ML20003G598
| ML20003G598 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1981 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Beaton GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20003G590 | List: |
| References | |
| REF-QA-99900403 NUDOCS 8104300230 | |
| Download: ML20003G598 (3) | |
Text
[Na UNITED STATES y 'ig g 7j NUCLEAR REGULATORY COMMISSION
" }~ [ /j j REGION IV g,,;, gg 611 RYAN PLAZA DRIVE. SUITE 1000 ARUNGTON, TEXAS 76011 Docket No. 99900403/80-03 0 8 FEB 1o81 General Ilectric Company Nuclear Energy Business Group Attn: Dr. R. H. Beaton Vice President and General Manager 175 Curtner Avenue San Jose, California 95125 Gentlemen:
This refers to the inspection conducted by Mr. J. R. Costello of this office on July 7-11, 1980, of your facility at San Jose, California, and to the dis-cussions of our findings with Mr. J. Barnard and members of your staff at the conclusion of the inspection and further meetings at the Region IV offices in Arlington, Texas, on August 8,1980, and IE headquarters office in Bethesda, Maryland, on August 27, 1980.
Areas examined during this inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an exam-ination of procedures and representative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, and as a result of the meetings identified above, we found no instance where you failed to comply with NRC requirements.
However, your procedures for implementing 10 CFR Part 21 appear to have weaknesses that have contibuted to questionable evaluating and reporting practices as further discussed below and in the enclosed inspection report.
In DetailsSection II, paragraph B.4. of the enclosed report, four GE Potentially Reportable Conditions (PRCs) are discussed, none of which were reported to the NRC via 10 CFR Part 21.
During this inspection and the subsequent meetings, these items were inspected and discussed at length. While it does not appear that an intentional violation of Part 21 occurred, certain practices are permitted by your Part 21 procedures that appear to violate the intent of Part 21 reporting requirements.
Examples of these practices include:
1.
Your Manager of Safety and Licensing determined (apparently unilaterally) a PRC, concerning Agastat relays, was not reportable under Part 21 even though your System Engineering group concluded the relays did not meet procurement document requirements and could not be used in the reactor protection system.
It appears your Manager of Safety and Licensing deter-mined that since the subject plant was only under construction, and no safety hazard could exist, the matter was not reportable.
2.
A GE engineering evaluation identified a design error that was ccumon to several foreign-and domestic operating plants concerning a water level instrument line that provided actuation signals to several safety systems including scram.
The Manager of Safety and Licensing concluded that this 8.10A 3 00)30
General Electric Company 2
item was not reportable since those same actions were initiated by a con-tainment pressure signal.
By making this conclusion the diversity of initiating signals appears to have been ignored.
(This error is in the process of being corrected in all affected plants.)
3.
A question concerning the seismic design of snubbers for the main steam and recirculation systems (PRC#79-23) was determined not reportable based on an engineering judgement, versus a documented evaluation.
The engineering judgement included assumptions such as the resultant forces would be trans-mitted and accommodated by other restraints in the system and further, if a problem did exist it would be identified by the affected licensees during their IE Bulletin 79-14 activities.
It does not appear that any of the practices described above were contrary to GE's procedures for Part 21 evaluations and reports; however, it is apparent that GE is expending considerable effort to avoid reporting items under Part 21, due either to procedural weaknesses or management policies, or a combination of both.
In light of the above, and regardless of your perception of the safety signifi-cance of the above examples, we request that you reevaluate your procedures and policies against the requirements of 10 CFR Part 21 and the further quidance contained in NUREG-302, Revision 1.
This evaluation should focus strongly on satisfying and implementing the intent of 10 CFR Part 21 Please advise us within twenty-five (25) days of the date of this letter of the results of your evaluation, proposed procedural changes, and any other related management actions taken in this regard.
Our future inspections will include continued effort in this area of your total program.
In accordance with Section 2.790 of the Camnission's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and your reply together with the enclosed inspection report will be placed in the Commission's Public Document Room.
If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within twenty-five (25) days of the date of this letter to this office to withhold such information from public disclosure.
Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary infor-mation identified in the application is contained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, gCL -
arl V. Seyfrit Director
Enclosures:
Inspection Report No. 99900403/80-03 I
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