ML18041A156
| ML18041A156 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1987 |
| From: | Merschoff E Office of Nuclear Reactor Regulation |
| To: | Felmus N GENERAL ELECTRIC CO. |
| Shared Package | |
| ML18041A157 | List: |
| References | |
| CON-IIT07-621-91, CON-IIT7-621-91, REF-QA-99900403 NUREG-1455, NUDOCS 8710070206 | |
| Download: ML18041A156 (78) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 October 5>
1987" Docket No. 99900403/87-02 General Electric Company Nuclear Energy Business Operations ATTN:
Mr. N. L. Felmus, Vice President and General Manager 175 Cultner Avenue San Jose, California 95125 Gentlemen:
This letter addresses the inspection of your facility at San Jose, California, conducted by Mr. R.
P. McIntyre and J. J. Petrosino of this office on July 20-31,
- 1987, and the discussions of their findings with Mr. J. J.
Fox and other members of your staff at the conclusion of the inspection.
The inspection was conducted to determine if comercial grade component parts which are part of the panels which make up the control room power generation control complex (PGCC) at Nine Mile Point 2 (NMP-2), were procured and dedicated for use in these safety-related assemblies as described by a GE "white paper" submitted to the NRC on July 2, 1987.
Areas examined during the NRC inspection and the inspection findings are discussed in the enclosed report.
Within these
- areas, the inspection consisted of an examination of procedures and representative
- records, interviews with personnel, and observations by the inspector.
During this inspection it was found that the implementation of your gA program for activities described in the white paper could not be fully determined.
For the sample of components chosen by the inspectors for review, sufficient documentation was not available during the inspection to reach a
conclusion regarding the adequacy of implementation of the GE quality assurance program in the area of commercial grade procurement.
Therefore, this issue will be classified as unresolved at this time and will be reviewed further during subsequent NRC inspections.
In accordance with 10 CFR 2.790 of the Corenission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
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October 5I 1987 General Electric Company Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
Enclosure:
Inspection Report No. 99900403/87-02 Ellis W. Merschoff, ief Vendor Inspection anch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation cc:
Niagara Mohawk Power Corporation ATTN:
B. J. Hooten, Executive Director Nuclear Operations 300 Erie Boulevard West
- Syracuse, New York 13202 General Electric Company Nuclear Eneroy Business Operations ATTN:
R. Artigas, Manager Licensing 175 Curtner Avenue San Jose, California 95125
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ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT NO.:
99900403 87-02 INSPECTION DATE:
Jul 20-31 INSPECTION CORRESPONDENCE ADDRESS:
General Electric Company Nuclear Energy Business Operations Attn:
Mr. N. L. Felmus, Vice President and General Manager 175 Curtner Avenue San Jose, California 95125 ORGANIZATIONAL CONTACT:
Mr. J. J.
Fox TELEPHONE NUMBER:
40 - "-
NUCLEAR INDUSTRY ACTIVITY:
General Electric (GE) is currently providin9 engineering design and service activities for many domestic nuclear plant utilities.
ASSIGNED INSPECTOR:
p c
c ntyre, pecsa roJect nspect>on Section (SPIS) qg~
APPROVED BY:
OTHER INSPECTOR(S):
J. J. Petrosino, Program Development and Reactive Inspection Section Alex r
IS cv U
is
- otapovs, C se en nspectson rane a e INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and Appendix B to 10 CFR Part 50.
B.
SCOPE:
This inspection was performed to determine if the GE procurement
~an control of industrial grade components for the Nine Mile Point-2 control room safety-related panels was accomplished in accordance with a GE white paper submitted to the NRC on July 2, 1987.
PLANT SITE APPLICABILITY: All BNR Facilities.
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA, REPORT INSPECTION A.
VIOLATIONS:
None.
B.
NONCONFORMANCES:
None.
C.
UNRESOLVED ITEMS:
1.
Unresolved Item (87-02-01).
Due to the fact that the majority of the NMP-2 PGCC procurement packages reviewed did not include all the necessary paperwork to substantiate the implementation of steps 1-4 in the GE white paper, and that only a limited number of complete procurement packages were
- reviewed, the inspectors could not reach a conclusion as to whether the control of the dedication process for comoercial grade component parts used in the Nine Mile Point 2 (NMP-2) power generation control complex (PGCC) safety-related panels and assemblies was accomplished as described in the GE white paper submitted to the NRC on July 2, 1987.
It appears that some of the statements in the white paper may be overly optimistic and that the gA program implementation for these activities was not as rigorous as stated.
Other factors also contributed to the unresolved status of the inspection.
One major factor is that of the approximately 50 safety-related PGCC panels for NMP-2, only 3 were manufactured at the Nuclear Energy Business Operations (NEBO) facility in San Jose, California.
The remaining safety-related panels were fabricated at the GE Ground Systems Department (GSD) in Daytona Beach, Florida.
A cursory review of the GSD purchase order, dated in 1978, indicated that GSD would be performing its own procurements, material control, fabrication process controls, testing activities and other control activities.
A second factor was that due to time limitations, the inspectors were only able to perform a cursory review of the process which implements steps 5-8, including functional and qualification testing during and subsequent to fabrication.
Follow-up inspections are anticipated at GE NEBO and GE GSD in the near future'nd will require a review of records to determine if the facilities adequately implemented their gA program comnitments as outlined in the white paper.
l
't
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
No previous inspection findings were reviewed within the scope of this inspection.
E.
OTHER FINDINGS AND COMMENTS:
Back round - The NRC staff identified concerns with the NMP-2 design re ative to IEEE-279 (1971), "Criteria for Protection Systems for Nuclear Power Generating Stations."
Specifically, it appeared that numerous non-safety-related systems electrical circuits were connected to Class 1E reactor protection system (RPS) power supply buses on RPS Class 1E circuits.
These concerns were identified during a staff review of a GE failure modes and effects analysis (FEMA) submitted by Niagra Mohawk Power Corporation (NMPC) on May 18, 1987.
Subsequent to this review, technical meetings were held between the
In a meeting held on June 19, 1987 to discuss possible generic implica-tions of the RPS non-lE component issue, GE stated that these isolation components were infact Class lE.
The NRC requested GE to document their position on the quality of parts contained in safety-related assemblies.
2.
On July 2, 1987 GE submitted a white paper to the NRC and to all domestic BMR utilities.
This white paper describes the process at GE for the upgrading of industrial grade items (or dedication of commercial grade items) to safety-related assemblies.
The Vendor Inspection Branch (VIB) was requested to conduct an inspection at GE to verify the implementation of the white paper for procurement and control of industrial grade components used in the NMP-2 PGCC.
The intent of the VIB inspection was to review the documentation for a representative sample of commercial grade components used in the NMP-2 PGCC and verify that the GE gA program was implemented as stated to assure that parts and assemblies supplied by GE meet all applicable requirements for safety-related equipment.
Review of D'edication of NMP-2 PGCC Com onents The inspectors chose several components that would have been procured commercial grade and been put through the dedication process using the eight steps described in the white paper for use
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION in safety-related assemblies.
GE put together procurement packages for these components including all the necessary paperwork verifying the process described in the white paper.
The white paper can be summarized as stating that GE controlled all of the individual components within its PGCC system panels by:
a)
Establishing an Appendix B structured system of "quality activity" implementing procedures and instructions; and b)
Rigorously implementing the applicable portions of its program to provide a reasonable level of confidence to assure that the quality and required performance for the parts is adequate.
The eight steps in the white paper were categorized into three general areas for inspection purposes.
The first area relates to step I of the GE white paper for establishing a gA program and implementation procedures at the "quality activity" working level.
The second area contains GE white paper step numbers 2, 3, and 4, which include:
a)
Development and documentation of the requirements for individual parts (design);
b)
Independent verification of the design requirements; c)
Delineation of specific requirements/controls on purchase orders; and d)
A receipt inspection that verifies the parts conform to the engineering requirements.
The second area is important because it determines the operating range and characteristics of a particular part to perform its function, and ensures that the correct parts are ordered and received.
The third area contains GE white paper step numbers 5, 6, 7, and 8, which include:
a)
Installation of parts into assemblies/panels with gA docu-mentation to verify the same;
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION b)
Performance of functionability testing; c)
Engineering performed qualification tests, either by test or combined test and analyses; and d)
- Records, inspection reports, nonconformance reports (NCRs) and other documents that verify the, applicable steps were taken.
The NMP-2 components chosen were from the High Pressure Core Spray (HPCS),
Reactor Core Isolation Cooling (RCIC) and the Nuclear Steam Shutoff System (NSSS),
and consisted of fuses, relays, switches,
- meters, diodes, resistors, controllers, and a signal resistor unit.
For each component, GE put together a package which was to include information such as the Purchase Part Drawing (PPD, which includes the requirements for purchase of parts),
the original Engineering Review'emorandum (ERM, which documents the independent design verification and approvals),
the Purchase Order, the guality Control Inspection Card (gCIC, which specifies any Test Instructions and receipt inspection requirements),
the receiving inspection history log, the Approved Suppliers List, and other background information.
Component parts to be used in PGCC panels are specified on Master Parts List (MPL), Elementary Diagram Device Lists (EDDL) and Electrical Device Lists (EDL).
The above documents should verify that steps 1-4 as described in the white paper (or the first two inspection areas) were accomplished.
Vhen reviewing the packages, it became obvious that in several cases certain paperwork, such as the original ERM, the gCIC, and the original purchase order were not included.
GE stated that since this information was extremely old, in some cases pre 1978, it could not be located.
The current process used by GE for the dedication of coaeercial grade items is different than the process which was in place when the NMP-2 PGCC panels were originally manufactured.
As GE has stated, the PGCC was originally fabricated using commercial grade components that were dedicated for use in safety-related applications through the process described in steps 1-8 of the white paper.
During the inspection, GE stated that the current system for replacement components uses dedicated PPDs and therefore does not fall under the process described in the white paper.
Dedicated PPDs are basically the original PPDs which are revised to include qualification requirements such as seismic conditions, r
- r
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION environmental conditions, applicable industry standards, and any special dedication tests.
The inspectors reviewed a total of 10 NMP-2 procurement packages with PPDs and associated documentation.
Of these 10 packages, 8
were for original PGCC equipment and 2 were for replacement equipment and included the current GE system using dedicated PPDs.
The packages for the current system were reviewed to establish a
basis for'he difference between dedication performed on PGCC components during initial fabrication and dedication of replacement PGCC components today.
The replacement component packages reviewed using dedicted PPDs contained all the documentation required to substantiate items 1 to 4 in the white paper.
The 8 packages for the original NMP-2 PGCC components, however did not contain all of the documentation necessary to establish full compliance with the white paper.
The missing documentation includes 7
PPDs without original
- ERMs, 2
packages without gCICs, 2 other packages without the original POs, 2 cases where the receiving history log shows none of the parts received during the appropriate time frame and 3 instances where GE was unable to demonstrate that the vendor was on the approved suppliers list.
These examples tend to demonstrate that all of the records to support steps 1-4 in the white paper may not be available and the statements in the white paper may be overly optimistic.
During the exit meeting, GE stated that they were going to review the white paper and discuss the possibility of revising it.
Below is a listing of the NMP-2 components reviewed with the applicable
- system, PPD number and panel number.
~Com onent Switch Diode Meter Rel ay Switch Meter Controller Fuse Fuse Diode
~Se tern HPCS NSSS RCIC HPCS HPCS RCIC RCIC HPCS HPCS NSSS PPD 8 249A1471 176A1572 159C4540 163C1170 214A1471 157C4570 163C1392 145C3039 DA317A6159 DA317A7898 Panel 8
H13-P852 H13-P 609/61 H13-P601 H22-P028 H13-P852 H13-P 601 H13-P014 H22-P028 H22-P028 H13-P 609
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION The inspectors began a review of the activities conducted by GE as described in items 5 to 8 in the white paper.
The inspectors reviewed documentation pertaining to inspection and functional testing of IEC subassemblies, assemblies, panel inserts, and complete panels (not including interconnected panel system testing) and determined that the procedures and methods appeared adequate for their intended purposes and that the documented results indicated proper operation as certified by the various technicians and gA personnel.
It was noted that the method of documentation normally does not involve recording observations and raw data, but rather only the technician's and/or gA inspector's certification that a particular step of the procedure was completed with satisfactory results.
The intended purpose of this functional testing would be adequate in many cases to detect malfunctioning or failed components, and in some cases to detect degraded performance.
However, there are some design attributes of components of these assemblies that are impor-tant to durability which cannot be evaluated solely by functional testing of unaged components under shop ambient conditions.
These attributes require individual component inspection, material verification, etc., to verify that all design specifications are met.
The installation, testing and qualification of components at the subassembly,
- assembly, panel insert, and panel level will be reviewed in more detail to verify that GE accomplished this process as described in steps 5 to 8 of the white paper.
This is considered unresolved item (87-02-01) and a further review will be conducted during a future inspection.
F.
PERSONNEL CONTACTED:
- Don H. Ferguson,
- Manager, MAES, GE-NSgA
- James J.
Fox, Senior Program Manager, GE-gA
- Roger K. Waldman, Principal Engineer
- George B. Stramback, Safety Evaluation Program Manager, GE-Licensing and Control Services
- Louis D. Test, Consulting Engineer, GE-gA
- Joseph M. Case, gA System,
- Manager, GE-gA
- Norman E. Barclay, Principal Engineer GE-NSgA E. Wester, Principal Project Engineer
<<H.
R. Peffer, Project Manager, Nine Mile Point
1
ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION
- R. Artigas, Manager, L8CS
- Noel Shirley, Sr. Licensing Engineer
- L. S. Bohl, Manager, QA/NSTO
- B. A. Smith, Counsel
- R. L. Fisher, Principal Engineer, Material Services
- Harry L. Shannon,
- Manager, Test Engineering
- H. C. Pfefferlen, HGR BMR Licensing Issues
- Attended exit meeting.
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P DOCKET SUBMITTAL NOT REQUIRED BY NRC DETAILED ANALYSES NOT REQUIRED BY REGULATION PRE R.G.1.75 ANALYSIS APPROACH RANGED FROM DETAILED CALCS TO ENGINEERING JUDGEMENT PLANTS LICENSED WITH NRC UNDERSTANDING OF APPROACH REVIEW TO DATE HAS SHOWN ACCEPTABLE DESIGN NO SAFETY PROBLEM IDENTIFIED
R E
LY NRC REQUIRES DESIGN ADEQUACY ASSURANCE FOR IEEE279(71)
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- PARTIALLY OR FULLY COMMITTED TO R.G.1.75
I
E EET D
PAAT LETTER TO NRC DOCUMENTING ASSOCIATED CIRCUIT POSITION (3/7/88)
LETTER TO NRC ADDRESSING QUALITY OF COMPONENTS IN CONTROL PANELS (3/15/88)
ANALYSES SUBMITTED TO NRC FOR ALL NON-lE, NON-ISOLATED CIRCUITS ON NMP2 (4/7/88)
PLAQED ASSESS UPGRADED NMP2 CIRCUITS
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HOPE CREEK ASSESS REMAINING IEEE279 (1971)
PLANTS ALL IEEE279 (71)
PLANTS CONFIRMED GE LETTER TO NRC CONFIRMING DESIGN ADEQUACY
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REVIEW TO DATE HAS SHOWN ACCEPTABLE DESIGN NO SAFETY PROBLEM IDENTIFIED (c
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PRIMARY REVIEW BASIS 0
USE
AS NECESSARY 0
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1981 SIMILARITY REVIEW 0
RELATED ANALYSES (FMEA, DAL-17)
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COMPONENTS 0
SUMMARIZE RESULTS (GE LETTER TO NRC)
I GE Nuclear Energy General &'esnlc Conoeny s75 Cunoef Avenue. Seo Jose, CA 95125 M/C 682, (408) 925-5040 MFN- 023-88 March 25, 1988 ye~
U.S. Nuclear Regulatory Commission Division of Engineering and Systems Technology Washington, D.C.
20555 Attention:
Ashok C. Thadani Assistant Director for Systems
Subject:
Reference:
QUALITY OP PARTS IN CONTROL PANELS July 2, 1987 Letter to Ashok Thadani from R. Artigas, "GE White Paper on Quality of Parts in Safety Related Assemblies".
As discussed in our March 2 phone conversation, attached is a clarified and expanded paper addressing the quality of parts in control panels.
It is intended as a replacement for the reference letter.
This letter is also being transmitted to all domestic BWR Owners.
I trust that this letter is responsive to your needs.
If you have any questions or comments please feel free to call me or Dave Robare (408) 925-3141.
Sincerely, P%1A
+
Licensing
& Consulting Services RA:GS/DJR:md cc:
L. S. Gifford H. R. Peffer R.. E. Skavdahl
This paper is both a clarification and expansion of the information supplied to the NRC in a July 2nd letter containing the White Paper on the Quality of Parts in Safety Related Assemblies.
It is provided to explain how GE has assured the appropriate quality of control panel components, including safety related, associated and non-safety related.
This paper addresses general topics which have been identified and discussed with the NRC during audits in San Jose and at our January 22, 1988 meeting with NRR.
Figure 1 provides a pictorial representation of classification of functions for all equipment and circuits and how GE performed design, purchasing and quality assurance to assure compliance with applicable regulatory requirements.
The paper necessarily includes only overview descriptions of these processes for safety related, associated, and non-safety related circuits.
The internal GE procedures contain the steps and tasks employed over the last two-plus decades of design and manufacturing of original electrical equipment assemblies for BWR plants.
Since these steps and tasks have evolved over
- time, they can only be covered here in a general summary fashion.
The only appropriate audit base would therefore be the procedures themselves.
The section entitled Safety Related Circuits includes both parts purchased and supplied as safety
- related, and parts originally purchased as non-safety related but ultimately performing safety functions within safety related assegblies.
The Associated Circuits section is provided to address those parts contained within safety related assemblies that are not per-
~V" t e safety functions.
iso included is informa on on non-safety related parts which do not eve perform any safety function.
Many components utilized in safety related assemblies which are required to perform safety functions are themselves
- designed, purchased and assembled in accordance with codes and standards required for safety related equip-ment.
In other cases, it has been necessary to purchase non-safety related components for incorporation into safety related assemblies.
This is due to the necessary, and appropriate, practice of designing safety-related equipment to utilize standard industrial-grade parts generally because safety-related versions of such piece-parts are simply not available.
At GE the following measures were implemented for these parts procured as non-safety related but utilized to perform safety functions in safety related assemblies:
l.
An NRC approved Quality Assurance (QA) plan (NEDO 11209) and the supporting and implementing procedures followed during the assembly process were generated and meet 10CFR50 Appendix B.
2.
The requirements for the parts were developed and documented as part of the engineering design process of the equipment.
These require-ments once established, were subject to a rigorous change control program.
The application of the parts to the assembly was indepen-dently verified.
3.
The parts were purchased to the documented engineering requirements, plus appropriate QA requirements defined during the QA review.
4.
Based on item 3
- above, QA defined inspection requirements.
Upon receipt the parts were inspected and tested as required to establish their conformance to these requirements.
5.
The parts were installed in safety-related assemblies, e.g.,
- panels, using approved and controlled processes, and were subject to various documented QA inspections and tests.
6.
Prior to release for operation, the safety-related assemblies were subjected to specified performance tests.
7.
In addition',
engineering performed the required qualification of the various safety-related assemblies, either by test or combined test and
- analysis, and documented the results.
Such qualification was in accordance with all applicable requirements between GE and the indivi-dual purchasing utility.
I
8.
Throughout the above
- process, the QA program
- generated
- records, inspection reports for defective or nonconforming materials and corrective actions as
- required, in accordance with applicable QA procedures.
Records retention occurred consistent with the designa-tion of the assembly at the point of identification as safety related (i.e. from step 5 above).
General Electric supplied safety-related assemblies contain features which are not necessary for the performance of safety functions.
In some cases these features are electrically connected to safety-related circuits and parts.
These are defined as "associated" circuits or as being a part in an "associated" circuit.
The "associated" circuits term is defined in IEEE 384-1981.
GE has designed associated circuits in compliance with the guidance in IEEE 279-1968
& 1971 and later its daughter standards (IEEE 308,
& 384).
GE has incorporated such associated circuits into the system designs contained in safety related assemblies.
The recognized design methods for associated circuits are
- 1) use of safety-related parts in the circuits,
- 2) isolation of the circuits, or
- 3) analysis or testing of the circuit or parts "to demonstrate Class 1E circuits are not degraded below an acceptable level" (IEEE 384).
This analysis approach is consistent with the requirements of IEEE 279-1968 and 1971 and has been formally established in the daughter standards (ie.
This design approach was used by GE and accepted by the NRC staff during the licensing review of BWR plants.
NON-SAH?TY RELATED CIRCUITS General Electric supplied safety and non-safety related assemblies also contain parts which do not perform any safety function, are not electri-cally connected to parts performing safety functions, and cannot prevent the performance of safety functions.
They have been applied to supply satisfactory performance for their intended non-safety function.
CLASSIFICATION OF ELEC%ICAL UIPHHRF AND CIRCUITS ASSOCIATED
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Self Contained Appendix B Class 1E Commercially Available (prior to assembly)
Appendix B guali.ty (following assembly)
Class 1E Coemercially Available Class 1E Isolation wc'< 4 g qo bc(
Class 1E
>fan Pmyw's Analyre to Deammtrate Acceptability c4r <co ll~ Co<wq QJ COHI99LCIALLYAVAILABLE Definitions Safety Related Performs safety function Associated
- Does not perform a safety function but is connected to a safety function circuit Non Safety Related Does not perform e safety function and is not connected to a safety function circuit FIGURE 1
1
Mr. R. Artigas, Manager Licensing 5 Consulting Services General Electric Company 175 Curtner Avenue San Jose, California 95125
Dear Hr. Artigas:
SUBJECT:
ASSOCIATED CIRCUITS IN CONTROL ROOM PANELS
Reference:
GE letter MFN-016-88 dated March 7, 1988 from R. Artigas (GE) to A. Thadani (NRC)
The purpose of this letter is to confirm receipt of and to respond to your letter (HFN-016-88) dated March 7, 1988 (issued pursuant to commitments made during our March 2, 1988 telecon) which provides clarification as to the meeting (January 22, 1988) the NRC had with GE to discuss "associated" circuits and equipment.
Your Harch 7, 1988 letter discussing associated circuits in control room panels states that GE will submit summaries of analyses and tests and that NHP-2 w'ould be the plant for evaluation.
- However, as reflected in the attached meeting summary dated February 22, 1988, the staff requested that a detailed FHEA (not a summary) including type test data should be submitted which addresses all of the electrical components classified as "associated" within GE's scope oF supply which were analyzed and tested
( 10%) to demonstrate acceptabi lity for their applications.
The meeting summary also reflects that the information should encom ass all.components within the NHP-2 scope of supply which fall within t s category and should be, as a minimum, to the level of detail as the information supplied on the NHP-2 docket (letters dated Hay 18 and June 16, 1987) during the licensing process.
It was never our understanding that any one plant such as NMP-2 would be selected for the evaluation.
If there are any questions or comments on this letter, please contact me (301-492-0774) or Scott Newberry of my staff (301-492-0782).
",qtr(N.:
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Enclosure:
As stated cc:
D. Robare (GE)
B. Grim (GE)
DISTRI BUTT ION:
Central Files SICB RF
'. Hartin L. Shao S. Varga J. Part low R. McIntyre M. Haughey R. Capra S. Newberry J.
Hauck J.
Joyce R. Stevens Ashok C. Thadani, Assistant Director for Systems Division of Engineering
& Systems Technology Office of Nuclear Reactor Regulation T
.bl 0 /
/88 IC T
auck 0 /ig/e8 ICSB:
T SN erry 03/+88
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. MEMORANDUM FOR:
THRU:
FROM:
SUBJECT:
Scott Newberry, Acting Chief Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology Jerry L. Mauck, Section Chief Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology Robert Stevens Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology
SUMMARY
OF MEETING WITH GENERAL ELECTRIC TO DISCUSS THE HISTORY ASSOCIATED WITH THE CLASSIFICATION OF ELECTRICAL EOUIPMENT AND CIRCUITS Upon request, NRC staff members met with representatives from General Electric (GE) on Januarv 22, 1907 to discu~s, on a generic basis, the history associated with the classification of electrical equipment and circuits at various BWR plants.
This issue surfaced during the licer sinq review of the NMP-2 design (June 1987).
The meeting was followed up by a telecon with GE on the same day to summarize staff thoughts and recommendations.
The following provides the results which include follow-up coomitments by GE:
o GE requested the meeting as a result of an NRC s+~~f audit performed at GE's San Jose office related to the verification of GE's generic gA program associated with acquiring Class 1E compone.".ts for use in safety-related systems.
The gA audit resulted from an issue which developed during the full power license review for NMP-2.
The audit revealed a
lack-of-traceability for verification that non-Class 1E electrical components indeed were qualified for Class 1E applications.
o The primary purpose of the meeting was to discuss new information on GE's historv of handling electrical equipment categorized as "associated."
GE defined "associated" componerts as those which perform non-safety related functions but are connected to Class 1E circuits.
GE's presentation revealed that 90% of the "associated" components are separated from Class 1E circuits through Class 1E isolation devices.
The remaining 1O% have been analyzed and tested to demonstrate acceptability.
During the NMP-2 licensing review, the NRC staff pursued the adequacy of the application associated with the remaining 10".~ which led to the follow-up gA audit discussed above.
o GE provided a draf. (attached}
packaqe describing a representative sample of the 10 category of "associated" components with supportino analysis CONTACT:
R. Stevens
( ICSB/DEST), x20785
L
Ashok C. Thadani 2
and tests.
Recent GE assessment has concluded that the associated equipment applications at BWRs have been reconfirmed to be acceptable for their applications (i.e., will not degrade the required safetv function below an acceptable level}.
Aside from the analyses and tests, GE assessment also considered BWR plant operating experience (about 30 ears revent a safe knowledge that not one of these components have fail d i p
t sa ety system from performfng its required safety function, and ve a
e n
a manner to the ability to detect failures during periodic surveillance.
o Based on GE's presentation, the staff's preliminary conclusfo i
th pp rs to be reasonable assurance that no unresolved safet issue exists.
The NRC staff informed GE that their e r approac (development of pp r '.ng analysis and tests) to address the application of "associated" components appears to be reasonable, for resolution of the issue.
- However, the staff informed GE that before any final conclusions can be made, formal informatfor should be submitted for staff review.
A-detailed FMEA'ncluding type testing data should be submitted which addresses all of the electrical components classified as "associated" which 1
d d
(
) to demonstrate acceptability for their applications.
GE was were ana yze an within the NMP-2 s informed that this informatior. should encompass ll f th a
o e components scope of supply whirh fall within this category and should be, as a minimum, to the level o~ detail as the information supplied to the e
nc et,letters dated May 18, and'June 16, 1987).
GE agreed and comnftted to submit a complete package for staff review.
The p
w u be subritted in approximately 30 staff understood that such a
ackane would j
mee f g.
Suhseruently, by telecon dated submitted until April 8, 1988.
ry,,
notified the staff that the ir ormation wo ld t b ou no e
o The NRC staff f NMP-2 licensee of the latest d v urther recommended that GE should imnediatel notif th to the NRC as to t t
evelopment so that they can respond formally yno y
e docket.
GE's o
e as to their planred approach to resolve the issue on th i on er info rma tion for c
.information to the licensee should include j tif'i continued plant operation.
The NPC staff stated that the us ica on generic approach would be acceptable for the resolution of the issue on NMP-2 should the licensee elect this method.
/5 Robert Stevens Instrumentation 5 Control Systems Branch Division of Systems 5 Engir.eerfng Technology cc:
L. Shao D. Neighbors R. Capra M. Haughey ICSB Members A. Thadani,.
C 0
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7 L
o GE Nuclear Energy Ge~e'~'
e:! <<: Company 125 Curtate A.e~~e San Jose. C4 95125 M/C 682, (408) 925-5040 MFN-016-88 March 7, 1988 U. S. Nuclear Regulatory Commission Division of Engineering and Systems Technology Washington, D.C. 20555 Attention:
Ashok C. Thadani Assistant Director For Systems Gentlemen:
Subject:
hSSOCIATED CIRCUITS IN CONTROL ROOM PANELS
Reference:
GE/NRC Telecon March 2, 1988 (Thadani/Artigas et. al.)
As you requested in our March 2 phone conversation, this letter provides a
summary of our position on "associated" circuit design as presented to the NRC in the January 22, 1988 meeting and our schedule of submittals to the NRC for supporting documentation.
General Electric supplied safety-related assemblies contain features which are not necessary for the performance of safety functions.
In some cases these features are electrically connected to safety-related circuits and parts.
These are defined as "associated" circuits or as being a part in an "associated" circuit.
The "associated" circuits term is defined in IEEE 384-1981.
GE has designed associated circuits in compliance with the guidance in IEEE 279-1968
& 1971 and later its daughter standards (IEEE 308, h 384).
GE has incorporated such associated circuits into the system designs contained in safety related assemblies.
The recognized design methods for associated circuits are
- 1) use of safety-related parts in the circuits,
- 2) isolation of the circuits, or
- 3) analysis or testing of the circuit or parts "to demonstrate Class lE circuits are not degraded below an acceptable level" (IEEE 384).
This analysis approach is consistent with the requirements of IEEE 279-1968 and 1971 and has been formally established in the daughter standards (ie.
IEEE 384"1981).
This design approach was used by GE and accepted by the NRC staff during the licensing review of BWR plants.
I 7
GE submittals to the NRC and utility owners will be as follows:
3/7/88 ASSOCIATED CIRCUIT POSITION & COMMITMENTS TO NRC & BWR OWNERS g'rJtrk(V~<<
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For all associated circuits and components which are neither Class lE nor
- isolated, the NRC requested in the January 22 meeting that GE submit supporting analyses summaries to demonstrate design adequacy to support GE's engineering judgement at the time of the design.
It was further agreed that Nine Mile Point 2 would be the plant for the evaluation and that the summaries would include both failure modes and effects analyses and component assessment information such as test data and similarity to 1E equipment evaluation.
5 0r (This letter) 3/7/88 NEUTRON MONITORING SYSTEM ISOLATOR TEST RESULTS
SUMMARY
TO NRC 3/25/88 REVISED WHITE PAPER TO NRC
& BWR OWNERS ADDRESSING ALL PANEL COMPONENTS C
L 4/7/88 ASSOCIATED CIRCUIT ANALYSIS SUMMARIES TO NRC All submittals to the NRC will.be sent to you by overnight mail from San Jose on the date indicated.
I trust that this letter is responsive to your needs.
If you have any questions or comments please feel free to call me or Dave Robare (408) 925-3141.
Sine rely, R. Art's, Manager Li sing
& Consulting Services RA/md cc:
B. Stevens, NRC L. S. Gifford
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v /j UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 16, 1988 MEMORANDUM FOR:
THRU:
FROM.'UBJECT:
Scott Newberry, Acting Chief Instrumentation
& Control Systems Branch Division of Engineering
& Systems Technology Jerry L. Hauck, Section Chief Instrumentation
& Control Systems Branch Division of Engineering
& Systems Technology Robert Stevens Instrumentation
& Control Systems Branch Divis1on of Engineering
& Systems Technology
SUMMARY
OF TELECON WITH GENERAL'ELECTRIC TO DISCUSS THE NEUTRON MONITORING SYSTEM CLASS lE/NON-CLASS lE INTERFACE AND CLASSIFICATION OF EQUIPMENT ISSUES NRC staff members participated in a telecon with General Electric (GE) on March 2, l988 to d1scuss the status related to the resolut1on of the Neuton Monitoring System (NHS) Class lE/Non-Class lE interface issue and classifica-tion of electrical equipment and circuits issue.
Information on the NMS item was addressed by GE in a September 21, 1987 letter (Attachment
- 1) to the NRC whereby GE comm1tted to submit resolution information by December 3l, 1987.
GE presented informat1on on the classification of electrical equipment issue during a meeting on January 22, 1988.
A summary of the meeting is prov1ded as.
The results of the March 2, 1988 telecon which include follow-up commitments by GE are as follows:
o The NRC informed GE of 1ts concern w1th delays in the submittal of information related to the resolution of the NMS Class lE/Non-Class lE interface issue and "associated" equipment qualification issue.
Subsequently, GE committed to 1) submit a
NMS suImary report on analyses and tests by March 9, 1988 and 2) submit by April 8, 1988 a detailed FMEA including type test data addressing all electrical components classified as "associated" which were analyzed and tested
( lOX) to demonstrate acceptab111ty for their applications.
Upon NRC request, GE also comIitted to submit, coincident w1th NRC's submittal from GE, the subject 1nformation to all domestic BWR utilities.
o The staff addressed the 1ssue related to GE's "white paper" on the quality of parts 1n safety related assemblies.
This information was issued to the NRC staff by letter dated July 2, 1987 (Attachment 3) and addresses GE's QA program that assures parts and assemblies suppl1ed by GE meet all CONTACT:
R. Stevens (ICSB/DEST) x20785
1
applicable requirements for safety related equipment.
As noted in,
a NRC audit (November 1987) revealed a lack-of-traceability for verification that Non-Class lE electrical components were indeed qualified for Class lE applications.
GE informed the staff dur1ng the March 2, l988 telecon that they are in the process of rev1sing the "white paper" to cover all categories of equipment (safety related, non-safety
- related, and associated) and that this 1nformation w111 be subm1tted to the NRC by March 25, 1988.
Upon request, GE committed to also provide, coincident with NRC's submittal from GE, this package to all domestic BWR utilities.
Such information is required to support the NRC Vendor Inspection Branch in a future audit for the purpose of verifying GE's gA program used to acqu1re qualified components for safety related functions.
o The NRC addressed the latest (as d1scussed in the January 22, l988 meeting) development on GE's history of handling electrical equipment categorized as "associated" in relation to the current 11censing basis for Nine Mile Point 2 (NMP-2) which is now inaccurate.
GE stated that they have recently been approached by the NMP-2 licensee on this issue and that GE is working directly with the licensee to correct the situation at NHP-2.
GE stated that they were scheduled (Harch 2, 1988) to inform the licensee on this issue.
NRC stated strongly that this item should be resolved with NMP-2 as quickly as possible and that the basis for resolution should be adequate to support continued plant operation.
It should be noted that GE also committed to submit by March 7, 1988 a letter to the NRC to provide an overall summary of the subject March 2, 1988 telecon.
GE stated that this 1nformat1on will identify their commitments and provide a summary of the scope of information required as a result of the January 22, 1988 meeting held between NRC and GE to discuss the classification of equipment.
CC:
A. Thadani T. Martin S.
Varga L. Shao J. Partlow M. Haughey J.
Joyce R. Capra R. HcIntyre Robert Stevens Irv'trumentation 5 Control Systems Branch Division of Engineering 8 Systems Technology
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>'041 3eP Cl >5( lO'ar r.IJZ GENERAL ELECTRIC AT78Cern~T I NUCLE>A>R ENERGY OVSINESS OPERATIONS GENERAL ELECTRIC COMPANY~ 17$ CURTNER AVENUE ~ SAN JOSE, CALIFORNIA95125 M/C 602, Ph.
(408) 925-5040 GBS-60-087 MEN-087 September 21, 1987 U. S. Nuclear Regulatory Commission Division of Engineering and Systems Technology Washington, D. C, 20555 httentioni hshok C. Thadani hssistant Director for Systems Gentlemen:
SUBJECT'EFERENCE.!
MEETING RESULTS " NRC hND GE,REVIEW OP THE NEUTRON MONITORING SYSTEM INTERFhCE ISOLATION
- 1) Letter R. hrtigas to hshok C. Thadani, "Similarity of Neutron Monitoring System Design" > dated June 22, 1987.
- 2) Letter R. hrtigas to hshok C. Thadsni, "NRC Reviev of the Neutron Monitoring System",
dated June 24, 1987.
This letter is to document the results of GE's discussions vith you and your staff, held last veek in Bethesda, GE representatives and NRC staff met on September 9 and 10, 1987 to discuss class 1B to non-class 1E interfaces oi the Neutron Monitoring System (NMS) design for BWR 4 and 5 planta.
GE vas represented by B. P.
Grim and G. B. Stramback and the NRC by J. L. Mauck and R.
W. Stevens in the vorking meetings on September 9th.
On September 10 h, the above presented the results of the vorking meetings to h.
C. Thadani (NRC)p R.
hrtigas (GB) and R. C, Mitchell {GB).
The issues vhich vere closed end those identified for further actions are as follovs<
- 1. Relay coil-to-contact and contact-to-contact isolation are acceptable betveen class 1E and non-class
]B circuits as described
GENERAL ELEC. TRlC Cu TEL No.
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NRC September 21 g 1987 Fsge 2
in existing documentation (TSAR's, Questions h Responses and SER's) an several licensing docksts mast notably LaSalls and Limerick.
Action~
This issue is closed.
No action is required.
- 2. The interface isolatoz network consisting af an operational amplifier, fuss and saner diade is acceptable between class 1K and non-class lE circuits.
Action>
This issue is closed.
No action is required.
- 3. Ths interface isolator netvoxk consisting af an operational amplifier (op amp), fuss and resistor appears acceptable and closable baaed on the information supplied with item 2 above.
The NRC staff is to rsvisv this information and ths ap amp alone to determine adequacy of the op amp/fuss/xasistor nstvox'k.
The NRC vill inform GE of their conclusion on acceptability far closure.
Psz a September 21st telecon, the NRC requested analysis and testing of this network configuration.
Action>
GE to analyze and test.
This GE response is to be provid-ed by Dscsmbsz 31>
19B7.
4.
One unique application of an NMS class 1E to nan.class 1E conputer interface vas found in tha Thermal Power Trip circuit.
This intexface uses an operational amplifier and three resistors.
GE did not hsva documentation that this vas specifically covered in any licensing review.
The NRC xequested that GE provide evidence of the isolation capabilities of this circuit.
The analysis should consider that the failure occurs simultaneously in all the channels (6),
GE has determined that this interface vas not ganexic, but plant unique.
Therefore it vill be addressed as a plant unique issue
~
Actiont This issue is closed.
Na action is required.
- 5. Five applicatians of a NMS class 1E to non-class 1E computer intarfeca network exists vith twa resistors in a voltage divider arxangemsnt in series vith a fuss.
GE stated that extensive testing on ths cizcuit vas paxformed in the early 1970' demon-strating acceptable iso1ation.
Naithex GE nox the NRC have been able to find previous documentation on this arrangement.
GE thexefoze, vill undertake to redocumsnt this circuits acceptable performance, substantiated by analysis and test data.
The NRC vas concerned about ths )ustification af fuses and resistors as ade-quate isolation devices.
The NRC staff stated that, they may not appzovs the use of fuses and xssistox's on licensing applications in the future.
In order foz ths NRC ta accept them on existing
- planta, GE must demonstrate, (in additian to the analysis and test
1
g ~ ~
NRC Septembaz 21>1987 Page 3
data), historical data indicating the acceptable performance of this network in operating plants.
Action~
GE is to analyse and test, as eall as, collect historical data.
This response is to be provided by December 31,19B7.
Zt vas agreed that closure of these five issues would represent accep-tance.of the NMS design interface isolation for BMR 4 and 5 planta.
R. Artigas, Manager Licensing 5 Consulting Services ccrc L.
S Gifford (GE Bethesda)
B. P. Crim R.
U. Mitchell R. E. Skavdshl G. B. St.ramback
'\\ ll
MEMORANDUM FOR:
THPU:
FROM:
SUBJECT:
Scott Newberry, Acting Chief Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology Jerry L. Mauck, Section Chief Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology Robert Stevens Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology
SUMMARY
OF MEETING WITH GENERAL ELECTRIC TO DISCUSS THE HISTORY ASSOCIATED WITH THE CLASSIFICATION OF ELECTRICAL EOUIPMENT AND CIRCUITS Upon request, NRC staff members met with representatives from General Electric.
(GE) on Januarv 22, 1907 to discu~s, on a generic basis, the history associated with the classification of electrical equipment and circuits at various BWR; plants.
This issue surfaced during the licensinq review of the NMP-2 design (June 1987).
The meeting was followed up by a telecon with GE on the same day to summarize staff thoughts and recommendations.
The following provides the results which include follow-up conmitments by GE:
o GE requested the meeting as a result of an NRC s.r~f audit performed at GE's San Jose of<ice related to the verification of GE's generic gA program associated with acquiring Class 1E components for use in safety-related systems.
The gA audit resulted from an issue which developed during the full power license review for NMP-2.
The audit revealed a
lack-of-traceability for verification that non-Class IE electrical components indeed were qualified for Class 1E applications.
I o
The primary purpose of the meeting was to discuss new information on GE's historv of handling electrical equipment categnr ized as "associated."
GE defined "associated" componerts as those which perform non-safety related functions but are connected tn Class 1E circuits.
GE's presentation revealed that 90% of the "associated" components are separated from Class lE circuits through Class lE isolation devices.
The remaining 1OX have been analyzed and tested to demonstrate acceptability.
During the NMP-2 licensing review, the NRC staff pursued the adequacy of the application associated with the remaining 10".i which led to the follow-up l}A audit discussed above.
o GE provided a draft (attached) packaqe describing a representative sample of the 10~ category of "associated" components with supportina analysis CONTACT:
R. Stevens (ICSB/DEST), x20785
T
Ashok C. Thadani and tests.
Recent GE assessment has concluded that the associated equipment applications at BWRs hav~ been reconfirmed to be acceptable for their applications (i.e., will not degrade the required safety function below an acceptable level).
Aside from the analyses and tests, GE assessment also considered BWR plant operating experience (about 30 years),
knowledge that not one of these components have failed in a manner to prevent a safety system from performing its required safety function, and the ability to detect failures during periodic surveillance.
o Based on GE's presentation, the staff's preliminary conclusion is that there appears to be reasonable assurance that no unresolved safety issue exists.
The NRC staff informed GE that their approach (development of support'.ng analysis and tests) to address the application of "associated" components appears to be reasonable for resolution of the issue.
- However, the staff informed GE that before any final conclusions can be made, formal information should be submitted for staff review.
A detailed FMEA including type testing data should be submitted which addresses all of the electrical components classified as "associated" which were analyzed and'ested
( 10%) to demonstrate acceptability for their applications.
GE was informed that this informatior. should encompass all of the components within the NMP-2 scope of supply whirh fall within this category and should be, as a minimum, to the level o~ detail as the information supplied to the staff on the NMP-2 docket (letters dated May 18, and June 16, 1987).
GE agreed and committed to submit a complete package fnr staff review.
The staff understood that such a packan~ would be suhr itted in approximately 30 days from the dat~ of the subject meeting.
Suhseruently, by telecon dated Februarv 3, 1988, GE notified the staff that the ir ormation would not be suhmitted until April 8, 1988.
o The NRC staff further recommended that GE should immediately notify the NMP-2 licensee of the latest development so that they can respond formally to the NRC as to their planned approach to resolve the issue on their docket.
GE's information to the licensee should include justification information for continued plant operation.
The NPC staff stated that the qeneric approach would be acceptable for the resolution of the issue on NMP-2 should the licensee elect this method.
Robert Stevens Instrumentation 5 Control Systems Branch Division of Systems 5 Engineering Technology cc:
L.- Shao D. Neighbors R. Capra M. Haughey ICSB Member~
A. Thadani,.
C QD)ST
'IC T
vers:bl auck 2/ig/88 W//g /88 IC EST S
wberry
/+f88 DISTRIBUTION:
Central Files ICSB RF R. Stevens
S
GENERAl O'LECTRIC Qgg/h SHERRY SQSINCSS OPERATIONS QENLKAL~ClNL'. (,0Whtvf ~ 175
< tJRTNER AVENUE~ SAN JOSE, CAUFORNIR '>5'R5 M/C 682, Ph.
(408) 925-5040 GBS-045-087 NFN-052-087 July ". 1987 U. S. Nuclear Regulatory Commission Division of Engineering and Systems Technology Washington, D.
C.
20555 Attention:
hshok C. Thadani Assistant Director for Systems GenE.leman:
SUBJECT!
GE WHITE PAPER ON QUALITY OF PARTS IN ShPEiY RELATED ASSE'.fBLIES This letter responds to your request that GE document in a "white paper" the information conveyed to you and your staff on the quality of parts contained in safety related assemblies.
Attached is the white paper covering this sub)ect. lt is also being provided to all domestic BWR utili ies.
The cover letter to the utilities also identifies that spare and replaceIIIent parts will have to be individually certified in order to be used in a safety related application.
I hope that the above information responds to your request.
Since ly, R. hrtigas, Manager Licensing 5 Consulting Services Rh/dc cc:
L. S. Gifford D.
G. Tibbils D. H. Furgeson (GE-Bethesda)
~
OP
NAMTT kEIATED PARTS General Electric is frequently asked abaut the quality of the parts used ir.
safcty-related'asscmblios produced by CE.
There has been raised a con"em that General Electric considered that such pazts vere non.safety-related are'.,
as such, that they might bb less than adequate ta perform the nocessarv se'eay furct'ons.
This is not the case.
GE is committed to providing the highest lovel quality product.
As such, GE hes a rigorous QA program that assures parts and assemblies supplied by GE moot ail applicable requirements, botl:
design and regulatory, for safety-related equipment.
Many of the componert parts (seals, bolts, certain valves, resistors, capacitors,
- diodes, fuses,
- meters, svitchcs, recorders, e"c.) of mast, if not a)1, safety-related equipment are not initially procured as nuclear safety-related parts.
This is duo to the necessary, and appropriate, practice of designkng safety-related equipment to utilixc standard industria'-grade (presently designated "commercial-grade" by lOGFR21) parts gererally because safety-rclatod versions of such piece parts aro simply nat availablo.
The NRC in both Appendix B to 10UFK50 (thc "l8 QA criteria") and in 1CCFR21 recognized this situation and provided the moasuzos necessary to assure the quality and required performance af the safety-related equipment.
ht GE such measured'ere implemented through the folloving steps; l.
An NR" approved Quality Assurance (QA) plan (NEDO 11209) and the supporting and implementing procedures was generated which meet 10CFR50 Appendix B.
2.
The requirements for tho parts. were developed and documerted ss part of the engineering design process of the equi.pmont.
These requirements vere independently veri="ied and, once established, werc sub)ect to a rigorous change control program, 4,
Thc parte vere purchased to the documented engineering requirements, plus appropriate QA requirements defined during the QA review.
The parts were inspected to the engineering requirements upon receipt, and tested as required to establish their conformance to the applicsblc requirements.
5
~
Thc parts were installed in safety-related assemblics
~ e.g., panels, using approved and controlled processes, and wczo sub)ect to various documented QA inspectians and tests.
6.
Prior to release fnr shipment, the safety-related assemblies vere sub)ected to speci ied factory performance tests.
7.
In addition, engineering performed the required qual'fication af the various safety-related assemblics, either by test or combined test end
- analysis, and docuraentcd the results.
Such qualification vas in accordance vith al applicable requirements between GE and the individual purchasing utility.
8.
Throughout the above process the QA program generated
- records, inspection reports for defective or nonconforming materials and corrective actions as required, in accordance with applicable QA procedures.
r<<
~
r
~
~
~
The result of the above process was the conversion of industrial-grade parts (or "dedication of "commercial-grade" items) to safety-related components as applied in the safety-related assemblies.
For example, this would result in non-Class 1E electrical components being converted to Class 1E for their application in the safety related assembly.
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION WASHINGTON, D. C. 20555 October 5, l987" Docket No. 99900403/87-02 General Electric Company Nuclear Energy Business Operations ATTN:
Mr.
N. L. Felmus, Yice President and General Manager 175 Cul.tner Avenue San Jose, California 95125 Gentlemen:
This letter addresses the inspection of your facility at San Jose, California, conducted by Mr. R.
P. McIntyre and J. J. Petrosino of this office on July 20-31,
- 1987, and the discussions of their findings with Mr. J. J.
Fox and other members of your staff at the conclusion of the inspection.
The inspection was conducted to determine if comercial grade component parts which are part of the panels which make up the control room power generation control complex (PGCC) at Nine Mile Point 2 (NMP-2), were procured and dedicated for use in these safety-related assemblies as described by a GE "white paper" submitted-to the NRC on July 2, 1987.
Areas examined during the NRC inspection and the inspection findings are discussed in the enclosed report.
Within these
- areas, the inspection consisted of an examination of procedures and representative
- records, interviews with personnel, and observations by the inspector.
During this inspection it was found that the implementation of your gA program for activities described in the white paper could not be fully determined.
For the sample of components chosen by the inspectors for review, sufficient documentation was not available during the inspection to reach a
conclusion regarding the adequacy of implementation of the GE quality assurance program in the area of commercial grade procurement.
Therefore, this issue will be classified as unresolved at this time and will be reviewed further during subsequent NRC inspections.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
October 5I 1987 General Electric Company Should you have any questions concerning this inspection, we wi 11 be pleased to discuss them with you.
Sincerely,
Enclosure:
Inspection Report No. 99900403/87-02 Ellis W. Merschoff, ief Vendor Inspection anch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation cc:
Niagara Mohawk Power Corporation ATTN:
B. J. Hooten, Executive Director Nuclear Operations 300 Erie Boulevard West
- Syracuse, New York 13202 General Electric Company Nuclear Eneroy Business Operations ATTN:
R. Artigas, Manager Licensing 175 Curtner Avenue San Jose, California 95125
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