ML20058A811
| ML20058A811 | |
| Person / Time | |
|---|---|
| Site: | 05200004 |
| Issue date: | 11/18/1993 |
| From: | Borchardt R Office of Nuclear Reactor Regulation |
| To: | Marriott P GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20058A814 | List: |
| References | |
| REF-QA-99900403 NUDOCS 9312010250 | |
| Download: ML20058A811 (5) | |
Text
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UNITED STATES
[h[.tj NUCLEAR REGULATORY COMMISSION
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November 18, 1993 Docket Nos,52-004 and 99900403 Mr. Patrick W. Marriott, Manager Licensing & Consulting Services GE Nuclear Energy 175 Curtner Avenue San Jose, California 95125
Dear Mr. Marriott:
SUBJECT:
NOTICE OF NONCONFORMANCE (NRC INSPECTION REPORT NO. 99900403/93-01)
This letter addresses the inspection of your facility at San-Jose, California, conducted by Richard P. McIntyre and Billy H. Rogers of the Nuclear Regulatory i
Commission's (NRC's) Vendor Inspection Branch, Alan E. Levin of the Reactor Systems Branch, Joseph L. Staudenmeier of the Analytical Support Group, and Frederick R. Allenspach of the Performance and Quality Evaluation Branch on August 9 through 13, 1993. The details of the inspection were discussed with you and your staff during the inspection and at the exit meeting on August 13, 1993.
The purpose of the inspection was to determine if 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 Nuclear Energy (GE-NE) 10 CFR Part 50, Appendix B, quality assurance program, as-implemented by the " Advanced Light Water Reactor Program Quality Assurance-Program-Plan" (QA Plan), dated November 26, 1986, prepared for Department of Energy Contract Number DE-AC03-86SF16563 and also to review the input modeling-l of the TRACG computer code for the GIST facility.
Areas examined during the NRC inspection and our findings are discussed in the enclosed inspection report. The inspection consisted of an examination of I
procedures and representative records, interviews with personnel,~ and observations by the' inspectors.
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 l
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 j
approval 'for referencing in licensing actions for the Simplified Boiling Water ~
Reactor (SBWR).
The CQD, which provides a description of the qualification of..
1 TRACG against various activities including the GDCS integrated systems test, did not receive independent design verification as is required for a level 1
[
code used to support design basis analyses. Also, the TRACG input. deck reviewed contained elevation errors that directly affected the results of the 9312010250 931118-0 PDR ADOCK 05200004 R l
A PDR.
4 Mr. Patrick W. Marriott November 18, 1993 TRACG analyses for GIST.
GE-NE was in the process of rerunning TRACG for GIST to correct these errors.
The classification of the GIST test program as a non-safety-related developmental test is not consistent with GE-NE's procedural requirements considering that (1) the GIST program represents the only integral systems test of the SBWR's gravity-driven cooling system (GDCS), and (2) GIST results were used directly in a licensing application, i.e., to demonstrate the applicability 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, identified that documentation required to be contained or referenced in the DRF was not included therein.
Specific documents that should have been included or referenced in the DRF were:
the Final Test Report for the GIST Program, NED0-31680; 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 related 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.
During a meeting with you at NRC Headquarters on October 4, 1993, we discussed our technical concerns prompted by the above described inspection findings, as well as continuing NRR concerns that the GIST facility does not adequately represent components and interaction paths in the SBWR.
During the meeting at your Rockville, Maryland office on Ncvember 16, 1993, you responded to these concerns and stated that you expect to respond formally to the concerns in the near future.
Until the staff has had an opportunity to carefully evaluate the information you have already provided and will be sending us shortly, be aware that GE-NE's failure to properly classify the GIST test program and its associated analyses, the failure to thoroughly evaluate the test data, and the failure to adequately verify calculations of both GIST and SBWR behavior may require additional GDCS testing in an integral facility to support SBWR design certification.
1 Mr. Patrick W. Marriott November 18, 1993 Please provide us within 30 days from the date of this letter a written statement in accordance with the instructions in the enclosed Notice of Nonconformance. We will consider extending the response time.if you can show 1
good cause for us to do so, l
The responses. requested by this letter and the enclosed Notice of Nonconformance are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No.96-511.
In accordance with 10 CFR Part 2.790 of the NRC's " Rules of Practice," a copy.
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of this letter and its enclosures will be placed in the NRC's Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
O Sincerely,
'i 1
Original signed by:
R. W. Borchardt, Director' i
Standardization Project Directorate Associate Directorate for Advanced Reactors'
~
and License Renewal Office of Nuclear Reactor Regulation
Enclosures:
1.
Notice of Nonconformance 2.
Inspection Report No. 99900403/93-01 FOR DISTRIBUTION AND CONCURRENCE SEE NEXT PAGE i
l a
t P
.-)A O. November 18, 1993 Letter to Patrick Marriott Dated DISTRIBUTION:
VIB R/F DRIL R/F DOCKET FILES / CENTRAL FILES /PDR DCrutchfield MMalloy SNinh PShea AThadani/MVirgilio DMcPherson RJones MRubin Alevin RCaruso JStaudenmeier RBarrett RElliott GZech RGramm FAllenspach BSheron/TKing LShotkin JHan MFinkelstein, 15B18 AGody, Jr., 17G21 ACRS (11)
RBorchardt JNWilson RHasselberg WRussell RIDS IE 09 TCollins FEltawila RMcIntyre SEE PREVIOUS CONCURRENCE
=-
DFFICE VIB/DRIL VIB/DRIL RPEB/DRIL lAb SRXB J.
MAME RMcIntyre BRogers FAallenspach; Staudenmeier Alevin
) ATE 10/29/9?*
11/02/93*
11/04/93
11/02/93*
11/02/93*
bl YES YES YES YES YES l0PY J
NO NO NO NO N0
- 0FFICE VIB C:SRXB C:VIB D:DRIL D:DSSA NAME UPotapovs RJones LNorrholm CERossi AThadani
!DATE 11/02/93*
(11/02/93*
11/C5/93*
11/12/93*
11/11/93*
YES YES YES YES YES
' COPY NO N0 NO NO IFFICE ADT:NRR D:P RBho 1AME WRussell ardt FATE 11/17/93*
11/ /93 YES gPY NO N0 i
FICIAL RECORD COPY Document Name: P:\\GE-GIST.RPT 26-1CE
.. November 18, 1993 Mr. Patrick W. Marriott Docket No.52-004 General Electric Company 99900403 cc:
Mr. Laurence S. Gifford GE Nuclear Energy 12300 Twinbrook Parkway Suite 315 Rockville, Maryland 20852 Director, Criteria & Standards Division Office of Radiation Programs U.S. Environmental Protection Agency 401 M Street, S.W.
Washington, D.C.
20460 Mr. Sterling Franks U.S. Department of Energy NE-42 Washington, D.C.
20585 Mr. John E. Leatherman SBWR Licensing Manager.
GE Nuclear Energy 175 Curtner Avenue, M/C 781 i
San Jose, California 95125 Mr. Frank A. Ross Program Manager, ALWR Office of LWR Safety & Technology U.S. Department of Energy j
NE-42 i
19901 Germantown Road Germantown, Maryland 20874 Mr. Victor G. Snell, Director Safety and Licensing AECL Technologies 9210 Corporate Boulevard Suite 410 Rockville, Maryland 20850 1
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