ML20059C822
| ML20059C822 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/19/1993 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| OLA-2-I-MFP-097, OLA-2-I-MFP-97, NUDOCS 9401060118 | |
| Download: ML20059C822 (13) | |
Text
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NCR DCO-92-MF-N025 Rev. 00 E.7/9 !jf3 February 17, 1993 i
MANAGEMENT
SUMMARY
Contrary to the QA manual requirements, the Agastat ETR Solid State Relays are not being controlled to preclude their use after 10 years from the date of manufacture or 25,000 cycles, whichever occurs first.
In addition, other issues have been identified on the referenced QEs (ref.
1, ref.
2, and ref. 3), regarding administrative controls on component shelf / service life.
PROBLEM STATEMENT FOR OE 00009656:
Design life limitations for non-EQ equipment as established by Engineering were not adequately implemented at DCPP.
PROBLEM STATEMENT FOR OEs 00009645 AND 00009628:
Contrary 1
to the requirements of 10 CFR 50 Appendix A, General Design Criteria 4, PG&E has not identified which safety-related items have a limited service life (less than or equal to 40 years).
These items fall outside the scope of the EQ program; examples include relays, circuit breakers, diaphragms, 0-rings, seals, etc.
I 1.
Root cause for QE Q0009656 is that there was a lack of training in the AP E-14 process.
2.
No root cause is required for QEs Q0009628 and Q0009645, as the 11/20/92 TRG determined that this problem was limited to only a smal1 number of components and has since been addressed.
See Corrective Actions below.
Corrective actions to prevent recurrence:
1.
Revision 2 of AP E-14 was previously issued to also provide guidance for disseminating solicited vendor information.
Training on E-14 was recently provided, as documented in QE Q0009589.
2.
A memo from NECS has been prepared (CHRON201408),
documenting that design / service life limitations are evaluated and addressed by variour mechanisms.
On February 16, 1993, the TRG reconvened to review the NCR write-up and to sign off the original NCR.
This NCR will now go to the PSRC for approval and to QA for c]osure.
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of 14 9401060118 930819 PDR ADOCK 05000275 G
t NCR DCO-92-MF-N025 Rev. 00 Februar/ 17, 1993 environmentally qualified (EQ) equipment ONLY.
Shelf Life -
period of time an item may be stored and still retain its full design life.
Service Life -
actual (not predicted) period of time an item is in operation.
Design Life -
period of time an item is expected to function as designed; or shelf life plus expected service life.
C.
Event "escription:
The following items were noted on QE Q0009656 (ref. 1) regarding the specifics of the Agastat relay problem:
1.
The " Product Specification ETR Rev.
E" from the Control Products Division of Amerace Corporation was received with PO 788085 in 1988.
All documentation was submitted to the PG&E, Chief Electrical Engineer.
The " Product Specification 6TR Rev.
E" was also received with PO C18418 in 1988 and filed with the PO documentation.
The vendor manual was not included in the vendor instruction manuals (VIMS).
As a result the manual has not been received nor reviewed by Electrical Maintenance (EM)
Engineering.
2.
RPE E-0052 includes a reference to Amerace test report ES 2000, an official / approved PG&E drawing for ETR relays (VP #663348-82).
This document was not in DCPP nor NECS Construction Document Control.
3.
RPE E-0052 was not received nor reviewed by EM Engineering.
4.
No action was taken after the installation of the relays regarding Standard Clause 8129 and 92NCRWP\\92MFN025.PSN Page 3
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4 NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 the 10 year limitation.
Standard Clause 8129 states that the "date of manufacture is specified on each relay".
However, the vendor product. specification is the only documentation explaining that the date is included in the first four digits of the serial number.
5.
The inventory parts catalogs (IPCs) for the ETR relays stated that there is no shelf life.
6.
The serial numbers of the relays are not maintained in PIMS, are not included on the Material Requisition, and are not recorded in the WO documentation.
As a result, the date of manufacture is not readily available.
7.
The Preventive Maintenance (PM) program does not include a requirement to replace the relays after 10 years.
8.
Maintenance procedure MP E-50.30, Rev. 10, Effective Date 1/20/92, " Testing Timing Relays" does not include any reference to ETR type relays and reference to the manufacturers projected life of the relay.
9.
The PIMS component database for the individual relays does not reference the manufacturers service life recommendations.
In addition, either no in-service date is specified or the date of installation i_ used instead of the date of manufacture, QE Q0009628 (ref. 2) identified a concern i
regarding potentially inadequate administrative controls on shelf life for subcomponents.
QE Q0009645 (ref. 3) identified a concern regarding potentially inadequate consideration of design basis accidents when determining equipment design life.
D.
Inoperable Structures, Components, or Systems that Contributed to the Event:
None.
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l NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 E.
Dates and Approximate Times for Major Occurrences:
1.
April 3-16, 1992:
QEs Q0009656, Q0009628, and Q0009645 were I
initiated documenting the identified concerns.
F.
Other Systems or Secondary Functions Affected:
None.
G.
Method of Discovery:
QA personnel, during the performance of audit 920011 - Safety System Functioral Audit and Review i
(SSFAR) of the Safety Injection (SI) System, identified concerns with administrative controls on shelf / service life.
H.
Operator Actions:
None.
I.
Safety System Responses:
None.
III.
Cause of the Event A.
Immediate Cause:
1.
Design life limitations for non-EQ equipment as establion_?. by Engineering were not adequately implemented at DCPP.
2.
Contrary to the requirements of 10 CFR 50 i
Appendix A, General Design Criteria 4, PG&E has not identified which safety-related items have a limited service life (less than or equal to 40 years).
These items fall outside the scope of the EQ program; examples include relays, circuit breakers, diaphragms, 0-rings, seals, etc.
B.
Determination of Cause:
See root cause analysis (ref. 5).
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C.
Root Cause:
1.
Root cause for QE Q0009656 is that there was a lack of training in the AP E-14 process.
2.
No root cause is required for QEs Q0009628 and Q0009645, as the 11/20/99 TRG determined that this problem was limited to only a small number of components and has since been addressed.
See Corrective Actions below.
IV.
Analysis of the Event A.
Safety Analysis:
No actual problems with existing installed plant equipment were identified.
In addition, the recent Vendor Manual Review program and the forthcoming memo from NECS (see Corrective Action
- 2 below) provide assurance that vendor recommendations have been incorporated for installed equipment.
Consequently, this problem does not adversely affect the health and safety of the public.
B.
Reportability:
1.
Reviewed under QAP-15.B and determined by management to be non-conforming in acenrdance with Section 2.1.8 as requiring resolution through the nonconformance process.
4 2.
Reviewed under 10 CFR 50.72 and 10 CFR 50.73 per NUREG 1022 and determined to be not reportable.
i 3.
Reviewed under 10 CFR Part 21 and determined that this problem will not require a 10 CFR 21 report, since no equipment problems or deficiencies have been noted.
4.
This problem will not be reported via an INPO Nuclear Network entry.
5.
Reviewed under 10 CFR 50.9 and determined to be not reportable since this event does not have a significant implication for public health and safety or common defense and security.
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4 NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 6.
Reviewed under the criteria of AP C-29 requiring the issue and approval of an OE and determined that no OE is required.
V.
Corrective Actions A.
Immediate Corrective Actions:
1.
A review indicated that the Agastat relays at DCPP were all manufactured in 1987 or later.
Therefore, the minimum design life of the relays should extend until 1997 (ref. 1).
B.
Investigative Actions:
1.
Perform a root cause analysis for this NCR.
RLSPONSIBILITY:
R.
Harris ECD:
COMPLT DEPARTMENT:
Materials Tracking AR:
A0267316, AE #01 2.
Investigate and report back to the TRG on the best way to proceduralize that design life limitations should be addressed in the design modification process, including how to communicate this information to the plant.
RESPONSIBILITY:
W.
Fargo ECD:
COMPLT DEPARTMENT:
NECS Engineering Tracking AR:
A0267316, AE #02 3.
Investigate and report back to the TRG on options for developing a program to implement shelf, service, and design life limitations.
RESPONSIBILITY:
J.
Nailen ECD:
COMPLT DEPARTMENT:
Materials Tracking AR:
A0267316, AE #03 4.
QA to close the following QEs:
Q0009628 Q0009645 Q0009656 RESPONSIBILITY: Hartz/Ketelson ECD:
COMPLT DEPARTMENT:
QA Tracking AR:
A0267316, AE #04 92NCRWP\\92MFN025.PSN Page 7
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NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 5.
Develop statements that clarify the problem outlined in the QEs (Q0009645 and Q0009628).
RESPONSIBILITY:
C.
Hartz ECD:
COMPLT DEPARTMENT:
QA Tracking AR:
A0267316, AE #05 6.
Establish a recommended service life for Agastat relays.
RESPONSIBILITY:
W.
Fargo ECD:
COMPLT DEPARTMENT:
NECS Engineering Tracking AR:
A0267316 AE #06 7.
Review the revision of E-14 that was in effect when the event occurred.
Determine if there was a requirement to send solicited information to Engineering.
RESPONSIBILITY:
T. Niemi ECD:
COMPLT DEPARTMENT:
Materials Tracking AR:
A0267316 AE #07 8.
NECS to provide a memo responding to the concern as discussed in Investigative Action i
- 5 (AE 05).
i RESPONSIBILITY:
W.
Fargo ECD:
COMPLT a
DEPARTMENT:
NECS Engineering l
Tracking AR:
A0267316, AE #08 9.
Recommend to the chai_ man of NCR DC2-91-IN-N087 that an evaluation of expectcd service life for ITT Grinnell diaphragms be performed as part of that NCR.
RESPONSIBILITY:
C.
Hartz ECD:
COMPLT DEPARTMENT:
QA i
Tracking AR:
A0267316, AE #09 C.
Corrective Actions to Prevent Recurrence:
1.
Revision 2 of AP E-14 was previously issued to also provide guidance for disseminating solicited vendor information.
Training on E-14 was recently provided, as documented in QE Q0009589.
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NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 2.
A memo from NECS will be prepared, documenting that design / service life limitations are evaluated and addressed by various mechanisms.
j (See Investigative Action #8 above) i Tracking AR:
A0267316, AE #08 Outage Related? No OE Related?
No NRC Commitment? No CMD Commitment? No D.
Prudent Actions (not required for NCR closure)
None.
VI.
Additional Information A.
Failed Components:
None.
B.
Previous Similar Events:
A search of the Records Management System for NCRs, QEs, ARs, or NPPRs with " LIFE" in the DSCR field revealed the following items:
NPPR DC1-84-QC-P0310 NPPR DCl-84-QC-P0331 NCR DCl-84-MF-N041 NCR DCO-85-PG-N018 C.
Operating Experience Review:
1.
NPRDS:
Not applicable.
2.
NRC Information Notices, Bulletins, Generic Letters:
i None.
A search of the NOS operating
[
Experience Assessment database under keywords COMMUNICATION and WAREHOUSE, SPR PARTS, and PROGRAM and WAREHOUSE, SPR PARTS revealed no applicable items.
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None.
A search of the NOS Operating Experience Assessment database under keywords COMMUNICATION and WAREHOUSE, SPR PARTS, and PROGRAM and WAREHOUSE, SPR PARTS revealed no applicable items.
D.
Trend Code:
Responsible department MF (Material Facility), and cause code A2 (Training Deficiency).
E.
Corrective Action Tracking:
1.
The tracking action request is A0267316.
2.
Are the corrective actions outage related?
No.
F.
Footnotes and Special Comments:
None.
G.
References:
1.
QE Q0009656 AR A0266593 2.
QE Q0009628 3.
QE Q0009645 4.
Memorandum, " Concerns Regarding Control of Shelf / Service Life; Examination of Environmental Qualification Program Aspects,"
l from NECS - EQUIPMENT QUALIFICATION (G.
Tidrick) to VARIOUS, dated June 9, 1992 (CHRON202695) 5.
Root cause analysis for QE Q0009656 6.
QE Q0009589 7.
Memorandum, " Equipment Design Life, NCR DCO-92-MF-N025," from DIABLO CANYON PROJECT ENGINEER (M. Tresler) to TRG Chairman (S.
Ortore), dated January 6, 1993 (CHRON201408) l l
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NCR DCD-92-MF-N025 Rev. 00 February 17, 1993 H.
TRG Meeting Minutes:
On June 2 and June 10, 1992, the TRG met and determined that the issues identified do not constitute a substantial programmatic or implementation breakdown, do not require reporting to the NRC.
(However, it was subsequently determined that this issue will remain an NCR per management directive.)
On September 24, 1992, the TRG reconvened and considered the following:
1.
The TRG discussed the NSIG-13 definitions of shelf, service, and design life, in order to clarify further discussions.
2.
Tie TRG reviewed the three QEs that initially noted this problem.
The QEs will be closed out and the problems addressed by this NCR.
~
3.
The TRG discussed and determined the problem statement, as listed above in the text of the NCR.
The three initiating QEs document instances where Engineering's knowledge of.
design life limitations were not adequately a
1 communicated to the field.
There are no quality problems that the TRG knew of regarding inadequate detcrainations of design life by Engineering.
4.
The TRG began discussions of root cause, and assigned an investigative actico to perform a root cause analysis.
Meanwhile, two additional investigative actions were assigned to begin considering ways to implement the proposed corrective actions.
5.
This TRG will reconvene on October 26, 1992 after the root cause analysis is completed.
On November 5, 1992, the TRG reconvened to discuss the following:
1.
A recap of the last meeting was discussed and the root cause analysis for QE Q0009656 was presented.
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NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 2.
Discussed how.to track previously installed relays.
RPE needs to note 10 year life and the manufacture date.
3.
The following investigative actions were identified: (1) develop statements that clarify the problem outlined in the QEs (Q0009645 and Q0009628); (2) establish a recommended service life for Agastat relays; (3) review the revision of E-14 that was in effect when the event occurred.
Determine if there was a requirement to send solicited information to Engineering.
4.
The TRG agreed to reconvene on 11/20/92 to review the investigative actions.
On November 20, 1992, the TRG reconvened and considered the following:
1.
QE Q0009628 is really just a subset of Q0009645.
The problem statement for these two QEs is that PG&E has not identified those non-EQ, safety-related components that have a service life less than 40 years.
Engineering responded that the Maintenanco department provides preventive maintenance on these items, and RPEs are used when needed to update the materials and designs.
2.
In addition, PM programs are responsible for monitoring these comn^nents.
Investigative action #8 above was assigned to prepare a memo to document this.
3.
The information regarding these diaphragms and relays was available and a program is currently in place to disseminate information regarding vendor components (AP E-14).
Previous to Rev. 2 of AP E-14, handling of solicited vendor information was governed by a different procedure, which previously caused some problems (ref. 6).
4.
This TRG will recommend to the TRG for NCR DC2-91-TN-N087 that they evaluate the expected service life for Grinnel diaphragms (considering temperature, dose, and aging).
See Investigative Action #9 above.
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NCR DCO-92-MF-N025 Rev. 00 February 17, 1993 5.
This TRG will reconvene on approximately 12/17/92 to finalize and sign the NCR.
On December 15, 1992, the TRG reconvened and considered the following:
1.
The TRG (except the cognizant QA individual who initially identified the concern) reviewed the draft NECS memo (Corrective Action #2).
The position taken in the memo is that there are no specific regulatory requirements to specify service lives for non-EQ equipment, and that existing preventive maintenance programs are adequate for inspection and replacement of parts.
2.
For example, the 10-year life for the Agastat relays was only a " commercial" recommendation by the vendor.
If desired, the plant could run them till failure and replace as needed.
4 Electrical Maintenance will discuss with the Predictive Maintenance group and confirm that they have all the info they will need to evaluate the ETR relays.
3.
The ECD for the memo will be extended to 1/12/93.
4.
This TRG will reconvene when the memo has been finalized and issued, and when the cognizant QA individual is available to review it.
The reconvene is tentatively scheduled for 1/19/93.
The TRG reconvened on January 19, 1992 and discussed the following items:
1.
The TRG reviewed the memo titled: " Equipment Design Life, NCR DCO-92-MF-N025".
The TRG agreed that the memo was very complete and comprehensive.
1 2.
The TRG discussed the root cause and trend codes. The TRG agreed that the trend code was MF (Material Facility) A2 (Training Deficiency).
T.
Niemi and N.
Koellish will re-draft the root cause analysis to match the i
trend code.
?
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The TRG determined the voting members to be:
S.
- Ortore, N. Koellish, C.
- Hartz, P.
Natividad, W.
Fargo.
The TRG reconvened on February 16, 1993 to review the NCR write-up and sign off the original NCR.
No changes were made to the NCR.
All members signed the NCR except for W.
Fargo, who is scheduled to sign on February 18, 1993.
l The overall ECD is set for April 15, 1993.
I.
Remarks:
None.
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