ML20059H881

Notice of Nonconformance from Insp on 930907-10. Nonconformance Noted:Changes Made to Computer Codes Redya, Odyna & Safer Not Being Documented & Verified in Formal Manner

ML20059H881
Person / Time
Issue date:	10/28/1993
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20059H858	List: ML20059H855 ML20059H881 ML20059H896
References
REF-QA-99900403 NUDOCS 9311100252
Download: ML20059H881 (3)

Text

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NOTICE OF NONCONFORMANCE GE Nuclear Energy Docket Nos.52-001 San Jose, California 99900403 Based en the results of a Nuclear Regulatory Commission (NRC) inspection conducted on September 7-10, 1993, it appears that certain of your activities were not conducted in accordance with NRC requirements.

A.

Criterion III of Appendix B to 10 CFR Part 50, " Design Control,"

requires that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the i

original design unless the applicant designates another responsible organi 4 tion.

Section 3.10 of the GE-NE QA Program Topical Report, NED0-11209-04A,

" Design Change Control," states, in part. 'Tae control procedure requires that every change must be docr d, design verified, approved by the responsible engineer, and revit -

/ the appropriate interfacing

+

components."

Contrary to the above, changes made to the computer codes REDYA, ODYNA, and SAFER were not being documented and verified in any formal manner.

No official records of the changes are required to be kept and the changes themselves do not have to be reviewed independently.

(93-02-01)

B.

Criterion III of Appendix B to 10 CFR Part 50, " Design Control,"

requires that the design control measures shall provide for verifying or checking the adequacy of design.

l Section 4.4.1 of Engineering Operating Procedure (EOP) 40-3.00,

" Engineering Computer Programs (ECPs)," states that "GE-NE components i

that apply approved ECPs to design and development activities are responsible for documenting both verification of inputs and confirmation that the utilization is within the application range of the ECP."

Contrary to the above, the flow area of the internal recirculation pump used for the modeling of the SAFER code was based on an unverified hand drawn sketch with a reference to an individual who provided the information, instead of a reference to the applicable dimensioned design drawing.

(93-02-02)

C.

Criterion XVII of Appendix B to 10 CFR Part 50,

• Quality Assurance Records," states, in part, that sufficient records shall be maintained to furnish evidence of activities affecting quality and that the records shall include operating logs and the results of reviews, inspections, tests, and that records shall be identifiable and retrievable.

9311100252 931028 PDR GA999 EMVGENE 99900403 PDR

q i

i Contrary to the above, GE-NE had not Gled the quality assurance documents or the test log required by Test 'lan and Procedure (TPP)

TP-515.1078,."ABWR Full Integral Simulation Test (ABWR FIST)," Revision A, dated October 17, 1983, for the ABWR FIST tests in DRF E00-149 and subsequently could not produce the documents.

(93-02-03)

D.

Criterion'XII of Appendix B to 10 CFR Part 50,

• Control of Measuring and-Test Equipment," states that measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices Li used in activities ~affecting quality are properly controlled, l

calibrated, and adjusted at specified periods to maintain accuracy ~

l within necessary limits.

Sections 1.1 and 4.2.b of E0P 35-3.20, " Calibration Control," stated i

that maintenance and test equipment calibrations were to be performed using controls which assured traceability to certified equipment having-known valid relationships to nationally recognized standards.

Contrary to the above, GE-NE purchased thermocouples used in the ABWR i

FIST tests from a commercial grade supplier, not on GE-NE's approved-l supplier list, and accepted and used the instruments as calibrated-by the supplier without further verification of the quality or traceability i

of those calibrations.

(93-02-04) l E.

Chapter 17 of the ABWR SSAR commits to ANSI /ASME NQA-1-1983. NQA-1 states, in part, " Design analyses shall be performed in a planned, controlled, and documented manner. Design analysis documents shall be legible and in a form suitable for reproduction, filing, and retrieval.

They shall be sufficiently detailed as to purpose, method, assumptions, i

design input, references, and units such that.a person technically j

qualified in the subject can review and understand the analyses and 1

verify the adequacy of the results without recourse to the originator.

Contrary to the above, the calculation notebooks for the inputs to the r

SAFER, REDYA and ODYNA computer codes did not have this level of. detail j

and in some cases were inadequately referenced.

In addition since

'l changes to computer codes are design analyses they should also be' documented in this level of detail..(93-02-05)

F.

Criterion V of Appendix B to 10 CFR Part 50, " Instructions, Procedures, i

and Drawings," states, in part,.that activities affecting quality shall be accomplished in accordance with these instructions, procedures, or 1

drawings.

Li GE Nuclear Energy Standard Safety Analysis' Report (SSAR) for the ABWR, Chapter 17, Section 17.1.2, " Quality Assurance Program,"~ states-

" Agreements between GE and its associates require an annual review to assure that the quality systems are being implemented. All associates are committed to correct discrepancies noted during these reviews."-

.)

Contrary to the above, GE-NE failed to perform an annual. implementation 1

review of Hitachi and Toshiba's QA program for the 1991 period.

This

!.* !.i

failure resulted in a 16 month interval between the audits performed in 1990 and the 1992 audits.

(93-02-06)

G.

Criterion V of Appendix B to 10 CFR Part 50, " Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be accomplished in accordance with these instructions, procedures, or drawings.

Criterion VII of Appendix B to 10 CFR Part 50, " Control of Purchased Material, Equipment and Services," states, in part, that the effectiveness of the control of quality by contractors and subcontractors shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or services.

Section 7 of the GE-NE QA Program Topical Report, NED0-11209-04A,

" Control of Purchased Material, Equipment and Services," states, in part, that each supplier of safety-related equipment or services is audited or evaluated initially to determine acceptability of their QA Program and if acceptable, the supplier is placed on the Approved Suppliers List (ASL). Active suppliers of safety-related items are audited at least every three yeais.

Contrary to the above, GE-NE failed to perform audits of Bechtel's ABWR QA Program Plan implementation for engineering services associated with GE-NE P0 No.190-ALWR-31387, and accepted safety-related services from Bechtel without them being listed on GE-NE's ASL for such services.

(93-02-07)

Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555 with a copy to the Chief, Vendor Inspection Branch, Division of Reactor Inspection and Licensee Performance, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance: (1) a description of the steps that have or will be taken to correct these items; (2) a description of the steps that have been or will be taken to prevent recurrence; (3) the dates your corrective actions and preventive measures were or will be completed.

Dated at Rockville, Maryland this 28th day of October

, 1993 :

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