NUREG-0040 

Vol. 23, No. 3

Licensee Contractor and

Vendor Inspection 

Status Report 

Quarterly Report 

July - September 1999 

U.S. Nuclear Regulatory Commission 

Office Nuclear Reactor Regulation 

Washington, DC 20555-0001
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NUREG-0040 

Vol. 23, No. 3 

Licensee Contractor and 

Vendor Inspection 

Status Report 

Quarterly Report 

July - September 1999 

Manuscript Completed: June 2000 

Date Published: June 2000 

Division of Inspection Program Management 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001
ABSTRACT

This periodical covers the results of inspections performed between July 1999 and 

September 1999 by the NRC's Quality Assurance, Vendor Inspection, Maintenance and 

Allegations Branch that have been distributed to the inspected organizations.

iii
CONTENTS 

PAGE 

A b stra ct ....................................................................................................................... iii 

In tro d u ctio n ................................................................................................................... v ii 

Inspection R eports .............................................................................................. . . ... 1 

ABB-Combustion Engineering, Inc. (99900401/1999201) ............................. 2 

Windsor, CT 

GENE (99900403/1999201) .......................... 14 

San Jose, CA 

Select Generic Correspondence on the Adequacy of Vendor .................................. 20 

Audits and the Quality of Vendor Products

v
INTRODUCTION

A fundamental premise of the U. S. Nuclear Regulatory Commission (NRC) licensing and 

inspection program is that licensees are responsible for the proper construction and safe and 

efficient operation of their nuclear power plants. The Federal government and nuclear industry 

have established a system for the inspection of commercial nuclear facilities to provide for 

multiple levels of inspection and verification. Each licensee, contractor, and vendor participates 

in a quality verification process in compliance with requirements prescribed by the NRC's rules 

and regulations (Title 10 of the Code of Federal Regulations). The NRC does inspections to 

oversee the commercial nuclear industry to determine whether its requirements are being met 

by licensees and their contractors, while the major inspection effort is performed by the industry 

within the framework of quality verification programs. 

The licensee is responsible for developing and maintaining a detailed quality assurance (QA) 

plan with implementing procedures pursuant to 10 CFR Part 50. Through a system of planned 

and periodic audits and inspections, the licensee is responsible for ensuring that suppliers, 

contractors and vendors also have suitable and appropriate quality programs that meet NRC 

requirements, guides, codes, and standards. 

The NRC reviews and inspects nuclear steam system suppliers (NSSSs), architect engineering 

(AE) firms, suppliers of products and services, independent testing laboratories performing 

equipment qualification tests, and holders of NRC construction permits and operating licenses in 

vendor-related areas. These inspections are done to ensure that the root causes of reported 

vendor-related problems are determined and appropriate corrective actions are developed. The 

inspections also review vendors to verify conformance with applicable NRC and industry quality 

requirements, to verify oversight of their vendors, and coordination between licensees and 

vendors. 

The NRC does inspections to verify the quality and suitability of vendor products, licensee

vendor interface, environmental qualification of equipment, and review of equipment problems 

found during operation and their corrective action. When nonconformances with NRC 

requirements and regulations are found, the inspected organization is required to take 

appropriate corrective action and to institute preventive measures to preclude recurrence. 

When generic implications are found, NRC ensures that affected licensees are informed through 

vendor reporting or by NRC generic correspondence such as information notices and bulletins.

vii
This quarterly report contains copies of all vendor inspection reports issued during the calendar 

quarter for which it is published. Each vendor inspection report lists the nuclear facilities 

inspected. This information will also alert affected regional offices to any significant problem 

areas that may require special attention. This report lists selected bulletins, generic letters, and 

information notices, and include copies of other pertinent correspondence involving vendor 

issues.

viii
INSPECTION REPORTS

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A UNITED STATES 

:, NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-000i 

Septerter 8, 1999 

Mr. Ron Fitzgerald, Director 

Quality Assurance 

Dept. 9500-1926 

ABB-Combustion Engineering, Inc. 

2000 Day Hill Road 

Windsor, CT 06095 

SUBJECT: NRC INSPECTION REPORT 99900401/1999201 

Dear Mr. Fitzgerald: 

This letter addresses the inspection of your facility at Windsor, Connecticut, conducted by Bill Rogers and Stephen Alexander of this office on June 30 through July 1, 1999. Following the 

onsite portion of the inspection, the NRC staff performed additional review of materials at the 

NRC office and conducted a final exit meeting, by telephone, on August 5, 1999, during which 

we discussed the findings with your staff. 

Areas examined during the inspection are discussed in the enclosed report. This inspection 

consisted of an examination of procedures and representative records, interviews with 

personnel, and observations by the inspectors. 

During this inspection, it was found that the implementation of your Quality Assurance program did not meet certain NRC requirements. ABB-Combustion Engineering, Inc., (CE) had not 

performed suitable qualification testing of a representative sample or performed an analysis to 

demonstrate the environmental qualification of the subject Litton-Veam electrical connectors 

installed in the Core Exit Thermocouple system provided to Palo Verde Nuclear Generating 

Station (Palo Verde). CE had not shown, with moisture present in the Litton-Veam connector 

during a portion of the environmental qualification test, that the single connector configuration tested would be representative of the installed multiple connector configuration at Palo Verde or 

that performing the environmental qualification test of the connector with the thermocouple 

maintained at a single temperature, would be representative of connector performance 

throughout the thermocouple operating range of the installed configuration at Palo Verde.

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Mr. Fitzgerald

Please provide us within 30 days from the date of this letter a written statement in accordance 

with the instructions specified in the enclosed Notice of Nonconformance. We will consider 

extending the response time if you can show good cause for us to do so. 

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its 

enclosure will be placed in the NRC Public Document Room (PDR). 

Sincerely, 

Theodore R. Quay, Chief 

Quality Assurance, Vendor Inspection, Maintenance 

and Allegations Branch 

Division of Inspection Program Management 

Office of Nuclear Reactor Regulation 

Docket No. 99900401 

Enclosures: (1) Notice of Nonconformance 

(2) Inspection Report 99900401/1999201

-3-

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NOTICE OF NONCONFORMANCE

ABB-Combustion Engineering, Inc. Docket No. 99900401 

Windsor, Connecticut 

Based on the results of an inspection conducted on June 30 through July 1, 1999, it appears 

that certain of your activities were not conducted in accordance with NRC requirements. 

A. Criterion III, "Design Control," of 10 CFR Part 50, Appendix B, "Quality Assurance Criteria 

for Nuclear Power Plants and Fuel Reprocessing Plants," requires in part that "measures 

shall also be established for the selection and review for suitability of application of 

materials, parts, equipment, and processes that are essential to the safety-related functions 

of the structures, systems, and components," "the design control measures shall provide for 

verifying or checking the adequacy of design, such as by the performance of design 

reviews, by the use of alternate or simplified calculation methods, or by the performance of 

a suitable testing program," and "where a test program is used to verify the adequacy of a 

specific design feature in lieu of other verifying or checking processes, it shall include 

suitable qualifications testing of a prototype unit under the most adverse design conditions." 

Section 50.49 of 10 CFR Part 50 requires environmental qualification of core exit 

temperature instrumentation as follows: Section 50.49 requires qualification of electrical 

equipment important to safety as defined in Paragraph 50.49(b). Subparagraph 50.49(b)(3) 

specifies certain post-accident monitoring equipment. Subparagraph (b)(3) invokes, in 

associated Note 4, the specific guidance of Revision 2 of Regulatory Guide 1.97, 

"Instrumentation for Light-Water-Cooled Nulcear Power Plants to Assess Plant and 

Environs Conditions During and Following an Accident." Table 2, "PWR Variables" of 

Regulatory Guide 1.97, Under "Type C Variables" lists core exit temperature as a variable 

required to be monitored by Category I instrumentation. 

Contrary to the above, ABB-Combustion Engineering, Inc., (CE) had not performed suitable 

qualification testing of a representative sample or performed an analysis to demonstrate the 

environmental qualification of the subject Litton-Veam electrical connectors installed in the 

Core Exit Thermocouple system provided to the Palo Verde Nuclear Generating Station 

(Palo Verde). CE had not demonstrated, with moisture present in the Litton-Veam 

connector during a portion of the environmental qualification test, that performing an 

environmental qualification test of a single connector configuration would be representative 

of the installed multiple connector configuration at Palo Verde or that performing the 

environmental qualification test with the thermocouple maintained at a single temperature, 

would be representative of thermocouple operation throughout the thermocouple operating 

range of the installed configuration at Palo Verde. 

(Nonconformance 99900401/1999201-01) 

Enclosure 1

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Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, 

ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Chief, Quality 

Assurance, Vendor Inspection, Maintenance and Allegations Branch, Division of Inspection 

Program Management, Office of Nuclear Reactor Regulation, within 30 days of the date of the 

letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a 

"Reply to a Notice of Nonconformance" and should include for each nonconformance: (1) a 

description of steps that have been or will be taken to correct these items; (2) a description of 

steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective 

actions and preventive measures were or will be completed. 

Dated at Rockville, Maryland 

this 8th day of September 1999

2

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i-I

U.S. NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION

Report No: 

Organization: 

Contact: 

Nuclear Activity:

Dates:

Inspectors: 

Approved by:

99900401/1999201 

ABB-Combustion Engineering, Inc. 

Ron Fitzgerald, Director 

Quality Assurance 

Designs, manufactures and supplies various safety-related systems to 

NRC Licensees

June 30 - July 1, 1999

Bill Rogers, Reactor Engineer 

Stephen Alexander, Reactor Engineer 

Richard Correia, Chief 

Reliability and Maintenance Section 

Quality Assurance, Vendor Inspection, Maintenance 

and Allegations Branch 

Division of Inspection Program Management

Enclosure 2

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I INSPECTION SUMMARY

On June 30 - July 1, 1999, the U.S. Nuclear Regulatory Commission (NRC) performed 

an inspection at the ABB-Combustion Engineering, Inc., (CE) facility in Windsor, 

Connecticut. Subsequent to the onsite portion of the inspection, the staff performed 

additional review of materials at the NRC office and performed the final inspection exit 

meeting during a telephone conference on August 5, 1999. 

The inspection was conducted to review selected portions of CE's quality assurance 

(QA) program, and its implementation, and the applicable programs and procedures 

used to design, manufacture and supply safety-related systems to NRC licensees. 

Specifically, the inspectors reviewed CE's activities related to the CE qualification of 

Litton-Veam electrical connectors used in the Core Exit Thermocouple system 

supplied to the Arizona Public Service Co. (APS), Palo Verde Nuclear Generating 

Station (Palo Verde) and other NRC licensees. 

The inspection bases were: 

• 10 CFR Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power 

Plants and Fuel Reprocessing Plants." 

* 10 CFR 50.49, "Environmental Qualification of Electric Equipment Important to 

Safety for Nuclear Power Plants" 

• 10 CFR Part 21, "Reporting of Defects and Noncompliance." 

2 STATUS OF PREVIOUS INSPECTION FINDINGS 

No previous finding were reviewed during this inspection. 

3 INSPECTION FINDINGS AND OTHER COMMENTS 

3.1 Background 

On October 24, 1998, Palo Verde issued Licensee Event Report (LER) 98-008 which 

indicated that the CE qualification reports used to document the environmental 

qualification of Litton-Vearn electrical connectors for the Core Exit Thermocouples 

(CET) used in Combustion Engineering plants may not adequately demonstrate 

appropriate equipment qualification. The LER stated that the CE qualification testing, 

of a single Litton-Veam connector containing one thermocouple circuit, did not 

represent the installed configuration at Palo Verde which contained multiple Litton

Veam connectors wired with several circuits. 

The LER indicated that the multiple connector, multiple circuit configuration was not 

accurately represented since, during a portion of the CE qualification test, moisture 

2

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had been present inside the Litton-Veam connector. The LER indicated that CE had 

not accounted for the possible system interactions caused by the moisture present in 

the Litton-Veam connectors which might occur with additional connectors and circuits. 

The LER identified five general areas, all related to moisture intrusion, which APS had 

determined could potentially affect qualification: (1) system interaction related to 

multiple circuits, (2) system interaction related to multiple connectors, (3) maintaining 

the thermocouple at a single temperature during the qualification test, (4) the use of a 

supplemental Battery Effects Test to support qualification, and (5) the use of the 

Quality Safety Display Parameter Display System (QSPDS) to support qualification. 

APS had determined that it would no longer use the original CE qualification reports to 

support the environmental qualification of the Litton-Veam connectors used for the 

CET system. APS had concluded that the use of an alternate Litton-Veam connector 

qualification report provided by the Litton-Veam company, combined with the action of 

replacing the Litton-Veam square section connector seal each time the connector was 

disconnected, demonstrated and maintained the environmental qualification of the 

Litton-Veam connectors used in the Palo Verde CET system. 

CE had reviewed the APS LER, documented the existence of the LER and CE's 

conclusions in a November 4, 1998, letter, and provided this letter to other applicable 

NRC licensees. The CE conclusion was that CE had demonstrated the qualification of 

the Litton-Veam connectors and that the connector seals were not required to be 

replaced each time the connector is disconnected. 

3.2 General Scope of Inspection and Environmental Qualification Requirements 

The purpose of the inspection was to determine whether CE had taken adequate 

actions to demonstrate and document the environmental qualification of the Litton

Veam connectors as installed in the application at Palo Verde and other NRC 

licensees. 

The inspectors reviewed the environmental qualification documentation prepared by 

ABB/CENP (then CE Power Systems) (CE) for the CET system, including cables and 

connections, supplied by CE to APS for installation at Palo Verde as post-accident 

monitoring equipment (Category 1, Type C Variable) as prescribed by Regulatory 

Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess 

Plant and Environs Conditions During and Following an Accident," Revision 2, dated 

December 1980 (RG 1.97) and required to be environmentally qualified by 10 CFR 

50.49(b)(3). 

The documentation reviewed included CE Nuclear Power Systems Report No. 14273

PE-5800, "Core Exit Thermocouple -.Mineral Insulated Cable Environmental 

Qualification Program for Arizona Nuclear Power Project Palo Verde Nuclear 

Generating Station," Revision 02, dated December 1, 1987; Report No. 14273-PE

5802, "Income Instrument Assembly Environmental Qualification Program for Arizona 

Nuclear Power Project Palo Verde Nuclear Generating Station," Revision 01, dated 

July 30, 1987; and related documents. The inspectors also interviewed cognizant CE 

3

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staff, reviewed drawings of the tested equipment and examined samples of the tested 

equipment types. 

3.3 Review of Test Results For the General Effects of Moisture Intrusion and Multiple 

Circuit Interaction 

a. Inspection Scope 

The inspectors performed a review to determine whether CE had adequately demon

stated that the apparent moisture intrusion into the Litton-Veam connectors observed 

during a portion of the CE environmental qualification test would not have an 

unacceptable, adverse effect on the performance of the CETs being qualified for the 

multiple circuit application at Palo Verde 

b. Observations and Findings 

The inspectors examined the actual chart recorder output from the CETs during the 

CE environmental qualification test. The charts indicated that the signal from the 

CETs was steady and within the margin of error prescribed by Item II.F.2 of NUREG

0737 as referenced in RG 1.97 (+/-22 0 F) with respect to the reference thermocouples 

throughout the CE environmental test with the exception of a few seconds of 

perturbation roughly corresponding to the peak pressure transient near the beginning 

of the loss-of-coolant-accident (LOCA) simulation. 

The CE environmental qualification report stated that the cable and connectors 

contained copper wires to simulate the presence of the ex-core leads for the rhodium 

detectors of the neutron flux, In-Core Instrumentation (ICI) system (a non-safety related system). These leads were open ended in the thermocouple oven, as they 

would be in an installation, then passed through the LOCA chamber in the cables and 

the single Litton-Vearn connector and were terminated outside the LOCA chamber at 

a terminal block set up to facilitate measurement of insulation resistance to ground. The CET element itself was grounded to its probe sheathing at the junction. 

According to the report, periodically during the testing, CE measured the insulation 

resistance to ground of each of the ICI leads with all the others grounded. The 

insulation resistance eventually deteriorated to as low as 2500 ohms to ground, 

measured at 10 Vdc. Examination of samples of the stainless steel-clad and mineral

insulated, multi-conductor cable and the Litton-Veam connectors of the type used in 

the equipment qualification test and installed at Palo Verde, as well as the drawings 

used to build the test specimens, confirmed the description of the tested configuration in the qualification report. Regardless of the low insulation resistance to ground, 

which was attributed principally to the moisture intrusion into the Litton-Veam 

connector, the CET output signal, as stated previously, was apparently unaffected. 

The inspectors also performed a review to determine the effect, if any, of the 

interaction between the CET signal and any electrical signal that may be present on 

any of on the ICI wires. The inspectors determined the following: (1) the ICI rhodium 

detectors are only used to provide very low amplitude (below the mV range) pulses for 

4

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an indication of power range neutron flux distribution during reactor operation, (2) the 

ICI signal drops off to an undetectable level after reactor shutdown as neutron flux 

decays into the source range, and almost immediately with the boration of the coolant, 

and (3) no detectable neutron flux signal would be expected from the rhodium detector 

circuits, in the Litton-Veam connectors, when the CETs must perform their post 

design basis accident safety function. In addition, the inspectors determined that any 

effect of the presence of the ICI wires would have been indicated during the 

qualification test because representative wires were installed the tested cable and 

connectors. 

c. Conclusion 

The inspectors concluded that CE had adequately configured the test specimen to 

represent the multiple circuits present in the Palo Verde installation. The 

documentation of the test results indicated that the connector functioned adequately, 

with the moisture present during a portion of the environmental qualification test, with 

respect to multiple circuits. The inspectors did not identify a concern in this area. 

3.4 Review of Test Results Related to Multiple Connector Interaction 

a. Inspection scope 

The inspectors performed a review to determine whether CE had adequately demon

stated that the moisture intrusion into the Litton-Veam connectors observed during a 

portion of the CE environmental qualification test would not have an unacceptable, 

adverse effect on the performance of the CETs being qualified for the multiple 

connector application at Palo Verde. 

b. Observations and Findings 

The CE qualification reports for the CET equipment at Palo Verde did not address the 

potential effects of multiple connectors. The tested equipment included a single 

Litton-Veam connector exposed to the harsh environment of the LOCA simulation. 

The Palo Verde qualification report did not contain an analysis to reconcile the 

difference between the tested configuration and the configuration of the equipment 

installed at Palo Verde which could contain as many as five Litton-Veam connectors 

between the containment penetration and the reactor vessel head. The inspectors 

determined that CE had not configured the test or performed an analysis to 

demonstrate that there would not be an interaction between multiple connectors, due 

to moisture discovered during a portion of the environmental qualification test, and 

therefore that CE had not demonstrated that a single connector would be 

representative of a multiple connector application. 

The inspectors reviewed a qualification report prepared by Southern California Edison 

(SCE) for the CE vessel head instrumentation connection system (including the CETs) 

installed at its San Onofre Nuclear Generating Station (SONGS), SCE EQ Document 

Package SONGS Unit No. 2 & 3 M38382, Revision 5, dated September 6,1996. The 

5 

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I I If
qualification report contained or referenced several CE environmental qualification documents that had also been used in support of the qualification of the CET cable 

and connector system at Palo Verde. The SCE document also contained analyses 

intended to address the limitations of those CE documents. 

The inspectors determined, based on a limited review, that the SCE analysis may have had technical relevance to the issues of multiple connectors with the presence of 

moisture in the connector. However, CE had not prepared a review of the SCE 

analysis that was applicable to Palo Verde or included the SCE analysis in the Palo 

Verde qualification package. 

c. Conclusion 

The inspectors concluded that CE had not performed suitable qualification testing of a 

representative sample or performed an analysis to demonstrate that the single 

connector configuration, with moisture present during a portion of the environmental 

qualification test, would be representative of the installed multiple connector 

configuration at Palo Verde. This was identified as an example in Nonconformance 

99900401/1999201-01. 

3.5 Review of Test Results Related to Maintaining the Thermocouple at a Single 

Temperature During the Qualification Test 

a. Inspection scope 

The inspectors performed the review to determine whether CE had adequately. 

demonstrated that maintaining the thermocouple at a single temperature during the 

CE environmental qualification test was representative of the installed configuration at 

Palo Verde considering the effect of the presence of moisture in the connector during 

a portion of the qualification test. 

b. Observations and Findings 

The inspectors reviewed the CE environmental qualification reports to determine 

whether CE had adequately demonstrated that testing the CET system with the 

temperature of the oven that contained the thermocouple element (external to the 

LOCA chamber) being held at a constant 4000 F, was representative or predictive of 

the performance of the CET over the entire temperature range of 200°F to 2300°F 

through which the instrument is supposed to be qualified as prescribed by Table 2 of 

RG-1.97, considering the potential effects of the moisture intrusion. 

The CE qualification reports for the CET equipment at Palo Verde did not address the 

effect of subjecting the thermocouple to its full temperature range during the 

qualification test. The testing was performed while maintaining the thermocouple at 

400'F for which, at this temperature, the thermocouple would produce approximately 8 mV. Neither the environmental qualification test, nor the qualification report, accounted for any potential differences which could be experienced if the 

6

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thermocouple was heated throughout its operating range and produced 

correspondingly higher voltages (at 2300°F the thermocouple would produce 

approximately 50.8 mV) with consideration of the effects of the presence of moisture 

in the Litton-Veam connector. 

The inspectors determined, based on a limited review, that the SCE analysis 

(previously discussed in Section 3.4) may have had technical relevance to the issues 

of the system response to the full range of CET output voltage with the presence of 

moisture in the connector. However, as stated previously, CE had not prepared a 

review of the SCE analysis that was applicable to Palo Verde nor included the SCE 

analysis in the Palo Verde qualification package. 

c. Conclusion 

The inspectors concluded that CE had not performed suitable qualification testing of a 

representative sample or performed an analysis to demonstrate that performing the 

environmental qualification test with the thermocouple maintained at a single 

temperature, with moisture present in the Litton-Veam connector during a portion of 

the qualification test, would be representative of the installed configuration at Palo 

Verde. This was identified as an example in Nonconformance 99900401/1999201-01. 

3.6 Review of the Battery Effect Test 

a. Inspection Scope 

The inspectors performed a review to determine whether CE used the CE Test Report 

No. CE NSPD-230P, Supplement 1-P, (Battery Effects Test) to support the 

qualification of the CET system, including the Litton-Veam connectors, and whether 

demineralized water was representative of the composition of the moisture that would 

be present during a LOCA in the Palo Verde containment and could penetrate the 

degraded connector seals. 

b. Observations and Findinqs 

Review of the Battery Effects Test report revealed that demineralized water and a 

solution of Boric Acid consistent with containment chemical spray was used during the 

Battery Effects Test. Further, according to the report, the two halves of the tested 

connector were mated while submerged in the test solutions to ensure complete 

penetration of the solution into the space between the connector faces and among the 

conductor pins. The test was intended to assess the potential severity of the possible 

electro-chemical effects of this moisture under the worst-case conditions, but there 

was no indication that the environmental qualification depended on the results of this 

test, nor that CE had intended to take credit for it to support the environmental 

qualification. 

7

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c. Conclusion

The inspectors concluded that CE had performed a supplemental test to assess the 

potential effects of a worst case situation but there was no indication that the test was 

required for the original environmental qualification nor was there indication that the 

supplemental test invalidated any portion of the original qualification. The inspectors 

did not identify a concern in this area. 

3.7 Review of the QSPDS Input Signal Processing Algorithm 

a. Inspection Scope 

The inspectors reviewed the documentation relating to the input signal processing 

algorithm for the quality safety parameter display system (QSPDS) to determine 

whether it could be expected to accommodate signal errors resulting from the 

moisture intrusion into the Litton-Veam connectors which was observed during a 

portion of the environmental qualification test. 

b. Observations and Findings 

The inspectors determined that there was a potential for increased uncertainties in the 

CET signal resulting from moisture intrusion into the CET cable connectors. The error 

had been determined to be able to exceed the specified tolerance for the CET signal 

on individual channels on a random basis. However, review of the associated 

documents and interviews with cognizant CE staff indicated that the QSPDS signal 

processing algorithm would be capable of rejecting erroneous signals, intermittent or 

sustained, from the various CETs such that the value of core exit temperature 

eventually displayed at any given time would be expected to represent a valid 

temperature. The inspectors determined that the QSPDS at Palo Verde is used for 

monitoring various safety-related parameters, but is not the primary instrumentation to 

be used by operators in executing the emergency operating procedures. 

c. Conclusions 

The inspectors concluded, on the basis of the review of the CET signal conditioning 

algorithm used by the QSPDS, that there was reasonable assurance that the QSPDS 

could accommodate the errors that might be introduced into the CET output signals by 

moisture intrusion into the CET cable connectors during a LOCA and still determine 

and display a valid core exit temperature value. The inspectors did not identify a 

concern in this area. 

4 PERSONS CONTACTED 

Ron Fitzgerald, Director Quality Assurance 

Joseph Burger, Supervisor Field Services 

Ted Bernard, Senior Project Manager 

Mike Linden, Project Manager 

Virgil Paggen, Licensing Engineer 

Ed Sirica, Consulting Engineer Reactor Equipment 

8

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UNITED STATES 

o iNUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

August 5, 1999 

Mr. Kenneth Brayman 

GENE 

175 Curtner Ave. 

M/C 117 

San Jose, CA 95127 

SUBJECT: NRC Inspection Report 99900403/1999201 

Dear Mr. Brayman: 

On July 20, 1999, the U.S. Nuclear Regulatory Commission (NRC) performed an inspection at 

the GENE facility in San Jose, California. The enclosed report presents the findings of that 

inspection. The inspection was conducted to review selected portions of your program relating 

to the supply of reactor vessel material surveillance capsules to the nuclear industry. This 

inspection specifically focused on activities related to the supply of the capsules for vessels 

manufactured by Chicago Bridge and Iron Works. The inspectors assessed GENE's 

conformance to their customer's procurement requirements and compliance with NRC 

regulations. Within the scope of this inspection, we found no instance in which GENE failed to 

meet NRC or customer requirements. 

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its 

enclosures will be placed in the NRC's Public Document Room. 

Sincerely, 

Theodore R. Quay, Chief 

Quality Assurance, Vendor Inspection, Maintenance and 

Allegations Branch 

Division of Inspection Program Management 

Office of Nuclear Reactor Regulation 

Docket No. 99900403 

Enclosure: Inspection Report 99900403/1999201 

-14-
U.S. NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION

Report no: 

Organization: 

Contact:

99900403/1999201 

GENE 

Kenneth Brayman 

(408) 925-6587

Nuclear Activity:

Date:

Inspectors: 

Approved by:

Manufacturer and supplier of components and services to the 

nuclear industry.

July 20, 1999

Gregory C. Cwalina, Senior Reactor Engineer 

Matthew Mitchell, Materials Engineer 

Richard P. Correia, Chiek 

Reliability and Maintenance Section 

Quality Assurance, Vendor Inspection and 

Maintenance Branch 

Division of Inspection Program Management

Enclosure

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1 INSPECTION SUMMARY

The NRC inspectors examined documentation related to the fabrication of reactor 

pressure vessel (RPV) surveillance specimens and surveillance capsules. Specifically, 

the inspectors reviewed the documentation for the surveillance materials and capsules 

associated with the RPVs manufactured by Chicago Bridge and Iron Works (CB&I) for 

four BWR/6 units (Clinton 1, Grand Gulf 1, Perry 1, River Bend 1) in the United States. 

Pertaining to the above, the inspectors examined the traceability of these materials to 

the original RPV materials. 

No violations or nonconformances were identified. 

2 STATUS OF PREVIOUS INSPECTION FINDINGS 

No previous inspection findings were examined during this inspection. 

3 INSPECTION FINDINGS AND OTHER COMMENTS 

3.1 Review of the Fabrication History of Reactor Pressure Vessel Surveillance 

Specimens and Surveillance Capsules 

a. Inspection Scope 

The NRC inspectors reviewed GENE document files related to the fabrication of 

RPV surveillance specimens and surveillance capsules associated with RPVs 

fabricated by CB&I. Specifically, the inspectors reviewed the documentation for 

four BWR/6 facilities in the United States: Clinton 1, Grand Gulf 1, Perry 1, and 

River Bend 1. The inspection traced the documentation on the surveillance 

materials from the Certified Material Test Reports (CMTRs) for the RPV plate 

and weld materials; to the CB&I procedures for and records of fabrication for the 

surveillance specimens; to the shipping and receipt information as the 

specimens were transferred from CB&I to GE; and, finally, to the documentation 

on the fabrication of the capsules and their shipment to the facilities. 

b. Observations and Findings 

b.1 Document Review 

The GENE documentation was presented in two categories: generic documents 

which were referenced or used in the development of each plant-specific case, 

and plant-specific documents. The package of generic documents included: 

Document No. 21A9477, "Purchase Specification Reactor Pressure 

Vessel" 

Document No. 21A9507, "Purchase Specification Reactor Pressure 

Vessel (RPV), Surveillance Samples" 

* GE Drawing 166B7063, "Charpy Impact Specimen" 

* GE Drawing 137C5365, "Charpy Impact Specimen" 

S QOCCI No. C-102.01, "Certification Procedure for Surveillance Program 

(SP), P/L 83X629 G001, G002"

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CB&I procedure STP-10, "Surveillance Test Specimen Preparation Plan," 

which defined the surveillance test specimen preparation plan that was 

used at CB&I for cutting, machining, and marking the Charpy specimens 

supplied for the GE surveillance programs. 

The documentation provided in the plant-specific files began with the GE 

Purchase Orders for each of the RPVs and accompanying surveillance 

specimens. It continued with the Vendor Print File (VPF) associated with the 

surveillance test specimen production for each of the RPVs. The VPFs for each 

facility examined contained: 

CMTRs for the RPV plates and weld materials used to fabricate the 

surveillance specimens * Welding procedures used to fabricate the surveillance welds 

• Heat-treatment history for the surveillance materials 

* Results of the non-destructive examinations (NDE) on the surveillance 

plates and weldments 

Cutting, machining, and dimensional -verification and marking procedures 

used on the finished Charpy specimens. GE Product Quality Certification records that were required when the 

surveillance specimens were transferred from CB&I to GE and when the 

finished surveillance capsules were shipped from GE to the facilities. 

b.2 Traceability 

The inspectors review of the traceability of the surveillance materials and the 

documentation that accompanied them identified four primary tracking numbers 

associated with the surveillance materials for each RPV, as shown in the 

following table. 

Reactor General CB&I Vendor Reactor 

Vessel Electric Contract Production File Vessel Code 

Purchase Order Number Number Number 

Number 

River 205-H8968 73-C112 3614-651-1 72 

Bend 1 

Clinton 1 205-H8989 73-6735 3653-615-1 78 

Perry 1 205-AE028 73-C108 3521-502-1 70 

Grand 205-AE027 73-C109 3519-738-1 67 

Gulf 1 

Table 1 - RPV Tracking Numbers 

In addition, each material type (surveillance plate, weld, and heat-affected zone 

(HAZ)) for each RPV's surveillance program was identified at CB&I and GE by a 

unique identifier as listed below.

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Heat affected zone [ P3 

Table 2 - Material Type Identification

The GE Purchase Order Number linked the documentation for a RPV to the 

appropriate CB&I Contract Number and Vendor Print File Number for the 

fabrication of the surveillance program specimens. The CB&I contract number 

was the primary identifier of the documentation used to record the fabrication 

history (heat treatment, NDE, etc.) associated with the surveillance material for 

each RPV along with the P-number to identify which specific material was being 

discussed. In some cases, the reactor vessel number was used on the 

documentation (in lieu of the CB&I Contract number) along with the appropriate 

P-number since this also uniquely identified the RPV material to which the 

documentation applied. 

Regarded the traceability of the surveillance materials themselves, the 

inspectors' noted that CB&I procedure STP-10 required that the original blocks 

of surveillance material be uniquely marked using the appropriate material P

number and the CB&I Contract Number. After sectioning into sub-blocks 

(approximately 7 inches by 6 inches by 3 inches), each sub-block was marked 

with the material P-number, CB&I Contract Number, and Reactor Code Number. 

Prior to cutting the Charpy specimens from the sub-block, the P-number and 

Reactor Code Number were stenciled on either end of what would become a 

finished Charpy specimen. This Charpy specimen marking convention was 

consistent with GE Drawing 166B7063, as referenced in CB&I procedure STP

10. Therefore, the inspectors concluded that, throughout this process, positive 

control was established for maintaining specimen identity and traceability. 

The inspectors reviewed the material traceability process for the specimens 

during shipping to GE's Wilmington, North Carolina facility for insertion into the 

surveillance capsules. In one case (Clinton 1) this was a direct shipment from 

CB&I, while the others went via GE's San Jose facility. When the specimens 

arrived at Wilmington, they were inspected and the results appropriately 

documented. The inspectors found two characteristic comments noted on the 

receipt documentation for each surveillance material shipment: first, no 

certification documents were sent along with the specimens and second, the 

material samples were not marked in accordance with the GE drawing. 

The first comment can be resolved by noting that all of the GE Product Quality 

Certification Documents were maintained at San Jose and were readily 

reproduced for this NRC inspection. The GE Quality Control procedures for 

surveillance program certification (QCCI No. C-1 02.01) did not require that the 

certification documentation be sent to Wilmington with the specimens. The 

-18-

I I II
inspectors were satisfied that maintaining the documentation at GENE, San 

Jose, was acceptable. 

The second comment stemmed from the fact that in the time between when the 

specimens were fabricated by CB&I (in the 1974 - 1975 time frame) and when 

they were received at Wilmington (in 1978), a new GE drawing on Charpy 

specimen fabrication had been produced (Drawing 137C5365). This drawing 

required that base material specimens be marked with a "B," weld material 

specimens with a UW," and HAZ materials with an "H," instead of the P-number 

designation used by CB&I (see Table 2 above). It was this drawing, 137C5365, 

that was being used by the GE staff during receipt inspection at the Wilmington 

facility, which resulted in their decision to have the specimens remarked. The 

NRC inspectors' noted that this remarking did not compromise the traceability of 

the material since it was evident that the Wilmington staff knew the correlation 

between the P-number marking and the material type such that they could 

unambiguously have them remarked before insertion into the capsules. The 

documentation regarding the shipment of the capsules to the appropriate facility 

was also reviewed and found to be in order. 

c. Conclusions 

Based on the information reviewed by the inspectors, it was concluded that the 

documentation provided by GENE for the four BWR/6 RPV surveillance 

programs was sufficient to assure traceability of the materials to the material 

used to manufacture the reactor pressure vessels. 

LIST OF PERSONS CONTACTED 

James Klapproth, Manager, Engineering and Technology 

Thomas Caine, Manager, Structural Assessment and Mitigation 

Louis Quintana, Manager, Nuclear Services Quality 

Betty Branlund, Technical Leader, RPV 

Kris Kotak, Desgn Engineer 

Patrick O'Neil, Co-op student

-19-
Selected Generic Correspondence on the Adequacy of 

Vendor Audits and the Quality of Vendor Products

Identifier 

Information Notice 99-25 

Information Notice 99-28

Title 

Year 2000 Contingency Planning Activities 

Recall of Star Brand Fire Protection Sprinkler Heads

- 20 -
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (2-89) (Assigned by NRC, Add Vol., Supp., Rev., NRCM 1102, and Addendum Numbers, if any.) 3201, 3202 BIBLIOGRAPHIC DATA SHEET 

(See instructions on the reverse) NUREG-0040 

2. TITLE AND SUBTITLE Vol. 23, No. 3 

Licensee Contractor and Vendor Inspection Status Report 3. DATE REPORT PUBLISHED 

Quarterly Report MONTH YEAR 

July-September 1999 June ___ 2000 

4. FIN OR GRANT NUMBER 

5. AUTHOR(S) 6. TYPE OF REPORT 

Quarterly 

7. PERIOD COVERED (Inclusive Dates) 

July-September 1999 

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor, 

provide name and mailing address.) 

Division of Inspection Program Management 

Office of Nuclear Reactor Regulation 

U. S. Nuclear Regulatory Commission 

Washington, DC 20555-0001

9. SP-UNSUI'NG'L UORGANIL.RI IlUN - NAMEI: ANDi ADDUURESS (If NRC, type 'Same as above',; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address.) 

Same as above

11. ABSTRACT (200 words or less) 

This periodical covers the results of inspections performed by the NRC's Quality Assurance, Vendor Inspection and 

Maintenance Branch, that have been distributed t the inspected organizations during the period July through September 1999.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT 

Vendor Inspection unlimited 14. SECURITY CLASSIFICATION 

(This Page) 

unclassified 

(This Report) 

unclassified 

15. NUMBER OF PAGES 

16. PRICE

NC( FUOM 435 (2-89)

IV. 0UrFP'LrFIrNIA lMT 4UIC'O
Federal Recycling Program
NUREG-0040, Vol. 23, No. 3 LICENSEE CONTRACTOR AND VENDOR INSPECTION STATUS REPORT 

JULY - SEPTEMBER 1999

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, DC. 20555-0001

years

JUNE 2000