ML19261A294
| ML19261A294 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19261A293 | List: |
| References | |
| REF-QA-99900403 NUDOCS 7901050102 | |
| Download: ML19261A294 (5) | |
Text
.
General Electric Company Docket No. 99900403/78-04 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on October 30-November 3, 1978, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A.
10 CFR 50, Appendix B, Criterion VI states in part, " Measures shall be established to control the issuance of documents which prescribe all activities affecting quality."
GE Topical NEDO 11209, Section 3.5, states in part, " Product design and quality requirements are transmitted from Engineering to Procurement through controlled issuance of Material Requests (MRs) which identify the product and specify applicable drawings, specifica-tions and QA requirements.
Initial issuance and revisions to MRs are controlled by written procedures."
Implementing procedure EEPP&P (Engineered Equipment Procurement Practices and Procedures) 5.02 states in part, "Upon receipt of the properly authorized MR and the supporting technical documents the buyer shall prepare the P. O. Revision."
Also, implementing procedure E0P (Engineering Operating Procedure) 42-5.00 states in part, " Engineering Services I controls release and distribution of approved MRs and maintains permanent MR and El files."
Contrary to the above, Revision 10 to P. O. 205-AJ430 was prepared and issued by the buyer incorporating MR AJ430, Revision 14, which was not properly authorized.
Also, MR AJ430 was never released or distributed by Engineering Services I and it was not in the permanent MR files.
B.
A stated corrective action to Part 21 Peport Number 78-064-000 (Switch Assemoly Lock Ring) indicated that manufacturing cocumentation had been revised to assure switches are installed with a lock ring.
Contrary to the above, manufacturing documentation had not been revised to assure switches are installed with a lock ring.
(See Comments, DetailsSection III, paragraph B.3.c.)
C.
Section 8 of Topical Report NED0-11209-04A states in part, " Procedures and practices are established and documented which provide for the identification and control of materials, parts, and components, including partially fabricated subassemblies."
9901050101
.Section VIII, Revision II, dated July 21, 1978, of the Nuclear Quality Assurance Manual-1.
Paragraph 8.5(a) states in part, "The Planning Card describes the events to be followed in the fabrication, assembly, inspection and/or test of the item." The Traveler (T) for Leak Detection VB H13-P642 requires stamping per MSP 11.002 which results in referring to Cannection Diagram No. 865E575, Revision 3, dated October 15, 1977, for identification of components.
2.
Paragraph 8.10(c) states, "The Fbterial Identification Tag shall contain, as a minimum, the drawing and revision number, T No.,
quantity accepted, and inspector's stamp."
Contrary to the above requirements:
1.
Switch G41A-51E had not been identified (stamped) in accordance with Connection Ciagram No. 865E575; Is: G41A-501B; Should be:
2.
Three (3) Material Identification Tags had not been stamped by the inspector for:
a.
The 51 Switch and the Resistor Switch Box of Wide Range Monitor, Serial No. 6, 614, 216.
b.
The 51 Switch of Wide Range Monitor, Serial No. 6, 614, 170.
D.
Section 5 of Topical Report NEDO-11209-04A states in part, " Activities affecting quality... are delineated, accomplished, and controlled by such documents as policies, procedures, operating instructions, design specifications, shop drawings, planning sheets, test and inspection procedures, and standing instructions."
Section V, Revision 9, dated July 21, 1978, of the Nuclear Quality Assurance Manual, states in part, "This section... describes the documented instructions, procedures, or drawings, which assure that activities affecting product quality are of a type appropriate to the work being performed, and that this work will be accomplished in accordance with these instructions, procedures, or drawings." Table 5-1 lists and briefly defines the documents directly affecting product quality.
The list includes Quality Assurance Procedures.
1.
Paragraph 2.0, and Item 11.b. of Exhibit 2 of Quality Assurance Procedure No. 15.2, Revision 2, dated August 25, 1977, states in part, respectively, "For RRs on in-house items an entry must
. be made either on the traveler or supporting documentation to show that an RR was issued," and "Use serial number if one item of the lot has a discrepancy.'
flote:
RR is Rework Record.
2.
The Mechanical section of the Manufacturing Workmanship Standards, Revision 0, dated September 1, 1978, states in part, " Tightness.
All bolt and screw type fasteners shall be free from evidence of loose hardware...." The Standard also depicted screw type fasteners with split lockwashers compressed (acceptable) and not compressed (unacceptable).
Contrary to the above requirements:
1.
Rework Record entries had not been made on the traveler or support-ing documentation for Wide Range Monitors (8) identified on Traveler 'T' Number TDCK7.
Rework Records Nos. 7, 8, and 9 did not reflect the serial number of the affected hardware.
Further, Nos. 6, 20, and 39 reflect serial numbers not directly traceable to a particular Wide Range Monitor.
2.
The screw / nut / washer assembly had not been tightened sufficiently to compress the spring lack washers (Item 106 of Parts List No.
368X102AA, Revision 21, dated May 10,1978) on Wide Range Monitor, Serial No. 6, 614, 170.
E.
Section 6 of Topical Report NED0-11209-04A states in part, "These measures provide assurance that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are promptly distributed for use at the location where the prescribed activity is performed."
Section VI, Revision II, dated July 21, 1978, of the Nuclear Quali ty Assurance Manual, states in part, "This system has been designed to provide assurance that documents, and those changes where applicable, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
1.
Paragraph 4.5.5.7 of Quality Assurance Procedure No. 6.7, Revision 4, dated May 10, 1978, states, "The revised TI is then reissued per t" procedure described in paragraph 4.4."
2.
Paragraph 4.5 of Quality Assurance Procedure t'o.17.1, Revision 5, dated March 15, 1978, states in part, "All correction: made to recordt must be neatly lined out and the correct information entered.
The correction must also be initialed, signed or stamped and dated...."
3.
Paragraph 4.1.5.1, of Engineering Operating Procedure No. 55-2.00, dated February 21, 1978, states in part, " Emergency...
The change will be issued inmediately following receipt of appropriate approvals."
Contrary to the above requirements:
1.
Test Instruction No. 2101, had been revised September 25, 1978, but had not been issued to individuals conducting the tests.
2.
Changes at Operation No.155 of Traveler
'T' tiumber TFCF8 had not been lined out, initialed, signed or stamped and dated.
3.
Engineering Change Notice NJ 06567, dated October 19, 1978, was identified with a priority of " Emergency" but had not been issued inmediately following receipt of appropriate approvals; i.e.,
Control Room Manufacturing staging operation had not received a copy by approximately 1:45 p.m. on November 2,1978.
Note: Quality Control did locate a copy in the Document Control Center at the Control Room Manufacturing location but this chr.ge notice had not been distributed to the staging operation personnel.
F.
Section 10 of Topical Report NED0-11209-04A states in part, " Inspection of materials, equipment, processes, and services is defined and executed in accordance with established QA plans, procedures, or instructionsSection X, Revision 7, dated March 15, 1978, of the Nuclear Quality Assurance Manu11-1.
Paragraph 10.1 states in part, " Examination, measurements or tests of material or products processed are performed for each work operation where necessary to assure quality."
Paragraph 1.0 of Inspection Instruction No. EL-022, Revision 4, dated March 27, 1978, states, "This document describes the inspection criteria for pages, modules and similar assemblies to ensure good workmanship and parts integrity." Paragraph 3.1.6 states in part, "All plug-in modules or components shall be fully inserted in their sockets."
2.
Paragraph 10.2.2.(e) states in part, "It is the responsibility of the QC Foreman / Supervising PCE to assure that the correct revision of the II (Inspection Instruction) and qP (Quality Plan) is entered in the Traveler where designated."
Contrary to the above requirements:
1.
Modules had not been inspected subsequent to assembly at Operation 11 0. 160 ( Assemble Modules) of Traveler 'T' ilumber TFCFS and Operation ilo.110 (Insert Cards) of Traveler 'T'
- ! umber TDCK7 to assure the modules are fully inserted in their sockets.
2.
Inspection had not been accomplished in accordance with the latest revision of Inspection Instruction No. EL-022 at Operation i!o.155 of Traveler 'T' flumber TFCF8; i.e., the operation reflected Revision 3 while the latest document is Revision 4.
Note: The corresponding Inspection Status and Serial Number Log indicates the first item was inspected on October 9, 1978, while Revision 4 of EL-022 is dated March 27, 1978.
U. S. NUCLEAR P.EGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900403/78-04 Program No. 44082 Company :
General Electric Company Nuclear Energy Business Group 175 Curtner Avenue San Jose, California 95125 Inspection Conducted:
October 30 - November 3, 1978 Inspectors:
b.
. hM, 11/10/77 J./RJ Costello, Principal Inspector, Vendor Date b(spection Branch 4h1 Ohw
/// u/ 7f J.(fl. Jqpnson, Contractor Auditor, Vendor Date' Ynspection Branch SIY k
UfL'/> c W. E. Foster, Contractor Inspector, Vendor Date Inspection Branch l1
['Ml (N
'h
^
/
Approved by: C N
C. Jge, Chief, Vendor Program Evaluation Date Section, Vendor Inspection Branch S u=1a ry Inspection on October 30 - November 3, 1978 (99900403/78-04)
Areas Insoected:
Implementation of topical report NED0-11209-04A in the areas of design corrective action, procurement document control, manufactur-ing process control, Part 21 Report followup and followup on Headquarters requests.
The inspection involved ninety (90) hours on site by three (3)
NRC inspectors.
790105010%
Results:
In the five (5) areas inspected, the following were identified in four (4) of the areas.
Deviations:
(1) Procurement Document Control - Contrary to GE topical report tied 0-11209-04A and GE implementing procedures, a purchase order revision was made without a prcperly authorized material request (See riotice of Deviation, enclosure, Item A).
(2) Part 21 Report Followup - Con *rary to GE stated corrective action, manufacturing documentation had not t een revised to assure switches are installed with a lock ring (See riotice of Deviation, enclosure, Item B. ).
(3) Manufacturing Process Control - Contrary to GE topical report NE00-11209-04A and GE implementing procedures, a switch had not been identified in accordance with a connection diagram and three (3) material identification tags had not been stamped (See t!otice of Deviation, enclosure, Item C.).
(4) Manufacturing Process Control - Contrary to GE topical report NED0-11209-04A and GE implementing procedures, rework record entries had not been made on the traveler for the Wide Range Monitor and did not reflect the serial numbers of the affected hardware; also the bolt nut to lock washer assembly had not been torqued enough to compress the spring lock washer (See Notice of Deviation, enclosure, Item D.).
(5) Manufacturing Process Control - Contrary to GE topical report NED0-11209-04A and GE implementing procedures, tests were being conducted to a marked up test instruction, changes to a traveler TFCF8 had not been lined out, initialed, signed or stamped and dated and an engineering change notice identified with a priority of " Emergency" had not been issued promptly (See Notice of Deviation, enclosure, Item E.).
(6) Manufacturing Process Control - Contrary to GE topical report NEDO-11209-04A and GE implementing procedures, modules had not been inspected subsequent to assembly as called for on the traveler and inspection at operation 155 was not to the latest inspection instructions (See Notice of Deviation, enclosure, Item F.).
Unresolved Item:
(1) Followup on headquarters Request - The adequacy and implementation of GE's cleaning procedure (s) for in process fabrication of the reactor vessel with internals installed and the adequacy of the reactor vessel seismic pin keeper welds are not apparent (DetailsSection I, para-grauh B.3.e. & f.).
DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted B. P. Brooks, Manager, Steam Valve Unit "W. C. Cohn, Manager, Quality Control Engineering G. A. Deaver, Design Engineer J. E. Gresham, Quality Control Representative at Chicago Bridge and Ircn Nuclear Company (CB&IN)
D. R. Heising, Senior Engineer L. C. Leber, Design Engineer
- J. L. flurray, Manager, Quality Assurance E. J. Plehn, Quality Control Engineer
- L. D. Test, Principal Engineer F. R. Ulrich, Senior Engineer Pressure Vessel Design
- Denotes those present at exit meeting.
B.
Verification of Sucolier Activities (CB&IN) 1.
Objectives The objectives of this area of the inspection were to answer the folicwing questions raised by the NRC Headquarters staff:
a.
How is the CB&IN QA program ccepliance with Criterion XIII determined in the absence of documented evidence of inspections?
b.
How dces GE verify that CB&IN complies with their specifica-tion recuirements in the absence of documented evidence?
c.
Was the welding of the seismic pin keepers performed and preserved in a suitably protected environment?
d.
Was an appropriate design review perfomed on the seismic pin keeper welds?
2.
Method of Acccmolishment The preceding objectives were accomplished by discussions with cognizant GE personnel and an examination of the following documents:
. a.
P. O. 205-AHJ31 to Chicago Bridge & Iron Nuclear Co.,
with 28 revisions covering Reactor Vessel with Internals Installed.
b.
QAR-1, Revision 0 - Quality Assurance Requirements.
c.
QA Supp. #17, Revision 0 - Supplement to CBI/CBIN QA Program Requirements.
d.
QA Supp. #14, Revision 2 - RPV Intervals and Assembly require-ments.
e.
Purchase Specification 21A2045, Revision 3 - Cleaning and Cleanliness Control for Assembly of Reactor Components.
f.
Installation Specification 21A2040, Revision 0 - Cleaning and Cleanliness Control for Field Modifications of Vessel Components.
g.
Installation Specification 21A2042, Revision 2 - Welding Requirements for Field Modifications of Vessel Components.
h.
BWR Plant Requirement 22A2749, Revision 1 - Cleaning of Piping and Equipment.
i.
Installation Instruction 22A2537, Revision 1 - Field Cleaning and Cleanliness of Nuclear Power Plant Components.
j.
Purchase Specification 21A3513, Revision 9 - Reactor Systems.
k.
Notification list for Shop Installed Intervals (hold points) issued October 3, 1975.
1.
Product Quality Certifications (1)
PQC No. N991, April 4,1977 - Reactor Pressure Vessel.
(2)
PQC No. HH764, June 6,1978 - Installation of Feedwatar Safe End Replacement.
(3) PQC No. HH768, June 9,1978 - Reactor Pressure Vessel with Internals Installed.
MR (Material Requistion) AK 390, Revision 8 - Remove existing m.
feedwater nozzle safe ends and install replacement safe ends in accordance with controlling documents.
n.
P. O. AK 390, Revision 0, to Chicago Bridge & Iron Nuclear Co. -
Pemove all existing feedwater nozzle safe ends and install re,;1acement safe ends.
o.
Trip Report - Top Guide Seismic Pin Keeper Problem, from L. C. Leber to R. E. Williams, Manager, Reactor Assembly Design dated April 6, 1978.
p.
Chicago Bridge & Iron Nuclear Co., Specification CP-302, Revision 0, Final Cleaning.
3.
Findings a.
In regard to the first question of how the CB&Iri QA program compiles with Criterion XIII in the absence of documented evidence of inspections the following infonnation is submitted:
(1) Product Quality Certificates (PQCs) accompany the material when it is shipped.
The PQC is signed by the CB&Ifl representative and the G. E. representative.
(2) Documented evidence of all inspections performed is retained by CB&IN in there record files.
This is permitted by the GE QA program.
(3)
If the utility would like all documented evidence of inspections to accompany the material this could be arranged by a change in the contract or purchase order.
b.
Concerning the second question of how GE verifies that CB&IN compiles with their specification requirements in the absence of documented evidence the following is submitted:
(1) CBSIN has documented evidence of all inspections performed in their record file.
(2) C3LIN must notify GE of all inspections whicn have a hold point for witnessing by G.E.
(3)
G. E. has a staff of resident inspectors at CB&IN.
(4) There was a notification point for GE witness established for the final visual inspection in preparation for shipment of the Reactor Vessel with Internals Installed.
(5)
There was no notification point for GE witness established for the modifications performed to install replacement safe ends.
(6) There was a less stringent cleaning specification inr7;ed when the seismic pin keepers were rewelded.
This cleaning was witnessed by GE.
c.
Concerning the third question of whether the walding of the seismic pin keepers was perforced and preserved in a suitably protected environment the following is submitted:
(1) The original welding was performed'in a suitable environment but the Reactor Pressure Vessel was exposed to subfreezing temperatures. Water had accumulated in the machining hole below the shroud to grid pin and had not been cleaned out.
The water froze and broke the welds. This condition was duplicated by GE engineer-ing in the laboratory.
(2) Purchase Specification 21A3513 has been revised (Revision
- 9) with explicit instructions on how to preclude this happening again (Ice damage).
This is done primarily by assuring all water is removed around the shoud to grid pins and a minor modification to the hardware so you can get the accumulated water aut.
i d.
Concerning the fourth question of whether an appropriate design review was performed on the seismic pin keeper welds
$l the following is submitted:
l
(
An independent design review was performed by an engineer c'f on the seismic keeper design.
The main difference in the circumstances was that the internals of the reactor pressure vessel (RPV) were factory installed versus field installed and it was not recognized that the vessei could be exposed,
to subfreezing temperatures.
If the welas had been performid i
at the site the environment would have bcen protected such that the RPV would not have been exposed to freezing tempera-tures.
e.
The cleanliness of the reactor pressure.ve.ssel with Installed Internals when delivered at the Perry site i,as obviously less than GE Specification 21A2045 would imply.
However, there
\\
5 om=-
has been no feedback from the GE staff at the site, there e
is a possibility some of the debris came from the two rework cperations (install replacement safe end and reweld seismic pin keepers), or it was shaken loose during shipment, or
/
the amount of debris observed was acceptable to GE at this stage of the in-process fabrication.
There will be more fabrication performed within the reactor pressure vessel and GE has additional cleaning specifications to be applied before pre-operational testing.
There is also the possibility that the translation of the GE specification to a CB&IN specifica-tion was less than desirable.
This will be further investi-gated during the next regular inspection.
'r f.
After the original welding of the seismic pin Feepers failed due to ice damage, the welds were repaired when the reactor,
pressure vessel was in the horizontal position. This posed some welding problems and it is possible that some of the welds could be defective.
These welds were to be reinspected on August 29, 1978, but as of November 3,1978, no inspection had been made. This will be further investigated during the next regular inspection.
C.
Design Corrective Action 1.
Objectives The objectives of this area of inspection were to examine and verify that (1) adequate procedures do exist and are being implemented far identifying deficiencies of a significant or recurring nature, {2) that measures exist for determining the cause of deficiencias and for initiating corrective action to prevent recurrence. (3) deficiencies and corrective actions are reported to appropt iate levels of management, (4) follow-up action is taken when necessary, and (5) the design process and verification procedures are re-reviewed when significant design i
)
changes or recurring ceficiencies occur.
2.
Method of Accomolisteent The preceding objectives were accorvolished by an examination of:
a.
GE topical report NED0-112')9-04A which establishes program commitments including:
(1) Measures for assuring design corrective actions.
These measures are described in Section 3, Design Control and Section 16, Corrective Action.
t (2)
Ide..tification of applicable procedures and instructions r,ed to implement the program commitments which are described in Section 2, Quality Assurance Program.
b.
BUR Quality Assurance Manual, Section 2 - Engineering, c.
Implementing procedures to satisfy topical commitments and satisfy the intent of the Objectives section above.
These procedures are Engineering Operating Procedures (EOPs) and are as follows:
E0P 25-4.00 Engineering Work Authorization E0P 40-7.00 Design Review Program E0P 40-9.00 Design Certification E0P 40-11.00 Field Failure Reporting and Analysis E0P 42-1.10 Design Control Program E0P 42-5.00 Engineering Document Release E0P 42-6.00 Independent Design Verification E0P 42-6.01 Design Calculations E0P 42-6.10 Engineering Document Issue and Applications E0P 50-3.00 Material Review Board E0P 55-2.00 Engineering Change Control E0P 55-3.00 Field Deviation Dispositions E0P 55-3.20 Field Disposition Instruction E0P 55-4.00 Change Control Board d.
Documents to verify implementation of topical commitments and procedural requirements and to satisfy the intent of the Objectives section:
(1)
Design Records DRF-313-81-1 Design of Reactor Hardware, Top Guide Installation DFR-B13-281-1 Design of Vessel and Component Assembly (2)
Engineering Changes i'A 61504-1, Revision 1 to Revision 2 - Delete prompt relief trip / relief vaive augmented bypass and substitute recirculation pump trip - Mandatory change.
ECM NE 79133, Revision 9 to Revision 10 - Incorporate 5 FDDRs to Elementary Diagram Reactor Protection System.
ECN NE 79943, Revision 10 to Revision 11 - Internal wiring revised to meet FSAR on Reactor Recirculation Pump and Motor Generator Set.
ECN NH 02868, Revision 0 to Revision 1 - Process Computer Operational Data - General changes to reflect changes to process computer software.
ECN NE 99766, Revision 3 to Revision 4 - Purchase Part Cylinder - N2 - Added items to N2 Cylinder.
(3)
Deviation Disposition Requests DDR 016890 - Component, Core Spray Sparger - Used incorrect material.
DDR 016042 - BW6 Core Structure - Hole pattern exceeds true portion tolerance.
DDR 016950 - 24" Recirculation Flow Control Valve -
Machining errors.
DDR 016588 - Recirculation Pump - Excessive thickness of final dry coatir.g.
DDR 014723 - Primary Recirculation Pump - Tested to wrong revision of test procedure.
DDR 014494 - Instrument Handling Tool - Mating part not dimensioned correctly, will require rework.
(4)
Field Deviation Disposition Requests FDDR KLI-C26, Revision 0 - Reactor Vessel - Requesting permission to deviate requirements on surface condition of weld.
FDDR KRI-050, Revision 2 - Request for approval o'.
deviations in cleaning and liquid penetrant inspection.
FDDR KLI-C24 - Description of broken welds on retainers used to hold down seismic pins.
FDDR HHI-136 - Shroud Heed Separator - Request for approval of deviated welding.
FDDR STI-084 - Recirculation Loop Piping - Inadequate support for instrumentation tap.
FDDR KLI-001 - Off Gas Condenser - Site contractor did not install anchor bolts in correct position.
FDDR KLI-004 - Thermocouple Arrangement - 7 heater pad studs broken.
(5) Audits (Conducted by Quality Assurance Reliability Engineering Operation).
Audit Report 78-02, June 1978, covering an audit of the design review process.
Audit Report 78-03, June 1978, covering an audit of design release and change control.
Audit Report 78-05, October 1978, covering an audit of design and release controls to Wilmington Manufacturing Department.
(6) Bimonthly Corrective Action Commitment dated September 5, 1978, from the Manager of Engineering to Department General Manager and Operations Managers.
(7) Stress Report No. G471.6 125.04.07, Revision 00 on 8" - 1500# Cast Iron Steel Safety Relief Valve.
3.
Findings In this area of inspection, no deviations from commitments or unresolved items were identified.
D.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on November 3,1978.
In addition to the individuals indicated by an asterisk in the Cetails Sections, those in attendance were:
W. A. Anders, Vice President & General Manager, Nuclear Energy Products Division R. C. Boesser, Manager, Quality Assurance and Operating Methods J. Barnard, Manager, Product and Quality Assurance Operation J. W. Cleveland, Senior Engineer D. H. Ferguson, Manager, Quality Assurance H. H. Hendon, Manager, Engineering D. E. Lee, Manager, Quality Control P. E. Novak, Manager, Engineering Systems Audits J. K. Powledge, Manager, Quality Assurance Engineering W. J. Roths, Manager, Reliability Engineering Operation A. Rubio, General Manager, t.uclear Energy Control and Instrumentation Department The inspector with the assistance of the inspection team members summarized the scope and findings of the inspection for those present at the meeting. Management representatives acknowledged the statements of findings, raised some questions for clarification and made the following comments relative to the deviation presented as Item A in the Notice of Deviation enclosure.
1.
Deviation was an isolated case.
2.
All technical and managerial approvals had been properly recorded but steps through administrative and clerical procedures had not.
3.
Work authorized was for information and had no impact on equip-ment to be shipped.
The GE management representatives were advised that their questions and comments would be considered in the documentation and review of their findings.
DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Persons Contacted J. Behlen, Manager, Project and Procurement Control
- C. L. Buc'<ner, Specialist, Quality Assurance (EE&I)
- W. C. Cohn, Panager, Quality Control Engineering (Vessels, Internals and Heat Exchangers)
R. K. Longerbeam, Quality Control Engineer W. R. Perrault, Manager, Quality Control Engineering (Valves and Piping Components)
- R.
J. Valencia, Quality Control Specialist E. Zitting, Release Analyst
- Denotes those present at exit meeting.
B.
Procurement Document Control 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been prepared and are being implemented to assure that:
a.
The organizations involved in the execution of procurement activities have been identified and their responsibilities del i neated, b.
Procurement documents include the scope of work to be per-formed by the supplier, the technical requirements, material and equipment specifications, procedures and instructions, test and inspection requirements, acceptance requirements, and identification. packaging, handling and shipping requiro-ments.
c.
Procurement documents require that the supplier have a docu-mented quality assurance program consistent with 10 CFR 50, Apperdix 3.
d.
The supplier is required to incorporate appropriate quality assurance program requirements in sub-vendor procurement documents.
e.
Procurement documents provide rights of access to the supplier's plant facilities and records, identification of manufacturing hold points, witness points and notifi-cation of the time of these events, documentation require-ments, records requirements, and requirements for reporting and approving of the disposition of nonconformances.
f.
Procurement documents are reviewed by the QA organization before transmittal to the prospective suppliers and these reviews are documented.
g.
Changes to procurement documents undergo the same degree of review and controls as the original documents.
h.
Measures to control the release and distribution of procure-ment documents are being implemented.
2.
Method of Accomolishment The preceding objectives were accomplished by an examination of:
a.
Documents establishing program commitments:
GE topical report NEDO 11209-04A: Section 4, Procurement Document Control; Section 3, Design Control and Table 2-1, NRC Regulatory Guide Positions.
b.
Implementing procedures to assure that procedural controls have been provided to satisfy topical commitments and items (a) through (h) of the Objectives section above:
(1) Engineering Operating Procedures (EOP):
ECP 45-2.00, Procurement of Engineering Services, EOP 2L-3.20, Project Procurement and Controi, E0P 42-5.00, Engineering Document Releases, E0P 85-1.00, Forms Index.
(2) Quality Control Standing Instructions (QCSI):
QCSI 7.2.18, Quality Requirements on Material Requests and Purchase Orders (Revision 4 and 5),
QCSI 7.2.16, QA Review of Engineering Documents,
. Quality Assurance Requirements - 1 (QAR-1), Revisions 0, 1, and 2.
(3)
Engineered Equipment Procurement Practices and Procedures Manual (EEPP&P):
EEPP&P 3.01, Material Requests (MR),
EEPP&P 4.01, P. O. (Purchase Order) Preparation and Di s tribution,
EEPP&P 5.02, P. O. Revisions.
(4)
GE ASME Boiler and Pressure Vessel Code Quality Assurance Manual :
Section 5.3, Equipment Procured by NEED (Engineered Equipment Procurement Operation).
(5)
Distribution Guide (NEDE 21670):
El-1.
c.
Documents examined to verify implementation of above progran and procedural requirements, and to satisfy implementation of (a) through (h) of the Objectives section above:
(1)
Documents examined associated with the purchase of approximately 220 Nuclear Safety Felief Valves for 10 U. S. Nuclear Plants from Dikkers Afsluiters.
(a)
P. O. (Purchase Order) 205-AJ430, Revision 0, and associated QRT (Quality Revie',' Transmittal) which documents QA review and approval of the P. O.
This P. O. includes scope of work and also delineates contingencies.
Evidence that Dikkers had met the contingencies was also reviewed.
(b)
Requirements invoked by the P. O. include:
QAR-1 (Quality Assurance Requirements -1), Revision 1, which includes requirements to meet ANSI N. 45.2, to pass applicable QA requirements to sub-vendors, and to allow access for surveillance and audit.
QRL (Quality Records List) 202, Revision 1, requiring document submittals including Design Deviation Peports (DDRs), Code Data Report, test results, NDE reports, etc.
-W
. 21A9538AB, Revision 0, (Data Sheet, invoking appli-cable ASME Code sections, edition and addenda.)
21A9538, Revision 4, (Purchase Specification, including technical design, performance, and hydrotest and performance test requirements.)
21A8793, Revision 2, (Quality Requirements - Vendor Design Documents).
21A8760, (Material Speci fication).
21A8659, (Export Packaging).
(c)
P. O. Revision 1 and associated QRT with QA connent, and resolution of this comment.
(d)
P. O. Revision 10, dated August 2, 1978, and associated QRT dated October 27, 1978.
Corresponding MR, Revision 14, dated June 23, 1978, and associated QRT dated October 27, 1978, with QA connent.
(e) Notification Points and Coding List (NL) indicating hold and witness points.
( f) Preliminary and final Attachment A, requiring submittal of outline drawings for valve and actuator, final radiographs, design calculations, etc.
(2)
Documents examined associated with the procurenent of Recirculation Pumps for one project from Bingham-Willamette:
(a)
P. O. AG906, Revision 0, which includes the scope of work, and applicable ASME Code edition and addenda.
QRT shows review and approval.
Purchase 21A9450 includes scope, proof of acceptability requirements, hydrotest, functional and performance test requirements, and preparation for shipment.
(b)
Revision 1 to F. O. AG906 adds QAR-1, Revision 0, with requirements for access, DDRs, N49.2 compliance, and passing applicable requirements to sub-vendors; adds QC Supplement 7 regarding minimum wall thick-ness verification; adds Purchase Part Drawing 762E637, Revisic "; and adds Attachment A regard-ing document submitals and NL No.165, Revision 0, regarding witness and hold points.
QRT shows review and approval.
. (c)
Revision 2 to P. O. AG906 incorporates Purchase Part Drawing 762E637, Revision 4, Weld End Prep Crawing 131C3662, Revision 1, Process Specifica-tion P50YP123, Revision 2, and QA Supplement 20, Revision 1.
(d)
Revision 4 to P. O. AG906 incorporates QRL 139, Revisic" 0, regarding document submittals.
(e) Purchase Order Revisions 1 through 11, incorporate approved MRs i through 42.
(f)
Engineering Change Notice (ECN) No. 72143.
An MR was generated which incorporated this ECM change in P. O. Revision 5.
(3)
Documents examined associated with the procurement of the Reactor Vessel for one project from CBIN ' Chicago Bridga and Iron - Nuclear):
(2 )
P. O. 205-H9448 and associated MR.
(b)
Incorporation of documents including:
Purchase Specification 21A9477, Revision 1 and Revision 6, (incorporated by P. O. Revision 18);
Purchase Part Drawing 762E573G2 and Parts Lists; QAR-1, Revision 0 and Supplement 10, Revision 0.
Supplement 10 indicates that the majority of records will be retained by CBIN in their Nuclear Records Center in Memphis, and requires submittal of a Final Records List and description of the storage facility for GE approval',
Attachment A (ER-74-98, Revision) regarding document submittal requirerents; 21A3861, Revision 0, regarding ultrasonic testing (UT);
NL No. 61, Revision 1, regarding hold and witness points; CC21A9477BB, Revision 0 and 1, Design Certification, which specifies applicable ASME Code sections, edition, addenda and Code cases.
. 21A94773B, Data Sheet including unique project requirements and specifying ASME Code sections, edition, and addenda, and listing applicable documents including specified revision numbers.
(c) The most recent P. O. revision is Revision 20, dated September 26, 1977.
Ninety-five (95) MRs have been written to P. O. 9448 and it appears from sampling that these have been reviewed, approved and incorporated except MRs AE029 flos. 94 and 95.
These were issued in December of 1977 and show Drawing 762E573P1 superceded by Drawing 137C6037P1, Revision 0, (for one part only).
These two MRs are still actively under negotiation with CBIrl per explanation by purchasing.
(d) Engineering Review Memorandum (ERM) No. DMD-2186 and Design Verification (DV) No. NE92575 and ECM No. NE92575 which caused issuance of MR AE029-94.
(e)
P. O. Revision 19 deletes Preparation for Shipment from the scope of work for this P. O.
It will be performed on P. O. 205-AJ732, which also includes internals installation.
( f) Letter EJP-72-25 accepts the use of the CBIN RAD (Request for Acceptance of Deviation) form in lieu of the GE form to document deviations.
3.
Findings a.
In this area of the inspection, one (1) deviation was identified (See Notice of Deviation Enclosure, Item A, and additional infonnation below).
(1)
It should be noted that mitigating circumstances related to this deviation include the fact that this MR and corresponding P. O. Revision add to test require-ments and therefore there is no potential negative quality impact involved in the change. IIRC concern is the bypassing of procedural requirements for release and processing (including QA review and approval which was not accomplished until approximately six months af ter issuance of this MR and P. O. Revision) and the fact that required records were not in the specified locations.
b.
Relative to Objectives section B.1.f., it was noted that the MRs, P. 0.s and P. O. revisions examined were frequently reviewed and approved by QA after the fact, that is af ter issuance, and any QA comments were incorporated by later MRs and P. O. revisions.
This appeared to satisfy GE procedural requirements at the time.
However, GE procedure QCSI 7.2.18, Revision 5, dated August 15, 1978, now requires sending, "unissued MR to QCE for review," and the new MR form has added a QA review signature as part of the initial review process.
4 DETAILS SECTION III (Prepared by W. E. Foster)
A.
Persons Contacted P. M. Briggs, Acting Manager, Process Control Engineering, PGCC "D. C. Brown, Manager, Quality Systems, Audits and Records H. Broxson, Engineer, Manufacturing, PGCC F. C. Cannizzro, Specialist, Project Document Control
- D. H. Currie, Senior Quality Control Engineer J. Fisher, Engineer, Manufacturing B. Grim, Manager, Nuclear Instrumentation and Protection Design N. Lambert, Manager, Process Control Engineering R. Long, Foreman, Quality Assurance Inspection and Test G. N. Minden, Lead Engineer, PGCC Requisition Design Engineering H
L. Occhi, Lead Engineer, Seismic Test E Sanchez, Foreman, Quality Assurance, Control Room Manufacturing D Sanders, Foreman, Cable Shop R. L. Sullivan, Supervisor, Quality Assurance, Electrical Process Control Engineering
- L. D. Test, Principal Engineer, Reliability Engineering
- Denotes those present at the exit meeting.
B.
Part 21 Report Followup 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
The report accurately described the defect or failure to comply and satisfied the reporting requirement with respect to infor: 2 tion provided and timing of submittal.
b.
The defect or failure to comply had been evaluated as required by Part 21 and reporting organization procedures, stated safety hazard is a logical conclusion, factual and complete data had been used, generic implication had been assessed.
c.
The stated corrective action is appropriate and adequate and implemented or planned.
e
.
- 2.
Methods of Accomplishment The preceding objectives were acccmplished by:
a.
Review of the following documents to verify procedures had been established to identify reporting requirements:
(1) Muclear Energy Divisions (NED) Policy Number 70-42, Revision 1, dated January 3, 1978, and (2) Manufacturing Procedures Number MP 5.08, dated February 1, 1978.
b.
Review of the following Part 21 Reports to verify they met the requirement of NED Policy Number 70-42:
(1) Number 78-064-000, Switch Assembly Lock Ring, (2) Number 78-062-000, Reactor Protection System Mode Switch, and (3) Number 78-063-000, Electrical Separation.
c.
Review of the following documents to verify the stated corrective action is appropriate and adequate:
(1)
Engineering Change Authorization Number 780322-1, Revision 0, dated July 11, 1978, Subj ect:
Electrical Separation, (2) Design Specification Number 22A2877AA, Revision 0, dated August 11, 1978, Subj ect: Main Control Room Requirements, (3) Separation Specification Number 22A4219, Revision 1, dated October 14, 1977, (4) Manufacturing Standard Practice (MSP) Number 17.002, Revision 4, dated May 8, 1978, and (5) The following Field Disposition Instructions, (a) Number WAEG, Revision 0, dated August 1, 1978, (b) Number WJEG, Revision 0, dated July 21, 1978, and (c) Number WJDV, Revision 1, dated July 21, 1978.
f
. d.
The following observations were made to verify the stated corrective actions are being implemented:
(1)
Cable cutting operation for identification of cable for separation requirements, and (2)
Termination of cabling in various panels to assure adherence to separation requirements.
3.
Findings a.
Deviation See Enclosure, Item B.
b.
Unresolved Items None.
c.
Comments (1) Notice of Deviation, Item B, Manufacturing Standard Practice (MSP) No.17.002 had been revised to assure installation of the lock ring.
However, the MSP related to G. E. Dag. No.164C5274 and not G. E. Dwg. No.
145C3040 which is the safety-related version.
- Further, manufacturing documentation had not been initiated to account for G. E. Dwg. No.145C3040, nor had engineering documentation been generated regarding installation of the switch.
Note: The inspector was provided with a copy of MSP 17.002, Revision 6, dated November 2, 1978, which includes provisions for G. E. Dwg. No.145C3040 and Engineering Change Notice No. NJC6591 (unreleased) which addresses switch installation.
(2)
Regarding GE-CR 2940 control switch manufacturing instructions now document the installation of lock rings.
Twelve (12) installed switches of three (3) panels were checked and the name plates incorporated provisions (lock ring) to prevent switch rotation during switch actuation.
(3) Regarding Reactor Protection System Mcde Switch - efforts are continuing in qualifying a replacement mcde switch.
Measures to prevent recurrence of the electrical separa-tion problem are in the forms of revised drawings and
Y
. specifications to identify and define areas that require separation based upon NRC Regulatory Guide 1.75.
Wiring and cabling are being acccmplished in accordance with correct instructions.
C.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Measures had been established to control manufacturing, inspection and test activities, b.
Performance of manufacturing, inspection and test activities had been accomplished by qualified personnel using qualified procedures, c.
Manufacturing, inspection and test activities had been accomplished in accordance with documented instructions, procedures and drawings, d.
Mandatory inspection hold points had been indicated in appropriate documents and honcred, e.
Measures had been established to indicate the status of items being processed.
2.
Methods of Accomplishment a.
Review of the following documents to verify measures had been established to control manufacturing, inspection, and test activities, and indicate status of items being processed:
(1) General Electric Company's Topical Report, Sections 5, 6, 10 and 11, and (2) Nuclear Quality Assurance Manual sections -
(a) Number V, Revision 9, dated July 21, 1978, (b) Number VI, Revision 11, dated July 21, 1978, (c) Number VIII, Revision 11, dated July 21, 1973, (d) Number X, Revision 7, dated Marcn 15, 1978, and (e) Number XI, Revision 8, dated March 15, 1978.
4 fr.
F
- b.
Observation of manufacturing and test operations, results of inspection and the following associated documents to verify objectives b, c, and d:
(1)
Inspection Instruction No. II PA-002, Revision 9, dated October 10, 1978, (2)
Inspection Instruction No. II PA-010, Revision 8, dated August 9, 1978, (3)
Inspection Instruction No. II EL-022, Revision 4, dated March 27, 1978, (4) Quality Assurance Procedure No. QAP 6.7, Revision 4, dated May 10, 1978, (5) Quality Assurance Procedure No. QAP 14.3, Revision 3, dated August 28, 1978, (6) Quality Assurance Procedure No. QAP 15.2, Revision 2, dated August 25, 1977, (7) Quality Assurance Procedure No. QAP 17.1, Revision 5, dated March 15, 1978, (8) Test Instruction No. TI 2101, Revision 2, dated September 25, 1978, (9) Manufacturing Procedure No. 2.15, dated November 14,
- 1977, (10) Manufacturing Standard Practice No.11.002, Revision 6, dated January 3, 1978, (11) Engineering Operating Procedure No. 55-2.00, dated February 21, 1978, (12)
Engineering Operating Procedure No. 65-2.10, dated August 5, 1977, (13) Engineering Change Notice No. NJ06567, dated October 19,
- 1978, (14) Travelers 'T' Number TDCK 7; 'T' Number TFCF3; 'T' Number TEAX 1; 'T' Number TEAX4; 'T' Number TFBW5; 'T' Number TBRL1', 'T' Number TBEW8; and 'T' Number TAWG4,
5
. (15) Connection Diagrams Drawing Nos. 851E935TR, Revision 0, dated April 1, 1977; 865E575, Revision 3, dated October 15,
- 1977, (16)
Drawing Nos.133D9306, 368X102AA, and Parts List No.
368X102AA, Revision 21, dated May 10, 1978, and (17) Manufacturing Workmanship Standards Mechanical - Electrical Revision 0, dated September 1, 1978.
3.
Findings a.
Deviations (1)
See Enclosure, Item C.
(2)
See Enclosure, Item D.
(3) See Enclosure, Item E.
(4) See Enclosure, Item F.
b.
Unresolved Items None.
.