IR 05000387/1979020
| ML17138B372 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/03/1980 |
| From: | Ebneter S, Gage L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17138B368 | List: |
| References | |
| 50-387-79-20, NUDOCS 8006240584 | |
| Download: ML17138B372 (17) | |
Text
U.
S.
NUCLEAR'EGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Repor t No.
50-387/79-20 Docket No.
50-387 License No.
CPPR-101 Priority Licensee:
Penns lvania Power and Li ht Com an Category 2 North Ninth Street Allentown Penns 1 vani a 18101 Facility Name:
Sus uehanna
Investigation At:
Allentown Penns lvania and Berwick Penns lvania Investigation Conducted:
Jul 26 and 27.
Au ust
9 and
October 29 and
and November and 6-9 1979 Investigators':
g
=
L. Gage, Reactor nspector'ate Accompanied by:
S.
Ebneter Section Chief for exit interview)
Approved by:
'
c<f <<Y~,
S.
Ebneter, Engsneerlng Support Section date No. 2, RC8ES Branch Investi ation Summar
Investi ation on Jul 26 and 27 Au ust
9 and
October 29 and 30.
and November 2 and 6-9
.1979 Re ort No.
0-38 9-2
~A" I
I d:
II di Ig I
I Iiggf Ig I 1nspectson actlvsties associated with interconnecting cables in the Power Gener-ation Control Complex (PGCC),
a part of the Advanced Control Room.. The investi-gation involved 69 inspection hours by one regional based investigator.
Results:
Neither of the aTTegations investigated were found to be substantiated.
However, two items of noncompliance with regulatory requirements were identified:
Infraction failure to provide independence to persons performing quality as-surance functions, for the PGCC (paragraph III.H), and Deficiency failure to assess effectiveness of the contractor's quality control department (paragraph III.I).
Region I Form 167 (August 1979)
8 OOBR 40~
Oi
I.. ~BB TABLE OF CONTENTS A.
Reason for the Investigation B.
Identification of Involved Organizations
.
II.
Summar of Findin s
A.'llegations and Investigation Findings B.
Conclusions III. Details A.
Persons Contacted B.
General C.
Site Effort Pri'or to NRC Investigation 0.
Review of the Management of the Si'te Effort E.
Completion of the Site Effort F.
NRC Conclusions Regarding Allegation No.
G.
NRC Findings and Conclusions Regarding Allegation No.
H.
Review of the Procurement of the ACR/PGCC I.
G.E; Product guality Certification (P(Cs)
J.
Exit Interview
I.
BACKGROUND A.
Reason for the Investi ation On July 20, 1979, Region I received a telephone call from an unidentified individual.
He read a prepared statement regarding the Susquehanna Unit 1 site which contained allegations of: (1) inadequate inspections of inter-connecting cables in the Power Generation Control Complex (PGCC),
and (2)
collaboration among Pennsylvania Power and Light Company, General Electric Company, NRC,- and ".
.
. possibly Bechtel (Power Corporation) to abort full inspection
.
.."" of the interconnecting cables.
An investigation of the allegations contained in the statement was initiated by the NRC, Region I, on July 26,,1979.
The investigation was conducted at the Susquehanna Unit 1 site and at the Pennsylvania Power and Light Com-pany's corporate office in Allentown, Pennsylvania.
B.
Identification of Involved Or anizations 1;
Pennsylvania Power and Light Company (PP8L)
Two North Ninth Street Al1 entown, Pennsyl vania 18101 A utility that has been issued a Construction Permit by the NRC for Susquehanna Unit 1.
2.
Bechtel Power Corporation (Bechtel)
Fifty Beale Street San Francisco,. California 94119 This company is responsible to PP8L for construction of Susquehanna Unit 1.
3..
General Electric Company (G.E.)
175 Curtner Avenue San Jose, California 95125, This company is responsible to PP8L for construction of the Nuclear Steam Supply for Susquehanna Unit I, including the PGCC.
quoted from NRC internal memorandum dated July 23, 1979 of the telephone conversation with the unidentified individua II.,
SUMMARY OF FINDINGS A.
,Alle ations and Investi ation Findin s
The NRC representative investigated the allegations made by the unidenti-fied individual during his telephone call to the NRC on July 20, 1979.
The allegations and the NRC findings on each are as follows:.
1.
Allegation No.
,""Mhen this inspection was commenced four months ago, it was 100K inspection of everything, with an 80K to 90K failure rate.
Since then almost every other day there have been inspection procedure changes.
It is to the point where the majority, 80K of the work done, is not even seen by the guality Control and what little checking the elec-tricians do does not insure the integrity of these cables.
"Mhat I am saying is that they have changed the procedures in such a
way as to make the inspections meaningless."
The NRC investigation found that the inspection procedures had been changed, that the changes reduced the total inspection effort (by substituting a sampling plan for a 100K inspection plan), but that the procedural changes did not result in making the inspections mean-ingless.
2.
Allegation No.
""I have never seen such sloppy, hastily done work as is visible in almost'll these GE cable terminations.
There is-no doubt in my mind that GE, PAL, NRC and possibly Bechtel collaborated to abort full inspection in an effort to save time and money."
The, NRC investigation found. no evidence to support the allegation that'lmost all the cable terminations exhibited sloppy, hastily done work and that GE, PPRL, NRC and Bechtel coll'aborated to, save time and money.
The evidence indicated that the vast majority of cable termi-nations were satisfactory.,
There was no evidence of collaboration among the involved organizations to abort inspections; there was evi-dence of PAL, Bechtel and GE wor king together in a client-contractor relationship; there was no evidence of the NRC working with any of the other involved organizations.
quoted from NRC internal memorandum of July 23, 197 B.
Conclusions There was no substantiation found for either of the allegations.
However, two items of noncompliance with regulatory requirements were identified during the investigation:
CFR 50, Appendix B, Criterion I, states:
".
.
. persons and organi-zations, perform'ing quality assurance functions shall report to a man-agement level such that this required authority and organizational freedom, including sufficient independence from cost and schedule
.
are provided."
However, from a review of the project files for 1973-1979, including the minutes of the scheduled monthly meetings that were held at G.E.
between 1977-1979 it was evident that PP&L's Engineering Depart-ment was responsible for (1) quality assurance for the ACR/ PGCC equipment, as well as for (2) expediting deliveries of this equipment when the schedule slipped.
Thus, the requirement for independence of quali'ty assurance functions was not achieved.
This was further sub-stantiated by interviews with PP8L personnel.
This, item is an Infraction.
2.
.10 CFR 50, Appendix B, Criterion VII, states:
"Measures shall be estab-lished to assure that purchased materials, equipment...conform to the procurement documents....The effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant...."
The-PP8L preliminary Safety Analysis Report, in paragraph D.4.9. 1, states:
"For essential items of equipment
.
.
. for which there are no.code requirements for record retention or transmittal, designated quality records such as
.
.
. inspection and test data will be pro-vided.to, or provisions made for maintenance for the owner
.
PP8L, gA Manual Procedure 8. 1 specifies that the Manager-Nuclear gua-lity Assurance. is.responsible for timely evaluation of the proposed contractors gA/gC system by auditing the contractors operations or by-reviewing the. documents which described his gA/gC system.
Contrary to the above, General Electric, a contractor, supplied defec-tive power generation control compl'ex electrical equipment to the project with product quality certificates which certified "that the products identified herein have been manufactured under a controlled quality assurance program..."
The licensee had not carried out a timely evaluation of the effec-
.tiveness of the contractor's quality control department responsible for the quality control of the defective equipment and preparation of the certificate of quality.
This is a deficienc III.
DETAILS Persons Contacted Penns lvania Power and Li ht Com an (PP8L N. Curtis, Vice-President, Engineering and Construction and Project Director
"A. Derkacs, Group Supervisor, I8C J.
Green, Resident'NQA Engineer
"M'. Gulliver, Sr. Project Engineer, NQA
"J.
Kauffman, Executive Vice-President, Operations
~S.
Kuhn, Project Engineer, Electrical
"A. Male, Assistant Manager, Nuclear Plant Engineer
~A. Sabol, Manager, NQA
"R. Schwan, Supervising Engineer, NQA
"R. Shovlin, Assistant Project Director Bechtel Power Cor oration Bechtel)
/
N. Covington, Test Engineer A..Bisesti, Supervisor, Engineering H. Lilligh, Supervisor, Quality Assurance General Electric Com an G; E.)
P. Briggs, Supervisor, C8IO Quality Assurance R. Post, Consultant B. Moodward, Manager, PGCC Programs U.
S. Nuclear Re ulator Commission R. Gallo, Resident Inspector denotes those attending the exit interview General The Region I office of the NRC Office of Inspection and Enforcement
~received information from an unidentified individual alleging inadequacy in certain aspects of the PP8L inspection program underway at the Susque-hanna Unit 1 site:
namely, the inspection of interconnecting cables in the Power Generation Control Complex (PGCC).
The PGCC, a part of the Advanced Control Room (ACR), is manufactured by G.E.
This investigation was conducted to review those aspects of the inspection program and to determine the validity of the allegations made by this individual.
This information was provided by a telephone call on July 20, 1979.
It was documented in an internal NRC "memorandum to file", dated July 23, 197 c.
Site Effort Prior to NRC Investi ation The NRC.investigator ex'amined the work in progress at the site and reviewed
. the inspection history of the PGCC cables.
As stated in the G.E. "Test and Analysis Report PGCC Cable Nonconformances,"
dated April 27, 1979:
"During October, 1978, Susquehanna site personnel noted while doing rework to shorten cables that some pins were coming off of conductors.
This occurred as operators used the conductor as a handle to complete the removal of partially extracted pins from connector inserts.
The forces
'esulting on the crimped joint would be between one and twenty pounds, depending on the pin size, the connector type and the degree to which the pin had been "started" with the extraction tool.
Nicks and cuts were also observed on the insulation of some conductors, extending 0-2 inches from the pin."
As a result of this, a site inspection program was instituted by Bechtel (the constructor)
under the direction of PP8L per G. E.
s Field Disposition Instruction (FDI) No.
WJGO, Revision No. 1, dated January 30, 1979.
This program required that each connector on each "SITS/FITS" cable manufactured at the G. E.
San Jose, California facility (with the exception of Twinax, Thermocouple, Coaxial, Honeywell Computer, and Annunciator cables)
be inspected.
The'cceptability of each connector was determined by:
'a.
A visual inspection of the assembled and disassembled connector b.
A pull test of each pin in the connector (to a predetermined value, dependent on the size of the wire crimped to the pin)
c.
An electrical test at each pin (a continuity test and a high-potential test of each pin to all other pins)
This program was subject to 100K surveillance by the Bechtel site guality Control department.
In June of 1979, this inspection program was changed.
The inspection his-tory accumulated in the preceding months convinced the licensee and G.E.
that a sampling inspection, rather than a 100K inspection of the connector pins, would be enough to assure them that the cables would function properly in service.
As stated in the Bechtel letter of June 13, 1979 to PP8L:
"The following is a summary of the deficiencies discovered in the 433 PGCC cables inspected:
a.
Nine failures were noted when pull testing ¹14 AWG conductors.
A total of 2,630 conductors were tested and. each failure occurred on a different connector.
b.
Fifty-five failures were noted when pull testing ¹20 AWG conductors.
A total of 2,720 conductors were tested.
The failures were found on
12 different connector assemblies, one connector having 15 failures, one with 12, one with ll, two with 3, two with 2, and the rest having only one failure per connector."
(This can be translated into a 0.34K failure rate for 014 AWG conduc-tors; a 2.02K failure rate for 820 AWG conductors; a 1.20K failure
= 'ate for all conductors; or a 4.85K failure rate for all cables inspected.)
G.E. Field Deviation Disposition Request (FDDI) No.
KR1-548, Revision 7,
'ated May 22, 1979 was instituted.
The acceptability of each connector was determined by:
a.
A visual inspection of the assembled and partially disassembled con-nector (six pins would be extracted, without complete disassembly)
b.
A pull test of each of the six extracted pins
'.
An electrical test (a continuity test of each previously extracted pin and a high-potential test of each pin in the connector to all other pins)
If any failures were experienced, the connector would be disassembled and 100K of the pins would be pull-tested and continuity tested.
When safety-related ("g") cables were involved, the site g.C.
department performed 100X surveillance; when non-safety cables were involved, the site g.
C; department performed surveillance on 20K of the cables being inspected.
In early July of 1979, another change was made in the inspection program:
per G.E.
FDDR No.
KR1-548, Revision 11, dated June 29, 1979, a special clamping device was approved.
It permitted the pins to be pull-tested
.without partial disassembly of the connector.
On July 23, 1979, the NRC received allegations from an unidentified indivi-dual regarding the adequacy of the new PGCC cable-connector inspection pro-gram, as compared with the original inspection program.
On September 28, 1979, G. E. sent the NRC a letter advising of a reportable condition per 10 CFR Part,21 for a similar-type defect in related equipment.
It stated:
"Defective crimps were found on pins used in connectors in the 72C.'nsert for panel H12-P853 for the Susquehanna plant...
It was deter-mined that a combination of manufacturing personnel error and crimping tool malfunction as a result of inadequate gA was responsible for the defective crimps.
The defect consists of a crimp which cannot meet the required pull for c Review of the Mana ement of the Site Effort The NRC investigator interviewed members of the PPBL Engineering Department, who were responsible for approving the site inspection program for the PGCC cable connectors.
(These interviews were conducted at the licensee's corpo-rate office in Allentown).
The investigator requested the PP8L Engineering Department to provide their rationale for substituting the sampling i.nspec-tion program for the original 100K inspection program.
They provided G. E.
s
"Response to PAL on NRC Cable guestions, Susquehanna ACR/PGCC," dated August 21, 1979, which stated that:
"The 6 pin per connector rate was selected for the Susquehanna 1 cables based on the results of (G.E.'s) gA's analysis of the distribution of low force crimps.
"
.
.
. Further reasons for 6/connector (instead of 100K) include:
a)
Engineering evaluation concluding that low mechanical strength crimps would have no effect on the electrical performance of conductors during their 40-year design life.
b)
gA's desire to disturb the cables as little as possible during the re-inspection.
The unavoidable flexing and stressing of conductors and components associated with pull testing all interior crimps was considered undesirable.
c)
A lOOX inspection is rarely 100K effective, and could not be expected to assure perfect crimps."
G. E. further stated that their sampling plan met the requirements of MIL-STD-
.105D, "Sampling Procedures and Tables for Inspection by Attributes," a nationally recognized sampling plan, when an acceptance quality level (AgL) of 0.65 was applied to the defective pins found. A(L is defined, per MIL-STD-105D, as
.
.
. "the maximum percent defective (or the maximum number of defects per hundred units) that, for purpose of sampling inspection, can be con-sidered satisfactory as a process average."
G. E. also stated that, based on their survey of the AgL assigned to other product lines, 0.65 was appropriate for'GCC cables.
On October 23, 1979, a meeting was held at PP8L's corporate offices in Allentown.
PP8L, G.E., Bechtel and the NRC were present at the meeting.
G. E. introduced Dr.
R. Post, a consultant, and a professor of statistics in the California state college system, who elaborated on their "Response to PP8L on NRC Cable guestions, Susquehanna ACR/PGCC" to provide further subst'antiation for their sampling plan.
However, subsequent to the NRC investigator's interviews with PP8L and subsequent to the meeting with G. E., per the direction of the PP8L Engi-neering Department, the inspection program was again modified (per FDDR No.
KR1-548, Revision 39, dated August 31, 1979).
The acceptability of each connector would be determined by lOOX inspection of the pins an
'inspection program that was essentially in accordance with the requirements of FDI No.
WJGO, Revision No.
1.
E.
Com letion 'of the Site Effort The NRC investigator asked the licensee to define the status of those con-nectors that,had previously been inspected in accordance with the sampling plan:
would they be re-inspected to provide 100K pin inspection and pull testing?,
The licensee stated that they were reviewing the status of these connectors and would advise the NRC of their decision.
On December 6, 1979, they provided the NRC with a copy of a letter from PP&L to,Bechtel, dated December 4, 1979.
This letter required Bechtel to ".
.
. proceed to re-inspect these sampled connectors to a 100X pull test.
Pull test crite-ria shall be taken from FDI WJGO."
F.
NRC Conclusions Re ardin Alle ation No.
The unidentified individual s first allegation, as quoted from the NRC internal memorandum of July 23, 1979, was:
"When this inspection was commenced four months ago it was 100K inspection of everything, with an 80X to 90K failure rate.
Since then almost every other day there have been inspection procedure changes.
It is now to the point where the majority, BOX of the work done, is not even seen by guality Control and what little checking the electrici'ans do does not insure the integrity of these cables.
"What I am saying is that they have changed the procedures in such a way as to make the inspections meaningless."
The NRC investigator concl,uded that the inspection procedures were not changed in such a way as to make the inspections meaningless.
They were changed to reduce the total inspection effort, substituting a sampling plan for 100K inspection.
G.
NRC Findin s and Conclusions Re ardin Alle ation No.
The unidentified individual s second allegation, as quoted'rom the NRC i'nternal memorandum of'July 23; 1979, was:
"I have never seen such sloppy, hastily done work as is visible in almost all these GE cable terminations.
There is no doubt in my mind that GE, PP8L, NRC and possibly Bechtel collaborated to abort full inspection in an effort to save 'time and money."
The NRC investigator performed a surveillance of the inspection program in progress on the PGCC cables, on July 26 and 27, 1979.
The inspections were being conducted by electricians employed by Bechtel.
Mechanical and elec-trical testing, and disassembly and reassembly of the connectors appeared
to be carried out in a careful, methodical manner.
Inspection results were being documented, and Bechtel quality-control personnel were in evidence.
During this investigation, the NRC investigator interviewed various person-nel employed by PP&L, Bechtel and G.E.,
as well as the NRC resident inspec-tor.
The investigator also reviewed contracts and correspondence between PP&L and Bechtel, PP&L and G.E.,
and Bechtel and G.E.,
from the inception of the purchase order for the ACR/PGCC in 1973 to the present day.
In addi-tion, the investigator reviewed all NRC inspection reports for Susquehanna
that involved the ACR/PGCC.
(These included Report Numbers 50-387/79-07, dated February 22, 1979; 50-387/79-14, dated March 19-23, 1979; and, 50-387/
79-18, dated April 30 - June 8, 1979).
The NRC investigator concluded that there was no evidence of collaboration among the involved organizations to abort meaningful inspections in order to save time and money.
There was evidence that PP&L, Bechtel and G.E.
were working together in client-contractor relationships to attempt to save time and money, but nothing to indicate an attempt to allow "sloppy
.
work" to pass inspection.
There was no evidence of the NRC working with any of the other organizations.
Review of the Procurement of the ACR/PGCC The NRC investigator examined the procurement records for the ACR/PGCC, at the licensee's corporate office in Allentown, to determine if the procure-ment was conducted in accordance with the licensee's preliminary Safety Analysis Report and with the quality assurance requirements of 10 CFR 50, Appendix B.
The ACR/PGCC was purchased by PP&L from G.E.
under Amendment No.
1 to the nuclear steam contract for the Susquehanna Steam Electric Station.
Among the applicable documents referenced in the Amendment is Specification No.
8856-J-l, "Control Room Systems."
In paragraph 1.8, it requires that G..E.
provide a quality assurance program that in essence follows the criteria of 10 CFR 50, Appendix B.
PP&L's Engineering Department administered the procurement, and on January ll, 1974 issued a letter to the Bechtel Power Corporation designating them as the "Authorized Project Representative."
As a part of this obligation, Bechtel was to provide quality assurance ser-vices to the PP&L Engineering Department.
Per PP&L's letter of February 14, 1974 to Bechtel:
"Bechtel will establish a surveillance and audit program
.
.
. for G.E.'s quality assurance program and facilities.
The investigator looked for evidence that PP&L Engineering, via Bechtel, performed quality-assurance surveillance of G. E. during critical stages of fabrication, inspection and testing of the ACR/PGCC.
He found none except for Bechtel's Engineering Department Project Instruction (EDPI) No.
2. 14.2, which describes the assignment of two Bechtel representatives to G.E.'s
factory during final system factory test.
However, the investigator deter-mined, from interviews with the PP&L Project Director and with one of the Bechtel representatives assigned to G.E., that quality assurance surveil-lance was not a part of their assignment.
The investigator asked the PP&L Engineering Department if any customer
,notification points (CNPs)
had been established for the ACR/PGCC.
(Per Bechtel Project Amendment,Section VI, No. 7, "titled "Quality Assurance Audits and Customer Notification Points (CNPs) for NSSS Contract," dated December 9, 1975:
Bechtel would "Coordinate with client and a Bechtel cognizant observer in preselected and established CNPs at the NSSS Con-tractor and NSSS Contractor's Supplier facilities to verify critical manu-facturing and testing operations.")
No CNPs had been established for the ACR/PGCC.
The investigator asked the PP&L Quality Assurance Manager to describe the role of his own Quality Assurance Department in the conduct of this pro-curement.
He indicated that PP&L Q.
A. took part in joint audits, with Bechtel, of G. E. for the nuclear steam system, but did not have any direct involvement in the planning or conduct of the Q.
A. program for the ACR/PGCC.
The Q.
A. responsibility for this procurement was with the Engineering Department.
The investigator reviewed the correspondence files between PP&L and G.E.
for 1973-1979; and in particular the minutes of the monthly meetings that were held at G.E.
from 1977-1979.
These meetings, attended by representa-tives of G. E., Bechtel and PP&L, were devoted to the status, delivery, and design and quality problems associated with the ACR/PGCC.
The inves-tigator noted the names of the PP&L representatives.
They wer e invariably members of the Engineering Department; no members of the Quality Assurance Department were noted.
The investigator verified, via interviews in both departments, that Quality Assurance never attended these meetings.
PP&L's Enginee'ring Department was responsible for expediting the G.E. deliveries of the ACR/PGCC when the schedule slipped, as well as for verifying that the G. E. quality assurance program was maintained.
The investigator concluded that the role of the PP&L Q.
A. Manager appeared to be at variance with the "Susquehanna Steam Electric Station Procedures Manual" (Revision J, dated December 22, 1975).
Paragraph 8.4 of this manual (which is PP&L's document that ".
.
. prescribes the procedures to be fol-lowed in the
.
.
. procurement of the project
.
..") states:
"The (PP&L)
Manager Nuclear Quality Assurance (MNQA) is responsible for all Quality Assurance performed for this project and the acceptability of any equipment and services supplied."
Furthermore, the investigator noted, quality assur-ance that was performed on the ACR/ PGCC program by PP&L's Engineering Department does not appear to be in accordance with 10 CFR 50, Appendix B, Criterion I, which states:
".
.
. persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule
.
.
. are provided."
Therefore, the NRC investigator cited the licensee for an Infraction to
CFR 50, Appendix B, Criterion I. (I79-20-01)
G.E.
Product ualit Certifications P
Cs The NRC investigator visited the 'site to review the receiving inspection records for the ACR/PGCC equipment delivered by G.E.
PP8L stated that receiving'inspection was docum'ented on Bechtel "Inspection Records for Receiving" prepared in accordance with Bechtel guality Control Instruction No. 8856/R-2.00 (Revision 4, dated July 20, 1978), "Receiving Inspection for NSSS Equipment."
The receiving inspection activities cover documen-tation, visual examination, identification and traceability, release for storage or installation, and exceptions.
Testing, electrical inspection, and mechanical inspection are not performed.
G.E. supplies a Product guality Certification (PgC) with each delivery, which certifies
.
"that the products identified herein have been manufactured under a con-trolled quality assurance program and are in conformance with the procure-ment quality requirements
.
.
. supporting documentation is either attached, or will be forwarded or retained in accordance with contractual requirements."
The PAL preliminary Safety Analysis Report, in paragraph 0.4.9.1, states:
"For essential items of equipment
.
.
. for which there are no code require-ments for record retention or transmittal, designated quality records such as
.
.
. inspection and test data will be provided to, or provisions made for maintenance for the owner
.
The NRC investigator asked the licensee if he had established a program to insure that this SAR requirement was adhered to and that records of inspec-tion and test for the ACR/PGCC were prepared, that these records were accu-rate, and that these records were maintained and available.
The licensee provided the investigator with copies of the reports of the annual audits performed by Bechtel, in conjunction with PP8L and two other utilities who were purchasing G.E. nuclear steam supply systems.
These were Report Nos.
BMRO-l, dated November 12-14, 1974; BWR0-4, dated July 15-17, 1975; BMR0-9, dated September 14-16, 1976; BMRO-ll, dated September 27-29, 1977; BWR0-13, dated October 10-12, 1978; and BWR0-15, dated September 18-21, 1979; The investigator reviewed the reports and concluded that they did not sub-stantiate that there were inspection and test records supporting the P(Cs.
The investigator concluded that this failure to substantiate the quality assurance records required by the SAR and committed to by the G.E.
Product guality Certification did not appear to be in conformance with 10 CFR 50, Appendix B, Criterion VII, which states:
"Measures shall be established to assure that purchased materials, equipment...conform to the procurement documents...The effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant...."
This is a deficienc J.
Exit Interview
~
~
~
The investigator met with the licensee representatives (denoted in para-graph 1) at the conclusion of the investigation and summarized the results of the investigation.
The licensee acknowledged his findings.