ML19276E675
| ML19276E675 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19276E670 | List: |
| References | |
| REF-QA-99900003 NUDOCS 7903200161 | |
| Download: ML19276E675 (4) | |
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General Electric Company Cocket No.
99900003/79-01 NOTICE OF DEVIATION Based on the results of a NRC inspection conducted on January 8-12, 1979, it appeared that certain of your activities were not conduc*.ed in full compliance with NRC requirements as indicated below:
A.
Table 2-1, NRC Regulatory Guide Positions, of the General Electric Topical Report, NED0-11209-04A, establishes a comitment to Regulatory Guide 1.38, Revision 2, and ANSI Standard N45.2.2-1972.
ANSI N45.2.2, Sections 3.6, A3.5.2, A3.6.3 and Regulatory Guide 1.38 require wraps, tapes, desiccants to have a halogen content less than stated max' ums.
Contrary to the abo.e, the specification to enforce the above comitments was inadequate in that it was to be enforced on a "best effort" basis (See DetailsSection I, paragraph B.4).
B.
Section 2.2, Quality System Documentation, of the General Electric Topical Report, NEDO-11209-04A, states that the Analytical Laboratory Control Instruction, NEBG 70-21, establishes the requirements for the analytical laboratory control programs needed.
NEBG-70-21, Revision 1, states in part, " Management responsible for analytical laboratory shall:
.. establish and implement the methods that are required to control the development, issuance, use, and revision of written procedures and documents which affect analytical measurement.
establish and document the procedures that are required to provide assurance that analytical instruments and other measurement devices used in activities affecting analytical measurement quality are properly controlled, calibrated,... as defined in the CM&S Manual.... establish and document the procedures for inclusion in the CM&S Manual... that are needed to provide assurance that sufficient records are generated, retained, transmitted and maintained to furnish documentary evidence that is necessary to assure that the necessary quality of analytical laboratory measurements is being achieved."
Contrary to the above, the Analytical Laboratory Control Instruction, NEBG 70-21, was found to be not fully implemented.
Four (4) examples of this problem are:
7903200lM
. 1.
certain applicable CM&S procedures were not fully implemented eg., pH meter calibration, 2.
activities affecting analytical measurements were nat controlled as required by the CM&S procedure eg., air flow in fluoride measurements, 3.
calibration of measurement devices was not performed as described by the CMas procedure eg., analytical scale and balance calibration, 4.
records to furnish documentary evidence to assure the quality of measurements were not maintained eg., records of the accept-ance of sample tubes (See DetailsSection I, paragraph C.3.c.(1)).
C.
Section 5, Instructions, Procedures and Drawings, of the General Electric Topical Report, NED0-11209-04A, states in part, " Activities affecting quality,... are delineated, accomplished, and controlled by such documents as policies, procedures...."
Chemet Lab Calibration and Operation Instruction, Chemet Laboratories Control Charting, C0I-002, Revision 0, states in part, "Any time that the alann limits are exceed, the probable cause of the occurrence must be investigated and the investigation results documented using the form that's shown in Attachment No.1."
Cont:ary to the above,' on numerous occasions the NBL-97 control charts on uranium assay exceeded alarm limits yet there was no documentation of the investigations of these occurrences (See DetailsSection I, paragraph C.3.c.(2)).
D.
Section 5 of the General Electric Topical Report, NED0-11209-04A, states in part, " Activities affecting quality are delineated, accomplished, and controlled by such documents as policies, procedures Section 10.4.4 of the approved ASME QA Manual states in part, "EPCE (Equipment Process Control Engineering) is responsible for the quality of all radiographs produced in WMD (Wilmington Manufacturing Department)... This is accomplished by the issuance and imple-mentation of detailed NDE procedures and instructions."
In addition, Quality Inspection Standards (QIS), number 100.3, Revision 1, paragraph 5.7, states in part, "The originator will notify applicable personnel by issuance of a QIS revision or cancellation notice when requirements or instructions change or become obsolete."
. Contrary to the above, QIS 109, Revision 2, which cites QIS 111, had not been revised to show that QIS 111, had been superceded ay QIS 243, although QIS 243 had been issued on May 15, 1978.
E.
Section 9, Control of Special Processes, of the General Electric Topical Report, fled 0-11209-04A, states in part, "These special processes are accomplished using qualified personnel, procedures, and equipment."
Wilmington Manufacturing Department, Quality Assurance Program, Section 6 of NEDE-20586, March 1978, Section 6.9, Subsection 6.9.1 states in part, "... special processes, including welding,...
are... accomplished by qualified personnel using qualified procedures...."
Contracy to the above, a special process, hardfacing of a stainless steel casting, was being performed using a procedure, Method Sheet 001 & 002, which had not been requalified after significant changes.
(See DetailsSection II, paragraph C.3.c.).
F.
Section 5, Instructions, Procedures & Drawings, of the General Electric Topical Report, NtD0-11209-04A, states in part, " Activities affecting quality, are delineated, accomplished, and controlled by such documents as policies, procedures...."
Detailed Weld Instruction (DWI) 251 requires the use of a 1/8" electrode for the root pass and D.W.I. 261 requires a maximum weld travel speed of 5.5 inches per minute (IPM).
Contrary to the above, at two (2) work stations welders were not following the D.W.I. requirements. At one station where D.W.I. 251 was in effect a 3/32" electrode was observed being used. At the other station where D.W.I. 261 was in effect a travel of 6.0-6.5 IPM was observed being used.
G.
Section 5 of the General Electric Topical Report, NED0-11209-04A, states in part, " Activities affecting quality... are delineated, accomplished and controlled by such documents as policies, procedures Section 6.2 of the 'ASME QA Manual states in part, "The Document Control Center (DCC) provides ready access to drawings by maintenance of controlled drawing files at applicable inspection stations on the shop floor.
The files are serviced by DCC to assure the latest Engineering Change Notices (ECNS) or revised drawings are included in the file." In addition, " Sign out cards are used to maintain drawing location control."
_4 Contrary to the above, Revision 4 of Drawing 105D6183 which had been isssed January 17, 1978, to the shop, was not in the controlled document t;le of the applicable inspection station 6710, nor did the sign out card indicate that the drawing had been removed.
.