ML19318A768
| ML19318A768 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/1980 |
| From: | Donna Anderson, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318A752 | List: |
| References | |
| REF-QA-99900403 99900403-80-2, NUDOCS 8006240126 | |
| Download: ML19318A768 (29) | |
Text
.
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900403/80-02 Program No. 51100 Company:
General Electric Company Nuclear Energy Business Group 175 Curtner Avenue San Jose, California 95125 Inspection at:
San Jose, California Inspection Conducted: March 31-April 11, 1980 Inspectors:
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. Costello, Principal Inspector Date dor Inspection Branch (w
L/R 5+rco D. G. Qd rson, Principal falpector Date Vendor Inspection Branch 0fN C/1/ 9 c s
W. E. Foster, Contractor Inspector Date Vendor Inspection Branch Approved by:
~
C. J.df de, Chief Date 3
Program Evaluation Section Vendor Inspection Branch Summary Inspection on March 31-April 11,1980 (99900403/80-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, and Topical Report NEDO-11209-04A in the areas of Procurement Source Selection and Product Verification, Procurement Control, 10 CFR Part 21 compliance, Follow-up on previous inspection findings, and follow-up on Regional requests.
The inspection involved one hundred thir"-two (132) inspector hours on site by three (3) NRC inspectors.
8006240l7 4
General Electric Company Results:
In the five (5) areas inspected four (4) deviations and two (2) unresolved items were identified.
Deviations:
Follow-up on previous inspection findings - Contrary to procedural requirements, the sample size and lot size had not been recorded in the In-Process Inspection log for numerous cables (See Notice of Deviation Enclosure, Item A).
Follow-up on Regional Requests - Contrary to procedural requirements, summaries and data sheets had not been submitted weekly (See Notice of Deviation Enclosure Item B).
Procurement Control - Contrary to procedural requirements, purchase order revisions to PO No. 282-KR083 did not contain information indicating that safety-related items were involved also the Quality Control Workmanship Standards Manual identified on Material Request No. AL421 was omitted from PO No. 282-KR083 (See Notice of Deviation Enclosure, Item C); and contrary to procedural requirements, Audit Report No. 79T-381 did not indicate that the Quality Assurance Manual had been evaluated for a description on how suppliers are selected and qualified; also this audit report indicated that test control was not applicable, but the supplier does perform tests (See Notice of Deviation Enclosure, Item D).
Unresolved Items: Follow-up on Regional Requests - The NRC inspector was unable
- o determine what was required to document the evaluation that damaged wiring in Control Room Inserts Nos. 72C and 73C represented a nonreportable condition (See DetailsSection III, paragraph D.3.b).
It was not apparent tc the NRC inspector during the review of available documentation supporting 10 CFR 21 evaluations that six (6) items identified as Potentiably Reportable Conditions should not have been reported to the Commission (See DetailsSection II, paragraph B.4).
! DETAILS SECTION I (Prepared by J. R. Costello) l A.
Persons Contacted
- J. Barnard, Manager, Product and Quality Assurance Operation B. J. Beach, Quality Control Engineer R. J. Bogisich, Manager, Retrofit Programs
- A. Breed, Manager, Quality Assurance P&QA0 C. L. Buckner, Specialist, Quality System Engineered Equipment K. I. Curry, Specialist, Quality Notification and Audits
- W. H. D'Ardenne, Manager, Safety Evaluation Programs M. P. DeSai, Principal Quality Control Engineer K. D. Jakabcin, Principal Quality Control Engineer D. E. Lee, Manager, Quality Control F. M. Monez, Principal Engineer
- J. K. Powledge, Manager, Quality Assurance Engineered Equipment and Installation
- L. V. Stonebraker, Specialist, Quality Assurance Nuclear Service Department R. J. Valencia, Audit Coordinator
- Denotes those present at exit meeting.
B.
Follow-up on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 79-02): Marvin Engineering Company was being used as a safety Category I supplier without being evaluated as a supplier of such items.
This matter pertained to Millstone Improved Interference Fit Feedwater Spargers ordered by Northeast Utilities to meet Category I requirements.
GE has proposed by letter to Mr. Starr of Northeast Utilities dated March 18, 1980, that the spargers be rejected as not meeting the requirements of NUSCO P.O. 604093 and a mutually agreed upon review and rework program be implemented to reconcile the hardware and associated documentation with the initial requirements. Northeast Utilities has indicated verbal approval with this proposal.
2.
(Closed) Unresolved Item (Report No. 79-02): Even though GE does not consider the steam dryer a basic component essential to safety, it appears that certain failure modes of the steam dryer could adversely affect other basic components that are clearly essential to safety.
In NRC Memorandum dated September 26, 1979, from Frank Schroeder to Harold D. Thornburg concerning Quality Group Classifica-i tion and Seismic Classification of Boiling Water Reactor Plant Internals, the NRC has taken the position that steam dryers are not i
I
,, L
c
. in themselves Category I components, but should be so constructed such that their failure would not adversely affect the functioning of the Seismic Category I components within the reactor vessel.
3.
(Closed) Unresolved Item (Report No. 79-02):
GE has classified the feedwater spargers and thermal sleeves as nonessential to safety.
This does not appear to be the proper quality classification.
In NRC Memorandum dated September 26, 1979, from Frank Schroeder to Harold D. Thornburg concerning Quality Group Classification and Seismic Classification of Boiling Water Reactor Plant Internals, the NRC has taken the position that feedwater spargers and thermal sleeves are not Category I components, but should be so constructed such that their failure would not adversely affect the functioning of the Seismic Category I components within the reactor vessel; however, this position continues to be evaluated by NRR relative to these components.
4.
(Closed) Deviation (Report No. 79-03):
Contrary to procedural s
requirements, four (4) pages from document binders (supplier QA records) examined had not been signed or stamped and dated by GE-l QC Representative.
The records were validated and have been reviewed by the GE QC Records Specialists and found acceptable. From a sampling of other records, GE has concluded that this deviation was an isolated event. To prevent recurrence a letter was issued December 28, 1979, to all QC Representatives and Record Spec alists reminding them of the obligation to sign or stamp and date all QA records and for vigorous adherence to this requirement.
5.
(Closed) Deviation (Report No. 79-03):
Contrary to procedural requirements, two (2) Design Record Files (DRFs) examined had not been submitted for generation of retention copies. The two (2)
Design Record Files were microfilmed as of February 1,1980.
To preclude recurrence, a formal plan has been established to schedule and track all DRFs.
Prior to this deviation DRFs were not being scheduled.
6.
(Closed) Deviation (Report No. 79-03):
Contrary to procedural requirements, the Master Parts List for Clinton 1 & 2 did not include the supplementary data sheets to Revision 5 of the Product Safety Standards.
Revision-5 without the data sheets was not correct so change notice NH06239 was issued December 3, 1979 to change the Master Parts List back to Revision 4 which has the data sheets.
Engineering
-Quality Control has investigated the problem and concludes that this deviation was an isolated event. To preclude recurrence, the responsible engineer has been instructed in the proper procedural approach.
7.
(Closed) Unresolved Item (Report No. 79-03):
It is not apparent that copies of procedure manuals are being properly maintained.
a '
This pertained to a " Lending Library" copy of an E0P Manual containing a superseded table of contents.
The " Lending Library" copies of procedure manuals are not updated while on loan.
The superseded table of contents was current when the procedure manual was loaned.
A sampling of other working copies of procedure manuals did not show any superseded documents.
C.
Procurement Source Selection and Product Verification 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented that provide for:
Requirements for evaluation of the potential supplier's capability a.
to provide items or services in accordance with the technical and quality assurance specifications of the procurement document.
b.
Performance of source evaluation audits that include appropriate checklists or instructions of systematic review of the prospective supplier's QA system.
Periodic re-evaluation of suppliers and that an up-to-date listing c.
of the evaluation status is being maintained.
d.
Distribution of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to companies designated in these documents.
The planning of verification activities including identification e.
of the inspection sequence, hold and witness points, acceptance criteria, documentation required by the procurement document and receiving inspection plans.
s f.
Implementing source surveillance including activities at supplier's facilities (i.e. inspections, audits) and receiving inspection dispositioning (i.e. accept, reject, hold).
g.
Reporting results of source surveillance activities and evaluation of reports.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
Applicable portions of GE Topical Report NEDO-11209-04A which a.
established QA Program commitments.
e
. b.
Implementing procedures to assure that procedural controls had been provided to satisfy QA Program commitments and to satisfy items (a) through (g) of the Objectives section above:
(1) BWR Engineering Operating Procedures E0P 20-3.20, Engineered Equipment Procurement Operation Function E0P 45-1.00, Introduction Procurement E0P 45-3.00, Supplier Bid Review, Evaluation and Qualification E0P 45-3.10, Procured Equipment Surveillance Plan E0P 65-2.10, Safety Importance Classifications (2) Quality Assurance Engineered Equipment and Installation Procedures:
QCSI 7.20, Quality System Description For Engineered Equipment and Installation QCSI 7.25, Final Inspection Product Release & Certification QCSI 7.2.7, Review of Supplier QA Manuals QCSI 7.2.12, Pre-Award Evaluation of Vendors EEPP&P 3.04, Established and Potential Supplier List QCSI 7.2.13, Review of Bidder Technical Proposals (BIDS)
QCSI 7.2.17, Supplier Quality System Audits, Records and Corrective Action d
QCSI 7.2.18, Quality Requirements On Material Requests and Purchase Orders QAR I, Quality Assurance Requirements (3) BWR Quality Assurance Manual Procedures (EEP&I) 4.4, Procurement Document Control 4.7, Control of Purchased Material, Equipment, and Services l
l
. 4.9, Control of Special Processes 4.10, Inspection Documents to verify implementation of topical commitments and c.
procedural requirements and to satisfy the intent of items (a) through (g) of the Objectives section above.
These documents are as follows:
(1) Established & Potential Supplier List For Engineered Equipment Procurement dated December 31, 1979.
(2) Quality Assurance System Audit of Marvin Engineering Company, In ilwood, California on March 24-26, 1980.
o (3) Quality Assurance System Audit of Western Piping and Engineering Co., San Francisco, California on March 27-29, 1980.
(4) Quality Assurance System Audit of Sun Shipbuilding and Dry Dock Company, Chester, PA. on March 26-28, 1980.
(5) Quality Assurance System Audit of Bingham-Williamette, Portland, Oregon on March 4-6, 1980.
(6) Purchase Ordcr No. AJ530 to Fisher Controls Company for 20 and 24 inch recirculation flow control retrofit kit.
(a) Material Request No. AJ530 for the above.
(b) QAEE&I Quality Reviews for PO No. AJ530.
(c) Quality Records List QRL No. 151AA for the above.
(d) QAEE&I Notification List NL No. 229 for the ebove.
(e) Equipment Surveillance Parameters for the above.
(f) Surveillance Report for visit on March 22-23, 1977.
(7) Quality Assurance System Audits of Fisher Controls.
(8) Surveillance Report on visit to Atlas Foundry & Machinery Company Tacoma Washington on November 2, 1979. This was a subcontractor of Fisher Controls Company.
(9) Quality Assurance Supplier Review Status Report dated March 7, 1980.
. (10)
Quality Assurance Purchase Order Log of GE Nuclear Energy Division dated March 18, 1980.
(11)
Purchase Order No. AH249 to Temp-Flex, Division of Associated Piping & Engineering, Compton, California for bellows fuel-transfer system.
(a) Material Request No. AH249 for the above.
(b) QAEEiI Quality Reviews for the above.
(c) Notification List NL 160 for the above.
(d) Quality Records List QRL No. 200 for the above.
(12)
Quality Survey of Temp-Flex Expansion Joints, Division of Associated Piping & Engineering, Compton, California dated November 22, 1977.
(13)
Purchase Order No. AJ412 to General Electric Company, San Francisco, California for HPCS metal enclosed switchgear.
(a) Material Request No. AJ412 for the above.
(b) QAEE&I Quality Reviews for the above.
(c) Notification List NL 137 for the above.
(14)
Purchase Order No. 205-AG402 to Byron Jackson Pump Division, Borg Warner Corporation, Los Angeles', California for ECCS and Recirculation Pumps.
(a) Material Request No. AG082 for the above.
(b) QAEE&I Quality Reviews for the above.
(c) Notification List NL 204 for the above.
(d) Quality Records List QRL 169 for the above.
(e) Audit Report dated July 24, 1979 for audit performed on July 10-12, 1979.
(f) Eight (8) Surveillance Reports dating from February 2, 1980 to March 27, 1980.
I
_g.
(15)
Purchase Order No. 205-AL 410 to Murdock Inc., Compton, California for recirculation pump restraints.
(a) Material Request No. AL 410 for the above.
(b) QAEE&I Quality Reviews for the above.
(c) Notification List NL 309 for the above.
(d) Audit Report for audit conducted March 5-7, 1980.
(16)
Vendor Approval Status February 18, 1976, for Murdock Inc.,
Compton, California for core spray nozzle safe ends and thermal sleeves.
(17)
Vendor Approval Status December 20, 1979, for Gould Manufacturing & Engineering Corporation, Santa Clara, California to manufacture top guide hold down clamps.
(18)
Vendor Survey of Gould Manufacturing & Engineering Corporation for qualification to QARI to fabricate jet pump nozzle plugs May 5, 1977.
(19)
Audit Report Gould Engineering & Manufacturing Corporation dated May 5, 1978, for audit conducted February 12-14, 1980.
(20)
Purchase Order No. 205-AF 489 to Joseph Oats & Company Camden, New Jersey for residual heat removal (RER) heat exchanger.
(21)
Vendor Approval Status for Joseph Oats & Company for heat exchangers (RHR and fuel pool ) July 14, 1976.
(22)
Quality Assurance System Audit of Joseph Oats & Company Audit conducted May 9-11, 1979.
(23)
Purchase Order No. AK 925 to Dravo Corporation Marietta, Ohio for safety relief valve T-Quenchers.
(a) Material Request No. AK 925 for the above.
(b) QAEE&I Quality Reviews for the above.
(c) Audit Report dated March 4, 1980 for audit conducted February 26-28, 1980, for the above.
(d) Product Quality Cert'.tication for six (6) pieces dated February 28,.980, for the above purchase order.
. (24)
Vendor Approval Status for Dravo Corporation to manufacture safety relief valve T-Quenchers February 14, 1979.
(25)
Purchase Order No. 205-AJ470 to Anchor Darling Valve Company, Williamsport, PA for 22 -24 inch suction recirculation gate valves.
(a) Anchor Darling V:1ve Co. was qualified prior to October 1972 therefore, did not follow any of present qualification procedures.
(b) Quality Assurance System Audit March 25-27, 1980.
3.
Findinas a.
Deviation From Commitments None b.
Unresolved Items i
None c.
Follow-up Item t
The Quality Assurance Audit Report for the Audit conducted at Dravo Corporation, Marietta, Ohio on Februa ry 26-28, 1980, did not follow the requirements of GE implementing procedures. This appears to be
{
an isolated case and all the required information was i
in the report. This matter will be further investi-
]
gated during the next NRC inspection.
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D.
Exit Meetina A, meeting was conducted with management representatives at the conclusion of the inspection on April 11, 1980.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance were:
R. C. Boesser, Manager Technical & Administrative P ogram, Projects Division R. E. Dingleton, Senior Quality Control Engineer D. H. Ferguson, Manager C&ID Quality Assurance D. L. Fischer, Manager Core Nuclear Design A. I. Kaznoff, Manager Product Assurance The inspector summarized the scope and findings of the inspection for those present at the meeting. Management representatives acknowledged the statements of the inspector.
. DETAILS SECTION II (Prepared by D. G. Anderson)
A.
Persons Contacted R. Artigas, Senior Program Manager H. Chang, Engineer
- W. H. D'Ardenne, Manager, Safety Evaluation Programs J. D. Duncan, Program Manager
- D. E. Lee, Manager, Quality Control R. B. Linford, Senior Program Manager J. H. Oates, Manager, Plant Systems and Structural Analysis C. D. Sawyer,- Manager, NSSS Performance Engineering G. G. Sherwood, Manager, Nuclear Safety and Licensing C. H. Stoll, Technical Leader
- J. E. Wood, Manager, Core Methods and Analysis
- Indicates attendance at the exit meeting.
B.
Compliance With 10 CFR Part 21 1.
Inspectior Objectives To determine whether General Electric and s.ppropriate responsible officers had established and implemented procedures and other instruc-tions as required to ensure compliance with 10 CFR Part 21 requirements relative to the reporting of defects and noncompliance with 10 CFR Part 21 as clarified by USNRC positions in NUREG-0302, Revision 1.
2.
Availability and Status of Adopted Procedures and Other Instructions Summary of Items Subject to Inspection Each organization, such as General Electric, that performs " design" which involves basic components as defined under 10 CFR Part 21 is subject to its regulations.
General Electric is also a firm supply-ing components to a facility regulated pursuant to the Atomic Energy Act of 1954, as amended, or the Energy Reorganization Act of 1974.
General Electric and its responsible officer must therefore ensure compliance with the requirements 10 CFR Part 21 as specified in Section 21.6 for posting, 21.21(a) for procedures, 21.21(b) for notification and written reports to the commission, 21.31 for inclu-sion of appropriate references in procurement documents, and 21.51 for preparation and maintenance of records, sufficient to assure compliance with regulations under Part 21.
, As a means to ensure compliance with 21.21(a) regulations, General Electric must establish procedures tu provide for the evaluation of deviations not already corrected in all basic components to which it is applicable when knowledge of the deviation is received (QA-22 under NUREG 0302, Revision 1 on page 21.21(a)-9), or informing purchasers of the deviation, so the purchaser may evaluate the deviation.
These procedures must also provide for informing a responsible officer with-in General Electric of any resulting conclusion of a defect or fail-ure to comply.
To ensure compliance with regulations under:
21.6, 21.21(b), 21.41, and 21.51, General Electric may adopt appropriate controls in the form of procedures or other instructions, as necessary, to ensure that the stated regulatory requirements will be implemented as appropriate.
3.
Method of Accomplishment The preceding objective was accomplished by an examination of:
i Procedure NEBG 70-42, Reporting Defects and Noncompliance, a.
11/22/78.
Procedure E0P 65-4.00, Potentially Reportable Conditions, 12/15/77.
Procedure E0P 42-10.00, Design Record Files, 11/13/78.
f b.
Copies of 10 CFR Part 21 that were posted on bulletin boards at entrances to Building 1850 and 1900.
Employee Bulletin No. 5, 10 CFR Part 21, 1/29/80, was transmitted to all engineering personnel in the Nuclear Energy Business Group (NEBG).
Documentation related to the identification, evaluation, and c.
determination of the reportability of eleven (11) items from the Potentially Reportable Conditions (PRC) file were reviewed by the inspector.
4.
Findings In this area of the inspection no deviatiota from commitment were identified.
The following unresolved item was identified:
During the review of the PRC file, the inspector identified six (6) items, which had been determined to be not reportable by General Electric, but for which insufficient information was included in the files to allow the inspector to make the same determination.
. GE personnel stated the necessary information was available in files at a different location.
GE will accumulate this documentation for review by the inspector during the next inspection.
C.
Follow-up On Regional Requests In this area of the inspection, three (3) regional requests related to items identified as either 10 CFR 50.55(e) or 10 CFR 50, Appendix K reportable events and applicable to General Electric were reviewed and evaluated by the inspector.
In reviewing these items, the inspector assured that the following objectives were accomplished:
1.
Objectives a.
Determination of how the item was identified.
b.
Assurance that followup actions were conducted under the requirements and procedures of the General Electric Quality Assurance Program.
Determination of the status of corrective action and preventive c.
action to assure that the item is satisfactorily resolved.
d.
Determination of the generic effects on other plants and notifi-cation of the affected utilities.
Determination of the accuracy, applicability, and timeliness e.
of reporting to the USNRC.
2.
Method of Accomplishment The inspector reviewed the following General Electric procedures a.
which establish the requirements that implement the activities related to the identification, evaluation, notification and report-ing of items which are tracked as Potentially Reportable Conditions (PRC):
Procedure E0P 65-4.00, Potentially Reportable Conditions, 12/15/77.
Procedure E0P 42-10.00, Design Record Files, 11/13/78.
Procedure NEBG 70-42, Reporting Defects and Noncompliance, 11/22/78.
b.
The inspector verified the implementation of these procedures to assure that the following deficiencies meet the above noted objectives:
(1) Error in ECCS Analyses for Break Sizes Less Than 0.1 ft This item was identified as a result of NRC request to
. consider the effect of single failure of station batteries in conjunction with loss of offsite power.
The inspector reviewed the following documentation related to this item:
(a) Design Record File E00 52, LPCI Loop Selection Logic which contains:
SCER 154, The recirculation line break detection and LPCI loop selection logic system for 1965 and 1967 BWRs, March 1969.
Unit File 5.1.1, LPCI loop selection logic, consequences of injection into the wrong (broken) recirculation loop, 1/22/78 and 4/6/79.
Probability assessment of a small break accident (SBA) with 125VDC power failure, 11/15/79.
L263 7808 217, Recirculation loop flow mismatch for operating plants, 8/21/78.
Potential Reportable Condition, Loop Selection Logic Limitations, 6/7/79.
G-EH-0-17, Small Recirculation Discharge Break Analysis with a Gas Turbine Failure and LPCI Injec-tion into the Recirculation Loop with the Break, 2/4/80.
Trip Report-LPCI Loop Selection Discussion With BWR Owners, 1/31/80.
Trip Report-REE-007-80, NRC Meeting LPCI Loop Selec-tion Logic, 2/6/80.
Millstone Analysis; Small Discharge Break with Gas Turbine Failure, LPCI Injection into Broken Loop and Isolation Condenser Credit, 3/12/80.
FPF-79-104, LPCI Loop Selection Logic, 7/24/79.
Memoranda as Follows:
1/8/80, ADS Capacity Assumed in Current Licensing Calculations.
1/29/80, Justification for Bounding MAPLHGR Multiplier and PCT Calculation for Small Breaks.
w
. 1/30/80, Verification of Effect of Improper Selection of Broken Loop for LPCI Injection.
2/1/80, LPCI Loop Select Capability.
i
~(b)
Findings:
Since BWRs have two (2) independent recirculation loops, a loop selection logic system is necessary to determine injection point for LPCI to assure that injection is not into the broken loop.
The logic is based upon differential pressure between the two loops.
The logic is effective for large breaks evet though the differential pressure may not be balanced between the two loops, however, for break sizes less than 0.1 ft2, the logic may not be able to determine the broken loop.
In addition, safety related valves on the LPCI are powered by the station DC battery supply during conditions of loss of all offsite power. During events where there is loss of offsite power, loss of coolant i
accident, the failure of one string of the station DC batteries, PCT can exceed 22000F.
General Electric determined on November 1,1979, that this item was t
nonreportable, however, Millstone reported this item l
under the requirements of 10 CFR 50, Appendix K on January 31, 1980.
Millstone has instituted a MAPLHGR derate, however, this item is generic to Quad Cities 1 and 2 and Dresden 2 and 3.
This item was evaluated as PRC 79-22, LPCI Loop Selection Logic Licensing Basis, 2/14/80, which indicated that a small break in conjunction with failure of DC station battery train and flow mismatch in the recirculation loop of greater than 8% could result in PCT greater than 2200 F.
GE 0
determined that to have a 0.04 to 0.1 ft2 break in one recirculation loop coincident with loss of all offsite power and 8% flow mismatch is considered incredible and therefore not reportable under the requirements of 10 CFR 21 or 10 CFR 50, Appendix K, GE indicated that NRR agreed that this event was not an original licens-ing basis and therefore the plants affected do not have to be designed for this circumstance.
The inspector verified this concurrence in a telephone discussion with NRR/RS on April 17, 1980, and in addition NRR/RS indicated that this item is still under evaluation for eight (8) operating plants (BWR's) and will con-tinue until it is resolved.
i (2)
Effect of LOCA Environment on Water Level Instrumentation.
This item was identified as a result of followup on the experiences at TMI.
The inspector reviewed the following documentation related to this item:
.- (a) Design Record File E00-76, BWR Implications of TMI, which contains the following:
SIL-299, High Drywell Temperature Effect on Reactor Vessel Water Level Instrumentation, 7/25/79.
Design Review Report, BWR Water Level Indication Inac-curacies, 4/24/79 through 6/4/79.
LER 2-79-21/1T-0, Peach Bottom 2 and 3, 5/18/79.
BWR 3/4 Steamline Break Analysis, 6/12/79.
Verification Statements:
LHY-79-55, GWM-79-20, LHY 56, MRL-79-15, GWM-79-21, GWM-79-22, and LHY-79-57.
Memoranda:
Verification of Set Points to be Changed-Yarway Level Inaccuracy, 5/30/79.
Raising RCIC Initiation Level Setpoint, 6/5/79.
Water Level Inaccuracies-Suggested Customer Notification, 4/30/79 and 6/5/79.
Potential Reportable Condition 7912, Water Level Indi-cation Inaccuracies, 4/7/79 through 6/21/79.
(b) Findings:
A LOCA resulting from a steamline break inside of the drywell causes a subsequent rise in drywell temp-erature. The resulting heatup of the level instru-mentation reference water column could cause the level trip function to be precluded.
The ADS actuation is dependent on coincident high drywell pressure and low level. This item was determined to be generic to the following plants:
Browns Ferry 1, 2, 3; Peachbottom 2, 3; Fitzpatrick; Shoreham; Cooper; Hatch 1, 2; Brunswick 1, 2; Duane Arnold; Vermont Yankee; Quad Cities 1, 2; Monticello; Millstone; Dresden 2, 3; Nine Mile Point 1; Oyster Creek; and Pilgrim.
Current corrective action is to reset Level 1 trip points.
(3) Main Steam Pipe Spool Wall Thickness Discrepancy.
This item was identified by a Bechtel engineer at Hope Creek 1 and 2 and reported to General Electric as a Field Deviation Disposition Request (KT-1-011) on January 17, 1980.
The inspector reviewed the following documentation related to this item:
17-(a) Nonconformance Report, Primary Steam Pipe Spool, 6/11/79.
GE Drawing 761E468, PS-1-C2.
P.O. #10855-M-001, NSSS/MS Pipe Minimum Wall Thickness (MWT).
Transmittals:
BLG-1093, Bechtel to General Electric, Minimum Wall Thickness, 1/21/80.
GB-80-70, General Electric to Bechtel, Wall Thickness Calculation, 3/3/80.
(b) Findings:
This item relates to interpretation of the ASME code equations for the calculation of minimum wall thick-ness. NB-3641.1, equation (1) requires that the out-side diameter of pipe be used to calculate the mini-mum wall thickness.
Pipe is not perfectly round and if the largest measured diameter is used to calculate MWT, instead of an average between maximum and minimum diameters, then a larger wall thickness is required.
The difference in question in this particular case is i
1.002 inches instead of 1.013 even when using the max-imum outside measured diameter. The inspector considers this item to not be safety significant nor generic to other plants. Even so, General Electric has provided a weld build up in the affected area.
3.
General Findings In this area of the inspection, ao deviations from commitment or unresolved items were identified.
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.e-
. DETAILS SECTION III (Prepared by W. E. Foster) i A.
Persons Contacted J. B. Allison, Engineer - Quality Control M. P. Aschoff, Engineer - Quality Control I. Bhandal, Supervisor - Process Control Engineering D. C. Brown, Engineer - Principal Quality Assurance j
F. C. Cannizzaro, Specialist - Procedures and Audits R. J. Casey, Engineer - Senior Quality Control j
- D. H. Currie, Manager - Quality Systems, Audits and Records
- W. H. D'Ardenne, Manager - Safety Evaluation Programs L. M. Downes, Manager - Customer Liaison E. M. Duke, Engineer - Senior Quality Control C. S. Eason, Manager - Farm-out Procurement Quality Assurance B. F. Fleischman, Manager - Quality Control, Electrical Products M. H. Flemming, Techrical Leader - Quality Assurance Training B. P. Grim, Manager. Reactor Instrumentation and Protection Design G. Jendrzejczak, Te..eman - Cable Shop
- F. MacLean, Project Manager, Hanford J. W. Millard, Project Manager - Susquehanna G. h. Minden, Senior Engineer - Engineering Programs C. E. Morris, Senior Project Engineer R. E. Pingleton, Engineer - Senior Quality K. Rabb, Engineer - Senior Application T. R. Regenie, Senior Engineer - Safety and Standards P. J. Ryan, Sr., Engineer - Manufacturing D. C. Taylor, Specialist - Quality Assurance Training L. D. Test, Principal Engineer
- Attend.ed Exit Meeting.
B.
Follow-up on Previous Inspection Findings / Deviations 1.
Objectives The objectives of this area of the inspection were to verify that the vendor had - taken the corrective actions and preventive measures stated in their correspondence to IE regarding identified deviations.
. 2.
Methods of Accomplishment The preceding objectives were accomplished by:
Reviewing Quality Plan No. 30.120, Revision 5, Approval Date of a.
March 31, 1980, to verify it included a requirement for shop travelers.
b.
Reviewing Quality Assurance Notice No. 80N-009, Revision 0, dated March 28, 1980, to verify a checklist had been developed for use by Procurement Quality Assurance Representatives at supplier facilitica.
Reviewing changes that occurred at Revision 14 of Inspection c.
Instruction No. CA-002 to verify that torque requirements had been addressed.
d.
Reviewing Section 9 of the PGCC Cable Assembly Instruction Manual to verify inclusion of a torque tolerance table.
i Reviewing Quality Assurance Notice No. 79N-011, Revision 0, e.
dated October 5,1979, to verify that it clarified QC Hold Points identified on cable work orders.
f.
Reviewing training records to verify that training had been conducted on Inspection Reports.
g.
Reviewing Quality Assurance Procedure No. 2.5, Revision 1, dated January 24, 1980, to verify that Manufacturing Procedure No. 3.15 had been deleted.
3.
Findings
(. Closed) Deviation (Inspection Report No. 79-03):
The a.
inspector verified that Quality Plan No. 30.120 had been revised to require shop travelers and Quality Assurance Notice No. 80N-009 required use of a detailed checklist at supplier facilities.
b.
(Closed) Deviation (Inspection Report No. 79-03):
The inspector verified that Inspection Instruction No. CA-002 and Section 9 of the PGCC Cable Assembly Instruction Manual had been revised to address torque requirements and specify torque tolerances, respectively.
(Closed) Deviation (Inspection Report No. 79-03):
The c.
inspector verified that QC Hold Points identified on cable work orders had been clarified.
. d.
(Closed) Deviation (Inspection Report No. 79-03):
The inspector verified that Quality Assurance personnel had attended a training session on Inspection Reports.
(Closed) Deviation (Inspection Report No. 79-03):
The e.
inspector verified that Revision No. 1 of Quality Assurance Procedure No. 2.5 deleted Manufacturing Procedure No. 3.15.
C.
Follow-up on Previous Inspection Findings (Unresolved and Follow-up Items) 1.
Objectives The objectives of this area of the inspection were to follow-up on unresolved and follow-up items identified.
2.
lkthods of Accomplishment The preceding objectives were accomplished by:
a.
Reviewing Inspection Instruction No. CA-002, Revision 15, dated January 25, 1980, to determine whether or not in-process inspection of cable assembly had been clarified regarding sample / lot size and frequency of inspection.
b.
Reviewing inspection Instruction No. CA-002, Revision 15, 4
dated January 25, 1980, to verify a requirement had been established to protect connectors of completed cables against contaminants.
Observing completed cables in stores to verify the connectors c.
had been protected to exclude contaminants.
d.
Reviewing Manufacturing Standard Practice, Revision 1, dated October 4, 1979, to verify a requirement had been established to identify the appropriate operation of the Traveler with the revision level of the applicable section of the Cable Assembly Instruction Manual.
Reviewing Traveler Nos. TKLW6, TRDT2, and TRDVI to verify the e.
revision level of the applicable section of the Cable Assembly Instruction Manual had been included at the appropriate
{
operation.
3.
Findings (Closed) Unresolved Item (Inspection Report No. 79-03):
The a.
inspector verified that Revision No. 15 of Inspection Instruction No. CA-002 clarified sample / lot size, frequency of inspection and recording requirements. However, reviewing the records revealed that lot / sample size had not been recorded as required (See Notice of Deviation, Item A).
b.
(Closed) Follow-up Item (Inspection Report No. 79-03):
The inspector verified that (1) a requirement had been established to protect connectors of completed cables against contaminants and connectors were, in fact, protected, and (2) a requirement had been established to identify the appropriate operation of the Traveler with the revision level of the applicable section of the Instruction Manual.
D.
Follow-up of '10 CFR 50.55 (e) Reports 1.
Objectives The objectives of this area of the inspection were to verify that corrective actions and preventive measures had been taken regarding:
Instrumentation for Power Generation Control Complex (PGCC) a.
not to specifications, and b.
Wiring insulation damage in Control Room Inserts 72C and 73C.
2.
Methods of' Accomplishment The preceding objectives were accomplished by:
Reviewing the following unissued documents to determine that a.
corrective actions and preventive measures were in work:
(1) Field Disposition Instructions Nos. WARP and WBIQ, and (2)
Project Work Authorization No. 1556JB.
b.
Reviewing Bechtel's Technical Information For PGCC Panel Mounted Instruments for Mississippi Power and Light Company.
Revision 5, dated April 11, 1977, and its appendices to determine which items were classified as safety-related and which items were not classified as safety-related and the method of classification.
. c.
Reviewing files at Safety and Licensing to determine status of reportable /nonreportable items and assess evaluations of such items.
d.
Reviewing the following documents and their implementation to verify that methods were in place for reporting significant conditions adverse to safety:
(1) Manufacturing Procedure No. 5.08, dated January 31, 1980,
- and, (2) Nuclear Energy Business Group Procedure No. 70-42, Revision 2, dated November 22, 1978.
3.
Findinas The Field Disposition Instructions (FDI) and the Project Work Authorization (PWA) were in the review cycle.
The FDIs will authorize replacement of unqualified devices with qualified devices, while the PWA will authorize testing that is necessary to qualify unqualified devices.
Bechtel's Technical Information identified the following Quality Assurance Requirements (among others) (a) QFI - Must function during and after a safe shutdown earthquake, and (b) QF2.- Must function after, but not necessarily during a safe shutdown earthquake. The docreents contain lists of devices classified as QFI, and QF2 (among others).
Some personnel of the Nuclear Energy Business Group did nat recognize that devices identified as QF2 were also safety-relateJ.
a.
Deviations from Coumitments None b.-
Unresolved Item Damaged wiring in Control Room Inserts Nos. 72C and 73C had been determined to be nonreportable by safety and licensing, as stated in their letter of July 3, 1979, to R. E. Skavdahl entitled - Potentially Reportable Condition 2
(PRC) 79-17.
Paragraph IV.B of Nuclear Energy Business Group Procedure No. 70-42, Revision 2,. dated November 22, 1978, states in part, If the PRC is determined to be nonreportable, the Manager, Safety and Licensing, will document this evaluation for the record and apprise the
. originating Section Manager and the discoverer of these conclusions."
T-'-
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. The NRC inspector was informed that nothing in the file satisfied the requirement of documenting the evaluation for the record. At a later date, the inspector was informed, by a different individual, that the letter apprising the originating Section Manager of the conclusions satisfied the requirement of documenting the evaluation for the record.
As a result of these conflicting views, the NNC inspector was not able to determine what was required to document the evaluation for the record.
More importantly, the file contained no information that could be assessed by the NRC inspector to verify the validity of the decision that the damaged wires represented a nonreportable condition.
c.
Comments Most of the engineering for Mississippi Power and Light Company PGCC instrumentation was completed in 1976.
The hardware was supplied in accordance with Bechtel's Techni-cal Information, Revision 5, dated April 11, 1977.
In October 1979, it was determined that some instrumentation had not been supplie3 as safety-related.
The NRC inspector was not able to determine that efforts had been taken to verify that failure to supply devices of the proper classification had not occurred on other pro-jects or that preventive measures had been taken subsequent to awareness of the problem.
Prior to completion of this inspection, the NRC inspector was provided with a copy of a memorandum which indicated that other projects, over the last ten years, had been i
reviewed and there was no instance where two different
{
classifications had been used for safety-related equipment.
Additionally, a schedule of training, with appropriate personnel assigned to classes, was provided.
Based on this 1
information, no further action is necessary.
l E.
Follow-up of 10 CFR 21 Reports 1.
Objectives The objectives of this area of the inspection were to verify that corrective actions and preventive measures had been taken j
regarding defective crimps in Control Room Instrumentation Panels.
l 2.
Methods of Accomplishment The preceding objectives were accomplished by:
. Reviewing the following documents to verify that adequate a.
corrective actions and preventive measures had been or were being taken:
(1) GE Control and Instrumentation Department Memorandum, dated August 28, 1979, to:
G. G. Sherwood, From:
B. F. Fleischman,
Subject:
Susquehanna I Crimping Problem on Insert P853-72C, (2) Inspection Instruction No. GA-022, Revision 4, dated February 13, 1980, Verification of Crimping Specifications, (3) Manufacturing Standard Practice No. 11.011, Revision 1, dated September 25, 1979 - Verification of crimping.
(4) Manufacturing Standard Practice No. 14.035, Revision 5, dated February 13, 1980 - Pin Assembly for Connectors, (5) Field Disposition Instructions, Nos. -
(a) TNDS, Revision 0, dated October 3, 1979 - Limerick Unit I Equipment Panel Connectors, (b) TRCU, Revision 0, dated October 3, 1979 - Limerick Unit II Equipment Panel Connectors, (c) WJIQ, Revisions 0, 1, and 2, dated October 3, 1979, December 4, 1979, and April 10, 1980, respectively -
Susquehanna Unit I Wire Insert Pins, (d) TCHJ, Revision 0, dated October 3, 1979 - Hanford Unit II Panel Mounted Connectorc, and (e).WAKK, Revisions 0, 1, 2, and 3, dated October 1, 1979, October 31, 1979, December 20, 1979, and April 10, 1980, respectively - Grand Gulf Unit I Panel connectors.
(6)
Inspection Instructions, Nos. -
(a). CA-014, Revision 1, dated October 2, 1979 - Field Connector Pull Test Inspection, (b) CA-013, Revisions 1, and 2, dated December 27, 1979, and April 9, 1980, respectively - Susquehanna Field Pull Test Inspection for Insert /Back Row / Relay Panel Connector Pins, and
. (c)
CA-015, Revisions 0, and 1, dated January 14, 1980, and April 9, 1980, respectively - Field Connector Pull Test Inspection, (7) Traveler Nos. TKNX8, TFVDA, and TGAC8, (8) Records of sample puL1 tests, (9) Training records for personnel engaged in crimping activity, b.
Observation of equipment used for pull tests and Connector and Crimping Display Boards.
3.
Findings Process controls of the crimping operation include pull testing of samples before and after production, in process sampling and veri-fication that the operator has been trained and is qualified to perform crimping operations.
The corrective action and preventive measures taken appear to be adequate.
a.
Deviation from Commitments See Notice of Deviation, Item B.
b.
Unresolved Items None.
F.
Procurement Control 1.
Objectives The objectives of this area of the inspection were to verify that:
Measures had been established to assure that applicable regu-a.
latory requirements, design bases, and other requirements necessary to assure adequate quality had been included or referenced in the documents for procurement of material, equipment, and services. Also, procurement documents required suppliers to provide a quality assurance program consistent with the pertinent provisions of Appendix B to 10 CFR 50,' ANSI N45.2-1971, or an adequate interpretation.
b.
Measures had been established to assure that purchased material, equipment, and services conformed to procurement documents; measures included provisions for, as appropriate, source
. evaluation and selection, objective evidence of quality, source inspection, examination of product upon receipt; and documented evidence showing material and equipment conformance to procurement requirements had been retained.
Also, effective-ness of the control of quality by suppliers had been periodically assessed.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Reviewing the following documents to verify that measures had been established to control procurement activities:
(1) Quality Assurance Procedures, Nos. -
(a) 2.4, Revision 0, dated May 4, 1979 - Procurement Document Control, (b) 4.1, Revision 5, dated March 31, 1978 Procurement Initiation Control, (c) 6.5, Revision 7, dated June 11, 1979 - Preparation of Quality Plans, (d) 6.6, Revision 7, dated June 12, 1979 - Preparation of Inspection Instructions, (e) 6.7, Revision 6, dated January 24, 1980 - Preparation of Test Instructions, (f) 7.5. Revision 10, dated December 28, 1979 - Supplier Audit and Evaluation, (g) 7.6, Revision 7, dated July 18, 1979 - Issuing and Controlling Qualified Suppliers Manual, (h) 7.7, Revision 7 1sted July 11, 1979 - Preparation and Use of Drawing Control Folders, (i) 7.8, Revision 5, dated September 22, 1977 - Receiving Inspection Quality Verification, (j) 7.11,-Revision 2, dated September 13, 1977 - Supplier Software Quality Verification, (k) 7.16, Revision 1, dated April 5, 1979 - Review of Supplier Submittals, and
. (1) 18.10, Revision 3, dated March 11, 1980 - Supplier Certificate Surveillance.
(2) Manufacturing Procedures, Nos. -
(a) 3.02, dated April 27, 1979 - Preparation of Travel Order Cards.
(b) 3.05, dated January 31, 1980 - Preparation of Material
- Request, (c) 5.01, dated August 6,1979 - Corrective Action Request, (d) 5.03, dated June 18, 1979 - Inspection Report, and its associated Quality Assurance Notice No. 79N-003, Revision 3, dated March 12, 1980, (e) 5.05, dated April 30, 1979 - Qualification of Nuclear Safety-Related Suppliers, (f) 5.10, dated September 6, 1979 - Controlling Production Procurement Documents, and (g) 5.19, dated April 27, 1979 - Supplier Document Review and Approval.
(3) Quality Plans, Nos. -
(a) 30.103, Revision 10, dated October 22, 1979 - ASME Code Purchased Material and Components, (b) 30.123, Revision 4, dated March 12, 1980 - Quality Assurance Requirements for Supplier Designed Nuclear Safety-Related Items, (c) 30.124, Revision 1, dated September 25, 1979 - Quality Assurance Requirements for Suppliers of Safety-Related Items (NED Designed), and (d) 40.701, Revision 2, dated July 12, 1977 - Receiving Inspection.
b.
Reviewing the following purchase orders, vendor listing in the Qualified Suppliers Manual, supplier submittals, Supplier QA Manual Review and Evaluation Summary, and Supplier Quality Assurance Program Evaluation Reports to verify implementation j
of the established measures:
j
. (1) 282-Y7973 ASME, Revision 00, dated October 11, 1979 to Keenan Supply, (2) 282-Y7958ASME, Revision 00, dated October 26, 1979, to Guyon Alloys, Incorporated, (3) 282-NP543, Revision 00, dated March 4, 1980 to Bailey Meter Company, (4) 282-NY155, Revision 00, dated February 27, 1980 to General Electric -Power Systems Management Business Department, (5) 282-NY129, Revision 00, dated February 25, 1980, to Electroswitch Willard Nott and Company, (6) 282-NY124, Revision 00, dated February 23, 1980 to General Electric - General Purpose Control Product Department, (7) 282-TF145, Revision 00, dated October 15, 1979 to Jensea Instruments Riley Company, (8) 282-KR083, Revision 00, dated June 23, 1978 to General Electric - Ground Systems Division, and (9) 282-KJ992, Revision 00, dated October 24, 1979 to Bravo Manufacturing, Incorporated.
3.
Findings a.
Deviations From Commitment (1)
See Notice of Deviation, Item C.
(2) See Notice of Deviation, Item D.
b.
Follow-up Items (1)
Paragraph 2.4.1, Item 4, of Quality Assurance Procedure No. 2.4, Revision 0, dated May 4, 1979, states, " Assure that procurement documents require that suppliers and subtier suppliers provide a QA Program acceptable to General Electric."
The NRC inspector 7as unable to determine the method used by General Electric to assure that subtier suppliers provide a QA Program acceptable to General Electric.
. (2) The Control and Instrumentation Department (C&ID) assigns some purchase orders to agents / distributors.
In turn, the agents / distributors initiate purchase orders that are sent to manufacturers.
It was not apparent to the NRC inspector how C&ID ensures that agent / distributor initiated purchase orders contain the requirements of the C&ID initiated purchase orders.
5 i
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