ML20215C924

Insp Rept 99900403/86-03 on 860811 & 12.Nonconformance noted:nonsafety-related Refurbishment Kits for Scram Solenoid Pilot Valve Supplied in Place of safety-related Type FV 204-139 Kits

ML20215C924
Person / Time
Issue date:	09/24/1986
From:	Merschoff E, Naidu K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20215C884	List: ML20215C882 ML20215C900 ML20215C924
References
REF-QA-99900403 NUDOCS 8610100530
Download: ML20215C924 (7)

Text

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ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION INSPECTION DATES: 8/11-12/86 ON-STTF HOIIR9- 17 NO.: 99900403/86-03 CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operating ATTN: Mr. W. H. Bruggeman, Vice President and General Manager 175 Curtner Avenue San Jose, California 95125 ORGANIZATIONAL CONTACT: J. J. Fox, Senior Program Manager TELEPHONE NUMBER: 408-925-6195 NUCLEAR INDUSTRY ACTIVITY: General Electric Company (GE), Nuclear Energy Business Operations (NEB 0) provides spare parts and services to Boiling Water Reactors.

ASSIGNED INSPECTOR: M 94 K. R. Naidu, Reactive Inspectico Section (RIS) Date OTHERINSPECTOR(S): E. Yachimiak, RIS APPROVED BY: . 4[5%

E. W. Merschoff, Chief, T)T(, Vendor Program Branch Date INSPECTION BASES AND SCOPE:

A. BASES: Appendix B to 10 CFR 50 and 10 CFR Part 21.

B. SCOPE: Obtain additional information on kits used to refurbish scram solenoid pilot valves (SSPV) at Vermont Yankee (VY) Nuclear Pcwer Plant and review the 10 CFR Part 21 evaluation of unusual control rod movement on June 14,1986 at VY.

PLANT SITE APPLICABILITY: Vermont Yankee (50-271); Limerick (50-352); Pilgrim (50-293); Dresden 2 (50-237); Fitzpatrick (50-333), Hatch 1 (50-321); Browns Ferry 1 & 2 (50-250/260); Brunswick (50-324); Duane Arnold (50-331); LaSalle (50-373); Nine Mile Point (50-220) and Cooper (50-298).

%OINhh 99900403

ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-03 RESULTS: PAGE 2 of 7 A. VIOLATIONS:

None.

B. NONCONFORMANCE:

Contrary to 10 CFR 50, Appendix B, Criterion V, GE failed to follow Nuclear Service Procedure 30-03 dated August 1,1985 for the VY purchase order (PO) 2260 supplement I dated August 9, 1984. The VY nuclear power plant required GE to supply 200 safety-related scram solenoid pilot valve (SSPV) refurbishment kits (kits) type FV 204-139. GE supplied VY with 200 non-safety related kits instead, without resolving the discrepancy between the P0 and the supply with VY (86-03-01).

C. UNRESOLVED ITEMS:

Subsequent to the inspection, an internal GE memorandum was made available, only for review, to the NRC inspector at the GE, Bethesda office on September 10, 19E6. From this and other related information it appeared that GE, San Jose, had not adecuately reviewed or evaluated the safety implications of the incorrect performance of VY SSPVs. The statement from GE "...the random, small number of occurrences of these discrepancies eliminate any potential safety impact...." does not constitute the basis for an adequate evaluation. The possibility that a number of discrepant SSPVs causing excessively long scram times does exist since five (5) of the VY SSPVs failed to initiate control rod motion until 5 to 7 seconds had elapsed.

Final Safety Analysis Peport transient analyses for BWRs usually allow on the order of 200 milliseconds from the initiation of a scram to the start of control of rod movement. Since the inspectors were not provided any supporting evidence to show that the sicwer scram times would not consti-tute a substantial safety hazard, this item is considered unresolved and open pending receipt of further information.

D. INSPECTION FINDINGS AND OTHER COMMENTS:

1. Background Information On June 14, 1986, during single rod scram time testing, VY nuclear power plant reported that one control rod failed to scram and five others hesitated a few seconds before scramming. The failure of these control rods to function correctly was attributed to the failure of their respective SSPVs. These valves were refurbished by VY personnel with replacement kits that were supplied by GE, San Jose, California and manufactured by Automatic Switch Company (ASCO),

located in Florham Park, New Jersey.

ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-03 RESULTS: PAGE 3 of 7 Three types of problems were identified in the faulty SSPVs. In one SSPV, the core assembly spring was separated from the core assembly.

This was attributed to improper assembly techniques. In another valve, on the exhaust side of the SSPV, the diaphragm was installed backwards. This was again due to improper assembly techniques. In four SSPVs, an incorrect core assembly was provided in the kit. This was attributed to personnel at ASCO selecting the incorrect core assembly which was not detected due to inadequate component QC inspections at ASCO.

Subsequent inspection of the remaining SSPVs found (1) one valve with a deformed core assembly spring and (2) one solenoid base sub-assembly with an out-of-round inside diameter. Both these conditions could have prevented free travel of the core assembly and could have adversely affected the scram performance.

2. Review of GE Purchase Orders The NRC inspectors examined GE P0s to ASCO for the supply of refur-bishment kits type FV204-139 to ascertain whether they were purchased as safety related items, and whether GE required ASCO to perform appropriate Quality Control (QC) inspections. Review of GE P0s during the period of February 1984 to July 1986 indicates that the quality requirements imposed on ASCO increased progressively with time. The following are the details of the review:

a. GE P0 #334-AL421 dated February 14, 1984 to ASCO required the supply of 3000 SSPV FV204-139 type refurbishment kits. GE

imposed QC plans A-42 and A-196 respectively. QC plan A-42 did

( not contain specific inspection requirements.

Similarly, QC plan A-196 described a quality assurance plan with 18 criteria and stated that this plan was applicable to items i

classified as " safety essential." The term " safety related" l was not mentioned in the P0. GE stated that they used the l

term " safety essential" as the predecessor of the term " safety I related." The above mentioned GE P0 referenced neither 10 CFR Part 21 nor 10 CFR Part 50 Appendix B.

b. GE PO #205-85-F848 dated July 8, 1985, required ASCO to supply 60 SSPV FV206-139 type refurbishment kits. Revision 1 to the l PO dated August 16, 1985, required ASCO to provide cure dates i on the 0-Rings and seals used in the kits. Revision 2 to the F0 dated September 10, 1985 required the cure date to be not more l

I

ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-03 RESULTS: PAGE 4 of 7 than 18 months prior to date of shipment. Revision 3 to the P0 dated November 16, 1985 changed the classification of the kits from non-safety-related to safety related. Revision 4 to the P0 dated November 21, 1985 stated that GE QAR 9, Revision 0 was applicable. The change in classification in Revision 3 to the GE P0 required ASCO to impose on itself, as per ASCO's QA program, ASCO QC procedure PP-467, " Scheduling Nuclear Power Customer Orders." This procedure required ASCO to perform additional QC inspections on individual components contained in the kits because the components are specifically intended for SSPVs installed in nuclear power plants,

c. GE P0 #205-86K032 dated April 14, 1986, required ASCO to supply 300 SSPV FV204-139 type refurbishment kits. This P0 stated that GE QAR 5, Revision 3 was applicable and required a GE representative to inspect the kits at ASCO prior to shipment.

ASCO treated these kits as safety-related and accepted 10 CFR Part 21 reporting requirements. The NRC inspectors reviewed the documents at ASCO for this GE P0 during an inspection conducted July 18-20, 1986 and determined that ASCO implemented their QC procedure PP-467 and stamped the cure dates for the 0-rings and seals on the individual blister packages.

3. Inspections Program by GE for Refurbishment Kits The inspectors discussed the types of inspections performed by GE, before and after July,1986 on SSPV refurbishment kits, which are shippeo in blister packs by ASCO to GE and determined the following:

a. Prior to July,1986, GE personnel verified the following attributes during receipt of each lot of SSPV refurbishment kits:

1. Visual verification that the identification on the blister pack is FV204-139.

2. Receipt of a certificate, accompanying the shipment, stating

" Identical replacement without change in design or material per GE QC plan A-42."

3. Document the lot number identifying means of traceability.

4. Compare that the cure date information on the ASCO certif-icate agrees with the information on the individual blister packs.

ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION RESULTS: PAGE 5 of 7 NO.: 99900403/86-03

b. Af ter July 17, 1986, GE issued P0s to ASCO imposing a pre-kit quality control inspection checklist identified as Vendor Print File (VPF) 3061-83-1. VPF #3061-83-1, which was developed with the cooperation of ASCO, requires ASCO to perform 100% inspection on the components in each kit. The plan specifies dimensional and visual inspection requirements. The NRC inspectors deter-mined that this inspection plan contains adequate quantitative acceptance / rejection criteria.

4. Review of the Vermont Yankee Purchase Order Vermont Yankee (VY) issued P0 #22601 dated April 25,1984 to GE for the supply of 100 safety related Pilot Head kits, GE part #236X558-14.

Appendix D,Section III item d of the P0 stated in part, "...the requirements of 10 CFR Part 21 do not apply to replacement parts when the parts are not supplied with IEEE-323 certification." Item 3 of Supplement 1 to this P0 dated August 9, 1984, increased the quantity from 100 units to 200 units and revised the identification of the kit as part number FV204-139. Appendix A,Section III of the supplement required a certification to the effect that the materials utilized in the fabrication of replacement are identical to material utilized in the fabrication of the original components. The classification of the kits as safety related remained unaltered.

GE issued two Product Quality Certificates (PQC) dated June 26, 1984 and November 2, 1984 to VY. Each referenced a " delivery to shipment" traceable to the shipping documents and certified that 100 kits tret the applicable purchase documents. GE stated that the 200 kits shipped to VY were stored at VY and subsequently used to refurbish the SSPVs which experienced rod movement problems in June 1986.

5. Results of the Inspection

a. The NRC inspectors determined that GE supplied VY 200 non-safety-related FV204-139 type refurbishment kits instead of safety related kits. Documents reviewed at GE indicate that these kits were from a batch of 3000 kits procured by GE P0 #332-AL421 dated February 14, 1984. The GE Nuclear Service Procedure (NSP) 30-03 in paragraph 3.3.1 states that it is the responsibility of the Personnel of S,+ and Renewal Parts to review the customer P0 to assure ti.3 accuracy of the specifications inciu-aing the appropriate quali W assurance requirements. Paragraph 3.3.2 states in part that tu discrepancies between GE and the customer shall be resolved prior to formal acceptance of tne

l ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA REPORT INSPECTION RESULTS: PAGE 6 of 7 NO.: 99900403/86-03 customer Purchase Order. Resolution of discrepancies will be reached by GE management, quality assurance and customer and shall be documented by P0 change or other written documentation signed by the customer.

GE stated that they did not obtain a reconciliation from VY to supply 200 non-safety related kits (instead of safety related).

The NRC inspectors informed the GE representatives that failure to follow GE procedure NSP 30-03 to obtain a reconciliation from VY for the variance in the safety classification of the kits is considered a failure to follow procedures and identified this failure as a nonconformance contrary to the requirements of Criterion V of 10 CFR 50 Appendix B (86-03-01).

The NRC inspectors determined that GE supplied the following nuclear power plants with refurbishment kits from the same batch of 3000 received from ASCO.

Plant Quantity Shipped Date of Shipment Limerick 50 06/13/84 Pilgrim 15 06/21/84 Vermont Yankee 100 06/25/84 Pilgrim 8 06/27/84 Dresden 2 50 08/03/84 Fitzpatrick 100 09/05/84 Vermont Yankee 100 11/05/84 Hatch 1 75 04/08/84 Browns Ferry 100 12/12/84 Brunswick 217 01/14/85 Hatch 1 100 02/28/85 Dresden 2 75 03/01/85 Brunswick 2 03/12/85 Hatch 100 03/14/85 Duane Arnold 180 03/26/85 LaSalle 150 03/27/85 Nine Mile 1 100 04/02/85 Cooper 150 04/12/85 Duane Arnolo ISO 04/25/85 Browns Ferry 2 140 11/14/85 Millstone 1 150 11/15/85

b. NRC issued Information Notice 86-78 alerting all BWR owners of the problems associated with the ASCO SSPV refurbishment kits.

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ORGANIZATION: GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA 1

REPORT INSPECTION NO.: 99900403/86-03 RESULTS: PAGE 7 of 7 I

c. GE issued SIL No. 441, dated July 17, 1986, recommending corrective action for all BWR owners. This consisted of the following:

1. Continued control rod surveillance per Technical Specifications to detect SSPV performance deterioration,

2. Return of all unused SSPV Replacement Kits FV 204-139 to GE for reinspection,

3. Inspection for correct engagement of the coil spring onto the core assembly for all kits during SSPV refurbishment

- at the reactor site, and

4. Verification of SSPV operability through scram valve time tests or single rod scram time testing.

E. EXIT INTERVIEW:

The inspectors met with the GE representatives identified in Section F and discussed the scope of the inspection and findings.

F. PERSONS CONTACTE0:

• J. J. Fox, QA Operations E. Gibo, Systems Engineer D. Arnold, Manager, Material Logistics W. Dye, Senior Buyer

• J. M. Bricken, CC Engineer

• B. A. Smith, CA Operations C. Lewis, CA Operations R. T. Hill, Licensing R. T. Kern, Electrical Design Engineer R. Waldman, Electrical Design Engineer i *H. P. Williams, Material Services Engineer l

• Denotes those persons who were present at the exit interview on August 12, 1986.

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