ML20031B812
| ML20031B812 | |
| Person / Time | |
|---|---|
| Issue date: | 07/30/1981 |
| From: | Barnes I, Foster W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031B792 | List: |
| References | |
| REF-QA-99900352 NUDOCS 8110060114 | |
| Download: ML20031B812 (11) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV r
Report No.
99900352/81-01 Program No. 51400 Company: General Electric Company Power Systems Management Department 6901 Elmwood Avenue Philadelphia, Pennsylvania 19142 Inspection at:
Aiiasco, Vieques Island, and Calle La Brisa No. 5 -
Sabana Llana - Rio Piedras, Puerto Rico Inspection Conducted: June 23-26, 1981 Inspector: M f'.
k 7/2 o /si l
i W. E. Foster, Ccntractor Inspector Date Reactive Inspection Section Vendor Inspection Branch ha-e 7/7c/e/
Approved by:
I. Barnes, Chief Date Reactive Inspection Section Vendor Inspection Branch Summary:
Inspection conducted on June 23-26, 1981 (Report No. 99900352/81-01).
Areas Inspected:
Implementation of 10 CFR Part 50, Appendix B criteria, and applicable codes and standards; including initial management meeting; follow-l up on a regional request; 10 CFR Part 21 implementation; change control; and manufacturing process control.
Inspection of the latter two areas was on a limited basis.
The inspection involved 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> on site by one NRC inspector.
i Results:
In the four areas inspected, the following violation, noncon-formance and two unresolved items were identified:
Violation:
Implementation of 10 CFR Part 21 practice was not consistent with paragraph 21.6 of la CFR Part 21 (See Notice of Violation).
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2 Nonconformance: change Control practice was not consistent with Criterion V of Appendix B to 10 CFR Part 50, and paragraph 3.4 of Section 6.2, Revision B, dated December 17, 1980, of the Quality Assurance Manual (See Notice of Nonconformance).
Unresolved Items:
Change Control - the Product Engineering Operations Manual did not contain:
(1) all of the items identified in its Table of Contents (See paragraph E.3.b(1)); (2) written procedures that defined when Alteration Notices should/should not be distributed (See paragraph E.3.b(2)).
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3 DETAILS SECTION A.
Persons Contacted
- I. Aranda, Manager, Quality Assurance (General Electric Low Voltage, Inc., Rio Piedras, Puerto Rico (GELVI-RP, PR)).
- R. A. Garcia, President, Manager (GE - Power Systems Management Business Department (GE-PSMBD) - Puerto Rico Operations).
R. Gonzalez, Engineer, Quality Assurance (Protective Relays, Inc./GE Aiiasco, Inc. (PRI/GEANI)).
A. Medina, Supervisor, Quality Control (GE Company, Switchgear and Distribution Transformer Division, Vieques (SDTD,V)).
- S. Ramirez, Manager, Quality Assurance (PRI/GEANI)
J. R. Ramos, Buyer, Material N. Rios, Supervisor, Material (SDTD,V)
R. Rios, Supervisor, Process Control Engineering (PRI/GEANI)
J. A. Santos, Manager, Purchasing C. A. Scott, Manager, Quality Systems (GE-PSMBD, Philadelphia, PA)
N. M. Torrech, Manager, Product Engineering
- L. Varona, Engineer, Product
- Attended Initial Management Meeting and Exit Interview.
B.
Initial Management Meeting 1.
Objectives An initial management meeting was conducted to acquaint the vendor's management with the NRC responsibility to protect the health and safcty of the public and to inform them of certain responsibilities imposed on vendors by the " Energy Reorganization Act of 1974" (Public Law 93-438).
Those in attendance are denoted in paragraph A.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Describing the historical events that indicated the need for the Vendor Inspection Program.
b.
Explaining the inspection base and how the inspections are conducted.
c.
Describing how inspection results are documented and how proprietary ite's are handled, including the vendor's opportunity to review the report for the purpose of identifying items considered to be proprietary.
4 d.
Describing the vendor's responsibility in responding to identified enforcement items relating to:
(1) Correction of the identified violations and nonconformances.
(2) Actions to be implemented to prevent recurrence.
(3) The dates when (1) and (2) above will be implemented or completed.
e.
Explaining that all reports and communications are placed in the Public Document Room.
f.
Explaining the publication and function of the Licensee Contractor and Vendor Inspection Status Report, NUREG-0040.
3.
Findings a.
Nonconformances None.
b.
Unresolved Items None.
C.
Follow Up on Regional Requests
===1.
Background===
a.
On January 6,1981, South Carolina Electric and Gas Company (SCEG Co.) notified the Office of Inspection and Enforcement Region II (0IE, RII) of a possible deficiency at the V. C.
Summer Nuclear Power Plant, Unit No. 1.
The deficiency related to clear Lexan coil spools used in Type HFA relays manufactured by General Electric Company in 1975.
The SCEG Company letter to 0IE, RII, dated February 13, 1981, identified the deficiency as cracked HFA relay coil spools.
b.
On May 13, 1981, the Tennessee Valley Authority notified the Office of Inspection and Enforcement, Region II of a possible deficiency at the Bellefonte Nuclear Power Plant, Unit Nos. 1 and 2.
The deficiency related to cracking spools
5 used in Type HFA relays manufactured by General Electric Company between 1974 and 1979.
c.
Additionally, correspondence includes:
(1) 10 CFR Part 21 reports; (2) Office of Inspection and Enforcement Information Notice; and (3) memoranda from the Nuclear Power Systems Division of General Electric Company.
Further, it is apparent from the available documents, that General Electric Company notified users that the Type HFA relays with Lexan spools were susceptible to cracks developing in the spools.
2.
Objectives The objectives of this area of the inspection were to verify that the manufacturer had:
(1) taken adequate corrective actions and preventive measures; and (2) assessed generic implications.
3.
Methods of Accomplishment Theprecedingobjectiveswereaccomplishedby:
Reviewing the following dccuments to verify that the objectives had been satisfied:
(1) General Electric Company Service Advice No. 721-PSM-152.2, dated November 2, 1980, (2) Quality Assurance Instructions (QAI) Change Notice dated April 14, 1981, for Revision 4 of QAI No. 234018 -
Long Life Relay Coil Program QA Planning and Flow Chart, (3) Alteration Notice No. 761697, dated January 28, 1977, (4) Purchase Requisition No. 81-0843, dated June 10, 1981, and (5) Technical Information Series Report No. 78-ESP-3, dated January 4, 1978-Long Life Coils for Hinged Armature Relays.
4.
Findings a.
Comments (1) Spools for HFA relay coils are no longer made of Lexan and have been made of Tefzel material since January 1979. The Technical Information Series Report No.
78-ESP-3, dated January 4, 1978, indicates that spools P
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6 made of Tefzel and Ryton have successfully undergone extensive testing.
(2) Service Advice No. 721-PSM-152.2 had been sent to users of HFA relays.
It recommends inspection of those relays manufactured during the 1974-1979 period to determine the integrity of the spools.
It also includes pro-visions for coil replacemeiit kits.
'. 3 ) Quality Assurance Instructions No. 234018 had been revised to institute Hardness and Specific Gravity Tests of Tefzel and Ryton R4 spools during Incoming Inspection.
Requisition No. 81-0843 had been initiated to purchase the required hardness tester.
b.
Nonconformances None.
c.
Unresolved Items None.
D.
Implementation of 10 CFR Part 21 1.
Objectives The objectives of this area of the inspection were to verify that suppliers of safety-related equipment had established and imple-mented procedures in acr'rdance with 10 CFR Part 21.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Reviewing Requisition Order Logs to determine whether or not the hardware was ordered as safety-related.
b.
Reviewing the Switchgear and Distribution Transformer Division's Procedure No. 06-01.001, dated Janucry 8, 1978, entitled - Procedure for Complying with Regulation 10 CFR Part 21 Reporting of Defects and Noncompliances, to verify that procedures had been established.
c.
Observing posting at the Rio Piedras and Vieques facilities to verify that the established procedures had been im.nlemented, t
6.
7 3.
Findings a.
Violation See Notice of Violation.
b.
Nonconformances None.
c.
Unresolved Items None.
l E.
Change Col.
i 1.
Objectives The objectives of this area of the inspection were to verify that measures i,cd been established to control changes to software and hardware. Also, to verify the measures for software changes i
included provisions for review, approval, and distribution to and usage at the location where the prescribed activity is per-l formed.
An additional phase was to verify the measures had been impicmented.
2.
Methods of Accomplishment The preceding objectives were ac'.omplished by:
a.
Reviewing the following documents to verify measures had been established to control changes to software and hardware:
(1) Quality Assurance Manual, dated June 15, 1981, Section Nos. -
(a) 3.1, Revision C, dated April 21, 1981 - Design
- Control, (b) 4.1, Revision 0, dated August 1, 1978 - Procurement Document Control, (c) 5.1, Revision 0, dated August 1, 1978 - Drawing Centrol, Instructions and Procedures, (d) 6.2, Revision B, dated December 17, 1980 - Control of Prints in Receiving Inspection,
8 (e) 6.5, Revision 8, dated December 17, 1980 - Control of Prints in Inspector's Files, (f) 6.4, Revision 0, dated October 1, 1979 - Sign Off
- Sheet, (g) 15.1, Revision A, dated March 9, 1979 - Material Review Board...,
(h) 15.2, Revision 0, dated August 1, 1978 - Control of Reject Material, (i) 15.3, Revision A, dated March 12, 1979 - Non-conformance Report..., and (j) 15.4, Revision 0, date<' August 1,1978 - Non-conforming Material in Assembly Area.
(2) Product Engineering Procedures, Nos. -
(a)78-321, dated August 1, 1978 - Drawit.g Change Procedure, and (b)78-322, dated August 1, 1978 - Engineering Drawing Control.
b.
Reviewing the following documents to verify that the established measures had been implemented:
(1) Engineering Drawing Master List, Report No. DRAW 003, dated June 23, 1981, at Product Engineering, Quality Assurance, and Purchasing, (2) Alteration Notice Log with entries dated January 12, 1981, to June 19, 1981, (3) Engineering Drawings on file at Receiving Inspection, and (4) Alteration Notices, Nos. 810317, dated June 16, 1980, i
811000, dated January 13, 1981; 811044, dated January 29, j
1931; 811061, dated April 23, 1981; 811103, dated February 20, 1981; 811147, dated April 24, 1981; 811219, dated April 23, 1981; 791375, dated July 26, 1979; and 809150, dated November 6, 1980, i
9 3.
Findings a.
Nonconformance See Notice of Nonconformance.
b.
Unresolved Items I
(1) The Product Engineering Operations Manual was initiated August 1, 1978.
Its Table of Contents lists 37 procedures and documents; however, the manual contains only 3 pro-cedures. Among those listed and considered pertinent to change control but not included in the Manual, are:
Standing Instructions; Engineering Work Requests; Drawing Request Forms; Design Change; Design Change Notice; Drawing Obsolescence or Superseding; and Retrieving of Engineering Documents.
As a result of the foregoing, the NRC inspector was unable to determine the adequacy of change control.
(2) Paragraph IV.g. of Engineering Procedure No.78-321, dated August 1, 1978, requires that the responsible engineer, (1) review Alteration Notices (AN) (2) identify appropriate functions, and (3) distribute copies of the AN and print.
AN i;o. 791375, dated July 26, 1979, and affected drawing had not been distributed because it indicated no material was affected and the lateness of its receipt (about 7 months).
The AN and print concerned j
rivets used on Type HFA relays.
There were no written procedures that defined when ANs should/should not be distributed.
As a result of the foregoing, the NRC inspector was not able to determine the validity of the decision to with-hold distribution.
F.
Manufacturing Process Control 1.
Objectives l
The objectives of this area of the inspection were to verify that measures had been established and documented to control manufacturing, inspection and test activities.
Also, to verify l
these activities had been accomplished in accordance with the established and documented measures.
Additionally, verification of indication of mandatory hold points in appropriate documents.
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Methods of Accomplishment The preceding objectives were accomplished by:
a.
Reviewing the following documents to verify measures had been established and documented to control manufacturing, inspection and test activities:
(1) Quality Assurance Instruction Manual, dated June 4, 1981, Section Nos. -
(a) 5.1, Revision 0, dated August 1, 1978 - Drawing.
Control, Instructions and Procedures, (b) 8.1, Revision A, dated February 22, 1979 - Control of Stock Rooms, (c) 8.2, Revision B, dated April 20, 1979 - Identifica-tion of Materials.
(d) 9.1, Revision A, dated March 8, 1979 - Special Processes, (e) 10.1, Revision A, dated March 8, 1979 - Fabrication and Assembly Inspection, (f) 10.2, Revision 0, dated August 1, 1978 - Final Product Inspection, (g) 10.4, Revision 0, dated August 1, 1978 - Inspection and Test Supplemental Instructions, l
(h) 10.5, Revision 0, dated June 4, 1981 - First Piece Inspection, and (i) 11.1, Revision B, dated April 22, 1980 - Test Procedures.
(2) Model Lists, Nos. -
(a) 12HFA151A (-).F, dated December 14, 1977 - Six Contact Auxiliary Relay, Type HFA - Long Life Coil, (b) 12HFA171A (-) A, datea December 14, 1977 - Six Contact Auxiliary Relay, Type HFA - Long Life j
Coil, and
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11 (c) 12HFA154E (-) H, dated December 14, 1977 - Five Contact Auxiliary Relay Type HFA - Long Life Coil.
(3) Standing Instruction No. 56229.3, Section 151A (-) F, dated October 1,1979 - Relay Equipment Testing Instruc-tions, Type HFA151A (-) F and selected subsections.
b.
Observed activity in the coil winding area and testing of a Type HFA relay to verify tnat the established measures were being implemented.
c.
Observed bobbins to determine whether or not cracks were evident.
3.
Findings a.
Nonconformances None.
b.
Unresolved Items None.
G.
Exit Interview The inspector met with management representativos denoted in paragraph A.
at the conclusion of the inspection on June 26, 1981, the following subjects were discussed-a.
Areas inspected.
b.
Violation identified.
c.
Nonconformance identified.
d.
Unresolved Item identified.
e.
Contractor response to the report.
The contractor was requested to structure his response under headings of corrective action, preventive measures, and dates for the violation and nonconformance.
Additionally, management representatives were requested to notify the Commission in writing if dates require adjustment or commitments require modification.
Management's comments related to clarification of the findings.
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