ML20148K090
| ML20148K090 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20148K008 | List: |
| References | |
| REF-QA-99900003 NUDOCS 9706170356 | |
| Download: ML20148K090 (2) | |
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j NOTICE OF NONCONFORMANCE I
General Electric Nuclear Energy Docket No.: 99900003 Wilmington, NC t
On the basis of an inspection by the staff of the U.S. Nuclear Regulatory a
Commission (NRC) from March 10 through 14, 1997, it appears that the following activities were not conducted in accordance with NRC requirements:
1 Criterion III of Appendix B to 10 CFR Part 50, " Design Control,"
requires, in part, that measures shall be established for the identification and control of design interfaces and for coordination j
among participating design organizations.
These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of 3
documents involving design interfaces.
I Paragraph 3.3 of Section 3, " Design Control," General Electric (GE)
Nuclear Energy Quality Assurance Manual NED0-11209, dated March 31, 1
1989, requires, in part, that GE design documents be furnished to the customer to provide for interface compatibility review and coordination by owner design organizations.
l Contrary to the above requirements, GE did not adequately inform licensee design organizations implementing the average power range monitor-rod block monitor-technical specification (ARTS) modification of the need to consider the 1 percent fuel plastic strain limits and the associated mechanical overpower (M0P) limits in addition to the minimum critical power ratio limits when evaluating rod block monitor (RBM) operability for a rod withdrawal error (RWE) event.
GE's supplemental reload licensing reports for ARTS plants did not adequately address requirements for RBM operability with regard to the M0P limits.
This inadequate interface between GE and ARTS licensees contributed to (1) the failure of licensees to ensure through their plant technical specifications that the RBM was operable to protect fuel cladding at applicable plants, and (2) occasions during Fermi Cycles 4, 5 and 6, Hatch Unit 1 Cycles 16 and 17, Hatch Unit 2 Cycles 13 and 14, Brunswick Cycle 10, and Duane Arnold Cycle 14 when based on GE's RWE analyses the fuel cladding had exceeded its M0P limits and had the potential of exceeding its plastic strain limits.
(99900003/97-01-01) 2 Criterion V of Appendix B to 10 CFR Part 50, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances, and shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
GE Nuclear Energy Quality Assurance Manual NED0-11209, Section 5,
" Instructions, Procedures, and Drawings," dated March 31, 1989, requires, in part, that documented instructions, procedures, and drawings be utilized to communicate quality requirements throughout all phases of design.
9706170356 970611 PDR GA999 EMVGENE 99900003 PDR
Contrary to the above requirements, GE (1) modified peaking factors when the MOP limits were exceeded in the RWE analyses, (2) applied alternate rod patterns in addition to normal rod patterns in the RWE analyses, and (3) revised the theoretical density values used in the peak cladding temperature (PCT) analysis to reduce the calculated PCT, without documented instructions or procedures.
(99900003/97-01-02) 3 Criterion XVIII of Appendix B to 10 CFR Part 50, " Audits," requires, in part, that periodic audits shall be carried out to determine the effectiveness of the quality assurance program.
Followup action, including reaudit of deficient areas, shall be taken where indicated.
GE Nuclear Energy Quality Assurance Manual NED0-11209, Section 18,
" Audits," dated March 31, 1989, requires, in part, that the audit program provide for followup action, including any necessary reaudit of deficient areas.
Contrary to the above requirements, Detroit Edison Company (Deco) audited GE in 1992 and 1993 and observed several deficiencies regarding design ccntrol, including GE's failure to inform Deco (and other ARTS licensees) that the MOP limits would be exceeded if the RBM was not operable during an RWE event.
GE took corrective actions for specific deficiencies but did not conduct followup action, including reaudit of the design control area, to determine the effectiveness of the program.
(99900003/97-01-03) 4 Please send a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with a copy to the Chief, Special Inspection Branch, Division of Inspection and Support Programs, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance.
Your reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should contain for the nonconformances (1) a description of steps that have been or will be taken to correct these items, (2) a description of steps that have been or will be taken to prevent recurrence of these items, and (3) the dates your corrective actions and preventive measures were or will be completed.
Dated at Rockville, Maryland this 20th day of May 1997