ML20056G753

Provides Summary of Most Significant Insp Findings in Advance of Insp Rept So That Appropriate & Timely Corrective Action Can Be Taken,Per Insp Rept 99900403/93-01 on 930809- 13

ML20056G753
Person / Time
Site:	05200004
Issue date:	09/01/1993
From:	Borchardt R Office of Nuclear Reactor Regulation
To:	Marriott P GENERAL ELECTRIC CO.
References
REF-QA-99900403 NUDOCS 9309070124
Download: ML20056G753 (5)

Text

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7 G ' UNITED STATES i i' %i NUCLEAR REGULATORY COMMISSION wassiwoTon, o.c. osss coot  ;

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September 1, 1993 [

3 Docket Nos.52-004 and'99900403- i Mr.-Patrick-W. Marriott~,' Manager Licensing & Consulting Services GE Nuclear Energy  ;

175 Curtner Avenue San Jose, California 95125  !

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Dear Mrf Marriott:

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SUBJECT:

FINDINGS-IDENTIFIED DURING'THE' VENDOR INSPECTION BRANCH INSPECTION l

AT GE NUCLEAR ENERGY (INSPECTION REPORT NO.99900403/93-01)  ;

During the week ~of August 9-13, 1993, the NRC's Vendor Inspection Branch led a  !

i-team inspection at the GE Nuclear Energy (GE-NE) office in San Jose, '

l- California. The purpose of the inspection was to determine if the activities performed _as part of the Gravity-Driven Cooling System (GDCS) Integrated  ;

Systems Test-(GIST)' program were conducted under the appropriate provisions of the GE-NE -10 CFR Part 50, Appendix B, quality assurance program, as implemented by the " Advanced Light Water Reactor Quality Assurance Program j L Plan" (QA Program Plan),' prepared- for Department of Energy Contract Number i

.DE-AC03-86SF16563 and also to _rev_iew the input modeling of the TRACG computer l code for the GIST facility. i The details of-the inspection were discussed with you and your staff during the inspection and at the exit meeting on August 13, 1993. This letter  ;

provides a summary of the most significant inspection' findings in advance of s the inspection? report so that you may take appropriate and timely corrective '

action.

-The results of the inspection indicate that-the GIST program and supporting independent design verification activities _for the TRACG computer code were

! conducted without fully implementing appropriate Appendix B quality assurance measures and controls expected for a safety-related activity. Specifically, the~ code qualification document (CQD),' Licensing Topical Report NEDE-32177P, "TRACG Qualification," February 1993, was submitted to the NRC for review and approval for-referencing in licensing actions for the SBWR. The CQD, which

. provides-a description of the qualification of TRACG against various activities including the GDCS integrated systems _ test, did not receive independent design verification as is required for. a level ] code used to support de' sign basis; analyses. .Also, the TRACG input deck reviewed contained p elevation errors that directly affected the results of the TRACG computer run j for GIST. GE-NE was in the process of rerunning TRACG for GIST to correct n these errors.

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• l Mr. Patrick W. Marriott September 1, 1993 4 i

The lack of independent design verification for TRACG also raises questions concerning the validity of other calculations included in Chapter 15 of the '

SSAR for SBWR. This issue is considered an unresolved item and will be i discussed with GE-NE in future meetings. j The classification of the GIST test program as a non-safety-related  !

developmental test is not consistent with GE-NE's QA procedural requirements l considering that (1) the GIST program represents the only integral systems  !

test of the SBWR's gravity-driven cooling system, and (2) GIST results were rsed directly in a licensing application, i.e., to demonstrate the epplicability of TRACG to SBWR analyses in the CQD, in support of GE-NE's SBWR design certification application. The review of Design Record File (DRF) A00-02917, for GIST, determined that documentation required to be contained or referenced in the DRF was not included therein. Specific

-documents that should have been part of the DRF were: the Final Test Report  :

for the GIST Program, NEDD-31680; instrument calibration records; and as-built '

design drawings for the facility.

Other deficiencies in the DRF include: (1) failure to reference the original data tapes from the GIST tests, which should be appropriately referenced as retrievable information; (2) failure to' include verified input from TRACG analyses r elated to GIST; (3) failure to generate and include in the DRF, non-conformance reports for tests that did not meet acceptance criteria and were classified as being " invalid," for various reasons; and (4) failure to include documentation of analytical or experimental verification of engineering calculations. For instance, the heat loss to the environment from the facility was a necessary datum for. accurate analysis of the test results. A single page with an estimate of the heat loss was located in the DRF, but no  !

documentation was included to show the basis for the estimate of effective heat transfer coefficient (e.g., thermophysical properties of insulation, film coefficient on outside of insulation, etc.), nor was there any indication that the calculated estimate was verified experimentally.

In response to the above findings, GE-NE committed to (1) verify the input deck for the TRACG code and rerun TRACG for GIST once TRACG becomes an independently verified level 2 code and, (2) upgrade the GIST DRF to include, to the extent possible, the missing information and documents described above.

This backfit of the DRF would attempt to represent a safety-related test conducted under the required Appendix B QA controls and include the required backup documentation. No response to this letter is required.

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Mr. Patrick W. Marriott September 1, 1993  !

l In accordance with 10' CFR 2.790 of the NRC's " Rules of Practice," a copy of  !

this letter will be placed in the NRC Public Document Room.  !

Sincerely,  ;

(Original signed by)  !

R. W. Borchardt, Director  !

Standardization Project Directorate  :

Associate Directorate for Advanced Reactors  !

and License Renewal  !

Office of Nuclear Reactor Regulation  !

cc: See next'page  !

DISTRIBUTION: i VIB R/F DRIL R/F DOCKET FILES / CENTRAL FILES /PDR ,

DCrutchfield MMalloy SNinh l PShea AThadani/MVirgilio DMcPherson j RJones MRubin Alevin RCaruso JStaudenmeier RBarrett  ;

RElliott- GZech RGramm l FAllenspach BSheron/TKing LShotkin i JHan MFinkelstein,.ISBI8 AGody, Jr., 17G21 i' ACRS (11) RBorchardt JNWilson PDST R/F p0FFICE VIB/DRIL VIB/DRIL VIB/DRIL DRIL/NRR DRIL/NRR NAME RMcIntyre* UPotapovs* LNorrholm* RZimmermd CERossi*

DATE 8/27/93 8/30/93 8/31/93 9/ M 8/31/93  !

COPY -~7ED #Y Yd DOC 1

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NO NO NO (kS y_J NO OFFICE SRXB POST __) PDSJf NAME RJones* lbNWilso h RWkrchardt DATE 9/ 1/93 9/d/93 9///93 COPY DOC

[YEh) v NO NO(

NO 0FFICIAL RECORD COPY Document Name: P:\GE-GIST.LTR ,

- *SEE PREVIOUS CONCURRENCE l

1 .- i L

l Mr.. Patrick W. Marriott September 1, 1993 i

!- In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of 5 l

this letter _will be placed in the NRC Public Document Room. l 1

Sincerely, j (Original signed by) l R. W. Borchardt,~ Director

.: Standardization Project Directorate

!' Associate Directorate for Advanced Reactors l and License Renewal l

. Office of Nuclear Reactor Regulation cc: See next page l DISTRIBUTION: '

i VIB R/F . DRIL R/F 1 DOCKET FILES / CENTRAL FILES /PDR

! DCrutchfield MMalloy SNinh PShea AThadani/MVirgilio DMcPherson RJones MRubin Alevin L RCaruso' JStaudenmeier RBarrett l-RElliott GZech . ~RGramm FAllenspach BSheron/TKing LShotkin '

JHan MFinkelstein,15B18 AGody, Jr., 17G21 ACRS (11) RBorchardt JNWilson PDST R/F

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0FFICE VIB/DRIL VIB/DRIL VIB/DRIL DRIL/NRR DRIL/NRR NAME- RMcIntyre* UPotapovs* LNorrholm* RZimmerd CERossi* -

DATE- 8/27/93 8/30/93 8/31/93 9/ /I3 8/31/93 Y-

]~TED NO(

NO @ NO Yd NO

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NO 0FFfCE SRXB- POST __9 PDSF/

NAME RJones* JT JNWilso RWhchardt-DATE 9/ 1/93 9/J/93 9/ / /93 Y NO NO NO (

=0FFICIAL RECORD COPY Document Name: P:\GE-GIST.LTR

• SEE PREVIOUS CONCURRENCE

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Mr. Patrick W. Marriott Docket No.52-004

! GE Nuclear Energy L

cc: Mr. Laurence S. Gifford i GE Nuclear Energy 12300 Twinbrook Parkway

Suite 315 Rockville, Maryland 20852 Director, Criteria & Standards Division Office of Radiation Programs

U.S. Environmental Protection Agency l 401 M Street, S.W.

Washington, D.C. 20460 Mr. Sterling Franks U.S. Department of Energy NE-42 Washington, D.C. 20585 l Mr. Jeffrey C. Baechler GE' Nuclear Energy 175 Curtner Avenue,.MC-782 San Jose, California 95125

( Mr. Frank A. Ross Program Manager, ALWR

, Office of LWR Safety & Technology j U.S. Department of Energy NE-42 19901 Germantown Raad Germantown, Maryland 20874 Mr. Kenneth Erayman GE Nuclear Energy

( 175 Curtner Avenue, MC-562 l

San Jose, California 95125 Mr. Philip Novak

GE Nuclear Energy l

175 Curtner Avenue, MC-754 San Jcse, California 95125 l

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