ML19309C626
| ML19309C626 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1979 |
| From: | Costello J, Foster W, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309C615 | List: |
| References | |
| REF-QA-99900403 99900403-79-3, NUDOCS 8004090086 | |
| Download: ML19309C626 (44) | |
Text
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U. S. NUCLEAR REGULATORY CO.TilSSION 0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900403/79-03 Program No. 51100 Company:
General Electric Company Nuclear Energy Business Group 175 Curtner Avenue San Jose, California 95125 Inspection at:
San Jose, California and NRC Region IV Inspection Conducted:
October 1-5, 1979, ana October 30, 1979 Inspectors:
[ bd8.
///7/79 R. Costello, Principal Inspector Ddte~
gram Evaluation Section Vendor Inspection Branch 8
.0/ f %d nh/n W. E. Foster, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch M
11/7 / /9 D. F. Fox, Inspector-Electrical Engineer Date Program Evaluation Section Vendor Inspection Branch O m Ch ph/n J.~.Joh6pon,ContractorAuditor Dat6 P
ram Waluation Section Vendor Inspection Branch D.
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//- f-79 C. J. H
, Chief Date Progra valuation Section Vendor Inspection Branch i
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2 Approved by:
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C. J. Qaye, Chief
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Date a
Program Evaluation Section Vendor Inspection Branch Summary Inspection on October 1-5, 1979, and October 30, 1979 (99900403/79-03)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, and Topical Report NEDO-11209-04A in the areas of Design Input, Design Process Management, QA Records, Manufacturing Process Control, and follow-up on previous inspection findings and headquarters requests.
The inspection involved one hundred sixty-two (162) inspector-hours on site by five (5) NRC inspectors.
Results:
In the five (5) areas inspected nine (9) deviations were identified in four (4) areas and two (2) unresolved items were identified in two (2) areas.
Deviations:
(1) Follow-up on Headquarters Requests - Contrary to GE Topical Report NEDO-11209-04A, qualifications of a functioning GE QA Representative were not certified (See Notice of Deviation Enclosure, Item A).
(2) Contrary to GE Topical Report NED0-11209-04A, no source inspections or surveillance was per-formed during fabrication of safety related fuel grapples (See Notice of Deviation Enclosure, Item B).
(3) QA Records - Contrary to procedural requirements, four (4) pages from document binders (supplier QA records) examined had not been signed or stamped and dated by GE-QC Representative.
(See Notice of Deviation Enclosure, Item C.I.).
(4) QA Records - Contrary to procedural requirements, two (2) Design Record Files (DRFs) examined had not been submitted for generation of retention copies (See Notice of Deviation Enclosure, Item C.2.) (5) Design Input - Contrary to procedural requirements, the Master Parts List for Clinton 1 & 2 did not include the supplementary data sheets to revision 5 of the Product Safety Standards (See Notice of Deviation Enclosure, Item C.3.).
(6) Manufacturing Process Control -
Contrary to procedural requirements, the break-away torque wrench used on a cable connector was set at 187 inch pounds instead of 190 as required.
(See Notice of Deviation, Enclosure, Item C.4.).
(7) Manufacturing Process Control - Contrary to procedural requirements, work had proceeded beyond designated QC hold points i
in the manufacture of cables (See Notice of Deviation Enclosure, Item C.S.)
(8) Manufacturing Process Control - Contrary to procedural requirements, nonconforming tags had not been removed from wide range monitors even through the inspection reports had been closM out.
(See Notice of Deviation Enclosure, Item C.6.).
(9) Manufacturing Process Control - Contrary to procedural i
requirements, manufacturing procedure MP 3.15 is not an implementing procedure for work order processing as stated in QA procedure 2.5, Revision 0 (See Notice of Deviation Enclosure, Item C.7.).
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Unresolved items:
(1) Design Inputs - It is not apparent that copies of proce-dure manuals are being properly maintained (See DetailsSection IV, paragraph B.3.b).
(2) Manufacturing Process Control - It is not apparent that a random in process inspection four (4) times each shift or inspection of twenty percent (20%) of each lot is being performed (See DetailsSection V, paragraph B.3.b).
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4 DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted K. I. Dawley, Manager Plant Definition and Release Control F. E. Funk, Responsible Engineer M. R. Lane, Principal Engineer
- S. L. Mather, Manager BWR 6 System Design R. E. Matthews, Principal Engineer J. M. Murray, Technical Leader Communication & Training H. Tafarrodi, Responsible Design Engineer
- L. D. Test, Principal Engineer
- Denotes those present at exit meeting.
B.
Design Process Management 1.
Objectives The objectives of this area of inspection were to examine the establishment and implementation of quality related procedures for the design process to verify that:
The design process system is defined, implemented, and enforced a.
in accordance with approved procedures, instructions, or other documentation for all groups performing safety related design activities, b.
Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures.
Appropriate quality standards for items important to safety c.
are identified, documented, and their selection reviewed and approved.
d.
Final design can be related to the design input with this traceability documented, including the steps performed from '
design input to final design.
i e.
Design activities are documented in sufficient detail to i
permit design verification and auditing.
f.
The methods are prescribed for preparing design analyses, i
drawings, specifications, and other design documents so that they are planned, controlled, and correctly performed.
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2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
Applicable portions of the GE Topical Report NEDO-11209-04A which a.
establishes QA program commitments.
b.
Sections 3.3 and 4.3 of the BWR Quality Assurance Manual entitled
" Design Control."
Implementing procedures to assure that procedural controls c.
had been provided to satisfy QA program commitments and to satisfy the intent of the objectives section above.
(1) BWR Engineering Operating Procedures (EOPs).
(a) EOP 25-4.00 Engineering Work Authorization.
(b) E0P 30-1.00 Introduction - Product Definition and Control..
(c) E0P 30-2.00 Standard and Requisition Plant Definition.
(d) E0P 40-7.00 Design Review Program.
(e) E0P A0-8.00 Design Freeze.
(f) E0P 40-9.00 Design Certification.
(g) E0P 42-1.00 Introduction - Technology and Design Control.
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(h) E0P 42-1.00 Supplement A - General Information Guidelines for Design Performance.
l (i) E0P 42-6.00 Independent Design Verification.
(j) E0P 42-6.10 Engineering Document Issue and Application.
l d.
Documents to verify implementation of topical commitments and procedural r equirements and to satisfy the intent of the objectives section above. These documents are as follows:
(1) 105D 5228 Interface Control Isolation Valve.
(a) ECN NE 59456 initial design freeze with open items, Revision 6.
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(b) ECN NE 80682 design freeze Revision 7.
(c) ECN NE 98935 post design freeze Revision 8.
(d) DRF 126-B21-F022/28-N&3, Design Verification.
(2) 135B8363 Outline Detector, EWA K28A0 design freeze Revision 14.
(3) DC 105D4935AE Valve, Isolation, Main Steam - Design Certification.
(4) 384HA380 Product Safety Standards for BWR/6 - Mark III, Revision 5.
(5) 112C3144 Detector Assembly, Revision 31.
(6) 135B8363 Outline Detector, Revision 14.
(7) 21A9370 Explosive Valve, Standby Liquid Control System -
Purchase Specification, Revision 6.
(8) DC 21A9370 Explosive Valve, Standby Liquid Control System -
Design Certification, Revision 2.
(9) 22A4052 Core Support Structure - Design Specification, Revision 8.
(10) DC 21A3502 Pipe Suspension - Design Certification, Revision 3.
(11) 21A3502 Pipe Suspension - Design Purchase Specification, Revision 4.
(12) DC 21A3872 Valves, Recirculation Flow Control - Design Certification, Revision 3.
(13) 21A3872 Valves, Recirculation Flow Control - Purchase Specification, Revision 4.
(14) 21A9506 Valve, Main Steam Isolation - Purchase Specification, Revision 4.
(15) 21A9546 Control Rod Drive Housing - Design Specification, Revision 2.
a
7 (16) 22A3731 System Design Pressures - BWR6 Mark III -
Design Specificatior., Revision 4.
(17) 21A9256AE Turbine Uteam Reactor Core Isolation Cooling Drive - Purchase Specification Data Sheet, Revision 2.
(18) 762E637 Purchase Part Pump & Motor, Revision 7.
(19) 22A6421 Valve Main Steam Isolation - Purchase Specification, Revision O.
(20) 21A9506 Valve Main Steam Isolation - Purchase Specification, Revision 4.
(21) PL 283X568 Core Spray Sparger - Drawing, Revision 9.
(22)
PL 112C3144 Detector - Drawing, Revision 34.
(23) 112C3144 Detector Assembly - Drawing, Revision 31.
(24) 767E957 Control Rod Drive Housing Outline - Drawing, Revision 2.
i (25) 213A5511CA High Pressure Core Spray System - B - Drawing, No. Revision Number - information document.
(26) 762E958 Control Rod - Drawing, Revision 3.
(27) 769E547 Flow Control Valve - Interface Control Drawing, Revision 1.
(28) 769E387 Recirculation Loop Suspension - Purchase Part, Revision 2.
(29) 112D1434 Interface Control Valve Explosive, Revision 0.
(30) 865E864 Outline Local Panels - Drawing, Revision 2.
(31) 137D8192 Main Steam Flow Local Panel D - Connection Diagram, Revision O.
(32) 133D9965 Main Steam Flow Local Panel D - Piping Diagram, Revision 6.
(33) 164C5912 Main Steam Flow Local Panel 3 - Assembly Revision 5.
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8 (34) 163C1973 Level Transmitter With Pressure Sealed System - Purchased Part, Revision 4.
(35) 920D496 Ind: cator and Trip Unit - Schematic Diagram, Revision 8.
(36) 193B1213 In31cator and Trip Unit - Outline, Revision 1.
(37) 129B2802 Indicator and Trip Unit - Assembly, Revision 31.
3.
Findings In this area of inspection, no deviations from commitment or unresolved items were identified.
C.
Exit Meeting A meeting was conducted with management representatives at the conclusion of the inspection on October 5, 1979.
In addition to the individuals indicated by an asterisk in the Details Sections, those in the attendance were:
J. Barnard, Manager Product and Quality Assurance Operation A. Breed, Manager Quality Assurance, P&QA0 N. J. Biglieri, Acting Manager Reactor Design end Containment W. H. Bruggeman, Vice President & General Manager Nuclear Products Division D. H. Ferguson, Manager Quality Assurance, C&ID H. Hendon, Manager Engineering, C&ID A. I. Kaznoff, Manager Product Assurance, P&QA0 D. F. Long, Manager Engineering Services Operation, NED G. A. Senn, General Manager Control and Instrumentation Department H. E. Stone, General Manager Nuclear Energy Division L. V. Stonebraker, Specialist Quality Assurance, Nuclear Services Department The inspector, with the assistance of the i.,spection team members, summarized the scope and findings of the inspection for those present at the meeting.
Management representatives acknowledged the statements of findings and made the following comments in regard to Cue rindings in the area of Manufacturing Process Control.
GE would like to have the option of closing out any findings made during the inspection for which they can complete corrective and preventive action before the end of the inspection.
The inspector acknowledged the GE comments and stated he would obtain-a policy decision and advise GE regarding this matter from USNRC Region IV management.
9 DETAILS SECTION II (Prepared by C. J. Hale)
A.
Persons Contacted
- J. H. Breseke, Manager Procurement Quality Assurance, Nuclear Energy Control and Instrumentation Department (NEC&ID)
- K. I. Curry, Specialist, Quality Notification and Audits K. M. Duke, QC Engineer, NEC&ID K. D. Jakabcin, Principal QC Engineer J. C. Majors, Manager Piping Equipment Design J. K. Powledge, Manager Quality Assurance Engineered Equipment and Installation (QAEE&I)
E. L. Wright, QC Engineer, NEC&ID R. B. Wright, QC Specialist, QAEE&I
- Attended Exit Meeting.
B.
Follow-up on Previous Inspection Findings 1.
(Open) Deviation (Report No. 79-02): Marvin Engineering Company was being used as a safety category 1 supplier without being evaluated as supplier of such items. See the following para-graph C.3.d., concerning the status of this deviation.
2.
(0 pen) Unresolved Item (Report No. 79-02): Even though GE does not consider the steam dryer a basic component essential to safety, it appears that certain failure modes of the steam dryer could adversely affect other basic components that are clearly essential to safety.
(See following paragraph for status).
3.
(0 pen) Unresolved Item (Report No. 79-02):
GE has classified the feedwater spargers and thermal sleeves as nonessential to safety.
This does not appear to be the proper quality classification and we requested an evaluation of this item and the item in B.2.
above by NRC: HQs.
We have received a response to our request from the Acting Director, Division of System Safety, Office of Nuclear Reactor Regulation.
This response includes the following statement, "In recent reviews (LaSalle) the staff has taken the position that all reactor internals be placed under the applicant's QA programs in accord with Regulatory Guide 1.29.
We anticipate further discussions with GE on this matter in the near future."
The Regulatory Guide 1.29 position is that the reactor core and the reactor vessel internals are subject to the pertinent
10 requirements of Appendix B to 10 CFR Part 50. Accordingly, these unresolved items (B.2. and B.3.) will remain open awaiting results from the NRR-GE discussion on this matter.
C.
Control of Procurement from Marvin Engineering Company (MEC) 1.
Objectives The objectives of this area of the inspection were to:
Follow-up on the deviation identified in Report No. 79-02.
a.
b.
Determine the effectiveness of GE's surveillance of MEC to assure product quality and compliance with purchase order requirements.
Verify the qualifications of the GE inspection and audit c.
personnel, d.
Determine all products procured from HEC, their intended use, and their current location.
2.
Method of Accomplishment The preceding objectives were accomplished by review of the following documents.
Quality Plans imposed on C&ID suppliers through GE purchase a.
orders (P0s):
QP 30.117, Material Quality Plan, Supplier Quality Assurance Requirements for Nuclear Safety-Related Items, Revision 2, August 24, 1977.
QP 30.124, Material Quality Plan, Quality Assurance Requirements for Suppliers of Safety-Related Items (NED Designed),
Revision 0, January 16, 1978.
QP 20.119, Product Quality Plan, Fuel Grapples, Revision 1, November 16, 1978.
b.
P0s to MEC from GE:
Po 205-AL709, Revisions 0, 1, 2, and 3 dated January 16, April 13, and May 4,1979, spargers and thermal sleeves for Millstone, ordered by GE's Engineered Equipment Procurement (EEP) Operations.
P0 282-KF-295, Revisions 0, and 1 dated August 8, 1978, and May 9, 1979, six (6) fuel grapples, safety-related, ordered by NEC&ID. Sixteen (16) other P0s issued by NEC&ID to MEC over the past three years.
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Other P0s reviewed:
P0 205-AK235, January 16, 1978, and two (2) subsequent revisions. This PO issued to CBIN for spargers and thermal sleeves.
P0 M8012722, January 30, 1978, and four (4) subsequent revisions. This PO was issued by CBIN to MEC for spargers.
PO 446731, Janua ry 10, 1978, issued by Northeast Utilities to GE for spargers - safety related.
PO 604093, October 24, 1978, issued by Northeast Utilities, amending and finalizing their January 10, 1978, P0.
d.
The following specifications imposed on certain of the P0s identi-fied in b. above:
22A5517, Purchase Specification Feedwater Sparger, Revision 3, January 30, 1978.
P50YP102, Process Specification - Arc Welding of Austenitic Stainless Steel, Revision 4, August 23, 1977.
ESDYP4, Proceas Specification - Liquid Penetrant Examination, Revision 4, June 1, 1979.
ESD-YPZ-51, Specification for Liquid Penetrant Inspection.
P50YP101, Process Specification - Arc Welding of Carbon and Alloy Steels, Revision 3, March 22, 1978.
P50UP105, Process Specification - Arc Welding of Nickel Base Alloys, Revision 3, February 10, 1978.
209 A 4290, Welding Requirements - General Use, Revision 3, January 10, 1977.
e.
Quality assurance documents:
QAR-I, Revision 2, March 10, 1977, QA requirements by EEP for safety related equipment.
QAR-II, Revision 1, May 17, 1976, QA requirements by EEP for non-safety related equipment.
12 QAS 26, Revision 0, October 3, 1975, Seller's Quality Control Records, QA supplement for QAR-II.
QAS 28, Revision 0, May 17, 1976, Seller's QA Program and Control of Processes, QA supplement for QAR-II.
QAS 29, Revision 0, May 17, 1976, Seller Quality Records Program, QA supplement for QAR-II.
QAS 30, Revision 0, May 17, 1976, Seller Final Radiograph Program, QA supplement for QAR-II.
f.
Records and receiving inspection documents concerning P0 282-KF 295, six (6) fuel grapples.
RI 872 Receiving Inspection Report i
RI 873 Receiving Inspection Report RI 688 Receiving Inspection Report RI 814 Receiving Inspection Report i
RI 815 Receiving Inspection Report i
1 Data package for each assembly including material certifications, l
PT records, metallurgical and heat treat reports, and certificates j
of conformance.
j g.
Inspection and audit trip reports:
76T-062, July 1, 1976 76T-109, August 11, 1976 76T-109, December 1, 1976 76T-121, Decembe'r 14, 1976 76T-122, December 14, 1976 76T-004, January 28, 1977 77T-0021, March 1, 1977 77T-085, August 23,-1977 L
13 78T-017, February 6,1978 78T-019, February 7,1978 78T-168, September 5, 1978 79T-019, January 8,1979 79T-038, January 8,1979 79T-062, February 5, 1979 79T-063, February 5,1979 79T-269, July 18, 1979 JA 79T-001, January 7,1979 JA 79T 009, February 2, 1979 JG 79T-003, March 2, 1979 JG 79T-004, March 16, 1979 h.
Numerous process checklists, equipment surveillance parameter checklists, and supplier quality surveillance reports completed by GE source inspectors at MEC.
i.
The training and qualification records of three (3) source inspectors and three (3) auditors.
3.
Findings Two deviations (See Notice of Deviation enclosure, items A and B) a.
and no unresolved items were identified in this area of the inspection.
Concerning the deviation identified as item A in the enclosure, the following actions were taken by CE before the conclusion of the inspection and no futher written response to this deviation is necessary.
(1) GE performed a review of the qualification records con-cluding that +.he condition identified in the deviation was an isolated case.
(2) On October 4, 1.179, the Manager of Procurement Quality Assurance (PQA) signed the Form RC-117, certifying the qualifications of the individual in question.
f 14 (3) On October 5, 1979, the Manager of PQA issued a memo to the Manager of Systems, Schedules, and Surveillance directing him to conduct monthly audits of personnel training records in PQA and document the results of this audit in a memo to him. These actions will continue until control of their record system is assured.
b.
The following are the GE procurements from HEC and their disposition:
(1) C&ID Ordered Items (a) Numerous brackets, bolts, tees, nuts, washers, pins, connectors, cable terminals, and keeper tools - as a rule not traceable, but used as stores for use on next assembly (sparger and fuel grapple).
Some are in stores at GE and MEC, others have been incorporated into assemblies and shipped to domestic and foreign plants.
All ordered as non-safety items.
(b) Ten fuel grapples, ordered as non-safety items, one is at a foreign plant and the remaining nine (9) have been returned to MEC on an engineering change notice.
(c) Two (2) spargers and numerous sparger parts, all ordered as non-safety, the spargers at two (2) domestic plants and the parts are in stores at GE and MEC for use on next assembly basis.
(d) Six (6) headers (sparger sub-assembly) and fourteen (14) thermal sleeves, all ordered as non-safety, eight (8) thermal sleeves are at a foreign plant and the other six (6) sleeves and (6) headers are in stores at GE.
(e) Eleven (11) sample chambers (radwaste system component),
ordered as non-safety, five (5) are presently in GE stores and the other six (6) are at six (6) reactor sites, two of which are domestic sites, (f) Seven (7) channel bolt wrenches, four (4) channel gage fixtures, and two (2) slings, all ordered as non-safety items.
Three of the wrenches are at-a domestic site and four (4) are in GE stores; three of the fixtures are at foreign sites, one is at a domestic site; the slings are used by GE.
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15 (g) Sixteen (16) control rod grapples, eleven of which were ordered as non-safety and have been sent to reactor sites, seven foreign sites and two (2) domestic sites.
The remaining five (5) control rod grapples were ordered as safety items and are presently being held in GE stores in Wilmington, North Carolina.
(h) Six (6) fuel grapples, ordered as safety items (P0 282-KF 295) have been returned for the second time to MEC for rework.
(2) Engineered Equipment Procurement (EEP)
Operations Ordered Items (a) Seven (7) header assemblies (spargers), four (4) to domestic sites and three (3) to foreign sites.
(b) Three (3) thermal sleeves, two (2) to domestic sites and one to a foreign site.
(c) Eleven (11) sets of headers and thermal sleeves, all to domestic sites.
Nine (9) of these orders were placed only recently, but none have been designated safety essential:
Only one of these eleven (11) sets have been designated as safety related and this one (P0 205-AL709) was at the request of the utility.
EEP imposes quality requirements on its suppliers via one c.
of two documents referenced in the P0s, QAR-I for suppliers providing safety related items, or QAR-II for suppliers providing non-safety related items.
QAR-I has not been imposed on MEC through any EEP P0s reviewed.
Of the P0s for items identified in b.(2) above for safety related equipment, the applicable P0 (205-AL709) imposed QAR-II together with QA sup-plements QAS No. 26, QAS No. 28, and QAS No. 29.
However, GE personnel stated that QAR-II, when supplemented by these QASs, was equivalent to QAR-I for-all intents and purposes.
A com-parison by this inspector of QAR-I to QAR-II with its supplements resulted in the following conclusion.
Considering only the scope of the PO issued by EEP to MEC (e.g. excluding design process control), the following differences are apparent:
(1) There is no requirement for MEC to audit its suppliers of materials for the GE P0s, e.g. weld material suppliers.
This requirement is in QAR-I.
16 (2) Shipment and storage activities are permitted to proceed without a written release from GE; QAR-I requires such a written release.
(3) MEC is not required to assure that their suppliers have removed, reported, and properly dispositioned deviations related to the ordered material; QAR-I has this require-ment.
(4) There is no requirement for processing radiographs to assure they can be stored for 40 years; QAR-I requires such pro-cessing.
(5) There is no requirement that MEC obtain GE approval when applying code cases or code interpretations; QAR-I requires GE approval.
(6) Neither QAR-II nor the QA supplements provide specific rules for weld repair and buildup or qualifications for NDE and audit personnel; QAR-I has such requirements.
(7)
In addition, the GE supplier qualification program requires that "QAR-I suppliers" be approved by an onsite audit prior to use, that these suppliers be evaluated annually to determine if an onsite audit is necessary for continued qualification of the supplier, and that such suppliers are audited, onsite, at least every three (3) years; a "QAR-II supplier" is not subject to any of these requirements in the GE program.
Notwithstanding the above programmatic differences imposed by QAR-I and QAR-II, topical report NEDO-11209-04A requires that suppliers providing safety related equipment be qualified and periodically evaluated in a manner consistent with those suppliers whom GE has imposed QAR-I.
Since GE is using HEC as a supplier of safety related equipment and QAR-I has not been imposed, GE is in non-compliance with their QA program.
This is the substance of the deviation identified in Report No. 99900403/
79-02, d.
The following are the results of the review concerning the deviation in Report No. 99900403/79-02.
A memo from a QC Specialist dated November 8, 1978, acknowledged the fact that there was a difference between the QA requirements imposed by Millstone for their feedwater spargers and the QA
17 requirements imposed by GE on HEC.
He concluded that either Millstone must accept the QA program imposed by GE, i.e.
QAR-II plus supplements, or GE would be required to find a suitable supplier using QAR-I.
The NRC inspector did not view documents from Millstone stating their position, but he was advised that Millstone did accept the use of MEC and the QA program imposed by QAR-II, plus supplements.
The PO for the Millstone spargers (205-AL709) was issued to MEC on January 5,1979.
Two (2) auditors from QAEE&I visited MEC on February 6-7, 1979, and documented this trip in a report dated February 9, 1979, QA Review and Surveillance of Marvin Engineering Co., for Fabrication of Feedwater Spargers for both Operating and Requisition Plant Orders.
It was found that the MEC QA manual on file at GE was obsolete and MEC was using a new QA manual.
1 The auditors identified a number of errors and weaknesses in the new manual and its implementation. The GE auditors obtained commitments from HEC to correct the items identified; however, no formal corrective action requests were issued.
This report concluded that MEC would be a fully capable supplier if their new manual was corrected, submitted to GE, approved, and fully implemented. Further, this report stated that a systems audit would be scheduled in two or three weeks to audit the new manual, verify its implementation, and verify that the items identified were corrected.
a The new MEC QA manual, with supplemental letters, was reviewed 2
and approved by GE on March 6, 1979. Further, the Manager, EEP-I Service unit, stated in a memo dated March 20, 1979, that MEC had added three (3) new QC people and that a new Production Control Manager was in place, both in partial response to the February 9,1979, report. Apart from surveys made by the GE site respresentative, neither an audit nor a systems audit was made of MEC subsequent to the visit on February 6-7, 1979.
In conclusion, it appears that:
(1) The appropriate QA program was not imposed on MEC for the Millstone feedwater spargers, namely QAR-I.
(2) The QA program of MEC and its implementation have not been appropriately evaluated, since the February 6-7, 1979, visit appears to have accomplished only an indepth review of the MEC QA manual, while the subsequent systems audit, that would verify implementation of the new MEC QA manual, has not been conducted.
(
18 These items are being followed up in conjunction with the correspondence pertaining to Report No. 99900403/79-02.
This matter will be evaluated further during subsequent inspections at GE.
The following is the status and results of this inspection e.
concerning the fuel grapples (P0 282-KF295) ordered by C&ID from MEC.
Six (6) fuel grapples were ordered on August 18, 1978.
GE classifies these grapples as safety-related and imposed quality plans QP 20.119, QP 30.117, and QP 30.124 in their P0. MEC appears to have been qualified as a supplier of 10 CFR Part 50, Appendix B products on December 1, 1976. The next source survey of MEC was on August 23, 1978.
Three (3) negative observations were reported which were closed during a followup audit on January 5,1979, MEC was retained on GE's qualified supplier list. A Supplier Performance Evaluation Checklist was completed on September 7, 1979, that concluded MEC was still a qualified supplier and no audit was required.
The six (6) grapples were completed and sent to GE, one received on January 25, 1979, four received on February 12, 1979, and one received on February 20, 1979.
GE's receiving inspection rejected all six grapples and issued inspection reports RI 688, RI 872, and RI 873 (defective switch and failed functional tests) returning the grapples to MEC on April 6,1979.
The six (6) grapples were returned to GE on June 7, 1979.
GE's receiving inspection rejected the grapples again, issued inspection reports RJ 814 and RJ 815 (failed functional tests, etc.), and returned the grapples to MEC on September 17, 1979.
Both of these inspection reports contained the following engineering directions, "Before releasing grapples, functionally test all grapples involved to twice their design load (1000#).
Following test, conduct dye penetrant of those welds illustrated on attached, marked up drawings:..., if grapples pass above tests refer to J. Breseke before releasing."
Subsequent to an FBI investigation alleging falsification of records concerning these grapples, several internals notes and memos were issued on the subject.
One such memo (Kaleda to D. Wright and Evankovich dated June 29, 1979) proposed the following actions:
(1) Review quality records at MEC (e.g. inspection, NDT, qualifications, weld procedures and NDE procedures).
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19 (2) Detailed review of records supplied with grapples.
(3) Review of one-time submittal records (WPSs and PQRs).
(4) Disposition of inspection reports RJ 814 and RJ 815 including the testing requirements quoted above.
In a memo dated August 1, 1979, from D. Wright to J. Breseke the following actions were documented relative to those proposed above:
(1)
" Completed 7-11-79.
No discrepancies noted. Welders (4) were qualified."
(2)
" Completed 7-6-79 by W. Steward, PQA.
Record Package complete and in order."
(3)
" Completed 7-9-79.
All one-time submittals received and approved."
(4) These actions were still incomplete, awaiting the grapples return to GE.
During this inspection, the NRC inspector confirmed two of these actions.
The one time submittals, WPSs and PQRs had been sub-mitted, and reviewed and approved by GE.
The data package for the six (6) grapples were reviewed and found to contain, for each grapple by serial number, certificates of compliance, material certifications, PT records, heat treat report, etc. Further, the documents ir. the data package had inspection stamps of both MEC personnel and the GE site QA representative attesting to the validity of the records.
The following is a quote from trip report 79T-269 documenting a visit by a GE QC engineer to MEC on July II, 1979:
"I visited Marvin Engineering to determine whether or not qualified welders were utilized on our orde'r for Fuel Grapples.
"The vendor did not use shop travelers or other types of documents when fabricating our order, therefore, there is no written record of the persons actually doing the work.
Mr. Barnack stated that the following persons welded the grapples:
In considering the attested validity of the data package by the GE site representatives and the finding of the GE QC engineer that no production documents were used, during fabrication, it is difficult to understand how the data package for each of the fuel grapples can be valid.
This concern was discussed wit a GE in several telephone conversations following the inspection teams return to the Region IV offices.
l l
20 GE requested a meeting with the NRC inspectors to provide additional information concerning the GE site representatives responsibilities.
A meeting was held in the Region IV offices on October 30, 1979.
The GE representatives in attendence were:
J. A. Aurelio, QA Representative A. Breed, Manager, QA, P&QA0 J. H. Breseke, Manager, Procurement QA, C&ID W. C. Cohn, Manager, QC Engineering S. Laub, Corporate Counsel D. L. Wright, QC Engineer, C&ID The following is a summary of that meeting.
GE described the responsibilities of the site representative concerning his review of the data package as being:
(1) A review of the package to assure that all PO required records were included.
(2) Verifying that the records were completed and legible.
(3) Stamping each record as being acceptable for shipment to GE - San Jose.
In the case of the fuel grapples, the site representative per-formed certain dimensional checks and witnessed certain functional tests before the grapples were released for shipment.
As explained by the GE personnel, the site representative was not responsible for verifying the accuracy or validity of the records in the data package. This verification is the responsibility of engineering in GE - San Jose prior to the records being submitted to the QA Records Center for retention.
Concerning the tracability of the material certifications to the specific fuel grapple assemblies, GE personnel states that all the material purchased for the grapples was procured at the same time in lots large enough for all six assemblies. Thus the same mate-rial certifications would be applicable to each fuel grapple as-sembly.
In conclusion, it appears that the GE site inspector performed in the manner that was required by the GE QA program and purchase order requirements. However, departures from PO requirements by MEC during the fabrication of the grapples, principally the absence of a flow plan, (manufacturing instruction, or traveler, etc.) for each as-sembly, indicates an apparant lack of necessary surveillance require-ments being provided by GE of this supplier. The adequacy of GE's surveillance of their suppliers will be a subject of our future in-spections of GE.
l
21 D.
Follow-up on Construction Deficiency Report (CDR) - Welded Attachments to Class I Piping 1.
Objectives The objectives of this area of the inspection were to:
a.
Review the actions by GE relative to this CDR.
b.
Assess the potential for generic applicability of this CDR.
Determine if a 10 CFR Part 21 evaluation was performed.
c.
2.
Method of Accomplishment The preceding objectives were accomplished by review of the following:
I a.
CDR issued June 29, 1979, by Long Island Lighting Company wherein 142 lugs (both field welded and shop welded) indicated i
some lack of penetration.
b.
Field Deviation Disposition Requests (FDDR) numbers:
KS-01-93, Hanger lugs on primary steam piping lacked full penetration, welding onsite.
KS-01-276, Lugs on received piping lacked full penetration, welded in shop.
Both FDDRs were initiated on June 16, 1979, and issued on September 25, 1979.
c.
Internal memos:
(1) Manager, Piping Equipment Design to Licensing, dated July 10, 1979.
(2) Principal QC Engineer to Manager, Piping Equipment Design, dated October 5, 1979.
3.
Findings No unresolved items or deviations were identified in this area a.
of the inspection, b.
GE issued the noted FDDRs for review and disposition of the problem identified in the CDR.
GE's conclusion on the FDDRs was that other plants were not affected.
22 GE's Piping Design group performed an analysis of this problem c.
and documented its results in a memo to GE's licensing group.
This memo stated that the " lugs were reevaluated by Piping Design, taking no credit for the identified area of lack of penetration and it was determined that the allowable stresses of B31.1 were still met."
On the basis of this analysis, GE concluded that a further Part 21 evaluation was not neccessary.
d.
GE did take further preventive action. The Principal QA Engineer in his October 5,1979, memo, requested that GE's QC surveillance inspectors at their piping fabricator shops institute a temporary witness point of the PT on the root welds of lugs. Also, to UT the next lot of lugs welded at one fabricator's shop to further assure full penetration of welds.
23 DETAILS SECTION III (Prepared by J. M. Johnson)
A.
Persons Contacted B. J. Beach, Quality Control Engineer, Technical Leader B. Brooks, Manager, Steam Valves Unit
- K. I. Curry, Specialist, Quality Notification and Audits
- D. R. Erie, Senior Engineer, Quality Assurance R. Ghosh, Design Engineer, Valves A. Gofstein, Quality Control Engineer R. Holt, Document Release and Control (DRC) Supervisor C. Johnson, Manager, Mechnical Equipment Design T. Lewis, Lead Designer, Drafting J. M. Marsh, Specialist, QA Records J. L. Murray, E0P Program Manager W. R. Perrault, Manager, QC Engineering (Valves and Piping Components)
W. Peterson, Product Services Engineer K. Rooney, Buyer B. L. Shepard, Manager, Quality Systems and Records
- Denotes those present at exit meeting.
B.
QA Records 1.
Objectives The objectives of this area of the inspection were to examine the establishment and implementation of quality related procedures for collecting, filing, storing, maintaining, and dispositioning of QA records to verify that:
A QA records system is defined, implemented, and enforced a.
In accordance with app oved procedures, instructions, or other documentation for all groups performing safety related activities including QA, design, procurement, administration, and services.
(QA records generated after commercial operation are subject to the record control system.)
i b.
QA records are legible, completely filled out, adequately identifiable to the item involved, validated, and listed in an index that indicates:
the record retention time, where the record is to be stored, and the location of the record in the storage area. Any changes or modifications to these records are controlled.
l
24 c.
A specific submittal plan for QA records is established between the licensee and contractor and records exist that acknowledged the licensee's receipt of QA records.
d.
A designated authority has been assigned to control the receipt of QA records by a system which includes a list of QA records required, a record of QA records received, and an inspection of incoming records including a current assessment of the status of incoming records.
e.
A custodian has been designated to assure that QA records are in accordance with b. above and to enforce a QA record storage filing system which includes a system description of the filing technique and storage area, rules for access and control of record files, accountability of records removed from record files and security requirements.
f.
The QA record storage facility is in compliance with applicable codes, standards, and regulations consistent with NRC Regulatory Guide 1.88 as modified in GE Topical Report.
g.
The QA record storage system is periodically audited to assure the record control system is implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
GE Topical Report No. NEDO 11209-04A: Section 2 (Quality Assurance Program); Table 2-1 (NRC Regulatory Guide Positions, including Supplement to the Alternate Position on Regulatory Guide 1.88); Section 17 (Quality Assurance Records),
to determine program commitments.
b.
Sections 2.17, 3.17 and 4.17 (QA Records) to determine requirements and procedures.
c.
Engineering Operating Procedures (EOP): E0P 42-10.00 (previously E0P 40-10.00, Design Record Files - DRF, including Appendix A);
E0P 42-12.20 (Material and Equipment Traceability Requirements);
E0P 60-1.00 (Document Control); E0P 60-3.10 (Engineering Records Retention, which references GE Document No. 21A1937) to determine procedural requirements for GE design documents, d.
Quality Control Standing Instruction (QCSI) No. 7.2.4 (Supplier Records for Engineered Equipment) and No. 7.2.5 (Surveillance, Final Inspection, Product Release, and Certification) to determine procedural requirements for supplier records.
i
25 GE document No. 21A1937 (Quality Assurance Records) to e.
identify record and retention requirements for design records (GE) and for records for procured equipment.
f.
Quality Assurance Requirements (QAR) No. 1, standard QA attachment to safety-related purchase orders delineating require-ments for the seller to submit data (document) packages containing quality assurance records, g.
QA Engineering Equipment and Installation (QAEE&I) Administrative Guide, procedure " General-28" to determine requirements / guidelines.
h.
Organization and Policy Guide (OPG), Instruction 70-12 (QA Records.)
i.
Document Release and Control (DRC) Instructions.
j.
QA Records related to Target Rock Safety-Relief Valves for Hope Creek (and one for Cooper) for P0205-AD 141:
(1) Target Rock Record Binder (data package) for valve serial number 369, including review of NV-1 form (Manu-facturer's Data Report), and Product Quality Certification (PQC) and Certificate of Conformance (C of C), Ultrasonic Test Report, and Supplementary Certificate Data Sheet among pages reviewed.
Note that legibility appeared good and each page examined showed record of GE review.
(2) Checked transmittal of copy of binder to the Hope Creek site from Target Rock, and the record of receipt dated March 2, 1979.
(3) QA records of original purchase order (to Dresser Valve) and purchase order revisions including number 22, transferring the purchase order to Target Rock, and number 30, shipping one valve to Cooper.
(4) QA record copies of Deviation Disposition Request (DDR) number 15220 approving deviation of Cooper valves (PO numbers 205-AB843 and 205-AD141) from specification require-ments for pressure range and backpressure range; and Supple-mental Product Quality Certification (PQC) numbers PP 358, PP 359 and PP 360 listing DDR 15220. Also, the inspector verified transmittal of these QA documents to Cooper site on July 16, 1979 (letter JMG - 79548).
26 (5) Microfiche records in DRC of Field Disposition Instruction (FDI) number 87/88524 and attached Reliability Study Summary requiring return of Shoreham Target Rock safety-relief valves for modification to correct design deficiency.
k.
Microfiche file of QA Document Binder for RCIC Pump from Bingham-Willamette for Grand Gulf (P0 205-AG533; MPL number E51C001).
1.
QA Document Binders from Dikkers for safety-relief valves for P0 AJ430, and related documents:
(1) Binder for valve serial number 106864 for Perry II, in-cluding unapproved DDR No. 1785. Note that status of all Dikkers' binders is that GE San Jose has not yet finally accepted these binders.
(2) GE letter dated March 14, 1979, to Dikkers concerning unsatisfactory Grand Gulf I binders (especially legibility and translation).
GE letter dated August 3, 1979, indi-cating additional corrections to binders needed.
Microfiche QA records (duplicate) in DRC for the following m.
documents:
(1) Drawings numbers 21A 9206 AM, revision 1; 21A 9206 AC, revision 4; 105D6222, revision 0; 920D802, revision 6.
(Note: Engineering Information Service (EIS) was checked for current revision status of these documents).
(2) Engineering Change Notice (ECN) number NE-88680.
(3) Specification number 21A9206, revision 7.
(4) Field Disposition Instructions (FDI) numbers 19/42382; 21/42382.
List of Records in Permanent Storage (Remote) was Ersmined n.
for inclusion of all the documents listed above in paragraph m.
Design Record Files (DRF) were examined for selected inputs, o.
design verification, etc. and duplication of files (not done) for the following:
(1) DRF 207-B21F041/51-DK-K, for Dikkers safety-relief valves for BWR-6 plants. Records examined included Design Veri-fication checklist and its design review (checking) and approval.
27 (2) DRF 207-TR-SRV-K, for Target Rock 2-stage safety-relief valves for BWR-4 plants, including design records for original design (as available), modifications, new top works per P0 AJ600, etc. Records examined included mechanical Equipment Design Engineering Memorandum (MED) number 126-40 (Evaluation of Downward Set Pres-sure Drift Observed on 2-Stage S/R Valves at Hatch 2) and Reliability Study Summary initiated by FDI 87/88524.
p.
Records of GE Audits performed of Design Records area:
(1) 1979 - Audit number 79-2 and Corrective Action Commitments (CAC) numbers 2-1 through 2-3.
Note that CAC 2-3 con-cerns outdated Verification Log of DRFs and requires sorting into packages to be transmitted to responsible Section Managers for action on revision of custodial assignment designations, copying of DRFs for record retention, etc. This DRF was scheduled for completion the week this NRC inspection was conducted, and no veri-fication had been performed yet.
(2) 1978 - Audit number 78-6 and CAC 6-1 through 6-6.
(3) 1977 - Audit number 77-9 and CAC 9-6 (a closed CAC concerning DRFs delinquent in being reproduced to be scheduled for microfilming).
q.
Engineering Work Authorization (EWA) number EAJ 36-8B delineating corrective action for Corrective Action Request (CAR) number 6 issued by Product and Quality Assurance Organization (P&QAO).
A retrofit of identified minimum design records required in DRFs for BWR-6s is committed to by this EWA.
3.
Findings In this area of the inspection, two (2) deviations were a.
identified.
(See Notice of Deviation, Item C.I. and C.2.)
No unresolved items were identified.
b.
Concerning Notice of Deviation Enclosure, Item B.1, please note the following:
The record binder for the RCIC pump (PO 205-AG 533) had been accepted by GE-San Jose, and the missing signature or stamp j
and date had not been identified. The record binders for safety-relief valves from Dikkers have not been accepted as yet by GE - San Jose.
It is recognized that the missing GE Representative's stamp or signature and date on-the two i
l i
28 e
pages of the Dikkers binder examined might perhaps have been identified and corrected during the GE - San Jose review.
However, the deviation as written relates to the failure of the GE QC Representative to stamp or sign and date the pages as required by the referenced procedure prior to his acceptance of the package and its transmittal by Dikkers.
Concerning Notice of Deviation Enclosure, Item C.2., please note c.
the following:
The status of components for which DRF 207-B21F041/51-DK-K provides GE design records includes shipped valves as well as valves in manufacture.
The status of components for which DRF 207-TR-SRV-K provides GE design records includes installed and operating valves, shipped valves, valves being returned for modification, top works modification, and valves in manufacture.
It is recognized that design changes are still in process and the DRF is therefore not considered complete.
However, design records for the sequence from initial to current design (including design inputs, reasons for design changes, evaluation of design deficiencies, etc. and their review and ap-proval) appear to need protection from fire, loss, etc. The pro-cedural requirements cited in the deviation recognize this need and require duplication of these records at certain intervals and indicated stages.
(See also E0P 40-10.00 dated 9/30/76:
Long term activities may require partial submittal of incomplete DRFs for generation of permanent copy to assure safeguarding of design documentation).
d.
It was noted by the inspector that most of the new Target Rock 2-stage valves for BWR-4 plants will be returned to the vendor, or held at Target Rock if not yet shipped, for modification to correct design / performance deficiency. Also, certain new valve top works were modified but still do not meet specification requirements (per DDR 15220).
29 DETAILS SECTION IV (Prepared by D. F. Fox)
A.
Persons Contacted
- R. C. Boesser, Manager, Technical and Administrative Program
- W. H. D'Ardenne, Manager, Safety Evaluation Programs K. I. Dawley, Manager, Plant Definition & Release Control L. E. Fisher, BWR-6 System Design Program Manager
- D. E. Lee, Manager, Quality Control
- S. L. Mather, Manager, BWR-6 Systems Design
- R. J. Murillo, Senior Engineer J. M. Murray, E0P Program Manager B. R. Rajala, Principal Engineer M. A. Ross, Lead Engineer W. Schultheis, Principal Engineer M. Shira, BWR-6 Overseas Program Manager
- L. D. Test, Principal Engineer
- R.
C. Valencia, Audit Coordinator J. E. Wood, Manager, Core Methods and Analysis
- Denotes those present at the exit interview.
B.
Design Input 1.
Objectives The objectives of this area of the inspection were to determine that:
Procedures have been established and are being implemented a.
that prescribe the system for control of those criteria, para-meters, bases, or other design requirements upon which detailed final design is based.
b.
Design inputs are specified on a timely basis, their selection reviewed and approved, incorporated into the design documents, and changes in input are justified, reviewed, and approved.
c.
Commitments are properly translated into design inputs, as applicable to the following:
(1) Basic functions (2) Performance requirements (3) Regulatory requirements, codes, and standards (4) Design conditions
30 (5) Loads (6) Environmental conditions.
d.
Design requirements are specified, when applicable, relating to interfaces, materials, mechanical, structural, hydraulic, chemistry, electrical, instrumentation and control, redundancy, accessibility, fire protection, and other requirements that prevent undue risk to the health and safety of the public.
2.
Methods of Accomplishment The preceding objectives were accomplished by the following:
Review of the GE Nuclear Energy Business Group BWR Quality Assurance a.
Program Description No. NED0-11209-04A dated March 31, 1978, Sections 2 (Quality Assurance Program) and 3 (Design Control) to determine the GE commitments relative to control of design inputs.
b.
Review of the General Electric Boiling Water Reactor Quality Assurance Manual No. NEDE-20586, Revision 9 dated May 1,1979, to determine if the GE Topical Report (NED0-11209-04A) commitments were correctly translated into the Nuclear Energy Division quality assurance program requirements.
Review of Section 3 (Design Input Requirements) of ANSI c.
N45.2.11 to determine the applicable requirements for identification, ' approval, timely implementation, documentation and control of design inputs.
d.
Review of the following procedures to determine that approved procedures have been established and are being implemented to prescribe a system for the identification, approval, timely implementation, documentation and control of design inputs in " design controlling" documents such as:
Project Work Authorizations Design Drawings Engineering Work Authorizations Software Data Bases System Descriptions Licensing Documents System Specifications Master Parts Lists Equipment Specifications Product Safety Standards Design Calculations Essential Components Lists
31 (1) Projects Division Policies and Procedures:
(a) P&P 35-1.0, Project Licensing Activities and Implementing Practices.
(b) P&P 40-3.0, Project Work Autiorization.
(2) BWRSD Operating Policy & Procedures OP&P 20-9.0, Obtaining
& Documenting Customer /AE Supplied Data.
(3) NED Engineering Operating Procedures:
(a) E0P 10-2.00 Control Card 2/21/78 (b) E0P 15-1.00 Introduction 3/2/79 (Engineering Oper-ating System)
(c) E0P 15-2.00 E0P Application 3/2/79 (d) E0P 15-3.00 E0P Issue 3/2/79 (e) E0P 15-3.10 Review of Interface 12/15/77 Procedures (f) E0P 25-4.00 Engineering Work 11/8/78 Authorization (g) E0P 30-3.00 Product Structure 7/18/77 (h) E0P 30-3.10 Product Summary 6/3/77 (i) E0P 30-4.00 Engineering In-12/13/78 formation System (j) E0P 40-7.00 Design Review 10/3/78 Program (k) E0P 40-8.00 Design Freeze 8/22/77 (1) E0P 40-12.00 Materials 6/25/79 (m) E0P 42-1.00 Introduction 5/1/79 (Technology & Design Control) l l
32 (n) E0P 42-1.00(A) General 12/5/78 Information Guidelines for Design Per-formance (o) E0P 42-6.00 Independent 2/13/78 Design Veri-fication (STDN-B)
(p) EOP 42-6.01 Design Calcu-2/13/78 lations (q) E0P 42-6.10 Engineering 11/20/78 Document Issue
& Application (r) E0P 55-2.00 Engineering 12/19/78 Change Control (s) E0P 60-1.00 Introduction - 6/29/79 (Document Control)
(t) E0P 60-6.00 Drafting 10/12/76 Manual Control (u) E0P 65-2.00 Product Safety 11/30/77 Requirements (v) E0P 65-2.10 Safety Import-8/5/77 ance Classi-fication (w) E0P 65-5.00 Licensing 8/2/77 Documentation (x) E0P 65-5.10 Fuel Reload 9/27/77 Relicensing (4) GE Drafting Manual:
(a) Section 7.1 Specifying 8/9/77 Codes &
Standards
'I
33 (b) Section 15.4 System 4/29/79 Specification Format (c) Section 15.5 Equipment 4/29/79 Specification Format (5) Other documents:
(a) PE 20-2.0 Preparation 2/6/79 Review, and Revision of Reference Technical Description (b) NEDE 22000 Publication 8/31/79 Handbook (c) GESSAR-6 Section 3.0; 9/3/74 Design Criteria -
Structures, Components, Equipment &
Systems (d) BWR BWR Project 1/20/76 Handbook Review of the following " design controlling" documents for the e.
Clinton Power Station Units 1 & 2 to verify by random sampling that the design inputs listed below were identified, approved, timely implemented, documented, and controlled:
Basic Functions Regulatory & Code Requirements Design Conditions Customer Requirements Environmental Conditions Software Data Bases Loads Suitability of Material Performance Interfaces Materials Mechanical Structural Hydraulic
34 Chemical Electrical Layout & Arrangement Operational Test Instrumentation &
Control Failure Effects Transportability Access & Admin. Control Personnel & Their Fire Protection Redundancy, Diversity &
Limitations Seperation Handling, Storage Safety Maintenance, Repair &
& Shipping ISI (1) Engineering Work Authorizations KL61J-02 Clinton Power Station 3/13/79 Units 1 & 2 (2) System Specifications Number Title Rev Date (a) 22A3153 Reactor Protection 2
3/15/76 System (b) 22A3153AB Reactor Protection 1
12/13/74 System - Data Sheets (c) 22A3131 High Pressure Core 5
4/7/77 Spray System (d) 22A3131AB High Pressure Core 6
9/14/79 Spray System - Data Sheets (e) 22A4622 Nuclear Boiler System 2
1/9/78 (f) 22A4622AB Nuclear Boiler System -
1 1/6/78 Data Sheets (g) 22A3899 Control Rod Drive System-4 8/24/78 Fast Scram f
(h) 22A3899AB Control Rod Drive System-3 8/24/78 Fast Scram - Data Sheets (i) 22A2734 Reactor Containment 2
7/29/76 System 1
35-(3) Equipment Specifications Number Title Rev Date (a) 21A9236 Engine Generator for HPCS 4 7/7/75 (b) 21A9236CD Engine Generator for HPCS 1 1/24/75
-Data Sheets (c) 21A9457 Valves, Motor Operated 3
1/9/78 (HPCS)
(d) 21A9370AB Valve, Explosive SLCS -
6 10/25/78 Data Sheets (e) 21A9326 Turbine, Steam, Aux.
2 12/10/76 Drive (f) 21A9477 Reactor Vessel 7
8/21/78 (4) Drawings Number Title Date (a) 828E317 Reactor Protection System IED 6/16/79 (b) 105D4919 Reactor Core Isolation P&ID (c) 769E305 Nuclear Boiler System P&ID 7/25/79 (d) 768E972 Group Classification & Contain-9/30/77 ment Isolation Diagram (e) 131C7911 Nuclear Boiler System - Proc. Diag.1/4/79 (f) 865E345 Multiplexer Control Schematic 3/22/77 (g) 767E800 Hydraulic Control Unit 4/29/78 (h) 105D5007 Valves, Motor 0.perated 1/18/73 (i) 105D5007K Motor Operated Valve 2/12/79 (j) 112D1434 Interface Control Valve, Explosive (5) Design Basis Documents Number Title Rev Date (a) 457HA909 Nuclear Design Basis 1
4/4/79
36 (b) 22A2576 Customer Supplied Data ~ 1 2/10/75 (c) 384HA380AR Product Safety Standards 0 8/15/78 (d) 22A3762 Essential Components &
1 4/23/74 Equipment Important to Safety (e) 383HA688AC Core Thermal Hydraulics 2
6/3/76 Data Book (f) 384HA380 Product Safety Standards 5 1/3/79 (g) 408HA100 BWR-Materials & Processes 8/28/79 Handbook (h) Y1002C100 BWR-Fuel & Control 8/14/79 Materials Handbook (i) Y1002E100 BWR-Chemical Technology 10/3/78 Handbook (j) Y1002A100 BWR-Plant Materials 8/16/79 Properties Handbook (6) Other " Design Controlling" Documents Number Title Rev Date (a) 18NS06B07 Master Parts List 9
7/24/79 (Clinton I & 2)
(b) 22A3076 Fire Protection &
4 9/26/78 Prevention (c) 22A2756 Inservice Inspection (d) 104R946 Product Structure 19 2/5/79 (e) DC105D-Design Certification 1/18/78 4935AU i
3.
Findings a.
Deviations from Commitment In this area of the inspection, one (1) deviation was identified. See Notice of Deviation Enclosure, Item C.3.
i l
37 b.
Unresolved Item In this area of the inspection, one unresolved item was identified:
The second paragraph of the Nuclear Engineering Division Engineering Operating Procedure E0P 10-2.00 (Control Card for Manual Number---) dated February 21, 1978 states in part,
"... Incumbents of positions assigned E0P Manuals are responsible for their maintenance.
A " Lending Library" copy of the EOP Manual contained a superseded table of contents.
The control of E0P manuals will be further reviewed during a future inspection.
c.
Follow-up Items (1) The Nuclear Engineering Division (NED) of the General Electric Company has established the requirements for identification, approval, timely implementation, and control of design inputs in a multiplicity of engineering procedures, instructions and handbooks rather than in a single (or cross-referenced set) procedure.
The inspector reviewed the approved and issued documents but time did not permit the inspector to verify, with a high degree of confidence, that they collec-tively prescribe a complete, unique and concise system for defining and controlling the design inputs into the basic
" design controlling" documents identified in paragraph B.2.d above.
This item will be further reviewed in a future inspection.
(2) Random examination of fourteen (14) system and component specifications indicated that design inputs usually were identified, reportedly were obtained from controlled sources, generally adequately detailed and sufficiently complete, and appeared to be technically correct.
However, time did not permit the inspector to:
(1) trace individual design inputs back to their specific sources to verify their accuracy since most design inputs were not uniquely referenced to their source, (2) verify that reliability, redundancy and separation criteria were considered in the System Design, since in accordance with NED practice, the safety classification of the system or component was not
1 38 identified in or on, the system or component specifi-cation itself, nor were the significant safety functions that the safety related system had to perform always clearly delineated in the system specifications, and (3) confirm that Inservice Inspection requirements were considered in the system or component design.
This item will be further reviewed in a future inspection.
l s
f I
39 DETAILS SECTION V (Prepared by W. E. Foster)
A.
Persons Contacted I. Bhandal, Supervisor, Process Control Engineering, PGCC F. C. Cannizzaro, Specialist, Procedures and Audits, PGCC W. D. Caruth, Specialist, Material Systems
- D. H. Currie, Manager, Quality Systems, Audits and Records A. L. Correnti, Forelady, Panel Shop Operations J. Fisher, Engineer, Manufacturing, Cable Shop A. J. Fotta, Working Group Leader, Panel Shop A. Gutierrez, Unit Manager, Shop Operations S. E. Hassan, Supervisor, Process Control Engineering G. Jendrzejczak, Foreman, Cable Shop N. Lamberti, Manager, Process Control Engineering B. Marsh, Supervisor, Process Control Engineering, PGCC H. C. Miller, Manager, Process Control Engineering, PGCC E. Sanchez, Supervisor, Process Control Engineering, PGCC J. N. Sokol, Supervisor, Process Control Engineering C. Villa, Foreman, Panel Shop Operations
- Attended exit meeting.
B.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that measures had been established and documented to control manu-facturing, inspection and test activities.
Also, to verify these activities had been accomplished in accordance with the established and documented measures. Additionally, verification of indication of mandatory hold points in appropriate documents.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
Review of the following documents to verify measures had been a.
established and documented to control manufacturing, inspection and test activities:
(1) Quality Assurance Procedures Manual, Revision 5, dated June 25, 1979, Section Nos:
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40 (a) 2.0, Revision 0, dated May 4, 1979 entitled, Glossary of Terms, (b) 2.5, Revision 0, dated May 4, 1979 entitled, Instructions, Procedures, and Drawings, (c) 2.10, Revision 0, dated May 4, 1979 entitled, Inspection, (d) 2.11, Revision 0, dated May 4, 1979 entitled, Test Control, (e) 2.14, Revision 0, dated May 4, 1979 entitled Inspection, Test, and Operating Status, (f) 5.1, Revision 4, dated June 25, 1979 entitled, Instructions, Procedures, and Drawings, (g) 10.1, Revision 4, dated April 19, 1978, entitled, Inspection Planning, (h) 10.3, Revision 0, dated June 20, 1975 entitled, Sampling Inspection, (i) 11.1, Revision 3, dated April 19, 1978 entitled, Test Planning, (j) 14.2, Revision 8, dated June 25, 1979 entitled, Inspection / Test Stamp Control, (k) 14.3, Revision 3, dated August 28, 1978 entitled, Inspection Status and Serial Number Log, (1) 15.2, Revision 3, dated January 2, 1979 entitled, Rework Record Procedure, and (m) 8.1, Revision 4, dated June 25, 1979 entitled, Identification and Control of Material, Parts and Components.
(2)
Inspection Instruction Nos:
(a) CA-001, Revision 1, dated July 17, 1978 entitled, Cable Records Check List and Certification, and (b) CA-002, Revision 10, dated September 18, 1979 entitled, Cable In-Process and Final Inspection.
41 (3) Manufacturing Procedures No. 5.03, dated June 18, 1979 entitled, Inspection Report.
(4) Manufacturing Standard Practice Nos:
(a) 10.003, Revision 0, dated February 5,1979 entitled, PGCC Cable Assembly Instruction Manual, (b) 18.005, Revision 3,. dated February 17, 1978 entitled, Connector - Cable Assembly, and (c) 20.016, Revision 0, dated February 2, 1979 entitled, PGCC Staging.
b.
Observed the following activities to verify accomplishment in accordance with established and documented measures:
(1) Measuring, cutting, and identifying cable in accordance with Section 5, Revision 6, dated September 18, 1979, of the PGCC Cable Assembly Instruction Manual, (2) Multi-Conductor Shield Preparation in accordance with Section 6, Revision 3, dated September 12, 1979, of the PGCC Cable Assembly Instruction Manual; (3) Multi-Conductor Lug / Pin Installation in accordance with Section 7, Revision 4, dated September 22, 1979, of the PGCC Cable Assembly Instruction Manual; (4) Multi-Conductor Connector Assembly in accordance with Section 8, Revision 4, dated September 10, 1979; (5) Multi-Conductor Final Assembly in accordance with Section 9, Revision 2, dated July 26, 1979; (6) Cable Testing in accordance with Test Instruction No. 1644, Revision 7, dated March 5, 1979 entitled, Cable Final Electrical Test; (7) Final inspection of cable in accordance with Inspection Instruction No. CA-002, Revision 10, dated September 18, 1979 entitled, Cable In-Process and Final Inspection; (8) Assembly on RPS Instrumentation Auxiliary Relay Panel in accordance with Engineering Change Notice No. NJ13004; (9) Testing of Power Range Monitor in accordance with Test Instruction No. 2267, Revision 1;
e 43 Inspection Status Log reflected no entries for the cable.
Cable Assembly Records identify Operation Numbers and are attached to individual cables being processed. Four (4) records were reviewed for cables related to Traveler T No. TRDT4 and none of the records reflected Operation No. 061 (Q.C. Hold Point) which was identified on the Traveler.
Regarding Notice of Deviation, Item C.6. - Nonconforming Tags were attached to the following Wide Range Monitors:
Serial Nos. 6, 614, 170; 6, 614, 171; 6, 614, 172; and 6, 614, 174. These units were located in the Shop Area.
Serial No. 6, 614, 169 was located in the Inspection area and displayed a badly mutilated Nonconforming Tag; an attached note indicated the unit was awaiting rework to Inspection Report (IR) No. R4792. The IR was dispositioned to 'Use As Is' on August 30, 1979 and ' Closed Out' on August 31, 1979; however, the NRC inspector observed that Serial No. 6, 614, 170 was undergoing rework to eliminate the deficient condition.
Regarding Notice of Deviation, Item C.7. - Manufacturing Procedure No. 3.15 (Work Order Processing) had been canceled, about March 1979. Work Order Processing is being accomplished in accordance with a proposed Materials Procedure (No. 3.11) which is in the final review / signature stage, b.
Unresolved Item Inspection Instruction No. CA-002, Revision 10, dated.
September 18, 1979 requires:
(1) A random in process inspection of wire preparation, and crimping operations four (4) times during each shift shop personnel are performing these operations, para-graph 3.3.2.2., and (2) Inspection of twenty (20) percent of any lot that is in process of being manufactured during these random inspec-tions, paragraph 3.3.2.3.
There were no records indicating when random inspections had been performed, which shift had been involved nor whether or not shop personnel had performed these operations the entire shift.
Consequently,_the NRC inspector was unable to determine that random inspections had been conducted four (4) times during each shift.
42 (10) Set-up for testing of Reactor Core Isolation Cooling cabinet in accordance with Test Instruction No. 2274, Revision 0, dated July 10, 1979; (11) Functional Test of Main Steam Isolation Valve Leakage Control Panel in accordance with Test Instruction No. 2610, Revision 0, dated August 15, 1979; (12) Wiring of SB-9 switches on Traveler T No. TEWE9 for the Remote Shutdown Panel; and (13) Wiring on Traveler T No. TEWK4 for the Outboard Isolation Valve Relay Panel.
Reviewed the following hardware / records to verify handling /
c.
completion had been accomplished in accordance with established and documented measures:
(1) Wide Range Monitors, Serial Numbers 6, 614, 169 through 6, 614, 176 and associated Inspection Report No. R479Z (2) In-Process Inspection Log (RC-254, 6/1/79), entries dated August 18, 1979 to October 1, 1979; and (3) Crimping Tool and Die Log (RC-326, 7/3/79), entry of October 2, 1979 and related crimpers and dies.
(4) Travelers, Cable Assembly Records and Cable Inspection Status Log for inclusion of hold points.
3.
Findings a.
Deviations from Commitment (1) See Notice of Deviation, Item C.4.
(2) See Notice of Deviation, Item C.5.
(3) See Notice of Deviation, Item C.6.
1 (4) See Notice of Deviation, Item C.7.
Regarding Notice of Deviation, Item C.5 - The Cable Inspection Status Log (RC-192, 9/7/79) for Traveler T No. TRDW4 indicated (by Final QA Acceptance Stamp), that cable No. AGG002 DC99-1-005 had been processed through Operation No 085 (Final Inspection);
however, Operation No. 061 (Q.C. Hold Point) on the Cable
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44 o,
t There were no records to identify lots, total of items in manufacture, or sample size; therefore, the NRC inspector was unable to determine whether or not twenty (20) percent of any lot had been subjected to in process inspection.
c.
Follow-up Items (1) Numerous completed cables in PGCC stores exhibited connectors that had not been protected to exclude contaminants.
It appears that the requirements only address such protection during shipping prepa rations. Examination of connectors revealed contamination is occurring during exposure to the shop environment.
The NRC inspector's concern is the lack of a requirement for protection against contaminants during the time when the cable is in the shop and has not been terminated.
(2) The PGCC Cable Assembly Instruction Manual provides specific assembly and quality requirements and is a supplement to the MSP Manual (MSP No. 10.003, Revision 0, dated February 5,1979, paragraph 5.1.1).
The Cable Assembly Instruction Manual is a multi-section document with each section individually controlled regarding revision level (paragraph 5.2.1 of the above MSP) with the pertinent section being specified at the appropriate operation of the Traveler.
Paragraph 4.9.5 of Quality Assurance Procedures No. 8.1, Revision 4, dated June 25, 1979, requires that operations performed to a specific instruction will have the document revision level entered on the Traveler.
The NRC inspector's concern is non-identification of the revision level of the pertinent section of the Cable Assembly Instruction Manual at the appropriate operation of the Traveler.