ML18041A158
| ML18041A158 | |
| Person / Time | |
|---|---|
| Issue date: | 09/24/1987 |
| From: | Mcintyre R, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18041A157 | List: |
| References | |
| REF-QA-99900403 NUDOCS 8710070224 | |
| Download: ML18041A158 (30) | |
Text
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 providing 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 U
is
- otapovs, C se en nspection rane a e INSPECTION BASES AND SCOPE'.
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 BI4R Facilities.
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ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION A.
VIOLATIONS:
None.
B.
NONCONFORMANCES:
None.
C.
UNRESOLVED ITEMS:
l.
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 comnercial 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.
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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, 1967 to discuss possible generic implica-tions of the RPS non-1E component issue, GE stated that these isolation components were infact Class 1E.
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 BWR 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 comoercial 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 Dedication 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
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ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT I
~
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;
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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 ljuality 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.
hyphen 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 comaercial 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 conmercial 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,
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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 the 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 alj 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
~Setem HPCS NSSS RCIC HPCS HPCS RCIC RCIC HPCS HPCS NSSS PPD ¹ 249A1471 176A1572 159C4540 163C1170 214A1471 157C4570 163C1392 145C3039 DA317A6159 DA317A7898 Panel ¹ H13-P852 H13-P 609/61 H13-P601 H22-P028 H13-P852 H13-P 601 H13-P014 H22-P028 H22-P028 H13-P 609
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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 I&C 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 QA 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 QA 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, QAES, GE-NSQA
- James J.
Fox, Senior Program Manager, GE-QA
- Roger K. Waldman, Principal Engineer
- George B. Stramback, Safety Evaluation Program Manager, GE-Licensing and Control Services
- Louis D. Test, Consulting Engineer, GE-QA
+Joseph M. Case, QA System,
- Manager, GE-QA
- Norman E. Barclay, Principal Engineer GE-NSQA E. Wester, Principal Project Engineer
- H. R. Peffer, Project Manager, Nine Mile Point
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ORGANIZATION:
GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION
- R. Artigas, Manager, LKCS
- Noel Shirley, Sr. Licensing Engineer
- L. S. Bohl, Manager, gA/NSTO
- B. A. Smith, Counsel
- R. L. Fisher, Principal Engineer, Material Services
- Harry L. Shannon, Manager, Test Engineering
- H. C. Pfefferlen, HGR BWR Licensing Issues "Attended exit meeting.
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USE SAFETY GRADE (1E)
COMPONENTS OR PROVIDE ISOLATION FROM NON-lE COMPONENTS OR ANALYZE ACCEPTABILITY OF NON-lE, NON-ISOLATED COMPONENTS 0 uk4isb
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ALY I R
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E DOCKET SUBMITTAL NOT REQUIRED BY NRC DETAILED ANALYSES NOT REQUIRED BY REGULATION PRE R.6.1.75 ANALYSIS APPROACH RANGED FROM DETAILED CALCS TO ENGINEERING JUDGEMENT PLANTS LICENSED MITH NRC UNDERSTANDING OF APPROACH REYIEW TO DATE HAS SHOWN ACCEPTABLE DESIGN NO SAFETY PROBLEM IDENTIFIED
RRE LY NRC REQUIRES DESIGN ADEQUACY ASSURANCE FOR IEEE279(71)
PLANTS ME TI BWR'ITH EEE2 1
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GRAND GULF
- PERRY
- CLINTON
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- LIMERICK 152 BRUNSWICK 1L2 HANFORD 2 HOPE CREEK X DUANE ARNOLD SALLE 152 SUSQUEHANNA 152 HATCH 2 SHOREHAM FERMI
- PARTIALLY OR FULLY COMMITTED TO R.G.1.75
E
E E T 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-1E, NON-ISOLATED CIRCUITS ON NMP2 (4/7/88)
PLAt ED ASSESS UPGRADED NMP2 CIRCUITS
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<<~J wr ALL ASSOCIATED COMPONENTS ADDRESSED FOR NMP2
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ED TI ASSESS R.G.1. 75 PLANTS ASSOCIATED COMPONENTS ASSESSED FOR BMR/6's 8
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 tc ASSESS UPGRADED CIRCUITS FOR NMP-2 ~ ~+ +a CG Al
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0 CONFIRM FMEA 0
RESEARCH TEST DATA IfcJ(g~
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TABULATE REFERENCES COMPARE ASSOCIATED CIRCUITS FOR ALL IEEE-279-1971 BWR'S TO NMP-2 0
REVIEW AT SYSTEM LEVEL 0
COMPARE ELEMENTARY CONFIGURATION 0
PRIMARY REVIEW BASIS 0
USE
AS NECESSARY 0
USE PREVIOUS WORK 0
1981 SIMILARITY REVIEW 0
RELATED ANALYSES (FHEA, DAL-17)
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0 IDENTIFY DIFFERENCES FROM NMP-2 DESIGN 0
ASSESS AND RECONCILE DIFFERENCES 0
CIRCUITS 0
COMPONENTS 0
SUMMARIZE RESULTS. (GE LETTER TO NRC)
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