ML20147C458
| ML20147C458 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1978 |
| From: | Costello J, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20147C400 | List: |
| References | |
| REF-QA-99900403 NUDOCS 7810130019 | |
| Download: ML20147C458 (16) | |
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VENDOR INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. - 99900403/78-02 Program No.'44082 Company: General Electric Company Nuclear Energy Business Group 175 Curtner Avenue San Jose, California 95125 Inspection Conducted: July 24-28, 1978 Inspectors: D. k. O,the F//4/77 :
J. K.J C'ostello, Principal Inspector, D' ate' VMdor Inspection Branch Q'.th W 9/I+l2P J.04. Johngfn, Contractor Auditor, D' ate '
Vendor IBspection Branch :
Approved by: _
( f_. -
C. J.(Hal), Chief, Projects Sectier., Date N[
Vendor Inspection Branch Summary Inspection on July 24-28, 1978 (99900403/78-02)
Areas Inspected: Implementation of topical report NED0-11209-04A in the areas of design verification, verification activities, product acceptance of RHR (Residual Heat Removal) heat exchangers and action on previous inspection findings. The inspection involved sixty '(60) hours on site by two (2) USNRC inspectors.
Results: In the areas inspected, no deviations or unresolved items were identified.
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DETAILS SECTION I (Prepared by J. R. Costello)
A. Persons Contacted D. D. Akers, Manager Electronic Design, Reactor Controls L. S. Bohl, Manager Design Review C. E. Buckner, Specialist, Quality Systems H. R. Clay, Manager Control Room Design, Engineering K. I. Dawley, Manager Plant Definition and Release Control W. H. Fleming, Engineer, Flow Control Valve Design R. R. Ghosh, Technical Leader, Steam Valves
- D. E. Lea, Manager Quality Control, Nuclear Energy Engineering Division J. S. Mokri, Engineer, Mechanical Equipment Design Section E. J. Plehn, Quality Control Engineer
- J. K. Powledge, Monager Quality Assurance, Engineered Equipment and Installation R. L. Reghitto, Manager Reactor Instrumentation and Protection Design R. C. Ryan, Senior Engineer, Reactor Protection Control and Electronic System B. L. Sheppard, Manager Quality Systems and Records A. R. Schick, Senior Engineer, Residual Heat Removal Heat Exchangers G. I. Skoda, Senior Engineer, Mechanical Equipment Design
- L. D. Test, Principal Engineer, Control and Instrumentation Department
- R. J. Valencia, Specialist, Quality Control, Nuclear Energy Engineering Division R. K. Young, Design Engineer, Drive Line Components
- Denotes those present at exit meeting.
B. Action on Previous Inspection Findings
- 1. (Closed) Unresolved Item (Report No. 77-04): GE topical report NED0-11209-03A, Table 2-1, commits to the requirements of ANSI N45.2.9. GE has submitted to NRR: QAB for review an alter-native to several portions of ANSI N45.2.9 that will require a revision to the topical report. On July 11, 1978, NRR:QAB approved GE's alternatives in revision 04A to the topical report.
- 2. (Closed) Unresolved Item (Report No. 78-01): Implementation of l GE's corrective action program to preclude recurrence of deviations l and/or nonconformances does not appear to be adequately documented.
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GE has instituted changes to their corrective actions program to improve it. These changes were examined by the inspector and are as follows:
- a. E0P 55-3.00 (Field Deviations Dispositions) and form FDDR (Field Deviation Disposition Requests) were revised in response to internal audit ESA-024. The new FDDR fom which will be available July 31, 1978, has a new block added covering supplier action required. E0P 55-3.00 which was revised March 29, 1978, mandates the use of the new fom.
- b. E0P 55-3.20 (Field Disposition Instruction) and fom FDI (Field Disposition Instructions) were also revised. The new FOI requires approval signatures of the responsible engineering manager and the materials application engineer.
E0P 55-3.20 was revised on March 29, 1978, and mandates the use of the new FDI form.
- c. All FDDRs and FDIs now receive a quality check before issue.
- d. The QA Comunicatior,: and Training Office is now conducting a course on field documentation systems which covers the procedural requirements for properly preparing FDIs, FDDRs, and DDRs. This course also covers the detailed interface in the field documentation system and how to most effectively utilize the system. Approximately 700 people have signed up to take the course as of July 25, 1978.
In the above unresolved item, some concern was expressed about the annual DDR and FDDR Trend Analysis Reports. In addition to the annual DDR and FDDR Trend Analysis reports there are monthly reports prepared by QA covering charts of Workload and Quality Tends. These reports have wide distribution to cognizant management and not only cover the trends of DDRs and FDDRs but also give the existing workload which provides a better means for statistical comparisons. Samples of these QA reports were examined by the inspector and appear to contain information necessary for appropriate action.
C. Product Acceptance of RHR (Residual Heat Removal) Heat Exchangers A review was conducted during this inspection of the surveillance activities and the procedures used to accept four (4) heat exchangers for the Susquehanna RHR heat removal system. The heat exchangers (MPL E11 B001) were manufactured by Montreal Locomotive Works and it was learned during a March 1978 NRC inspection that they
f contained defects. The defects were identified as welds on the impingement plates not meeting specifications and a hole in one tube of one heat exchanger.
This review disclosed the following:
- 1. Montreal Locomotive Works (MLW) produced four (4) heat exchangers all of which were shipped to Susquehanna. MLW was deleted from GE's Established Vendor List on June 29, 1976, and no further purchase orders were placed with MLW.
- 2. In a design review (RHR Heat Exchanger Design Review Report, November 24,1976) of the residual heat removal heat exchanger conducted over and above the independent design verification of the system, GE discovered that the welds specified for the shell side inlet nozzle impingement plates and their support bars were questionable. GE then developed a rework procedure to modify the impingement plate and welds to better accommodate the expected thermal stresses.
- 3. A hole in the U-bend of one tube of heat exchanger serial number 10638Q was discovered by a boilermaker craftsman when he removed the shipping cap of the RHR heat exchanger to modify the impinge-ment plate in accordance with GE retrofit instructions. After the shipping cap was removed it was also discovered that MLW had not met the specifications for welding on the impingement plate.
- 4. The shipping cap was removed by burning off the weld with equip-ment commonly called a stinger. It is possible the hole. could have been burned in the tube by dropping the stinger when removing the shipping cap or the hole could have been made at MLW when they removed the hydro cap with a stinger to install the shipping cap. The hole was repaired by plugging the tube f with the hole in it, plus the five (5) adjacent tubes which showed some heat discoloration. This would not affect operation of the heat exchanger as there are forty (40) repair tubes.
- 5. The above mentioned heat exchanger had successfully passed a hydro test at MWL on February 3,1976,(675 p.s.i. for one hour) which was witnessed and signed by the Interprovincial Government Inspector and the GE inspector. This would indicate there was no hole in the tube at the time of this final acceptance test. -
- 6. The tubing used in the RHR heat exchangers was purchased as U-Bend Condenser Tubes from Phillips Dodge and there was t
l a Certificate of Analysis and Test dated June 17, 1975, indicating the tubes were sound when shipped.
- 7. GE was using an itinerant inspector from the East Coast for ,
surveillance inspection and he was visiting Montreal Locomotive Works every other week. There were no hold or witness points for the welds on the impingement plates as this is not a pressure boundary area and their failure would not affect the successful operation of the RHR heat exchanger. Montreal Locomotive Works did not meet GE's specifications for the impingement plate welds and these welds would have been rejected had they been inspected by a GE inspector. GE has since made this an item for surveil-lance inspection.
- 8. GE has since procured additional RHR Heat Exchangers from four (4) other manufacturers and has not encountered any quality problems with them.
- 9. There were no apparant deviations or unresolved items identified in this area of the inspection.
D. Design Verification
- 1. Objectives The objectives of this area of the inspection were to determine that procedures have been established and are being implemented that:
- a. Identify individuals or groups who are authorized to perform design verification reviews.
- b. Require the results of the design verification effort to be clearly documented, with the identification of the verifier clearly indicated, and filed so they are identifiable to the document reviewed and can readily be retrieved.
- c. Require that the extent of design verification take into con-sideration the importance to safety, complexity, degree of standardization, state of the art, similarity with previously proven designs, applicability of standardized or previously proven designs, known problems and their effects, and changes to previously verified designs.
- d. Identify and document the method by which design verification is to be performed.
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- e. Identify the items to be considered during design verification
- by reviews including selection and incorporation of' inputs, necessary assumptions, quality. and QA requirements, codes,
. standards, regulations, construction ~ and operating expe-rience, interfaces, design method used, comparison of out- i put with input,: item application suitability, material compatibility, .and maintenance features.
- f. Prescribe the requirements for performing design ~ verifica :
tion by alternate calculations which shall include perform-ance by a person or persons other than those who performed
,the. original calculation, the review of appropriateness of assumptions, input data, and code or other calculation method used. The selection of method shall. provide- results consistent with the original calculation.
- g. Prescribe the requirements for performing design verifica-tion by qualification testing which shall include require-ments:
(1) For the identification, documentation, a demonstration of the adequacy of performance under the most adverse conditions, and consideration of all pertinent'op-erating modes. Where the test is only intended to-verify a .sp,cific design feature, the other features of- the desigr, shall be verified by other means.
(2) That testing bel performed in accordance with written test' procedures which incorporate or reference the test requirements, ' acceptance criteria limits and include. provisions for assuring that prerequisites for the'given test have been met, adequate instrumenta-tion of'the required range and accuracy is used, and that necessary monitoring is performed.
'(3) That test results1be documented and evaluated by the
- responsible designer and, if test results indicate the modifications to the item are needed, these
. modifications shall be' documented and the item modified, retested, or otherwise verified.
(4) That scaling' laws be established and verified for tests performed on models or mock-ups and the test configurations clearly defined and documented.
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(5) That the results of model test work be subject to error analysis, where applicable, prior to use in final design.
- 2. Method of Accomplishment The preceding objectives were accomplished by an examination of:
- a. Gener6i Electric Topical Report NED0-11209-04A which establishes QA program commitments including:
(1) Design verification covering the use of design reviews, alternate or simplified calculations methods or the performance of a suitable qualification test. This is described in Section 3, Design Control.
(2) Product acceptance covering the use of vendor surveil-lance and product quality certifications. This is described in Section 7, Control of Purchased Material, Equipment and Services.
(3) Identification of applicable procedures and instructions used to implement the program commitments which are described in Section 2, Quality Assurance Program.
- b. Implementing procedures to satisfy topical commitments and satisfy items (a) through (g) of the objectives section above, including:
(1) Engineering Operating Procedures:
E0P 25-4.00 Engineering Work Authorization E0P 35-3.00 Engineering Tests E0P 40-1.10 Design Control Program E0P 40-5.00 Engineering Document Release E0P 40-6.00 Independent Design Verification E0P 40-6.01 Design Calculations E0P 40-6.10 Engineering Document Issue and Application E0P 40-7.00 Design Review Program E0P 40-9.00 Design Certification E0P 40-10.00 Design Record Files E0P 65-2.10 Safety Importance Classification (2) BWR Projects Department Operating Policies and Procedures 25-2.0, Independent Design Reviews
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(3) Quality Control Standing Instructions: ,
QCSI 7.2.0 Quality System Description for Engineered Equipment and Installation QCSI 7.2.5 Final Inspection Product Release and Certification QCSI 7.2.12 Pre-Award Evaluation of Vendors QCSI 7.2.18 Quality Requirements on Material Requests and Purchase Orders (4) Quality Assurance - Engineered Equipment and Installa-tion Quality Assurance Requirements - I.
- c. Documents to verify implementation of topical commitments and procedural requirements and to satisfy implementation of (a) through (g) of the objectives section. These docu-ments are as follows:
(1) Design Record Files:
DRF 206-835-F060N*9, Flow Control Valsas DRF 912-C11-N*3, Control Rod Drive Hydraulic-System DRF 913-H13-2010-K, Control Room Panels Interface Control DRF 913-H13-4010-K, Main Control Room Panels DRF 147-C11D001-N*3, Hydraulic Control Unit BWR-6 DRF 944-006, Assy Rod Gang Drive Cabinet DRF 207-TR-SRV-X, Safety Relief Valves (2) Drawings and Specifications:
21A3884, Valves Recirculation Flow Control BWR-6 21A3873, Valve Flow Control L _ . _
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762E201, Heat Exchanger Residual Heat Removal System 762E221, Shell Residual Heat Exchanger MPL B21-F013, drawing no. 7567-000 6 x 10 Safety Relief Value 851E478BA, Elementary Diagram, Rod Control and Information System 762E429, Functional Diagram, Control Rod Drive Hydraulic System MPL H13 P651, Division One Rod Action Control Cabinet Supplement W/H13-U711 MPL H13 P62, Division Two Rod Action Control Cabinet Supplement W/H13-U710 MPL H13 P, Rod Gang Drive Control Cabinet Supplement W/H13-U711 MPL H13 2010, drawing number 828E425BA Control Room Panels Interface Control MPL H13 4010, specification number 22A3741AC, Panels, Main Control Room MPL H13 P653, drawing number 865E406, Assembly Rod Gang Drive Cabinet MPL H12 P651/2, parts list PL 865E140AA, Rod Action Control Cabinet 21A9206AM, General Requirement for Dual Function Safety / Relief Valve 22A4997, Qualification Specification Target Rock Safety / Relief Valve 9210898E, Safety Relief Valve (3) Field Disposition Instructions:
FDI 18/68754, Susquehanna Unit 1 FDI 9/68755, Susquehanna Unit 2
(4) Design Review Reports for:
BWR-6 Jet Pump Riser Brace Material Change RHR Heat Exchanger Duane Arnold Recirculation Inlet Replacement Safe End Design Concept Big Rock Point Core Spray Sparger and Baffle Kf Curves for BWR-5 Reactor Pressure Vessel Fluence Calculations Post LOCA General Electric Design Basis Additional Safety Relief Valve Testing at CA0RS0
- 3. Findings
- a. In this area of inspection, no deviations from commitment or unresolved items were identified.
- b. While reviewing verification statements, the inspector identified a concern with the method used by the verifier ,
to indicate his date of verification. This will be further evaluated in the next inspection.
E. Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on July 28, 1978. In addition to the individuals indicated by an asterisk in the Details Section those in attendance were:
J. Barnard, Manager Nuclear Energy Product and Quality Assurance Operation R. C. Boesser, Manager Quality Assurance and Operating Methods D. C. Brown, Manager, Quality Systems, Audits and Records A. I. Kaznoff, Manager, Product Assurance D. F. Ling, Engineering Services, Nuclear Energy Engineering Division J. L. Murray, Manager Quality Assurance, Nuclear Energy Engineering Division P. E. Novak, Manager, Engineering Systems Audits W. J. Roths, Reliability Engineering Operation, Nuclear Energy Engineering Division i
A. Rubio, General Manager, Nuclear Energy Control and Instrunentation Department L. V. Stonebraker, Specialist BWR Systems, Nuclear Energy Engineering Division
- 0. D. Terrell, Manager Engineered Equipment Procurement Group II The inspector summarized the scope and findings of the inspection, discussed the details- related to the closing of previous inspection findings, and reviewed the corrective action taken in regard to prod-uct quality certifications and surveillance activities for residual heat removal (RHR) heat exchangers. Managenent representatives acknowledged the statements of the inspectoi .
DETAILS SECTION II (Prepared by J. M. Johnson)
A. Persons Contacted C. E. Buckner, Specialist, Quality Assurar.ce Systems F. C. Downey, Project Manager R. R. Ghosh, Technical Leader, Steam Valves A. Gofstein, Quality Control Engineer
.R. C. Graeser, Design Engineer (Valves)
- G. R. Hosack, Manager Quality Audits G. Heinhold, Design Engineer (ECCS Pumps)
- J. A. Kahermanes, Senior Engineer, Quality Assurance and Operating Methods S. Widjaja, Design Engineer, Piping and Pump Design Unit
- D. E. Lee, Manager, Quality Control K. S. Manrao, Quality Control Engirieer
- J. K. Powledge, Manager, Quality Assurance, Engineered Equipment and Installation (EE&I)
W. E. Smith, Project Manager
- Denotes those present at the exit meeting.
B. Verification Activities
- 1. Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for verification activities that provide for:
- a. Qualified personnel (e.g. ANSI N45.2.6) to be assigned to check, inspect, audit or witness the activities of suppliers as early as applicable,
- b. The planning of verification activities including identifica- !
tion of the inspection sequence, hold and witness points, acceptance criteria, documentation required by the procure-ment.
- c. Implementing source surveillance including activities at supplier's facilities (i.e. inspections, audits).
- d. Measuring and test equipment including requirements for selection for accuracy and control sufficient to determine
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conformance to specified requirements and calibration and :
control to recognized standards to detemine validity of inspection and test results.
- e. Reporting results of source surveillance activities and evaluation of reports.
- 2. Method of Accomplishment The preceding objectives were accomplished by an examination of:
- a. General Electric Topical Report Number 11209-03A and 11209-04A, Sections 7, 10, 12, and 18.
- b. Implementing procedures to assure that procedural controls ,
have been~ provided to satisfy topical commitments and items (a) through (e) of the Objectives section above:
(1) BWR Quality Assurance Manual, Section 1, 4.7, 4.14, !
4.18.
(2) Product and Quality Assurance Operations Manual, P&QA0 Procedure 3.4.
(3) Engineering Operating Procedures Manual, E0Ps 45-6.00, 55-3.00, 55-3.20 and 75-2.10.
(4) Quality Control Standing Instructions Manual, QCSIs 7.2.5 (Final Inspection Product Release and Certifica-tion), 7.2.17 (Supplier Qual.ity System Audits and Corrective Action), 7.2.37 (Training, Examination and Certification of NDE Personnel), and 7.2.19 (Deviation Disposition Request). ,
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- c. Documents examined to verify implementation of above program and procedural requirements, and to satisfy implementation of (a) through (e) of Objectives section: !
(1) Audits of Vendors (for buy items) by EE&I (Engineered l Equipment and Installation).
(a) Audit of Target Rock dated June 30, 1978, and CARS (Corrective Action Requests) issued for five (5) deficiencies; time extensions for correc-tive action requested and granted; closure of 1
all CARS from prior audit 77-1 dated June 9,1977, including CAR concerning calibration. (Note that CAR Number TRC-78-1-4 dated June 8, 1978, will be examined later to review Target Rock
-response and GE closure.)
(b) Audit of Ingersoll-Rand dated April,1976, and status of four (4) CARS issued. (Note that GE has no recent procurements from Ingersoll-Rand except repairs.)
(c) Audit of Byron Jackson dated August 17-19, 1977, closure of CARS issued, and response to rec-ommendations.
(d) Audit of Bingham-Willamette dated October 11-13, 1977, closure of attached CARS, and response to recommendations.
(2) Audit of EE&I (including their vendor audit and sur-veillance activities) performed April 11-22, 1977, and closure of seven (7) CARS issued.
(3) Audits of GE shops (for make items) by P&QA0 (Product and Quality Assurance Organization):
(a) Audit Q7801 of C&ID (Control and Instrumentation Division) issued April 11, 1978, and status of twenty-three (23) CARS issued; prior audit of C&ID performed August 15 through October 11, 1977, and closure of nineteen (19) CARS issued.
(b) Audit Q7803 of Wilmington performed April 24 to May 12, 1978, and closure of fourteen (14) CARS issued.
(4) Vendor Surveillance Activities and Reports (for buy items) by EE&I for the following:
(a) LPCS (Low Pressure Core Spray) Pumps for la Salle 1 and 2 (dE P. O. (Purchase Order) 205-AC-765 from Ingersoll-Rand):
Component Notification Matrix attached to P. O.
to identify required hold points; Manufacturing and QC (Quality Control) Plan generated by Ingersoll-Rand showing hold and witness points for GE; Inspection Report of witnessing of Final Release Inspection and records review by GE-QC Representative for La Salle 2 pump; QA Record Binders for La Salle 1 and 2 pumps, including PQC (Product Quality Certification) and required quality records (note that this pump was not code stamped because it is a Class 2 item on old orders like this one); record of Perfonnance Test wit-nessed by GE-QC Representative for both pumps (notethatonepumpwaslatersentbackforrepair by the Licensee. A new PQC and a Surveillance Report were issued after repair by the GE-QC Representative. There was no performance retest after repair of this pump.)
(b) LPCS Pump for Zimmer (GE P. O. AC 764 (original purchase) and P. O. 205 G6A37 (repair of returned pump)) from Ingersoll-Rand:
QA Records Binder including two (2) PQCs (one original authorizing shipment to the site, and one after repair of the returned pump); P. O.
205-G6A37 to Ingersoll-Rand authorizing repair; GE-QC Inspection Report dated April 18, 1975, after return of pump for repair and rework, identifying the need to replace the shaft and one impeller; FDDRs (Field Deviation Disposition Requests) numbers KN 1-1 and KN 1-002 and FDIs Field Disposition Instructions) numbers 19/63000, 23/63000, and 38/63000, concerning the damage and repair of this pump; Equipment Surveillance Par-ameter List for repaired pump including dimensional check; QC Inspection Report dated August 14, 1975, for assembly of repaired pump; and QC Inspection Report regarding surveillance of packaging and release for shipment after repair, which states "a Performance Test was not run on this repaired pump."
(c) Safety Relief Valves for Hatch 2 from Target Rock:
Technical Specification number 21A9247, Revision 4, Sections 4 and 6; ten (10) Surveillance Inspec-
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tion Reports, including surveillance of assembly and testing; DDRs (Design Deviation Requests) numbers 106168,15204,15203, and 11356; and QA Records Binder.
(5) Vendor Surveillance for GE shops at San Jose and Wilmington is performed at facilities by shop QC personnel, and therefore was not examined during this inspection.
(6) Qualificationsandcertificationsofsix(6)QC Engineers and QC Representatives performing audits, of above GE and vendor facilities and surveillance of above vendor shops. Certifications were to ANSI N45.2.6 requirements and to NDT (Non-Destructive Testing) Methods as specified.
- 3. Findings
- a. No deviations or unresolved items were identified in this area of the inspection.
- b. Concerning items examined related to the LPCS Pump for Zimmer (which are identified in B.2.c.(4)(d) above),
although it appears that an additional FDDR should have been generated when the pump was sent to Ingersoll-Rand for repair, no finding was written because documentation of this action appeared retrievable. Also, GE's current training program on the use of the FDDR form, and GE's revision of the FDDR form and procedure, appear designed to prevent recurrence of FDDR inadequacies. These actions are related to GE audit findings, and were identified in the unresolved item from Inspection Report 78-01 which is discussed in Section I.B.2. of this Inspection Report (78-02).
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