ML19309C623
| ML19309C623 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309C615 | List: |
| References | |
| REF-QA-99900403 99900403-79-3, NUDOCS 8004090081 | |
| Download: ML19309C623 (4) | |
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6 General Electric Company D'ocket No. 99900403/79-03 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on October 1-5, 1979', and October 30, 1979, it appears that certain of your activities were tot conducted in accordance with NRC requirements.
A.
Section 18 of GE Topical Report NED0-11209-04A states that personnel performing audits of QA activities will be appropriately trained.
I Form RC-117, Record of Personnel Qualification, provides (or the signature of Control and Instrumentation Department's QA management to certify that the named individual has received the necessary training and indoctrination that would qualify him to perform his assigned functions.
Contrary to the above commitments, Form RC-117 for one individual had l
not been signed by anyone in GE to certify his qualifications even though the individual was performing the function of QA Representative for GE at a safety related supplier.
GE provided corrective and preventive actions relative to this deviation before the end of this inspection; therefore no further written response j
to this finding is necessary.
(See DetailsSection II paragraph C.3.a.)
B.
Section 7 of NEDO-11209-04A states in part, " Source inspection or surveillance is performed by NEFG QA organizations as necessary to assure the required quality of an item or service.
. The QA rep-resentatives responsible for supplier audit and surveillance are typically assigned responsibilities as follows:... Review suppliers' detailed fabrication process sheets to assure proper sequencing and adequate in process inspection, test, and control."
Contrary to the above commitment, no source inspections or surveillance was performed by NEBG QA representatives during the fabrication of six (6) safety related fuel grapples, procured from Marvin Engineering Company on purchase order (PO) 282-KF295.
Consequently, these fuel grapples were fabricated without the production planning documents required by the P0 and the required quality was not assured since it has been necessary to return all six grapples to the supplier two times-and additional testing by GE will be necessary before the grapples will be released.
(See DetailsSection II, paragraph C.3.e. for related information.)
80 0 4090 (){fl
2 C.
Criterion V of Appendix B to 10 CFR states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Deviations from these requirements are as follows:
1.
Quality Control Standing Instructions (QCSI) 7.2.4, Supplier Records for Engineered Equipment, paragraph 5.3, Operations at Suppliers' Plants, states in part:
"The GE-QC Representative shall review and accept supplier QA records; he shall ascertain that suppliers have approved the record, then sign or stamp and date each page of each acceptable record."
Contrary to the above, four (4) pages from document binders (supplier QA records) examined had not been signed or stamped and dated by the GE-QC Representative.
These were pages 100 and 104 (Airco Certs) for RCIC pump from Bingham-Willamette (P.O. 205-AG533), page 25 (Material Cert for weld electrodes) and page 210 (tensile test record, etc.) for safety-relief valves from Dikkers for Perry II.
2.
Engineering Operating Procedure (EOP) 42-10.00 requirements are as follows:
Current revision, in effect 11/13/78 to the present:
Submittal of DRFs (Design Record Files) for the generation of record retention documentation is required for design when all activities relating to verification, certification of an initial design are completed and it has been released for procurement, er when subsequent design activities such as design changes or design deviations havibg a significant technical impact are approved and verified.
Prior revision, in effect from 7/8/77 to 11/13/78:
Submittal of DRFs to Engineering Services I for generation of retention copies is required when the DRF is incomplete but design documents supported by the DRF are applied to a Standard or Requisition Plant, or the DRF is incomplete but one (1) year has passed since the previous copy was made.
3 Contrary to the above, the two Design Record Files (DRFs) examined had not been submitted for generation of retention copies on either a yearly basis, when the items were released for procurement, when applied to a Standard Plant, or when cignificant changes had been ap-proved or verified. Hence, the DRF records examined are retained as single copies in regular file cabinets in the responsible engineer's office, although required for duplicate retention by the above E0P and the GE Topical (lifetime: GE retention of design verification records). The specific DRFs are:
207-TR-SRV-K (Target Rock Safety-Relief Valves for 2-stage valves for BWR-4 plants, including orders for new top works and orders for spares) 207-B21F041/51-DK-K (Dikkers Safety-Relief Valves for BWR-6 plants).
3.
Section 1.2 of the Nuclear Engineering Division Engineering Operating Procedure E0P 30-2.00 (Standard and Requisition Plant Definition) dated January 13, 1978, states in part, "... MPLs (Master Parts Lists) are controlled lists, structured by system, that contain the identification of hardware and software documentation required to define product (nuclear steam supply systems and fuel products offered to customers) to offerings.
Contrary to the above, the current MPL for Clinton 1 & 2 did not contain documentation that defines the product (NSSS) being offered to Illinois Power and Light.
Specifically, the MPL did not contain the supplementary data sheets to Revision 5 of document 384 HA 380 (Product Safety Standards) that define certain systems of the BWR-6 (e.g. the Nuclear Boiler System, the Control Rod Drive System), as essential safety systems.
4.
Paragraph 4.4 of Section 9, Revision 2, dated July 26, 1979, of the PGCC Cable Assembly Instruction Manual, states in part, " Attach the connector to the proper position on the connector board. Tighten the connection between the clamp shell and the adapter with a small strap wrench and the torque wrench, using the torques listed on the connector board." The connector of cable No. VC99-0-024 was placed on Connection Assembly Board No. SK-PJR-7815-3 in a position that indicated a torque requirement of one-hundred and ninety (190) inch pounds.
Contrary to the above, the connector on cable No. VC99-0-024, Traveler T No. TRDT4 was torqued with the break-away torque wrench pre-set at one-hundred and eighty-seven (187 inch pounds) as opposed to the required one-hundred and ninety (190) inch pounds.
4 5.
Quality Assurance Procedures No. 2.0, Revision 0, dated May 4, 1979, states in part,
" HOLD POINTS Those designated inspection points which require witnessing or inspecting by designated customer, regulatory agency or company QA representatives and beyond which work shall not proceed without the consent of such designated representatives (also see ' Check Points')."
Contrary to the above, work had proceeded beyond the Company QC Hold Points designated on Travelers T Nos. TRDW4 and TRDT4 for manu-f acture of cables without the consent of designated representatives.
See DetailsSection V, paragraph B.3.a.
6.
Paragraph 4.4.17 and its subparagraphs b. and c. of Manufacturing Procedures No. 5.03, dated June 18, 1979, state, "When all deviations have received final disposition and work is accepted... Sign and date block No. 30, IR Closeout... Remove nonconforming tags from parts."
Contrary to the above, nonconforming tags had not been removed from Wide Range Monitors identified in Inspection Report (IR) No. R479Z which exhibited a close-out date of August 31, 1979.
See DetailsSection V, paragraph B.3.a.
7.
Paragraph 2.5.3 of Quality Assurance Procedures (QAP) No. 2.5, Revision 0, dated May 4, 1979, states, " Assure the documented quality-related activities are accomplished in accordance with the instructions, procedures and drawings."
Paragraph 2.5.3.2 of the same document identifies MP 3.15 (Work Order Processing) as one of the implementing instructions.
Contrary to the above, since Manufacturing Procedures (MP) No. 3.15 (Work Order Processing) is not an implementing procedure for assuring that documented quality-related activities are accomplished in accordance with instructions, procedures, and drawings, this procedure was not accomplished as required by QAP 2.5.
See DetailsSection V, paragraph B.3.a.
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