7: Plan the activities required to demonstrate functionality, 4.3.6: Determine the activities required to demonstrate functionality, 4.3.7: Complete the activities required to demonstrate functionality NRC Reverse Engineering Findings and EPRI Guidance13Dating back to 1998, licensee procured reverse-engineered item commercially, then CGD.* 2. River Bend, control rod hydraulic accumulators (2015)Licensee did not verify adequacy by either design reviewor sufficient testing.3002011678 step 4.2.7: Plan the activities required to demonstrate functionality, 4.3.6: Determine the activities required to demonstrate functionality, 4.3.7: Complete the activities required to demonstrate functionality*Commercial-Grade Dedication NRC Reverse Engineering Findings and EPRI Guidance14Dating back to 2004, vendor reverse-engineered a GE 3. Nova Machine Products, accumulators (2015-2016)Vendor failed to verifyand checkby either design review, calculational methods, or sufficient testing3002011678 step 4.2.7: Plan the activities required to demonstrate functionality, 4.3.6: Determine the activities required to demonstrate functionality, 4.3.7: Complete the activities required to demonstrate functionality*Part 21 violation, as well as Appendix B nonconformances.

NRC Reverse Engineering Findings and EPRI Guidance15In Conclusion3002011678 (Rev. 1 to TR-107372) does provide adequate guidance that both licensees and vendors may use to identify/verifyand check/testthe critical design characteristics.

NRC Vendor Inspection Report Improvement Plan16 NRC Vendor Inspection Report Improvement Plan17The NRC is currently in the process of evaluating past inspection reports content. The objective of this review is to identify and establish an inspection report format and level of detail that is informative and beneficial to stakeholders.

NRC Vendor Inspection Report Improvement Plan18Background ContinuedInspections up to 2012 were informative, but long.Report details were reduced to lower the potential for proprietary vendor information.In an effort to shorten the report, the NRC also changed the level of detail. The staff is currently revising Inspection Manual Chapter 0617, Discussion of Waterford Inspection 19 Discussion of Waterford Inspection finding 20In April 2016, the NRC conducted an inspection at Electroswitch (Report issued May 27th) On May 10, 2016, vendor issued a Part 21 On March 24, 2016, vendor discontinued its Appendix B Program Cited for failing to dedicate commercial materials or control under its Appendix B programWaterford inspection in October 2018 resulted in Green NOV for failure to take appropriate steps to accept commercial relays as basic componentsConcern expressed that licensee must dedicate all relays in the plant used in safety-related applications.

Discussion of Waterford Inspection finding 21Licensee Response: In May 2016, initiated a Condition Report. In July 2016, completed Engineering Evaluation concluding adequate. In October 2018, provided White Paper to NRC. Justification was previous NUPIC audits and 2015 source surveillance.

Discussion of Waterford Inspection finding 22Inspectors identified that CR failed to evaluate for Part 21, as vendor lacked information to determine if issue was reportable. Inspectors identified components in warehouse may be issued and used in safety-related application.NUPIC audit and 2015 source surveillance failed to identify the existence of this programmatic weaknesses.

References23EPRI TR-107372: http://jtaken.csoft.net/school/excelsior/Corco/School/EPRI%20TR-107372%20-%20Reverse%20Eng.PDFGutor Inspection Report (IR): Agencywide Documents Management System (ADAMS) Accession No. ML18206A438Westinghouse Electric Sweden IR: ADAMS Accession No. ML18324A427Hayward-Tyler IR: ADAMS Accession No. ML18250A302IN 2016-09: ADAMS Accession No. ML16075A285 (Associated IRs for Callaway, River Bend and Nova Machine ADAMS No. provided in the IN)Waterford IR: ADAMS Accession No. ML18319A379Electroswitch Part 21Report: ADAMS Accession No. ML16243A472 24