Text

Draft GE Record in Nuclear Safety:Independent Study of GE Nuclear Control & Implementation Dept Based on Records of SA Milam & Nrc. NRC Lists of Documentation Examined & Related Info Encl
	ML20205N709
Person / Time
Site:	Perry
Issue date:	03/23/1987
From:	Stokes C; GOVERNMENT ACCOUNTABILITY PROJECT
To:	;
Shared Package
ML20204B851	List: ML20204B845; ML20205M716; ML20205M825; ML20205M876; ML20205M908; ML20205M934; ML20205M974; ML20205N021; ML20205N045; ML20205N414; ML20205N473; ML20205N549; ML20205N614; ML20205N655; ML20205N709; ML20205N726; ML20205N755; ML20205N798; ML20205N818; ML20205N835; ML20205N878; ML20205N914; ML20205N933; ML20205N965; ML20205N994; ML20205P034; ML20205P041; ML20205P068; ML20205P101; ML20205P223; ML20205P280; ML20205P316; ML20205P355; ML20205P387; ML20205P411; ML20205P428; ML20205P473; ML20205P503; ML20205P521; ML20205Q091; ML20205Q142; ML20205Q176; ML20205Q182; ML20205Q211; ML20205Q241; ML20205Q253; ML20205Q265; ML20205Q275; ML20205Q287; ML20205Q300; ... further results
References
	CON-#189-8125, REF-QA-99900403 2.206, NUDOCS 8704030089
	Download: ML20205N709 (148)
	v • d • e

r i

4;.

j

?f!

i;tR:y;yp - -

,e

\\C f,b L lV

($-

I I

A'oRKIN G COPY k

_ l c

GENERAL ELECTRIC'S RECORD IN NUCLEAR SAFETY An Independent Study of GE's Nuclear control and Implementation Department Based on the Records of Mr. San A. Milan, III and Those of the Nuclear Regulatory. Commission Prepared by Charles E. Stokes, PE, JD for the Government Accoun+. ability Project 1555 Connecticut Avenue N.W.

Suite 201 Washington, D.C.

20036 8704030089 870323 PDR GA999 EMVGENE 99900403 PDR n

.____________.____C._____________,__

4:-

3gtypo v:

-=:,

, y

-n" $

TABLE OF CONTENTS

^

Page ii Summary / Preface

~ i15.

Overview.

iV Disclaimer.

Abbreviations, Acronyms and Definitions.

a-a f

List of Systems.

g List of Planta Referenced Part I.

GE Employment, 3/2/78 to 3/29/80.

1 Part II.

GE Employment, 3/31/80 to 10/24/80.

8 Part III.

GE Employment, 10/27/80 to 5/31/81.'.

25 Part IV.

GE Employment, 6/1/81 to 10/30/81.

29 3 5.,

Part V.

GE Employment, 11/2/81 to 3/31/82..

Part VI.

GE Employment, 4/1/82 to 4/30/82 41 Part VII.-

Deferred Verifications.

42 Part VIII.

NRC Files on GE and Five Plants.

46 l

3 l

9

g

' r g sy?

wm p :

m, a;_

u g :,

INTRODUCTION Durin[thesummerof1984, I was asked to review some documents E the possession of Mr. San A. Milan, III for Mr.

Thomas Devine of the Governament Accountability Project.

I was to review the documents as to their relative importance and how they bear on the safe design and future operation of nuclear plants being designed by General Electric's San Jose employees.

My review started with.the reading of Mr. Milan's work record without focusing on problems, but to understand his prose and the terminology used.

I then reviewed again for specific areas of concern.

Following this second reading, Mr. Milan was consulted for answers to particular questions which I had not been able to clear up within the documents.

I then reviewed the Inspection Reports by the Vendor Inspection Branch of the Nuclear Regulatory Commission starting with a letter dated October 21, 1983, of an inspection conducted on August 29-September 2, 1983 and ending with a letter dated October 26, 1984.

Lastly, I had a couputer search performed of five plants under consturction that The were listed in the work records supplied by Mr. Milan.

narch time frame was from 1980 to the present and was performed for the following facilities:

Grand Gulf Limerick Nine Mile Point Perry Shoreham l

These plants may not be listed outright but are included in l

connection with listings of other plants.

For example, information about the Perry plant is discussed in connection with the Shoreham facility.

Many other plants are referenced in other sections of the report.

i s

11 l

l

.~.~.

g.

y,:n....

OVERVIEW The following narrative is an example of the most significant day to day activities and problems recorded by Mr.

The following report is arranged in Milan in his work record.

chronological order.

It has been broken down based upon the department manager to whom Mr. Milan reported for each time frame, and the areas of concern are different.

Mr. Milan's files include his work record, which was prepared on a day to day basis, and other files which were created specially by Milan due to the significance of the subject.

These files created are on the following subjects:

Deferred Verifications, Reactor Mode Switch, Change Requests, Engineering Change Notices, and Engineering Review Memoranda.

These special files contain more detailed entries.on Mr. Milam's work log, and GAP did not elaborate beyond the work record entries.

The issue of Deferred Verifications is dealt with separately at the end of the report because it i's the only issue officially reported to the NRC.

1 D

l e

lii

%%-v n

+-.

l i

DISCLAIMER i

t l

This report is based on my review of the daily work logs of Mr. Milam Mr. San A. Milaa, III, and discussions held with him.

l l

worked at GE from 11-72 until 4-82.

He started in 1972 as an f

- associate engineer in the Boiling Water Reactor (BWR) Systems-Engineering Department, Comp'onent 295 under managers D.T. Weiss and H.W. Tanai.

In March 1978, he changed jobs and went to work in the Nuclear Energy Products Division, Component 941 (Radiation Monitors Engineering Unit) under manager C.L. Cobler.

He made another change in october 1980, to the Nuclear Energy Products Division, Component 913 under manager R.L. Raghitto and acting He continued to work for G.B.

manager G.B. Strambaack.

In Stramback, who on 6-1-81 was made manager of Component 913.

November 1981, Mr. Roelow took over Stramback's position as manager of Component 913.

i In an attempt to reduce the number of areas of concern, I reviewed some of the records of the Vendor Inspection Branch for-corrective actions which might have been taken during ths last few years of Mr. Milan's employment and those following his termination, which would not have been included in his records.

I also searched the records in the Public Document Room for five plants which were under construction and were mentio.ed in Mr.

Milan's records as having some association with tne San Jose General Electric offices.

l I understand that a design organization is constantly evolving.

In this process, many design control deficiencies are Similarly, it is recognized corrected and many others develop.

that it is impossible for any organization to come in for a few days, perform an audit or inspection and find anything but the most blatant errors.

.It takes a participant in the day to day operations to see the operation as it realistically exists in practice, and the problems with getting the work done using a particular organizational system.

I do not claim to have caught every problem as evidenced by the work record wh(ch'I reviewed, but I agree with Mr. Milan that many problems existed during the period covered by his work The evidence already on record from the NRC confirms record.

that violations existed but only a small portion of the relevant universe had been investigated to date..

I Charles E. Stokes, P.E.,

J.D.

iv e

.m-

.,v._.,-,-,,,,,.m..-..,

___---.,-,-.--.--.--d-

n.

f fy

~

ABBREVIATIONS, ACRONYMS & DEFINITIONS Some of the smaltiple abbreviations below are not used directly in this report, but were included to show that in many cases when the abbreviation was used in a document without the full name The use of abbreviations and that the true meaning was unclear.

acronyms is so complicated that GE has a booklet called ABBREVIA-ACRONYMS & DEFINITIONg' control no. NEDO-10733E, 79NED99,

TIONS, Many.of the above definitions came from CLASS I (JULY 1979).

Many, however, were not provided and the defini-this document.

tions for many of the teras used in Mr. Milan's documentation In those cases the definitions are merely came from memory.

functional for purposes of this report.

In fact as is stated in para. IV KOSLON, infra, and on page L-2 of NEDO-10733E, neither the General Electric Company no any of the contributors to that document --

"makaa any warranty or representation, express or A.

implied, with respect to the accuracy, completeness, or usefullness of the information contained in this i

, document, or that the use of any information disclosed in this document may not infringe privately owned righter or

" assumes any responsibility for liability or damage of B.

any. kind which may result from the use of any informa-disclosed in this document."

Yet, the employees of GE, its subcontractors and others must rely on this document and/or guess the meaning of many terms used i

in the design documentation for safety-related equipment.

The use of abbreviations, acronyms and definitions in letters and other Design Documents is so unclear and uncertain in many instances their use is a violation of 10 CFR 50, App. B requirements.

AMC Applied Metallurgy and Chemistry AML None known (ex. CAR AML2997)

ARN Area Radiation Monitoring BWR Boiling Water Reactor C&I Control and Instrumentation Control and Instrumentation Department C&ID CAR Corrective Action Request Indicates used, but not in NED0-170733E ABBREVIATION, ACRONYM

& DEFINITION book.

Licensing course acronym list.

a.

e

'M by rm=

x

,y.

i

CES Change Evaluation Board

- CEssAR Combustion Engineering Standard Safety Analysis Report

CNP Unknown Centrale Nuclear de Valdecaballeros (Spain)

CNV~

CRD Control Rod Drive CS Core Spray CSR Conditional Shipping Release CSR Cable Surplus Report CSR Contractile Strain Ratio

~

CSR Cycle Summary Report CSR Certified Stress Report DCS Drawing Control System

DCS Document Control Sheet DCS Display Control System

DCSCN Drawing Control System Change Notice DI Drafting Instructions DI Density Indicator DRF Design Record File

DVSCN Design Verification Status Change Notice

EAP Engineering Applied Practices ECA Engineering Change Authorization.

ECB ECN Coordination Board ECN Engineering Change Notice ECR Engineering Change Requat EDL Electrical Device List

EDDL Elementary Diagram Device List EE Electrical Engineer EEPO Engineered Equipment Procurement Operation EI Engineering Instruction EIS Engineering Information System i

EMPIS Engineering Material an Processes Information Service

ENT Electrical Metallic Tubing EOF Engineering Operating Procedures ERM Engineering Review Memorandum

ESOP Engineering Standard Operating Procedures EWA Engineering Work Authorization FCD Functional Control Diagram FCD Functional Control Drawing FDI Field Disposition Instruction FDDR Field Deviation Disposition Request t

FPCC Fuel Pool Cooling and Cleanup FSAR Final Safety Analysis Report l

l

FT Fuel Transfer FW Feedwater

FW Fiscal Week (ex. FW8019 = Fiscal week 19 of year 1980)

GE General Electric Company (US) l l

GE Gas Ejection

- GESSAR General Electric Standard Safety Analysis Report HPCI High Pressure Coolant Injection b.

l I

nu m;,m Migh Pressure Core Spray HPCs Symbole defined in the Engineering Documentation

ICER Practices Section C1, pg. 1 dated 8-24-79 which indicate status of document verification.

I - Incomplete for internal reasons (awaiting GE input)

C - Complete E - Incomplete for external reasons (waiting customer or supplier input)

R - Incomplete Sor both internal and external reasons ID Inside Diametdr-

ID Identification IED Instrument and Electrical Diagram IED Instrumentation and Equipment Diagram IED Instrumentation Engineering. Diagram IEEE Institute of Electrical and Electronic Engineers IR Information Report IR Inside Radius IR Inspection Report

ITN Inventory Transfer Notice

LD Leak Detection

(

LE Limiting Environment LSE Lead system Engineer

LTR Later (as used on Parte List)

LTR Licensing Topical Report

MDL Mandatory Distribution List MDL Master Drawing List MDL Master Demand Limiter MPL Master Parts List MR Material Requisition (ex. Mk required on ECN's)

MRS Material Review Board MsIV Main steam Injection valve MsIV Main steam Isolation valve Map Manufacturing. standard Practice N5 Nuclear Boiler NC No Charge

NC Nuclear control NC Normally closed

NC&ID Nuclear Control and Instrumentation Division

NEDE According to Mr. Milan, all NEDE documents were reports which could be written by anyone on almost any subject.

The one separating point was that the wending letter such as E or 0 stood for a specific subjectr.

For instance, NEDO was referred to in the documentation in relation to the technicalities of a nuclear plant which can be compared to a brochure on a car giving such data as engine size, length, wheel base, tire size, number of doors, etc.

These docu-ments guarally were not checked for accuracy of information and were very loosely controlled in that employeees requested a NEDE number or NEDO number but employee could use the same NEDE number with differ-c.

g.

p,w,,~.,

s-o; e s ont revision number for a report on a different sub-ject.

NEDO See NEDE

NEMS Nuclear Engineering Management Systen NMS Neutron Monitoring System NRC Nuclear Regulatory Commission NRC National Research Council

NUREG Nuclear Regulation C

OG Offgas OG Owner's Group OPG Organization and Policy Guide OPG Operating Procedures Guide PCAMS Primary Containment Atmosphere Monitoring System

PCR Problem Correction Request

PFE Production Following Engineering PGCC Power Generation Control Complex

PIR Production Information Request / Release PL Parts List PL Product Line PR Mr. Milan believes this stood for Projects.

He indicated that in learning to fill out many docu-k ments, the usual method was for the new employees to copy one which had been completed.

In many cases, this meant filling in blanks with terms of question-able meaning and/or leaving blanks open which were not understood.

Placing comments in blanks at another's instruction or copying comments from one document to another without understanding the meaning of the request or response violated 10 CFR 50 App.

B,Section II Quality Assurance Program.

PR Plutonium Recycle PR Pressure Recorder PR Professed Resources PR Purchase Request PRC Potentially Reportable Condition PRM Power Range Monitor PWA Process Radiation Monitor PWA Program Work Authorisation PWA Project Work Authorization QA Quality Assurance QAEE Quality Assurance Engineered Equipment QAEE&I Quality Assuranca Engineered Equipment and Installation

.QAO Quality Assurance Operation QAP Quality Assurance Procedure QAP Quality Assurance Prograa QC Quality Control QP Quality Plans RCICS Reactor Core Isolation Cooling System

- RESAR Westinghouse Standard Safety Analysis Report RHR Residual Heat Removal d.

e 7

mn RP Reactor Pressure RP Riverwater Pumphouse l

RPV Reactor Pressure Vessel RS Remote Shutdown RWC Reactor Water Cleanup SEHR Special Emergency and Heat Removal SER Safety Evaluation Report

SJ Unknown (ex. CAR SJ-39222)

According to Mr. Milan, "an. arbitrary nupbering system for CARS, and had no meaning."

SL Safety Limit

SL Standby Liquid Control SL Shortage List Mr. Milan believes this was the designation for a

SNI proposed plant which never materialized.

SUN Symbole defined in the same documentation as ICER codes-to indicate status of verification, except l

these were to be used only in EIS.

S - Incomplete (no work planned)

I U - Unverified or deferred verification N - Not evaluated (entered in EIS before implementa-tion of completion status code)

- SWISSAR Stone and Webster Standard Safety Analysis Report l

TE Temperature Element TI Temperature Indicator i

TI Test Instruction TI Turbine Island TSS Technical Support Services e

TSS Time-Share System TVA Tennessee Valley Authority (US)

UK United Kingdom of Great Britain l

US United States

VB Vertical Boards i

WPPSS Washington Public Power Supply System (US) 1 I

i Indicates used, but not in NEDO-170733E ABBREVIATION, ACRONYM

& DEFINITION book.

Licensing course acronym list.

e.

e

.-e.-

,e-

- --, -~ _.- -,,

--.--,..--.c..

.-~.--.

o--.-.

75th%ea-a:::

r.

LIST OF SYSTEMS FOR WHICH C&I ENGINEERING HAD RESPONSIBILITY

Abbreviation Systen NB System Nuclear Boiler System Reactor Recirculation Valve Flow Control System CRD Syste's Control Drive Rod Hydraulic Control System FW System Feed Water control System SL System Standby Liquid Control Sygtalli NM System Neutron Monitoring System RS System Remote Shutdown System.

RP System 4

Reactor Protection System Steam Bypass and Pressure Regulating System Computer System or Performance Monitoring System Simulator DC System Display Control System (Nucionet)

PRM System i

Process Radiation Monitoring system ARM System Area Radiation Monitoring System PCAN System-Primary Containment Atmosphere Monitoring System.

RHR System Residual Heat Removal System CS System Core Spray System HPCS System l

High Pressure Core Spray System SEHR System Special Emergency and Heat Removal System LD gysten Leak Detection System Main Steam Injection Valve and/or Isolation Valve Leakage control System MSIV Systen i

HPCI System High Pressure Coolant Injection System RCIC System i

Reactor Core Isolation Cooling System FT System Fuel Transfer Systen Radwaste Systea

'RWC System Reactor Water Cleanup System Filter /Demineralisation Systen FPCC System Fuel Pool Cooling & Cleanup System control Room Panels I

Local Panels & Racks Offgas System OG System Flammability Control System This list,may not be complete.

+

9 f.

e

_O

g$.,

JSR* '-

g.

NUCLEAR PIANTS REFERENCED IN MIIAM'S WORK RECORD

Kuo Sheng 1/ 2 FW8014 work record San Milan III (Cobler)

Perry 1, 2 April 4, 1980 ECN Verif. State. Memo (Cobler) 2 Clinton 1 Hope Creek FW8015 work record San Milan III (Cobler)

La Salle 1, 2

" 8016 Grand Gulf 1, 2

TVA 22 CNV 1, 2

" 8018

=

Cofrentes TVA 17

" 8021 Black Fox

" 8022 i

Leibstadt June 13, 1980, Reactor Mode Switch letter Susquehanna 1, 2 Nine. Mil Point FW8036 work record San Milan III (Cobler)

Allens Creek Sept. 4, 1980 letter Cobler Draw. Discre.

Skagit Laguna Verda FW8043 work record San Milan III (Cobler)

Ferr.i

"~

a a

Hatch 1, 2 Leibetadt Lilco SiEBer River Band 1, 2 Alto Lazio

" 8101 a

(Stramback)

Hanford Rd.

" 8123 CHP 7 GESSAR

" 8124 a

c (Koslow)

SNI-650

" 8146 Match 2 l

l Note:

This list may not be complete.

9

--%--~+,,,,_

-~

)J

??ssprfuw m p y s,

y;

~

f. -.

='

y-l l

l-1 f(

l R

PART I V

GE EMPLOYMENT

(

3/20/78 to 3/29/80 Introduction During this period, Mr. Milan worked for Mr. C. W. Hart, L

@ </.

,first in the Radiation Monitors Engineering Unit of the Control N-and Instrumentation ~ Department, and then in the Control and b

A<

tInstrumentation (CEI) Panel Er.gineering. Unit.

On May 1, 1979, the

~

Radiation Monitors Engineering Unit was disbanded and the C&I Panel Engineering Unit was created.

Mr. Hart was appointed I

Manager, C&I Panel Engineering.

Mr. Milan, along with the other personnel in the old unit, was transferred to CEI Panel Engineer-

'ing.

Mr. Milan's work record began in March 1978 while-working in the Radiation Monitors Engineering Unit.

Review emi Analysis of the Record Soc. 1.1 Synopsis During the second week of May,1978, Mr.:

l Malan recorded that he began verification of CNV 1 & 2 and Cofrentes panels H13-P654 and E-13-P655.

H13-P654 and.H13-P655 are standard Nuclear Reactor Protection System panels for nuclear reactor facilities at Grand Gulf 1 & 2,. Black Fox 1 & 2, Clinton 1 & 2, Centrale Nuclear de-Valdecaballeros (CNV) 1 & 2,

[

Cofrentes, and Skagit.

Mr. Milan encountered a problem with the

{

CNV 1 & 2 and Cofrentes electrical device list (EDL).

The item numbers did not match those on the standard assembly drawing.

.Mr. Milan wrote, " Note that I did the verification although Russ

,g.

7 will sign as verifier, following which I will resolve the

[-

. verification comments."

Comment: When one person does an act which is recorded as having been done by another, such as checking a drawing, several possi-bilities result.

-(1) The document record is false.

(2)

The work has not been independently verified, as required by 10 CFR 50, Appendiz 3.

Sec. 1.2 Synopsis:

An entry made during the first week of August 1978, identified multiple labeling errors.

In reviewing a drafting package for H13-P631, Mr. Milan encountered two sets of labeling errors on the isolators (1 set on assembly, 1 set on the connection diagram).

With both wrong, he could not use i'

either to correct the other.

Comment: The normal progression of drafting is for the more general type arrangements to be designed, drawn, and checked first, and the more specific and detailed to be drawn using the data from general. drawings with additional facts.

Here, it 1

f-n, 4~

m appears that both the order of development between the assembly and connection diagrams were uncontrolled, and neither was accurately, checked.

This could also be a sign of a "let someone else do it* attitude problem among the employees.

A violation of 10CFR50' exists, since (1) either the procedures do not exist to ensure against this or -(2) the procedures are not being followed.

Sec. 1.3 Synopsis:

Mr. Milas did.some research on document labeling requirements duritty the third. week of August.

After reviewing IEEE standard 494-1974, he came to the conclusion that some of GE's drawings were not labeled in accordance with the IEEE standards.

Mr. Milan notified the Syracuse office and decided to correct the drawings in his office himself.

Comment:

Without communication and cooperation of management, there is no guarantee that all corrections were made nor corrective trairing held to prevent the same problem from continuing.

Mr. Milan's actions did not satisfr the gequirements of 10CFR50 App. 8.

This reflects a trainingr problest phich is obvious in Sections 1.5 and 1.13.

Sec. 1.4 Synopsis:

Mr. Milan, when reviewing H13-P614, discovered that many devices had not. been deleted from the Device -

i List :(and EDLs) per earlier instructions from Systems Engineers.

The drawing was per deletion instructions and was not supported by Systems drawings.

Comment:

Mad Mr. Milan been assigned to update the Device List, this entry would not have auch importance.

However, he was not.

This indicates that somehow this work was overlooked.

10CFR50, App. B Section III, Design control prescribes that controls be established to ensure that this does not happen.

Sec. 1.5 Synopsist A letter to H. H. Hendon on September 19, 1978, concerned-the audit of Centro Nuclear de Valdecaballeros (CNV).

Several of the highlights listed were of interest.

a)

The first was that E0p 75-5.00 (Training) was not being implemen-ted for new employees.

S. Garg (Reghitto, Manager), professed ignorance of procedures due to only having been on the job two

, months.

Comment:

There are basically two functions for any auditing department -- (1) to discover problems within the system; and (2) to resolve the cause of the problems to prevent similar future This entry indicated that the first function was occurrences.

being perforzied.

The question remaining is, were the probless resolved?

Many entries which followed this one indicate that the problem was not resolved, a violation of 10CFR50, App. B Section XVI, corrective Action.

b) The second was that ECN (NE65571) stated that verification was l-contained in DRF 921D17 N*3, but the DRF did not contain the l

verification for,this ECN (W. Fraser).

2

jg qw -

s~

jnl?

Sec. 1.6 Synopsis:

In the first week of November, 1978, the

" Bill Millard said either following line was part of an entry:

he would sign the ERMs or I (Sam) could forge his signature to them."

(Clarification added.)

See Sec.

1.1.

This indicates an employee attitude problem and lack of Comment:

training about liability un(er the Atomic Energy Act for falso Mr. Milan's efforts to challenge the inaccuracies with records.

GAP and twic now with the NRC were his own initiatives rather than a product of GE's training program.

Sec. 1.7 Synopsis:

Continuing with a problem of a similar i

1978, a letter to C. W. Hart on the nature on November 14, subject of the CNV connection had an interesting paragraph.

It seems that the CNV elementary diagram drafting effort was subcontracted to an outside firm, the Power Division of C.

F.

Braun & Co., in Alhambra, California.

When completed, the diagrams were provided to the General Electric System-Engineers for signature.

The System Engineers felt that they were not being given sufficient time for review and refused to sign the The documents were later signed by the C&EE CNV documents.

Engineer, without review.

gfgg This problem was worse than those above, where in one Comment:

case a signature may have been forged and in the second someone else's name possibly was signed as verifier.

In those cases, verification was done, but not by the person indicated.

Here, A

at best, only a partial verification could have taken place.

violation of 10CFR50, App. B Section III. Design Control.

Sec. 1.8 Synopsis:

During the second week of March 1979, Mr.

Milan recorded his discovery of an error in his, Russ's, and Don's work.

They had assigned connector numbers in the E51A Elementary which duplicated connector numbers that were previous-l Three panels (H11-P618, H11-P621, and Hil-P640) ly assigned.

Mr. Milan and don attempted to perform corrective were affected.

action.

E The problem here was the absence of any clearly defined Comment:

The responsi-l authority for the assignment of connector numbers.

bility would normally' lie with the design engineer, unless he The delegates it to another engineer, designer, or draftsman.

positions which Russ, Don, and Mr. Milan held'were not noted.

Synopsis:

The fifth entry, for the last week of April, Sec.

1.9_

stated that Mark Durkton had reported finding many errors 1

1979, Mr. Milam was surprised to on drawings for CNV panel H22-P028.

hear of so many errors, because he thought he had done a careful He says one point to consider was that the CNV reviews review.

were mostly between the panel drawings with relatively little attention to the elementary diagrams.

3

--v-w--

,-v

,mm.--- - -, -

,-w,,------.-e-...wem,_-,-m.ww--

w

,--w--...

p p

gg3% w w:a

+ m m~

.gp This incomplete verification is in violation of Comment:

10CFR50, App. B.

Sec. 1.10 Synopsis:- A minor problem was noted during the last week of aune, 1979.

In reviewing Hil-P620 engraving drawing, Mr.

Milas discussed some marker plate legends with T. Garg, Systems Engineer for HPCI.

Mr. Milats was surprised to learn that T. Garg was not aware that the circuit labels on elementary diagrams are used for marker plate legends.

This was one of many references to problems with the Comment:

marker plate legends.

Milan's note indicated that Garg previous-ly should have been aware of the use of.the circuit labels.

Synopsis During FW7929 (the third week of July, Sec. 1.11 1979), Mr. Milan completed comment resolution for E M ANS-3603, with Isolator Terminal Board Assembly and ConnectiesPMegress'.

These were sent to 3. Tashjian, Electrical Product Design, for further review.

Virginia Woldow reviewed document qualaty instead of performing independent design verif'ication.

It is difficult to understand how one can check quality '

Comment:

- without checking the design, unless quality means the presenta-tion of the work.

In any case, this violated 10CFR50 App. B..

Synopsis:

A letter dated October 25, 1979, to D. M.

Sec. 1.12 Currie from R. J. Giel voices Giel's concern for what she sees She says that after looking at various happening within C&ID.

procedures she did not find outright conflicts but a cumbersome The problem stemmed from previous redundancy of procedures.

issuance of incomplete, poorly researched and documented proposed ECNs on the part of engineering, thereby generating the need for additional review / signatures per each ECN approval.

She stated that recently there had been a proliferation of concern on this subject, resulting in two new procedures and their respective and the Change boards -- the ECW Coordination Board (ECB)

Evaluation Board (CEB).

She advocated a simplification rather than a proliferation of procedures.

She said the present system encourages a "let someone else check that aspect" attitude.

Synopsis

' Entries were made during the second week of Sec. 1.13 November 1979, when Mr. Milan had attended ca EIS users class and an IR class.

This was the first record that Mr. Milan had 7

~

received any training in these two subjects.

Upon consultation, Mr. Milan said that based upon his

" Comment:

The lack of memory he had not received any training before this.

any previous training in these areas as well as others is a violation of 10CFR50 App. 5,Section II.

Sec. 1.14 Synopsis During the last week of November, 1979, Mr.

Milan indicated that Jack Cooper was continuing to reject ECNs 4

~gg3 e

~me with PR on distribution and NA for projects approval.

Mr. Cooper also change 4'Mk to telecon approval on one of Mr. Milan's ECNs without his knowledge or consent.

ECN was to correct note 2 on

~

828E466TD, Bemote Shutdown VB, La Salle C6LP001.

Per Mr. Milam's record, responsibility for the projects approval block was assigned to Mr. Milan or the project manager.

j comment:

Changes made without authority are a violation of design control procedures.'

i Sec. 1.15 Synopsis:

On November 29, 1979, Mr. Milan wrote R. F.

Franciose about category III changes.

The problem was that the t

drafting practice when adding parts or groups to drawings designates the ERM in the drawing revision block as a category i

III change, which is incorrect.

This practice derived from the Drafting Manual, Section 10.1, page 10, whereon an example (Figure 14) illustrated this practice.

Per Mr. Milan's review of

' E0P 42-4.10, which spells out the responsibilities for ERMs, and l

1

- EOF 55-2.00, Appendix B, Section 33.1.3, which defines category III change requirements for ECNs, he was not able to find I

anything that relates change categories to ERMs, which do not I

make changes but.rather additions.

He requested a revision to the Draft:,ng Manual.

Me wanted to see line 4.8.4.3 deleted and the ERN reference in Figure 14 in Section 10.1 deleted.

Sec. 1.16 Synopsis Mr. Milan made an entry during the. third week of December 1979, that Cofrentes H13-P602 became a problem on Tuesday.

" Projects wants to ship 'as-is' but panel has many problems."

Comment:

Shipping known nonconforming components is a violation of 10CFR50, App. B Section XV, Nonconforming Materials, Parts, or l

Components.

Synopsis On December 14, 1979, the work required by Floor ECNs was not complete but was signed off by the shop.

While Mr. Milan was writing this entry on December 18, 1979, the shop was trying to finish some of the work before the panels were shipped.

The work was on Cofrentes H13-P602.

Comment:

Signing documentation before completion could result in defective equipment-being installed and used.

If these panels were shipped prior to a complete inspection being completed, this was a violation of 10CFR50, App. B Section X, Inspection.

Sec. 1.17 Synopsis:

Mr. Milan requested an EMPIS information manual from Sarah Sanders in Schenectady during the first week of 1980.

Sec. 1.18 Synopsis:

Weekly report FW8005 to L. C. Wimpee from C. W. Hart had an interesting paragraph.

"The design for the Hope Creek 1 & 2 Reactor Protection System Vertical Boards Hil-P609 and P611 cannet be completed because the elementary drawings 5

y. y

- w. a y.

7 -

a g)Rl Ts2 M y' % p m W m % w r

f f

t continue to change drastically.

Promises by control and Electrical Engineering are not being kept.

The work-around efforts-heth CSI Panel Engineering and Engineering support ted in very much wasted time.

In the interest of have supporting projects and the department, C&I Panel Engineering will continue to complete the design using as many work-around procedures as are possible."o Comment:

" Working around' normal operating procedures" can only mean that they were violating 10CFR50, App. B criteria.

Sec. 1.19 Synopsis:

Mr. Milan wrote ECN NJ-12971 to remove a generic interference problem on 163C1122, conduit Strap, for Joystick Switches,during the first week of February, 1980.

According to his record, this required FDIs for Kuo Sheng 2 and Cofrentes and a very carefully worded disposition because ten other shipped panels are affected.

Comment:

It is unclear why Mr. Milaa had to carefully word the disposition.

It is equally unclear whether the other ten were not fixed, or whether Milan was simply afraid'of what management would think if they were fixed?

Sec. 1.20 Synopsis Mr. Milan made a comment concerning me A switek assemblies also during the first week of February.

Het stated that the assembly was not being properly documented.

The switch was purchased as a non-safety-related part and should have been sesembled, tested, etc., with its.own work order and other paperwork, the same as a panel.

This did not happen on Cofrentes.

Instead, the switch was delivered to the panel in a t

disassembled condition with no certification.

The switch was assembled and disassembled many times by many people and l

eventually shipped with a bootleg work order.

Mr. Milan believed that the same thing happened to Kuo Sheng.

Comment:

This is a violation of 10CFR50 App. 5,Section VII, control of Purchased Material, Equipment, and Services.

Sec. 1.21 Synopsis On Friday of the second week of February, 1980, Mr. Milas discovered an error in the Corrective Action They would not run if there were only l

Request (CAR)~ programs.

one CAR.

It' appeared'that the sort routine " blew up" when it tried to sort only one CAR.

Mr. Milan entered in his log that he fixed the CAR program during the third week of February.

Comment:

There appears to be no program control, independent verification, or notification of errors to other users; all violate one or more sections of 10CFR50, App. B. criteria.

Sec. 1.22 Synopsis During the last week of February, 1980, Mr.

Milan wrote that the drawings for Kuo Shang C61-P001 did not show the cutout for the utility outlet.

Yet per Pat Falconia, the outlet was instelled in a rear post on unit 1 in the field.

He 6

y

pw j

,n i

I stated that he had no design details and could not make unit 2

!~

like unit 1..

i A quality assurance program should ensure that the comment:

drawings are accurate representations of components installed in since these records may prove vital during an a nuclear plant, Since the drawing is made from design calculations emergency.

and sketches which precede the fabrication of components, the components fabricated shoultf be per the drawing and not vice changes to fabricated components should not be made versa.

without both verification of the original design and changes to the documentation indicating the changes and their acceptability.

The notation above by Mr. Milan indicates that these things did This is a violation of 10CFR50, App. B,Section III, not happen.

Design Control, and Section VII, Control of Purchased Material, Equipment, and Services, and others.

Sec. 1.23 Synopsis During the second week of March, 1980, Mr' Milam completed a long "back-burner" job.

He sorted and-filed While doing this, he discovered four (4) white copoies old CARS.

(originals):

Three' committed corrective actions not completed i

1.

SJ-32635 on Kuo Sheng 2 H13-P402 written 4-13-78 SJ-32444 on Kuo Sheng 2 H13-POO2 written 5-12-78 SJ-32634 on Kuo Sheng 2 H13-P602 written 4-13,

2.

One completed but not returned:

SJ-32245 on Cofrentes H13-P603 written 5-04-78 Mr. Milan was not sure how to handle them.

l Comment:

From the brief statement, there was sufficient information to indicate a violation of 10CFR50, App. 5,Section III, Design control, since CARS are engineering documentation.

Synopsis:

On March 24, 1980, when resolving CAR SJ-Sec. 1.24 54194, Mr. Milan found out that, on C61-P001 enclosures, the cutouts called out cause interference between marker plates.

Unit 1 engraving drawing had been changed to call for smaller marker plates, but the enclosures were still wrong, as was unit 2 engraving drawing.. The Fab shop " bootlegged" the cutout; so, Mr.

marker plates were offset to the side to avoid interforance.

Milan did speciry rework on these enclosures.

However, there is no written guarantee that the work was done.

Again, this circumvention of procedures is a violation Comment:

of 10CFR50 App. B requirements.

Response

indicates anonymous records in the Q/c record center.

Are all TI's signed off?

Response should include a list of them.

How about ship short items, which are not tested, but either simulated or bypassed during test?

See also Sec. 2.54

)

(example drawing left out of EIS) and Sec. 2.72 (ECN not logged i

on EIS).

Sec. 5.13 Synopsis:

Mr. Milan's work record includes a non-This approved form titled PWA No. 1229LD rev. lJ for River Bend.

document, which is dated February 5, 1982, was caused by an excluded equipment list which was sent to the utility, Gulf States Utilities Company, by the NRC.

The second page of this document states that there is no controlled tracking system for vendor l'dentification of these devices and that a complete item by item search of the entire River Bend database would be GE felt that the scope of such a search was necessary.

prohibitive and furthermore was not considered to be necessary.

Excluded equipment as referred to in this list is equipment which has been found at other facilities to be so deficient that plant safety is seriously in question.

GE neither admitted nor denied that this equipment was installed at River Band.

Since GE believss the cost of the search to ensure that Comment:

it is not installed is prohibitive, the plant should not operate.

This is because all necessary requirements of 10CFR50 App. B have not been met justifying the granting of the operating license.

Sec. 5.18 Synopsis:

A letter dated January 29, 1982, and received on February 8, 1982 informed everyone of the forthcoming NRC Inspection on February 22 through February 26 and indicated the team assignments would be as follows:

Chamberlain 1.

Review and close out, if possible, the nonconfor-mance reported in the previous inspection 81-03.

This nonconformance relates to the material requests for safety-related components not being controlled by established procedures and instruc-tions.

2.

Follow-up regional request for investigations:

Check allegations received by Region V that a.

GE has furnished technical publications with technical, as well as typographical, errors.

Subjects are control rod drives, control 44

l

.I l

systems, and fuel handling platforms.

b.

Check allegations by Isa Yin of-Region III, who accompanied La Salle on La Salle's 1981 audit, that there are problems with design.

report specifications.

Yin felt,that wrong.

revision numbers were being used.

c.

Region II, involving Hartsville and Phipps Bend, a TVA audit finding indicated that GE was not performing and reporting reportable

. conditions to TVA per 10CFR50.55(e).

d.

Inspect the situation reported in which, on the Grand Gulf project, GE. furnished RPV level transmitters which cannot be adjusted to the specified setting.

Foster 1.

Inspection of series 20, type PR-20, electro switches (reported at Grand Gulf),

Termination of wiring in termination cabinet junction 2.

boxes (PGCC reported by Grand Gulf).

3.

Incompatible design documents with actual hardware

("as shipped" panels did no match "as shipped" drawing reported by Grand Gulf).

4.

Inadequate circuit separation (separation of Class lE and non-lE in accordance with Reg. Guide 1.75.

Reported by Grand Gulf).

5.

Incorrect assembly of cable connectors.

Note:

These five items were left unresolved since the 81-03 NRC audit, one year ago.

The NRC apparently has its own deferred verification system.

l It is easy to see why GE started the Deferred Verification l

program when the NRC defers verification of nonconformances from inspection to inspection or longer.

Sec. 5.15 Synopsis:

Mr. Milan noted in his work record-for the first week of March 1982 that he was involved in a fight over He insisted that a DVSCN was required in addition to l

procedures.

the ERN.

He also insisted that a DRF reference was not required on the ERN.

R. L. Raghitto was blocking the issue of the DVSCN and was requiring the DRF reference.

Comment:

From a review of EOP 42-6.00 para.

4.1.2, it seems that per para. 4.1.2(b) a DVSCN is necessary to notify engineering services and from para. 4.1.2 (a) either an ERM, or ECN, or applying document, or DVSCN may be used to show the DRF con-taining verification, if applicable, para. 4.1.2(b).

Has Mr.

Reghitto attended a training class on the issuance of DVSCN's?

See Sec.

1.5.

Sec. 5.16 Synopsis:

Per letter on March 4, 1982, Mr. Milam 45

2 h

informed Mr. A. Koslow that ERN AML-2997 for which he is responsible was-changed after-his-signature, without his knowledge, and in direct conflict with specific. instructions he hadh given.

The accompanying DVSCN disappeared.

Comment:

Did Raghitto alter the ERM and throw the DVSCN away?

See Sec. 5.15.

s l

i e

46

O 8 - l PART VI GE EMPLOYMENT 4/1/82 TO 4/30/82 Introduction' During Mr. Milam's last month of employment with GE, until he was dismissed, he worked for Mr. T.R. Wortham in the same Technical Licensing Unit of the Control and Instrumentation Department.

Review and Analysis of the Record Sec. 6.1 Synopsis:

On April 7, 1982, a letter from W. H.

Hendrix to D. W. Reigel was written on the subject of NC&ID w Fusing Policy.

Mr. Milan circled a line and included a comment 4

of his own.

Comment: ~ The-line circled is "No credit is taken for fuses protecting specific pieces of equipiment nor is it required by Mr. Milan's comment was "In our control any NC&ID documents."

system failure analyses, we take credit for fuses preventing failure propagation."

Does GE still take credit for fuses as Mr.

l Milan said?

Is this acceptable or not?

Sec. 6.2 Synopsis:. Mr. Milan wrote a letter to W. M. Barrentine on April 14, 1982 ab 1ut unauthorized, post signature changes.

In this: letter, Mr. Milan states that R.L. Raghitto made an authorized change to ERM AML-2997 without Mr. Milam's knowledge See also Sec.

-and in direct conflict with specific instructions.

5.16.

Synopsis:

'On May 22, 1982, Mr. Milam wrote Mr.

Sec. 6.3 Barrantine a letter and included a copy of his work record while Cobler.

In this letter, Mr. Milam requested Mr.

-working for C.L.

Barrentine to read sobut the on-going underworld of C&ID and says he tried to communicate some of these things to Mr. Barrantine on several occasions but was discouraged by Mr. Barrentine's managers and attitude.

Mr. Milam says:

Since you no longer hold my form 38 (a standard threat),

I have nothing further to fear from either you or your conspiratorial managers.

I hope, by sending you this Record, to give you a glimpse into that hidden world of r

-uncontrolled bootleg activity we all know so well.

l Mr. Barrantine was the manager of the Nuclear Control & Instru-I mentation Product Design Operation (NC&ID) or (C&ID).

He was L

Mr. Hart's, Mr. Cobler's, Mr. Reghitto's, Mr. Stramback's, Mr.

Koslow's, and Mr. Fortham's supervisor.

Mr. Sann, who was

. mentioned in Sec. 3.6, was Mr. Barrentine's supervisor.

47

r-o Mr. Samuel Milan, III had been notified of his layoff when this last letter was written and his reference to from 38 had to do with the constant threat of layoff if you did not go along with the system.

He did not.

e T

48

t PART VII DEFERRED VERIFICATIONS

' Introduction In June of 1983, Mr. Milan authored a report titled

" Deferred Verifications."

This report was written after his-termination from General Electric because of his on-going concerns about the problems relating to the use of unverified documents at GE.

Mr. Milam breaks the problems-down into four areas.

These are:

1.

Use of unverified documents as source documents-for changes in other controlling design documents.

2.

Production and shipment of hardware whose design included unverified documents.-

1 3.

Technical review of Final Safety Analysis Reports using unverified documents.

4.

Responses to customer and NRC questions using unverified documents.

Analysis and Review of Report Mr. Milan's recommended solution to these problems is on page 54 of his report: "I feel that the only reliable approach is l

to simply not allow verification to be deferred."

In support of l

l Mr. Milan's solution, the author cites his past experience: the following companies did not, to the author's knowledge, defer verification:

Southern company Services, Inc., Quadrex, Bechtel, and the Lawrence Livermore Laboratory.

While working for Bechtel in Gaithersburg, Md., the author witnessed an example of what to do to avoid issuing an unverified i

document.

A drawing was scheduled for release on a specific date l

but for some reason had not been started.

The date came and the title

-manager simply had a drafting person pull a blank sheet, it, date it, and place a large circle on it with a note that the information would be supplied at a later date.

This blank drawing was released.

Even though nothing could be built by this I

drawing, it did perYorm several functions:

1.

A drawing with the scheduled-number was released on schedule.

2.

The contractor was notified that engineering was aware of the need for that information and had not forgotten it.

3.

An unverified document was not released for use simply because of a schedule.

The author is not advocating this procedure, but it is an example of yet another method which could be used to avoid releasing an i

unverified document.

49

E, l

l The problem with deferred verifications is not new within GE's organisation.

According to Mr. Milan's report, the deferred verification problem was recognized in a letter on July 19, 1976, from L.D. Test (NCEID Engineering) to J. Ward -(Manager QA NC&ID).

As an indication of the depth of this problem, a letter on August 9, 1976, from D. C. Brown to J. Ward documenting a meeting on. August.Sth with D. E.

Lee, B. J. Beach and D. F. Long made several points.

The most significant was that " engineering was I

now keeping track of all deferrals."

Evidently, before this time.

no record of deferrals was kept.

In January 1977 (approximately January 25th), a meeting of iT. Ward and D. C. Brown was held with D. F. Long and D. E. Lee.

One subject was deferred verification.

" Jim Ward's notes on the letter prepared for this meeting indicate that we were to 'back off a little' on our request for status information by February 15th."

In a meeting of the BWR Quality Council on April 21, 1978, John Barnard identified an iten: " Control of Products Produced to Unverified Designs (78-2-1)."

He expressed a concern on the subject of Conditional Releases and required that letter reports from CEI, Wilmington, and EEPO QA organizations be transmitted to the Council by May 18, 1978, as to controls in place for such t

items.

Mr. J. K. Powledge responded on April 28, 1978.

His main in a review with D. F. Long, it was agreed that points were (1) systems to control shipments on unverified designs did not exist in NEED; (2) the Design Engineers must have positive and contractual means to prevent shipments until Powledge has accomplished the design verification.

Based on these documents, the statement in the above letter of August 9, 1976, appears to have been false.

In a letter cn September 22, 1980, from P. M. Briggs to D. H. Ferguson on P&QAO CAR # P8005-6 and J. Wilson's proposed Conditional Release Shipment Control System, Briggs concluded that:

l.

(A)

Total scope of past items is unknown.

l (B)

Projects has no tracking system.

'1 (C)

EIS requires modification before it can carry l

l complete status information.

(D)

QA and Materials are not in the loop after shipment except for specific FDI/FDDR action.

Mr. Milan made the following recommendations on page 54 of his report.

1.

Completion of verifications which have been i

1 50

D previously deferred, and Resolution of deficiencies in the control of L

2..

deferred verifications.

It should be noted that his point #1 can be broken down (a) previously deferred, no record of deferral into two parts:

in EIS or otherwise, and (b) previously deferred,.and recorded in EIS or other record system.

Upon reading Mr. Milan's report, the author was mystified as to how this could have happened and gone on undetected by the NRC for so long.

The point stressed most by the author's instructors

~

in engineering school was to have an independent review of your design for one reason:

to ensure that an error was not made which might lead to a design failure and someone's death.

This goes beyond any legal mandate established by state or federal law.

The author graduated in June 1975, prior to all recorded evidence of GE's deferred verification problem.

Surely the engineers at GE received similar training.

After Mr. Milam gave his report.to the NRC in 1983, he was contacted by two inspectors from Texas.

They met with Mr. Milam in his home to discuss with him his concerns.

The main issue discussed was the-Deferred Verification practice since that was the subject of his report.- They did also discuss other topics such as ECN's, the Fab Shop, EIS, and others, but.not in detail.

The first mention of deferred verifications in inspection reports of the Vendor Inspection Branch of the NRC was in a letter dated Oct. 21, 1983, about an inspection conducted by D.D.

Chamberlain on August 29-Septemberr 2, 1983.

The cover letter does not mention deferred verifications but Appendix A does.

Appendix A, title Notice of Nonconformance, states that the

" design verification of Nuclear control and Instrumentation Division design documents are being deferred without implementa-tion of controlling procedural requirements."

On page 5 of the inspection results, "a review of the design / design change docu-ments on the River Bend project revealed that DVSCNs were not being prepared for verification deferrals in most cases and the external users were not being notified about the deferred verifi-cation status of appliable design data.

This area will be

~

reviewed further during a future NRC inspection to access GE program from tracking and close out of deferred verifications."

The next recorded comment about deferred verifications comes in a letter dated Jan. 9, 1984, concerning an inspection conducted by Mr. P. Harrell on December 5-9, 1983.

On page 3 under status of previous inspection findings, item 2.a. just mentions that design verifications of NCEID design documents are being deferred without controlling procedural requirements being implementd.

Deferred verifications are mentioned again in a letter dated l

51

O Nov. 17, 1983, from GE to the NRC which is attached to a letter dated Feb.

6, 1984 from the NRC to.GE stating that the NRC had received the information.

GE's response to the nonconformance was The status of design documents currently identified in deferred verification status on all projects is being reconfirmed.

Completion of the verification will be scheduled as required by the Engineering Operating Pro-cedures (EOPs).

This action is scheduled for completion by December 1, 1983.

The nonconformance_was closed by the NRC according to an inspection report dated Mar. 12-16, 1984.

From page 3:

-- GE has initiated an action plan to review all documents listed in the Engineering Information System (EIS) to assure that current earification status is correct.

The inspector also reviewed customer notification of design documents currently in deferred verification status as required by Engineering Operating Procedure (EOP) 42-

.600.

GE Quality Assurance and Reliability Operation (QA&RO) conducted an internal audit of the implementa-

)

tion and effectiveness of the deferred verification l

action reports (CARS).

As of this inspection, one CAR is still open.

(Emphasis added)

This action by the NRC falls far short of the necessary corrective action required.

First, no review was made of the deferred verifications prior to 1976 before any records were kept on deferred verifications.

Second, the NRC has overlooked its own inspectors' findings.

They found in one of their inspections i

that not all deferred verifications were being logged on EIS.

In fact, many were not recorded in EIS.

Third, EIS did not have the necessary QA controls over its operation to be used as a sole source of information in a Quality Assurance corrective action program.

I GE Corrective Action Required It should be determined when the deferred verification policy started and how many deferred verifications were allowed before any tracking system started.

All deferred verifications should then be verified -- both those not tracked and those that were tracked -- either by EIS or some other system.

The deferred verifications should be stopped and immediate notification of document status problems given to plant owners.

A study should be done to determine the causes of emergency shutdowns or other safety-related occurrences in operating plants, and a correlation of the instances where GE instrumentation, etc., was the cause.

It should be determined whether or not the design verification was deferred.

52

~.

5 NRC Corrective Action Required It is time for an investigation into why the NRC did not discover this for themselves before 1983, when evidence existed at GE that deferred verifications started prior to 1976.

Because the early deferred verifications were not documented, there may not be a nuclear plant in existence which GE worked on that doesn't have.open deferred verifications sitting silently waiting to cause damage greater than Three Mile Island.

Therefore, the NRC should place temporary maximum operating limits on each plant designed by GE pending the completion of the verification of all safety related components.

This would include a new as-building program of all GE safety-related equipment.

Public Action Required We recommend that the general public be encouraged to express concern to Congress and state legislatures, asking that an outside firm take part in the required review of GE's quality assurance and design organization -- a fira employing known honest and ethical (as well as knowledgeable) engineers, welding l

inspectors, QA and QC inspectors, computer analysts, and members-at-large from professional organizations and educational institu-tions, who have no financial or employment ties and who do not actively profess to be anti-or pro-nuclear, but who do profess honesty and.the ability to perform an unbiased review.

l l

53

E PART VIII REVIEW OF NRC FILES RELATIVE TO GENERAL ELECTRIC AND FIVE NUCLEAR REACTOR PLANTS

-Introduction After a review of Mr. Milan's work records and his report on Deferred Verifications, the author attempted to investigate both the by the NRC and/or utility during the construction of five plants which were noted in Mr. Milam's work record in connection with the GE design organization which are on. file at the Public Docu-ment Room in Washington, D.C.

This was done for two reasons:

(1)

To see if any of the nonconforming equipment, drawings,.

etc., were caught in the field and (2) to see how much corrective action was made, if any, of nonconformances which were caught in the field.

The following narrative has been split into two subgroups.

The first contains a synopsis of entries and the author's comments, if any, from the review of the five plants:

Limerick, Grand' Gulf, Shoreham, Perry, and Nine Mile Point.

The second contains findings from a review of the NRC Inspection reports of GE's offices in San Jose and elsewhere.

NOTE:

The plants. listed above may not have individual sections, but may be referenced under others.

Many l

of the plants had references in the PDR files which were identical to others.

Review and Analysis of Documents A.

Documents from NRC Files on Five Plants The information listed in the following short synopsis is given in the following order:

accession number, document title, paper file-location, microfiche location, and number of pages.

Comments may or may not be included by myself with references to

[

paragraphs in other sections of this report.

The author's comments, if included, will follow the synopsis.

It should be noted that the references to plants usually include multiple I

units.

1.

DRESDEN Docket No. 50010 8311090348S 10CFR Part 21 report.

During performance requalifi-cation tests on Vertical Lift Metalclad Switchgear Equipments (4.16KV-250 and -350MVA - 78,000 Amperes Momentary) conducted July 11, 1978, test results indicated that the short circuit bus bracing was'not adequate for a 10 cycle - 78,000 Ampere withstand test. ' Plants affected:

Grand Gulf, Waterford, Calloway, Wolf Creek, skagit, Hanaford, La Salle, Shoreham, Nine Mile, Quad Cities, Millstone, Pilgrim Vermont Yankee, Turkey Point, Maine 54

\\

E Yankee, Diablo Canyon, Duane Arnold, Arkansas, Farley, and Salem.

i FILE /P:.83110903488, FICHE:

unknown, 7 pages.

There was no reason stated for the requalification test being performed in the report.

It is now no surprise that the switchgear. failed a qualification. test, given that the switchgear should hava undergone a qualification test and passed before being.used in a nuclear safety-related capacity.

Given the many entries in.Mr. Milan's work log concerning the lack of functional testing (see Sec. 2.13) and/or the lack of complete environmental testing '(see Sec. 5.11), it is evident that either no functional qualification testing was performed or that inadequate environ-mental testing was performed originally on the switchgear.

i 2.

NINE MILE POINT Docket No. 50220 f

84082403485 10CFR Part 21, Reportable Condition Scram Solenoid Pilot Valve.

Presence of Loctite-242, thread locking material, in the solenoid plunger of the scram pilot solenoid valve of the Control. Rod Drive Hydraulic Control Units at Unit 3 of Peach Botton Atomic Power Station.

Recent testing has shown that Loctite-242 exhibits unpredictable characteristics under certain conditions.

It has potential of changing state to a liquid form after solidifying.

It can also re-bond after breaking loose from previous bond.

GE's information indicates DUAL-ASCO valves

-(NVA90-405) could-be affected.

Plants with these valves are:

Dresden, Quad. Cities, Millstone, Big Rock Point, Monticello, oyster Creek, Fitzpatrick, Brunswick, Fermi, Zimmer, Browns J

. Ferry, La Salle, Vermont Yankee, Limerick, Pilgrim, Cooper, Hatch, Duane Arnold, Hanford, and Shoreham.

Loctite-242 could be used on plants under construction, as well as operating plants in applications unrecorded.

FILE /P:

8408240348S, FICHE:

Unknown, 3 pages.

The following questions should be asked:

Who made the i

decision to use Loctite-242 or, for that matter, any other material in a safety-related capacity?

Was the decision made by a design engineer, someone in purchasing, someone in fabrication or someone in construction?

Did the material undergo environ-mental testing as required by 10 CFR 50 for use in a safety-related system?

None of these questions can be answered by the document on file.

However, it is doubtful that a design engineer verified that Loctite-242, 272, or 290 could be used.

Nor was any environmental testing performed on this material prior to this use.

On occasion, the author has used Loctite products and recommended their use, but not without reviewing design literature or calling a company representative and discussing the proposed use.

The author became aware of Loctite products in an automotive parts store.

This should tell the user a little about the product, not enough upon which to decide to use it in nuclear safety-related systems, but enough to cause concern over using it in a nuclear application.

How many automobiles operate in a radioactive area?

None.

The author has an automotive catalog 55

.a..

J

a Weatherly Index no. 732 on Loctite, Duro, and Permatex products.

This document does not have sufficient technical design informa-tion on these products to warrant recommending their use in a nuclear facility.

This document does supply some information which would be useful in making a decision on their use.

on page 19, is a chart of features and suggested applications for 640, -811, -592, and Permatex 14AR, Lectite-242, -271, -290, 14H, 14D, 51H, 51D, and 51F.

The minimum temperature range given The was -65 degrees and the maximum was +400 degrees Fahrenheit.

maximum for Loctite-242 was +300 degrees.

Loctite-242, also, has the smallest shear strength, 1600 psi, of the Loctite thread-locking compounds.

Based on the technical information available, the author would not have recommended using Loctite-242 in a nuclear safety-related capacity.

3.

SHOREHAM Docket No. 50322 82042101375 HMA relays manufactured from January 1976 through June 1981, contact leads may not be fully insulated.

Examples of systems in which potentially defective HMA Relays exist include:

Susquehanne 1,2 RHR, HPCI, Auto. Depressurization (ADS)

Hope Creek RHR, Core Spray Perry 1 RCIC, RHR Limerick 2 RHR, Core Spray Grand Gulf 1,2 RHR, LPCS, HPCS (Power Supply)

CNV-HPCS (Power Supply)

Clinton HPCS (Power Supply)

TVA Hartsville HPCS (Power Supply)

River Bend LaSalle 1, 2

Fermi Zimmer f.

Nine Mile Point 2 Hanford l

l FILE /P:

8204210137s, FICHE:

Unknown, 4 pages.

This problem is similar to terminal boards bridging the wire The terminal grill gap which is referred to in Section 2.34.

board problem was on the CNV facility listed above.

8209080138A Report-on Nuclear Steam Supply Systems panel designA evaluation for electrical separation IE and non-IE interface.

sample of only two NSSS cabinets Hil-P609 and H11-P617 were used l

to evaluate all NSSS panels.

According to GE, design complies with IEEE 279-1971.

GE made three assumptions for this evlua-tion.

They are:

1 All essential and non-essential wiring is assumed to be a.

bundled together within the panel.

b.

Adequate separation was provided by AE/ customer for the cables agressing at the terminal boards between 56 t

,,n, w

=-

o,mn, - - -_ -a

---,w.,n.w--------e------~~n n

O essential and non-essential circuits as per separation requirements.

Brideing circuits (non-IE. wires interfacing with mora c.

than one division) are not-considered.

It is assumed-that at'no instance non-IE wires run with more than one division.

In conclusion, GE' states that "the safety of the Shoreham Plant and is not impaired by the. presence of non-essential (non-IE) essential (IE) in close proximity to each other inside panels.

-FILE /P:

8209080138A, FICHE:

unknown, 12 pages.

This evaluation is completely without merit.

A quality evaluation would not make assumptions.which-could not be proved in 100 por cent of the cases nor would have non-conservative results if used.

Without the three assumptions made above, GE could not come to.their conclusion.

Although-GE gave three assumptions, they made one other assumption.

Some amount of review may have gone into the use of only two panels, but when GE made the statement that "these panels are typical of the rest of the NSSS panel configurations and the.results of the analysis are 1

considered applicable to all NSSS panels furnished by General l-Electric for.the Shoreham Plant," they made a big assumption --

d' one that is not conservative -- that the panels are typical.

Beyond the assumptions stated and implied in the preface of their report,: the biggest error made by GE was in using IEEE 279-1971.

This is because, according to NUREG-580 Vol. 12, No.

7, the

. application for construction of Shoreham was tendered on 09/00/75 and according to 10 CFR 50.55a Codes and Standards

-(h)

Protection systems:

For construction permits issued after January 1, 1971, protection systems shall meet the requirements set forth in editions or revi-sions of:the Institute of Electrical and Electronics Engineers Standard:

" Criteria for Protection Systems for Nuclear Power Generating Stations,"

(IEEE-279) in effect on the formal docket date of the application for a construction permit.

.GE should have used IEEE 279-1974 as the b ews f their design.

In reviewing this evaluation made by GE, f.. U.g become apparent that in'all the reviews done to date and discussions held with Mr. Milam about GE's operations, there is no evidence that GE has a procedure or system for ensuring that the correct design are used with each of the plans they documents (date of isenance) for are working on (date of issuance of construction permit)

Compliance with 10 CFR 50.55a compliance with 10 CFR 50.55a.

requirements when designing one facility is difficult to control, since most engineers only own a certain edition of a code and few At to none own each subsequent edition or editions in effect.

GE, compliance with 10'CTR 50.55a becomes nearly impossible with 2 under contract, and approximately 26 plants under construction, 57

O 125 under service contracts.

This is even more true in light of the information in Mr. Milan's work record indicating that a drawing could be used in part or in whole for multiple plant documentation.

It is' doubtful that GE has a program or procedure in force to ensure that 10 CFR 50.55a is complied with by all personnel working on all projects.

8410250115S 10CFR Part 21, Reportable condition inverter low voltage shut off.

Original manufacturer (Power Mark, a Division of Topaz) set low voltage cutoff at 105 volts DC.

GE checked for operable range of 105 to 140 volts DC instead of 100 to 140 volts DC.

Subject inverters used to power 24 VDC instrument buses in RCIC and various Emergency Core Cooling Systems (ECCS) including HPCI/HPCS, ADS, RNR and LPCS.

Other applications include Remote Shutdown and Leak Detection Systems.

Other projects where these were used:

Limerick, Hope Creek, Fermi 2, Nine Mile Point 2,

. Perry, River Bend, Grand Gulf and Clinton.

GE states that this e of problem could exist in applications beyond GE's technical tn ore tion.

FILE /P:

8410256115S, FICHE:

unkno'wn, 3 pages.

(Emphasis added.)

Again, there is a problem with a purchased component.

(See Nine Mile Point above.)

There may be other reasons for this deficiency other than that given in the report.

Many entries in Mr. Milan's work log indicated that incorrect drawings were being used in functional testing (see also Sec. 2.12), or incomplete shop work being signed off (see also Sec. 1.16).

In any case, the NRC has been only_too willing to accept the correction of the specific defect rather than investigate and correct the root of This-is very the problem as required by 10 CFR 50 App. B.

troubling in light of the last line of the entry by GE.

b 4.

LIMERICK Docket No. 50352 and 50353 8012300527S Final report:

violations of separation criteria in the power generation control complex.

During visits to the General Electric fabrication facility, Philadelphia Electric Co.

(PECO) engineering personnel observed violations of Project separation criteria in Limerick safety-related PGCC panels which were under construction.

After receipt of the PGCC pannis at Limerick, PECO QA gersonnel identified several instances of vio-lations of the Project separation criteria.

Several of these violations were in addition to those previously identified at the It is concluded that this deficiency can be attributed factory.

to a lack of adequate instruction of the factory wiring personnel and'a breakdown of the factory QC inspection. -FILE /P:

8012300527S, FICHE:

unknown, 8 pages.

(Emphasis added.)

other possibilities include:

incomplete shop work signed off (see also Sec.1.16) ; tootleg manufacturing changes (see also Sec. 1.24); Engineering having told Shop to accept not-per-drawing panels with intent of buying-off panels with an IR (See also Sec.

2.10), or QC hold points missed (see Sec. 2.78); the breakdown 58 i

exceeds the NRC's findings, review, and corrective action.

83061000925 10CFR Part 21, Reportable Condition Local Instrument Panel Piping.

Error on four local instrument panel piping dia-grams which resulted in a potential incorrect interface with the reactor pressure vessel instrument piping.

Panels H23-P004,-

-P005, -P026,.and -P027 containing water level and pressure transmitters would have.been incorrectly connected resulting in reverse indications.

FILE /P:

8306100092S, FICHE:

unknown, 3 pages.

5.

GRAND GULF Docket No. 50416 7907030493 Interim report for Reportable Deficiency 79/10 on 791521:. problem identified as gross failure output function of master and slave trip units of Rosemount 510 trip calibration system.

Remedial action will be completed by 791116.

FILE /P:

7907030490A, FICHE:

00415 351, 2 pages.

7909190295 Submits interim report of Potential ReportablN Defi-ciency 79/11 re cracked control devices on 4.16 kV switchgear, 6.9 kV switchgear & 480 volt controls.

Deficiency is under investigation.

Reportability provided by 791130.

FILE /P:

7909190295, FICHE:

00965 144, 2 pages.

7909190475 Interia Report 3 for Potential Reportable Deficiency 79/05:

GE has issued field deviation disposition request re changes in wire and cable lists.

All termination cabinet panels at site are being reviewed.

Final report by 791130.

FILE /P:

7909190475, FICHE:

00977 287, 1 page.

7909250596 Part 21 report re. failure of inverters supplied by Topaz Electronics used to supply divisional power from station batteries to ECCS transmitter / trip analog sensors, by transient distu:bances.

FILE /P:

7909250596, FICHE:

01020 083, 2 pages.

t Was functional and/or environmental testing performed by GE?

(See Sec. 2.13 and Sec. 5.11).

This concern applies to four entries above.

7909270378 Interim deficiency report re failure to establish and implement approved QA program for electrical work performed under field deviation disposition requests and field deviation 1/ This documentation against Grand Gulf may appear to be heavy, but the reader should understand that many of the entries provided apply also to other plants, and when these are compiled the author expects every plant designed or built by GE -- or having GE-built components purchased by other companies for plants not under contract with GE -- to be listed.

59

,-,,,--,,,,s

,,y

,w,,

,.y,,,,_-.,,,-,w,.,,,,.m,,,.

-m m

---,ema,,.,

..,,,m_,m%-,--*,.-._,,.,..-..-,,,-,,,,,,,s.---,,--,,e------

--.,----r,

instructions.

Final report will'be issued on 800131.

FILE /P:

7909270378, FISCHE:

01046 275, 1 page.

This'is similar to the non-compliance with procedures' mentioned in requiring an ECN log and Coordinator (see Sec. 2.49)

Even when brought up by Mr. Milam to Mr. Milam's work record.

his superiors, they ignored the issue.

This deliberate evasion of the legal requirements of 10CFR50 should be punishable as a criminal offense.

7910010803 Final Deficiency Report 78/04 re defective GE control room panels.

Control switch CF2940 was installed without locking ring.

No safety hazard exists.

Documentation has been revised to insure proper installation in future.

FILE /P:

79100108801A, FICHE:

01033 087,-1 page.

This is but a small part of the problem with CR2940 switches (see Sec. 2.32 and Sec. 2.65).

7910100127 Forwards interim. report on Rosemont 510 DV trip units drawing more current than planned causing power supplied to be inadequate.

Corrective action is expected to be completed by 800321.

FILE /P:

7910100127, FICHE:

01134 082, 2 pages.

(See comments given under 7907030493 above.)

7910170382 Interim Deficiency Report 7914 re ASCO solenoid valves becoming inoperable when exposed to radiation doses and tempera-tures specified in purchase requirements.

All corrective actions taken and final interm report will be submitted by 791221.

FILE /P:

7910170377A, FICHE:

01161 274, 2 pages.

7910240536 Interim report for Deficiency 79-14 on 7903830, noted that NAMCO EA180, series limit switches may have top gasket emitting vapor at temperatures above 175 F. and could condense on open contacts causing malfunctions.

Analysis due by 791221.

FILE /P:

7910240536, FICHE:

01205 176, 2 pages.

7910240634 Interim deficiency report re defective inverters manu-factured by Topaz Electronics for equipment supplied by GE.

Inverters that supply power from station batteries to ECCS trans-mitter/ trip unit analog sensors failed.

GE investigating.

FILE /P:

7910240634, FICHE:

01207 023, 1 page.

The three entries above are functional testing problems (see I

Sec. 2.13) and/or environmental testing problems (see Sec. 5.11).

7910310320 Third interim deficiency report re circuit separation Will make discrepancies in power generation control complexes.

determination on reportability by 800131.

FILE /p:

7910310320, FICHE:

01245 015, 1 page.

(See first entry 8012300527S under Limerick above.)

60 I

f-7911070434 Interim deficiency report re ASCO solencid valves.

Design does not conform to design criteria in purchase specifica-tion.

Final report will be filed by 791221.

FILE /P:

.7911070433A, FICHE:

01292' 213, 2 pages.

-(See para. 7910170382 above.)

7911270473 Interim Report 3 for Potential Reportable Deficiency 79-04 re inadequate crimping in power generation control complex inter-connecting cable pen connections.

Field disposition instructions issued.

FILE /P:

7911270473, FICHE:

01399 138, 1 page.

This is not the only problem with cable pen connections.

In Sec. 1.8, Mr. Milam gives an account of a case where duplicate connector numbers were assigned.

The problem with crimp connec-tions is not new.

If any interested person were to review the records on all the nuclear plants, they would find countless entries of this type of deficiency.

The reasons for using crimp

(

connectors are understandable.

They are quick and can be used without electricity or heat.

However, due to the number of problems, the NRC should consider banning the use of crimp connectors in safety-related systems in nuclear plants, since a failure during a seismic disturbance might jeopardize the safe shutdown of the reactor.

Requiring all connections to be either soldered or of a type which may be screwed or bolted would result in safer, more secure connections.

These could be checked by using a pull test exerting a set amount of load which would be predetermined based on the strength of the wire being connected.

Given the battle which would ensue over this proposal, another proposal is offered:

require a pull or tug test of all crimp connections using a tension scale and utilizing 80% of the wire strength capacity as the pull or tug force.

If any slippage occurs during the test, this would be an automatic failure requiring the connection to be redone and ratested.

7911280405 Final deficiency report:

gross failure output may reset when gross failure is energized and trip unit operated through preset trip points.

Caused be malfunctioning of trip output load switching.

Trip units returned.

FILE /P:

7911280404A, FICHEL:

01402

357, 1 page.

79121130524 Interim deficiency report re failure of Type L2 auxiliary switch assembly in 4.16 kV switchgear.

Switch assem-for bly returned to equipment supplier, Gould Electric Systams, analysis.

Resolution expected by 800228.

FILE /P:

791J230524, FICHE:

01553

327, 1 page.

The two entries above are functional testing problems (see Sec. 2.13) and/or environmental testing problems (see Sec. 5.11).

79121180054 Confirms verbal report re noncompliance to specifica-61

~

tions for nuclear valves.

Caused by error in computer program, developed by subcontractor.

All reported frequencies will be re-analyzed.

FILE /P:

7912180054, FICHE:

01399, 138, 1 page.

4 There are entirely too many computer programs being used which have inadequate documentation, development and error response.

The use of programs which have no profit incentive promoting a quality product-is probably one of the most serious safety concerns in the nucisar industry.

Programs like McDonnell Douglas's ICES STRUDL, and Swanson's ANSYS which have technical staffs who constantly work to improve them are not-being utilized.

Instead, poorly written, documented, verified and tested programs are being generated in-house even by smaller firms like Sargent and Lundy.

Bechtel not only generates programs but continues to use an old MIT version of STRUDL which has been modified in-house.

These should be checked against other programs able to do this analysis and problems which were performed by hand.

All logical. steps and lines of code should be checked.

~7912130532 Final Deficiency Report 79-00 re failure of solid-state trip devices in low voltage power circuit breaker.

Caused by defective assembly of printed circuit boards supplied by Gould-Brown Boveri.Switchgear Division.

FILE /P:

7912130528A, l

i FICHE:

01553 337, 2 pages.

Another functional testing problem (see Sec. 2.13) and/or an environmental' testing problem (see Sec. 5.11).

L 7912190633 Interim deficiency report re improper drawings sup-plied by GE.

All termination cabinet panels being reviewed against as-shipped drawings.

Findings will be submitted by 800115.

FILE /P:

7912111190/633, FICHE:

01626 213, 1 page.

The review of panels by comparing them to the as-shipped drawings assumes that the problem is one completely in the manu-facturing process.

However, there have been numerous examples of other causes for improper drawings.

Such as duplicate connection numbers, (see Sec. 1.8), incomplete or no verification of drawing (see Sec. 1.11), drafting errors (see Sec. 1.15), multiple use of drawings (see Sec 2.7), questionable knowledge of Engineering (see Sec. 2.44).

791219072 Final deficiency report, re: use of inadequately sup-po'ted long terminal strip in junction boxes on electrical r

penetration assemblies for containment building.

" Procedure to Brace CR151-Terminal Blocks for Electrical Penetration," issued.

FILE /P:

791219072, FICHE:

01626 332, 2 pages.

This could have been the result of the design verification not being done.

(See Sec. 1.7).

8001040337 Part 21 Report 79-159-000:

on 790924, defective 62

~ - - --,-,,

crimps found on pins used in 72C insert for panel H12-P853.

Caused by manufacturing personnel error and crimping tool mal-function ~resulting from. inadequate gauge.

Utility to be advised of inspection and repair program.

FILE /P:

8001040337, FICHE:

none, 3 pages.

(See para. 7911270473 above).

It is hard to believe that a crimping tool. malfunctioned.

The fact is'there was no crimping tool malfunction.

The manufacturing personnel used the wrong crimping tool for the gauge of wire.

As an' example of the type of problems created by reliance on crimping tools, the author has included the following scenario Lfrom his personal life.

The author frequently uses crimp connectors on his auto-

~

mobile and owns a pair of Waldon HT1919 Prototype-Hand Tool which crimps.093" pin diameter terminals.

On the back of the package the crimps were sold in was information on wire size and part numbers of crimp. connectors which the tool would work.

There were seven crimping instructions, also:'

1.

STRIP WIRE 3/16" (as shown in Illustration No.1).

Insert in proper striping die, rotate tool one-half turn, and pull insulation off wire.

Illustrations have not been included here.

2.

Leaving wire aside for the moment, with tool fully open (engraved side toward you) bring a terminal tool into posi-tion from the unmarked side of the tool.

Place the conduc-tor tabs (inner set as shown in Illustration No. 2) on the "B" anvil (slightly curved surface) so that the circular portion of the tabs rests in the curved surface of the anvil and the two tabs face up into the walls of the female jaw.

3.

Close tool very slightly only to the point of holding the terminal in position.

4.

Insert wire into terminal until wire insulation is stopped by conductor tabs.

CRIMP by squeezing handles until jaws are fully closed or sufficient crimp is made.

DO NOT REMOVE FROM TOOL.

(Illustration No. 3) 5.

Move terminal and conductor forward so that insulation tabs (outer set) are properly positioned in the center of anvil "A"

(Illustration No. 4).

CRIMP AGAIN until jaws are closed or sufficient crimp is made.

6.

If necessary, straighten terminal while still being held in jaw.

The wire lead, with its properly crimped terminal, is now ready to be inserted and locked into the nylon con-nector housing.

When correctly inserted, a " click" can be felt (and even heard), indicating that the locking ears have 63

...n,-_

,,,,.- _,.,__--,n.

o t

been set.

There is no necessity to pull back on the lead itself except to' test for the " locking feature," and then only with moderate pull.

7.

'If erroneously inserted into the wrong housing position,-

f or if at some later time a circuit change is desired, and Extractor Tool will be required to extract the Pin Terminal from the Nylon Housing.

An ECONO Extractor, No. HT-2054,,or l

DELUXE Extractor, No. HT-2 is available.

For a particular wire gauge, if the correct crimp connectors for the particular crimping tool are used and all instructions are followed, there will be no loose crimp connections made.

The reason for loose crisp connections is non-compliance with the manufacturer's instructions for using the crimping tool.

l This is not a crimping tool malfunction. 'This is operator error caused by inadequate training and/or the fault of purchasing i

incompatible components -- crisp connectors and tools for use.

8001150421 Final report, re: potential deficiency of NAMCO-supplied limit switches.

Switches do not meet safety-require-monts of original purchase specifications.

Condition not reportable per 10 CFR 50.55(e).

FILE /P:

8001150419A, FICHE:

90023 158, 1.page.

3001230096 Interim deficiency report, re:. mounted instruments not purchased according to nuclear safety-related requirements.

-Findings will be reported by 800229.

FILE /P:

8001230096, FICHE:

01791 250, 1 page.

The two entries above are functional testing problems (see Sec. 2.13) and/or environmental testing problems (see Sec. 5.11).

8001230144 Interim Deficiency Report 5, re: improper drawings of wire and cable lists supplied by GE.

All termination cabinet l.

panels at site are being reviewed against as-shipped drawings.

Final report will be filed by 800331.

FILE /P:

8001230144, l

FICHE:

01792 011, 0 page.

(See para. 7912190633 above.)

re: cracks on control device 8002040559 Final d'eficiency report, assemblies used on switchgears and 480-volt load controls.

Cracks showed no signs of propagation during testing and will not result in control device failure.

FILE /P:

8002040553A, FICHE:

01866 323, 1 page.

8002070286 Final deficiency report, re: common mode failure of S1 and S2 model 510DV master and slave trip units.

Cause not stated.

Switch will be replaced by Rosemount Inc. and func-tionally tested on reworked units.

FILE /P:

8002070283A, FICHE:

01938 655, 1 page.

64 m

+

w

,e--,----o,-,v

wr a-n,-,

--ve,-ww.-,,,,.,_.-wa,.

,_,-.a__,,,,------.,,-m--,m---------r----

~.

S 8002110610 Final deficiency report, re: ASCO solenoid valves becoming inoperable when exposed to radiation dosages'and temperatures specified as purchase requirements.

Will replace six active valves in reactor containment.

FILE /P:

8002110569A, FICHE:

01940 251, 3 pages.

The three entries abov.a are functional testing problems (see Sec. 2.13).and/or environmental testing problems (see Sec. 5.11).

8002210523 Deficiency report, re: circuit separation discrepancies.

On 790323, improper separation noted with Division 174 wiring in Panel 2H13P692.

Deficiencies discovered on Panels 2H13P693 & 4.

Wires relocated and redressed.

Final report by 800515.

FILE /P:

8002210523, FICHE:

04067 330, 2 pages.

(See first entry 80123005275 under Limerick _above.)

4 8004280481 Second interim deficiency report, re: faulty GE CR2940-US203E hand switch in plant SVC water system.

Switch returned to GE for failure analysis.

Final report will be forwarded on I

800618.

FILE /P:

8004280481, FICHE:

04696 032, 1 page.

i 8005080484 Status report on deficiency, re: Rosemount Model 510 DV trip / calibration units and Model 1152 pressure transmitters.

Transmitter has common mode failure of capacitor when transmitter

. operating temperature greater than 175 F.

Review underway.

FILE /P:

8005080480A, FICHE:

04868 224, 1 page.

8005280495 Interim deficiency report, re: erroneous output readings t

noted in Model 1151A pressure transmitters supplied by Rosemount, Inc.

Final report will be forwarded by 800731.

FILE /P:

8005280495, FICHE:

05095 093, 2 pages.

l 8005280510 Interim deficiency report, re: improper installation of high pressure core spray diesel generator control panel supplied l

by GE.

Panel apparently installed incorrectly.

Final j

report should be forwarded by 800818.

FILE /P:

8005280510, FICHE:

05092 148, 2 pages.

8005280627 Status Report 5 of potentially reportable deficiency re inadequate circuit separation.

Investigation expanded to address adequacy of GE supplied components and control room panels.

Final report by 801201.

FILE /P:

8005280627, FICHE:

05095 206, 2 pages.

8007020615 Status deficiency report, re: effects of loss of site power on rod position indication and neutron monitoring.

Defi-ciency still under investigation.

Final report will be forwarded on 800723.

FILE /P:

80070220615, FICHE:

05603 147, 2 pages.

8106050351S 10CFR Part 21 reportable condition CR2940 Switches.

Contact blocks are loose on CR2940 tandem block control switches 65

e used in the Power Generation Control Complex panels.

Loose nuts.

FILE /P:

8106050351S, FICHE:

unknown, 2 pages.

81082003085 Reportable condition reactor mounting brackets HPCS diesel generator control panel.

The HPCS reactors were ordered by Nuclear Energy Business Group (NEBG) and furnished by Morrison-Knudsen, Power Systems Division.

After delivery at site, it was discovered tha*. the mounting brackets had failed during shipment.

Supplier subsequently notified GE that the reactor brackets in the panels furnished to the Grand Gulf and Skagit Projects were different from those which were in the Cofrentes panel which was seismic qualification tested.

FILE /P:

8108200308S, FICHE:

unknown, 2 pages.

This is quite similar to what Mr. Milam found in Section 3.5 concerning the Reactor Mode Switches.

81092404765 10CTR Part 21 reportable condition -- possible defec-tive Woodward governor for HPCS diesel generator.

Power Systems (division of Morrison-Knudsen) supplied spara governor for HPCS Woodward diesel generator which was not actually installed.

Governor Co., manufacturer, advised Power Systems of possible defective droop level spring.

Power Systems notified GE.

FILE /P:

81092404765, FICHE:

unknown, 2 pages.

Another Functional testing problem (see Sec. 2.13) and/or an environmental testing problem (see Sec. 5.11).

81121140105 10CFR Part 21, reportable condition loose termina-tions on relays in panel at Grand Gulf site. While reshaping wire bundles in a Main Steam Line Isolation Valves (MSIV) Leakage Control panel, some wires were found to fall out of their termin-ations when a slight force was applied.

Only Potter-Brumfield relays mounted in panel were loose.

FILE /P:

8112140105, FICHE:

unknown, 3 pages.

(See para. 8001040337 above.)

8111240770S Reportable Condition -- Transmitter and trip units for reactor vessel water level scrams.

Transmitters have wide range instead of narrow range.

Several master trip units are also wrong.

Other. plants affected:

Clinton, Perry, and TVA, (Hartsville).

FILE /P:

8111240770S, FICHE:

unknown, 3 pages.

Another functional testing problem (see Sec. 2.13) and/or an environmental testing problem (see Sec. 5.11).

8206010407S Final report, RCIC turbine relay.

Relay requiring 125V DC to operate was installed into a circuit utilizing 24V DC in the Reactor Core Isolation Cooling (RCIC) System.

FILE /P:

8206010407S, FICHE:

unknown, 5 pages.

B.

Inspection Reports from NRC Files on GE Docket No.

66

\\

]

99900403

'I.

Document dated October 21, 1983 referring to inspection conducted August 29-September 2, 1983, at GE's San Jose facility beginning with A.

NOTICE OF NONCONFORMANCE, listed the following nonconformances with NRC requirements.

Design verification of Nuclear Control and A.

Instrumentation Division design documents are being deferred without implementation of controlling procedural requirements.

This is evidenced by the following (River Band project) documents.

1.

Verifications on five design documents (828E536AA, 828E537AA, 184C5467, 851E225AAA, and 828E239AA) were deferred and no evidence existed that the DVSCNs were processed.

2.

No evidence existed that the projects had been notifying external users about the deferred verification status of applicable design data.

A'.

GE responded to this noncompliance in a letter dated November 17, 1983, to the NRC.

Three (3) areas of corrective action are stated by GE.

The status of design documents currently identi-1.

fled in deferred verification will be scheduled as required by the Engineering Operating Procedures

]

(EOPs).

This action is scheduled for completion by December 1, 1983.

Customers have been or will be notified of design 2.

documents currently in deferred verification sta-tus as required by the EOPs.

The required notifi-cation actions are currently scheduled for comple-tion by December 21, 1983.

Priority has been assigned' based on plan fuel load schedules.

l 3.

In addition to the foregoing, QA & RO is conducting.an independent audit of the implementa-tion and effectiveness of the NEBO deferred verification control system.

The results of this audit will be available for review at San Jose.

This action is incomplete.

The NRC has found that not all deferred verifications were logged into EIS, (see para. A above),

L and to add to the problem, the DVSCNs which were used to enter the deferred verifications into EIS did not have document control numbers assigned to them which were referenced on the design documents so that the DVSCN could be traced.

(See Sec. 4.19).

Thus, if the DVSCN were lost, there is nearly no method which may be used to prove the existence of the DVSCN.

One method which might be used to clear up the status of documents is to reverify all safety-related documents.

Those which cannot be verified 67

.-_u__,..__..~._

4 would be listed and compared with the deferred documents recorded This would both reestablish the status of documents and in EIS.

verify their status as recorded in EIS.

The reveriff. cation of drawings would require the complete as-building of all safety-related equipment supplied by GE, both manufactured and pur-chased, installed or in inventory.

For more information on deferred verifications, see section titled Deferred Verification.

GE received and accepted purchased equipment (Rosemount B.

1152 Transmitters) that did not conform to the procure-ment document).

B'.

GE responded in a letter dated November 17, 1983.

As noted on page 8 of the NRC Inspection Report 999004303/

83-03, GE issued an Engineering Change Notice to change the qualification requirements from IEEE-323-1974 to IEEE-323-1971.

Subsequent to the purchase of the Rosemount 1122 transmitters, GE has instituted a Supplier change Request form and procedure by which the supplier can formally submit exceptions to purchase order require-ments.

The form and procedure should prevent recurrence of this type of nonconformance.

GE's resolution, to simply revise the qualification requirements to an earlier version, is not as easy to evaluate as the problem in_(A) above where an entire time frame when the problem existed was omitted from any review.

First one must ask "Is there a legal requirement which would bar this action?"

Upon

- review of 10CFR, it seems to me that 10 CFR 50.55a(h) is an applicable section.

(h)

Protection systems:

For construction permits issued after January 1, 1971, protectica systems shall' meet the requirements set forth in editions or revisions of the Institute of Electrical and Electronics Engineers Standard:

" Criteria for Protection Systems for Nuclear Power Generating Stations,"

(IEEE-279) in effect on the formal docket date of the application for a construction permit.

i Protection systems may meet the requirements set forth in subsequent editions or revisions of IEEE-279 which become

~

effective.

l l

l Upon reading this section, one might ask, "Why does this section apply to the Rosemont transmitters?

This section refers l

to IEEE-279 a'nd the one required for qualification (see para. B')

I is IEEE-323."

Refer back to Section 50.55a, which is titled

" Codes and Standards".

In para. (h) above and the other parts of l

50.55a, the main theme is that the minimum acceptable date for a code or Standard which is used in designing and building a Nuclear Power Generating Station is that Code or Standard which is in effect on the formal docket date of the application for a 68

o b

n t

I construction permit.

The second idea presented is that codes or Standards may meet the requirements set forth in subsequent editions or revisions, but not the past editions or revisions.

In para. B'-above, GE starts with a Standard dated 1974 and changes it to'a Standard dated 1971.

This should not take place if any plant which will use the Rosemont trnsmitters received its construction permit aft er the Standard dated 1974 became effective.

Nor should the earlier Standard be allowed from just common logic.

Standards are continually being reviewed and revised to improve them.

This results in a better Standard --

one which should be safer.

Apparently, when the qualification requirements were developed, the 1974 Standard was in effect.

The 1971 Standard is The 1974 standard was the one used by GE.

obviously easier to meet and therefore not as safe as the 1974 Standard which was not met.

The bottom line is that there has been a reduction in safety by GE's acceptance of the 1971 Standard.

This should not have been allowed by the NRC.

Rather all Rosemont transmitters should be replaced with one which will meet the 1974 qualification requirements.

But let us not over-look the real problen.(see para. B above).

GE accepted equipment which did not meet the procurement requirements.

The fact that GE has lowered the procurement requirements so.that the item accepted now meets the revised procurement requirements does not correct the problem -- a nonconforming piece of equipment was accepted by GE.

At GE or any other company when an' order for an item is placed, the contract usually calls for the items to be delivered to a specific location.

Upon delivery, the item still is not accepted.

Almost all companies have an inspection of the item comparing the ites to a drawing or other form of documentation and, also, reviewing the paper work presented with the item, such as a Bill of Lading.

In the present case of Rosemont trans-mitters where GE is more than likely to use them in safetyrelated systems in nuclear facilities, the documentation is as important as the item.

This is because 10 CFR 50 App. B prescribes very high standards on quality and records control throughout the life of the plant.

Usuallyi this receiving inspection is performed by a quality control inspector.

There are two possibilities here for nonconforming equipment being accepted.

(1)

Either no inspection was made or (2) the inspector who did the inspection GE and didn't do his job -- return the nonconforming equipment.

the NRC have not investigated the two possibilities above.

GE and the NRC have not addressed the real problem.

The problem is still unresolved.

C.

. Control rod drive (CRD) system clamps supplied by GE on all BWR-6 design plants were not classified as essential components (important to safety) ; even though there was no assurance that their failure would not cause a loss of integrity of the reactor coolant pressure boundary.

69

m C'

GE responded in a letter dated November 17, 1983. 'The control Rod Drive line clamps supplied by General Electric are classified non-essential for the following reasons:

(1) -Clamps are provided by GE to support CRD lines during construction and during shipment for those plants with shop-installed internals.

, (2)

General Electric does not have design-responsibility for the CRD hydraulic lines (Ref.

21A8845).

The owner /AE has this responsibility.

(3)

The owner /AE is responsible for classifying the clamps appropriately if he elects to use them in the plant, i.e., code, non-code, essential.

General Electric advised A/ES and customers that, in our opinion, clamps could provide support up to the-limits specified on the interface Control Drawing.

(4)

Any postulated failure of the clamp must be eval-uated by the owner /AE in regard to maintaining the safety function of the CRF lines and the integrity to the reactor coolant pressure bound-

.ary.

GE's reply is another instance where they fail to address the real problem.

The root of this problem is that GE did not indicate that the CRD clamps were shipping clamps and had to be removed on the installation kit drawing, nor did GE communicate in writing that the CRD clamps were nonessential components and could not be used as a permanent structural item in the CRD system piping analysis performed by RCI.

(See page 11 of Inspec-tion Report No. 99900403/83-03 item g. and the last para.)

D.

GE did not communicate needed design information to S&W that the CRD clamps supplied by'GE were essential or nonessential components or whether they could be considered as ASME-qualified items in the analysis of the CRD piping system.

D' GE responded on page 4 of a November 17, 1983 letter.

The fact that the CRD clamps are non-essential and non-Code was defined to the A/E as follows:

(1)

The GE method of identification is that the equipment drawings or interface documents must specifically designate the Code and essential requirements.

Components not specifically

-identified are non-code, and/or non-essential.

(2)

When GE became aware of the S&W interpretation, GE notified all affected customers that the clamps were non-Code and non-essential.

This notification will prevent any future recurrence.

70

GE's response-to this problem is quite similar to their method of handling deferred verifications by noting thr: a document has had its verification deferred on a computar file and not the document which was deferred.

Here GE does not state that their drawings contain a note which specifically states that components not specifically identified are non-code, and/or non-essential.

Rather their statement seems to be an explanation of

~how their drawing should be interpre e.

Per 10 CFR 50 App.

B, it td should not be necessary for a qualified person, engineer cr NRC A document shoull inspector, to require an interpretation by GE.

be cle rly understandable within the_ framework of the docuasnt and other documents referenced on it.

GE's method may allow them in the future to say "We notified them of this fact in letter so and so, on date so and so", but unless they add a note on the drawing and all future drawings stating that the clamps are shipping clamps and should be removed, someone who has not. read the letter sent by GE will again mistakenly assume that the clamps are code and essential.

The DRF index or equivalent was not established and/or E.

maintained for DRF No. A00-ll60 (SAFER 01) and A1002 (GESTR08) ; e.g.

i (1)

A00-ll60, the date entered and author's name wara missing and (2)

A1002, the date entered was missing.

E'.

GE responded on page 4 of a letter dated Novether 17, 1983.

The following actions have been or will be taken to correct this nonconformance and to prevent recurrence.

(1)

All DRF indexes contained in DRFs A00-ll60 and A1002 have been replaace with index form SD-006.

Where appropriate, form SD-006 has been added to sections of the DRFs.

(2)

A letter will go to all Engineering Computer Pro-gram (ECP) responsible engineers within the NEBO.

The letter will remind the responsible engineers of the forms index requirements or EOP 42-10.00 and will recommend that the engineers review their DRTs for compliance approximately one week j

prior to the scheduled Level 1 and Level 2 computer code design reviews.

The letter is scheduled for issue December 1, 1983.

GE's response to this problem appears to be the most However, there was no mention of any measures complete so far.

to ensure that this is covered in any training class so that new It remains to be employees will also receive this knowledge.

t seen if the forms are used and if they work.

71 l

--~n-,-

- - ~, - ~. r

,e w www-v

-,.w,w-w,r-e---wv_em_

_mww, n--.

e-w,-

w-- -,---w-w

J

.An analysis contained in Section 8 or DRF No. A00-1160 F.

was not prepared and documented so that a technically qualified person could review and evaluate its accuracy without recourse to the originator; e.g.,

the

. identification of the purpose, references, date, originator,. reviewer, etc., were missing.

F'..GE responded on page 4 of a letter dated November 17, The following actions have been or will be 1983.

taken to correct this nonconformance and to prevent recurrence.

(1) -The analysis sheets contained in Section 8 or DRF A00-1160 have been reviewed and the purpose, author, references, date, and page numbers added, where necessary, to allow a technically i

qualified person to review and evaluate their accuracy without recourse to the orfginator.

These additions were completed November 4, 1983.

p A letter will go to all ECP responsible engineers (2) within the NEBO responsible for analysis, re-i minding them of the requirements of E0P 42-1.00 and specifying the requirements of purpose, reference, originator, date, and page numbers.

The letter recommends that the responsible-engineer perform an EOP requirements review and check on appropriate DRFs approximately one week prior to the Level 1 and Level 2 computer code design reviews.

This letter is scheduled for issue by December 1, 1983.

p As was stated in E' above, GE has omitted any inclusion of corrective measures to be made in any training class to ensure that new employees are informed of the requirements.

t G.

The functional specification for the computer program SAFER 01 was not controlled in accordance with EOP I

42-6.10; e.g.

(1) there was no identifying number there was no revision number (2) the* identification and signature of the origin-i (3) ator, reviewer, and approver were missing.

G'.

GE responded on page 5 of a letter dated November 17, 1983.

The following actions have been or will be taken to correct this nonconformance and to prevent recurrence.

(1)

The DRF A00-1160 is a closed DRF (has been l

i microfilmed for off-site storage).

However, t

the DRF identification and page numbers have j

been added to each sheet of the functional i

72

~-,e---~--w.,-a_m-,,n.-m.,,a em m m w e, w-m

_w-wwe,

.. au r-w a me cm w w e w ww.

specification.

In addition, the name and signature of the originator, reviewer, and approver have been added to the initial sheet of the functional specification.

(2)

EOP 40-3.00, " Engineering Computer Programs" (ECPs), will be revised by January 6,

1984, to include more specific controls for ECP' specifications.

This sounds very much like the. probable results of Mr.

Milam's corrective action to'the CAR program in Sec. 1.21.

It appears that all documentation for computer programs should be reviewed-for compliance-with the new EOP'40-3.00 requirements y

after first reviewing EOP-40-3.00 for procedural control and completeness.

II.

Document dated January 9, 1984, referring to inspection conducted December 5-9, 1983, at GE's San Jose facility Appendix A, NOTICE OF NONCONFORMANCE, listed the following nonconformances with NRC requirements.

A.

Field Deviation Disposition Request (FDDR) HH1-1467,

{

Revision 2, was issued without initiation of change documentation.

A'.

GE responded to this nonconformance in a letter dated February 1,.1984.

The design change documentation for FDDR HH1-1467, Revision 2, has been initiated as a part of a larger design change package which is currently scheduled for completion by June 8, 1984.

The current EIS data base reflects the field implem-ented design changes authorized by FDDR HH1-1467, Revision 2.

QA&RO is currently conducting an independent audit of Field Change Control.

This audit will provide assurance that a) other FDDRs which authorize design changes are included in the current revision of the drawing or are reflected in the EIS data base, and b) FDDR changes reflected in EIS have been scheduled for incorporation in the affected drawings.

The audit results will be available for review at San Jose by March 30, 1984.

Th.e current EOP 55-3.00, Change Notice A, issued 9/30/83, includes requirements which will prevent recurrence of this type of nonconformance.

This sounds like everything is covered.

But not so.

Referring to Inspection Report No. 99900403/83-04 page 3 and 4 para. E, we find in the first para. that GE filed a 10 CFR Part 21 Report, Errors in Drawings for Local Control Panels.

In this 73

_~ _

report, it is' stated that drawing errors in local instrument panel piping diagrams for the Limerick project resulted in a potential incorrect interface with the reactor pressure vessel instrumentation P&ID.

This discrepancy was detected in the field when the instrumentation piping was being connected to the-local panels.

Nuclear Safety and Licensing Operation (NSLO) who evaluated this problem and reported it also determined that Limerick was the only plant affected.

The NRC made a spot check of panel drawings on other projects and confirmed that Limerick appears to be the only plant affected.

The first problem mentioned was drawing errors.

This was overshadowed by the second problem -- the responsible engineer failed to initiate design change documentation for FDDR HH1-1467.

Why was such a serious drawing error made?

This was not looked into.

But from Mr. Milan's work record, the reason seems obvious.

The drawing was more than likely never verified or at the most only partially verified.

The second problem which GE did address was the responsible engineer failed to initiate design change documentation for FDDR NH1-1467.

This is not the only instance where necessary action did not take place.

For examples in Section 1.4 - drawing was not updated; Sec. 2.20 -

drawing not updated; Sec. 2.49 - no ECN coordinator or ECN log; i

Sec. 2.54

" Mortgaged ECN's"; and Sec. 5.3 - wrong person l

signing-off on spaces indicating FDI, MR, EI, etc. required.

If I

all of these were looked into by someone looking for the cause, they would find the hardest problem to correct within a quality assurance program -- WORKER ATTITUDE.

When the workers' attitude towards quality and doing a good job falls so low that they do not care, serious safety errors will continually turn up.

This attitude at GE is evidenced by Sec. 1.12.

A bad attitude can be caused by management's lack of concern and by poor procedures

. going uncorrected.

B.

FDDR NH1-1467, Revision 2, was not entered into the Engineering Information System (EIS) data base to reflect field implemented design changes as an out-standing change requirement against the affected document.

S'.

(See GE's response A' above)

EIS was not jhst used to indicate which approved design change document (i.e., FDDR, engineering change notice (ECN),

engineering change authorization (ECA) was yet to be incorporated into the affected drawing (s) and/or specification (s).

It was also used to track the status of a document (i.e., deferred or not).

It is possible that the drawing which was in error should have had its status indicated as deferred.

It was not uncommon for other documents which should have been reflected as an unincorporated change requirement to be omitted from EIS.

For example, Mr. Milan made frequent entries 74

-+

ws-re-,e,--ri.---,

.,-arm----ee-eewe-m=~--r

ra-+

E in his work record of this. fact.

See Sec. 2.54 - drawing omitted from EIS; Sec. 2.72 - ECN-not entered into EIS; Sec. 5.12 -

l update to EIS may take months; and Sec. 5.16 - DVSCN destroyed.

C.

Also, noted in the Inspection report on page 5, but not noted as a nonconformance, was the-following statement:

It had been reported by field personnel that the RHR t'B" pump at the La Salle, Unit 1, project was experi-encing excessive vibration.

The GE evaluation deter-mined that the pump problem was not a substantial safety hazard.

The NRC inspector reviewed the PRC file, but the file did not contain sufficient information to complete the review.

The NRC resid-ent inspector at the La Salle, Unit it project was notified of the gung Vibration problem.

This item will be reviewed further during a future inspection.

This statement appears to be related to several paragraphs in Mr. Milan's work record concerning the PRC on the reactor mode

{

switch.

Especially Sec. 2.79, where Mr. Milan was instructed by W. Marklein and C.L. Cooler to give Rodger Waldman a copy of the tamper test report instead of the package of data, letters, etc.,

relating to the mode switch problems which was requested by It is also Thonts Regenie of the Safety and Licensing Operation.

a source of concern that the resident NRC inspector had to be notified by an external party.

III.

Document dated August 28, 1984 referring to inspection conducted June 4-8, 1984, at GE's San Jose facility beginning with A.

NOTICE OF NONCONFORMANCE, listed the following nonconformance with NRC requirements.

A.

Paragraph 3.4.1 of Quality Control Instruction 7.2.17, Revision 12, regarding information to be included in an Audit Report, states in part that "the Lead auditor shall.

. ensure that the report contains the following minimum information:"

i

. a summary of audit results, including an "evaluation regarding the effectiveness of the Euality assurance program elements which were audited."

(Emphasis added.)

Contrary to the above the lead auditor did not include an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited in the Brown Boveri Electric Inc. Qua?ity Assurance Audit Report dated February 3, 1984s A'.

GE responded in a letter dated September 24, 1984 as follows:

75

l In our opinion, the audit report contains all the

" elements required to express the auditor's evaluation of the effectivenessiof the quality assurance program elements which were-audited.

The audit report references the General Electric l..

18 Criteria Checklist which was used.

2.

The audit report includes corrective action

. requests and observations to identify areas of concern within the 18 Criteria audited.

3.

The audit report includes the following positive statement:

" Brown Boveri Electric, Inc., is judged ~an approved supplier of safety-related relays; however, BBE must provide 'commited corrective action to all findings before shipping relays to GE.'

However, to prevent future misunderstanding of our audit reports, the Manger, Quality Assurance -

Engineered Equipment and Installation (QAEE&I) has issued a letter (dated September 7, 1984) to QAEE&I audit personnel reminding them to include in each report a concise evaluation statement regarding the effectiveness of the quality assurance program elements which were audited."

(Emphasis added.)

Despite GE's response as to what was included, there was not including an included a specific " summary of audit results, evaluation statement regarding the effectiveness of the quality assurance program elements wh:ch were audited."

(Emphasis added.)

In spite of GE's reference to the GE 18 Criteria Checklist in the Audit, this does not provide proof that the 18 Criteria were each reviewed as part of the audit.

Without the l

inclusion of a checklist, which has been signed and notations made indicating the review of each criteria, there is no guarantee that each criteria was reviewed.

10 CFR 50 App. B requires the Checklist to be included as audit documentation and not a reference to.it as used by GE.

I B.

General Electric (GE) Engineering Operating Procedure (EOP) 42-10.000, " Design Record Files," Section 4.2.d.4 states, in part, that " Calculations are to identify the subject (structure, system, or component 4

to which the calculation applies), originator, reviewer's name and date when performed and the current date.

Contrary to the above, the Design Record Files (DRF's) that supported the verification calculations for the 76 e

..-w

+.m.,,,-,---,y-,._

-,w--,_e,-r--w,%.

.-,,.,-e---w,---.-,---,w-,,-

y

,,,....,w---..--~w--,.-,rw,-

,-,.--w-

~

SAFER 02 computer code did not' identify the reviewer and date when reviewed.

In addition, the calculations did not always identify the originator and date performed.

These DRF's are identified as A00-1249 (April, 1982),

-A00-1320 (October, 1981), and E00-137 (May, 1981).

Topical reports describing the. verification of SAFER 02~have been submitted to NRC; the Safety Evalua-

. tion Report regarding the use of SAFER 02 in safety-related calculations has recently been issued.

B'.

GE responded in a letter dated September 24, 1984 as follows.

To correct this condition, the referenced design record files will be revised to identify approximate dates, the originators, and the reviewers of the calculations.

This action will be completed by October 15, 1984.

To prevent recurrence of this type of nonconformance, the Manager, Core and Fuel Technology, will issue a letter to responsible methods engineers, reminding them of the specific EOP requirements.

This action will be completed by October 15, 1984.

In addition, a Quality Assurance Newsletter was issued to NEB 0 engineers and managers in August 1984.

This newsletter contains a "DRF Closeout Checklist," which includes reminders l.

about signing and-dating DRF entries.

This nonconformance was the responsibility of the Core and Fuel Technology group, as are some of the nonconformances which However, in reading these nonconformances, one is follow.

reminded of the things which are recorded in Mr. Milan's work record, especially Sec. 1.21, when Hart managed the Radiation If GE stressed the legal Monitors Unit of the CEI department.

requirements of 10CTR50 instead of the EOP requirements, many personnel would listen.

It appears that when the NRC reviews a department of GE and discovers a nonconformance, it is assumed to be only applicable to that department.

This should not be the case, since all the parts share common leadership and organizational practices.

It also appears that the NRC audits the various departments of GE on an alternating basis which may mean that years may pass before each department ;.s' reviewed again.

If these hypotheses are correct, then, it is easy to see why the many problems recorded by Mr. Milan were not discovered for nearly ten years, example Deferred Verifications started before 1976, nonconformance entered 1983 (after Mr. Milan submitted his report to the NRC),

complete resolution still open.

C.

EOP 42-1.00, " Introduction-Technology and Design Control," Section 3.3.2 states that " mathematical analyses are required to be prepared and documented 77

\\

o

so that a technically qualified person can review and evaluate their accuracy without recourse to the

~~

originator."

(Emphasis added.)

contrary to the above, no documentation (i.e., Design

' Record File) was available for GE Topical Reports that describe the analytical basis for two computer codes that are used in safety-related conditions.

The Topical Reports, NEDE-23785-1-P Vol. II, describing the SAFER 02 code, and NEDE-14984, describing improvements to the ODYN code, have been submitted to NRC.

C'.

GE responded in a letter dated September 24, 1984 as follows.

EOP 40-3.00, Paragraph 4.3.5.1, does not require that a copy of the User's Manual be placed in the Design Record File.

Reference to separately controlled documents is acceptable.

EOP 40-3.00, Paragraph 4.3.B.1, requires generation and maintenance of the DRF in accordance with EOP 42-10.00, " Design Record Files."

EOP 42-10.00 states that " Documents with retrievable identities, which are i

individually controlled, should be referenced."

DRF I

A00-1716 references the User's Manual as a retrievable document identity which is individually controlled.

The DRF reference to the User's Manual conforms to the i

EOP requirements.

If GE's reply is correct, then the preparation of mathemat-l ical analyses by GE fails to satisfy the requirement that they be i

" prepared and documented so that a technically qualified person can review and evaluate their anccuracy without recourse to the originator", since the NRC will have to rely on GE's explanation.

then the noncon-On the other hand if GE's reply is not correct, formance would still be valid.

So, in either case, GE is guilty of a nonconformance.

D.

GE Topical Report NEDE-11209, Section 3.12, " Design change control," states in part, that "Followthg issuance of engineering documents, a design change control procedure is implemented with controls commensurate with those applied to the original design

. The and result after all changes have been incorporated, is reflected in accurate drawings, speci-fications and other documents which fully describe the final design for equipment-supplied.

The control procedure requires that every change must be documen-ted, design verified, approved by the responsible engineer, and reviewed by the appropriate interfacing components.

The responsible engineer is charged 78

~

k f

with the responsibility for defining all other design documents affecting the change and for resolving and coordinating changes with other engineers whose documents are affected... "

contrary to the above, error reports affecting the i

ODYN computer code are not formally distributed to and coordinated with all engineers in interfacing i

components.

(ODYN is used for safety-related analyses.)

For example, the ODYN04 code was used to complete a safety-related analysis prior to the discovery of a potentially significant code errors however, the responsible engineer was not notified of the error such that the proper evaluation of the error could be performed.

D'.

GE responded in a letter dated September 24, 1984 as follows.

i The Topical Reports NEDE-23785-1-P and WEDE-24984.

describe computer codes which have been independently verified and approved for use by NERO in accordance with EOF 40.-3.00.

These topical reports are supported by the Design Record Files for the SAFER and ODYN computer codes.

The equations used in these topical reports are commonly used, and any unique or complex derivations are incorporated therein.

The accuracy of mathematical analyses was checked by code comparisons to data and by user checkout prior to NEB 0 verification and approval of the SAFER and ODYN computer codes.

A separate design record file for i

these topical reports is not required.

The topical reports are not desian documents; therefore, the requirements of E0P 42-1.00, Section 3.3.2, do not l

apply.

(Emphasis added.)

I l

It seems that the NRC has misunderstood GE's use of Topical GE states above that " topical reports are not design f

Reports.

documents."

What does this mean?

It means that they do not have to conoly with the reauirements of 10 CFR 50 App. 8 Quality They are not checked for technical Assurance reauirements.

accuracy or revised to reflect the constantly changing design of the plant.

See NEDE and NEDO on page 2 of Abbreviations, l

l l

Acronyms & Definitions and the note at the beginning of i

Abbreviations, Acronyms & Definitions.

i In many of the NRC inspection reports, they frequently compare GE's design and QA programs to Topical Reports, as well i

as, in at least once instance a plant FSAR was compared to a See Sec. 3.10 and Sec. 5.4.

Not only is the NRC Topical Report.

under a misinterpretation of these documents use, but so have l

many other organizations, such as Catec and MP&L, who owns Grand Gulf.

For how many years and how many times has some aspect of r

79 l.

GE's work been verified incorrectly by the NRC or by a subcon-tractor of GE to a topical report or another document which does not cowply with the quality assurance requirements cf 10 CFR 50 App. 87 E.

EOP 40-3.00, " Engineering Computer Programs,"

Section 4.3.B.1 assigned the " Responsible Engineer" the task of

" Generating and raintaining the EOP Design Record File.

.In accordance with the EOP 42-10.00, including, except where exempted by the Software Management Plan, but not limited to.

. j) User's Manual."

Contrary to the above, the Design Record File for SAFER 02 (DRF A00-1716) did not have a completed user's manual.

E'.

GE responded in a letter dated September 24, 1984 as follows.

The error report affecting the ODYN04 computer code was distributed to user groups as evidenced by a letter from the responsible engineer dated April 9,

1982, subject, " Action Plan for Error in ODYN04C."

During the NRC Inspection, a responsible engineer in one user group stated that he had not been notified of this error report.

Our investigation has revealed that this engineer actually used the ODYN02 version and his use was not affected by the CDYN04 error reports.

However, we recognize the importance of communicating error reports to potentially affected users of computer codes.

To emphasize the need for effective communica-tion of error reports, the Manager, Core and Fuel Technology, will issue a letter on this subject to all affected NEB 0 managers by September 30, 1984.

In addition, the Manager of Core and Fuel Technology and the Manager of Quality Assurance and Reliability 4

Operation will conduct a meeting by November 9,

1984, to determine whether additional assurance actions are necessary.

I l

GE's response raises a concern over this question:

Does GE maintain a log of what computer program version is used on all work which may better be referred to if an error is detected in that version, so that they can evaluate or rerun any analyses l

Mr. Milan was not aware of any such log.

Is it a affected?

routine practice to rerun past computer runs when a new version j

is issued to correct errors?

The verification tests which were run on in-house programs I

j are also subject to question.

The Electric Power Research Institute (EPRI) sponsored a report titled " Software Development i

l 80

1 2

9 and Maintenance Guidelines, Vol.

1," also known as EPRI EL-3089 i

V.31. 1, issued May 1983.

On page 4-64, under Testing Reviews, it is recommended 3.

Capability of the Plan to test all capabilities of the code' including full scale testing.

~

There are many programs which are used in the design, fabrication, etc. of safety-related nuclear components which do not comply with the EPRI recommendations.

The program code has never had all capabilities tested.

This means all logical paths and code lines used by a controlled test problem.

An example of this at GE can be seen in Sec. 1.21 when Mr.

Milan discovered that the CAR programs would not run when only one CAR was used.

1 i

IV.

Document dated September 18, 1984 referring to inspection conducted July 24-26, 1984, at GE's San Jose facility i

beginning with page 3 iten E.2 Automatic Depressurization System (ADS) Digital Sianal Conditioner Card Fuse Failures.

Illinois Power Company notified the Regional Administrator of Region III USNRC of a potential defect or noncompliance (10CFR i

Part 21) involving the failure of the automatic depressurization system in Clinton Power Station, Unit 1, due to blown fuses.

The basic components involved were digital signal ~ conditioner printed i

circuit cards manufactured by GE and conditionally shipped to Clinton.

Because the units were conditionally shipped for initial operation testing and had not been released for use, this All of the malfunction was not reportable under 10CFR Part 21.

units were returned to GE and reworked to prevent fututre malfunctions.

Investigation revealed the cause of the fuse failures to be attributable to GE's assianment of pins in the cord ed_ge connector.

This ablem was unique to this shTuraent so there were no generic aspects involved.

Was thIs a unique occurrence?

(See Sec. 1.8.)

It is true that in Sec. 1.8 Mr.

Milan discovered the duplicate connector number before the unit was shipped, but his discovery does not mean that other duplicate connector number assignments did not occur.

There is no guarantee that multiple assignments did not occur, since no training or corrective coordination occurred.

i 81 n

gy 7

.c w:

h("

s i

_ c.-

E s

<?

.1,.

.)

' ENCL SURE 4.

A; DOCUMENTS PREPARED'BY NRC B. -DOCUMENTS OBTAINED.DURING INSPECTION C.

CORRESPONDENCE'CONCERNING MR.'MILAM'S ALLEGATIONS I

F j

D-r i

4h" s

d

?

t

. q. -- _

7 A.

DOCUMEllTS PREPARED BY NRC i

I

F'

~

_)

)

E

)l C

s s

r.

I e

h s

p l

A

)

p e

I c

d S

f' p

(3 a

N I

f r

b 4

n r

3 F

o F

. )5 1

T6 c

('

r (9

M s

G 9 l

6

~

T T

e M 4 S

A

. f T

n T

t t

i S

A R

e 4

A F

T e g

E D

E l

B t

T e

3 H e i

A L

o 5

R C

U f

3 G e s u H c t

t s

i L_

wt P

r m

E 4

D Q i

)ea t

i 8 (

4 S

fr G w

u A

s s

s.

F s K G S

U E L t

s fr C F

t 9 F P

N U

o D

[

S w e s A

c C

e W-t w

/

L K

T D

W o C ( o T

u w o P g

n S r F

d E M f e v t

T T s K r d E K o

t M e l t s e s P 1

W T

u.

L i

T s

J G W I

(r f

u M

u b o

A t.

l E

E-D E e 0 n

L c N A T-F T W

I u

o t

K Q A

f t.

T l

t D

M r

E A d D

E L e

E o A u

0 g E w

L E R N

n M c d

O M

d V

m 4 l

1 t

9 o M o

/

P s

o o O

~

l 1

a i

h b(

N T O E T

F D o c T P e T o o F

i F

t t

U c

T I

C t

e T C E T E c

M O

E c-E S r D T

s 0

P 2

L s

R e

R. e A

io RJ D

d s

P C e e (K

A e

C.

T r e e

v u K e e

u n T U 5

X K e K o

=t S

i E

R p

R S a P

C M E

E L sp a T Q 5 u

g D

C r

b a

P t

i u o X C E e p

o E E E

O Ep O E e P

F E A W E A R R A w L 9

G

/

W GA A

Q R A

R W

\\

S t

t 1

l l

T A

l l

1 l

\\

?' 7 8 g

$ E R 1

g D

8 l

t l

)h r

F e F

F E

7 1 1 l2 a 6

- n 1 M

V 7-s

]'-

?-

l 1

E

(

t t

I l-D l2 2

1 1

u R

1 1

l u

2 2

1 C_

\\

1

\\

L l

l 1

l O

D 0

0

.z T

8 t

1 7

o r

J E

3 2

g s

M 2

5 7

S i

T O.

c 0

T o

t 1

D 1

2 e

h a

a, t

R.

o o

R R

po c.

O m A O

t e

P. o M

o T I

c ym E

~

E -

T b -

M f

tc T

E E e

M M

G l

Ps M

n i 9 o I

E o.

1 3 % 6 d(o 7 3

4 6 b

] 3 9 0 2

I l

d t

r b G 7 ~7 7

- w 7

5 5

5 E 6 5 5 6 6 G 6 (o 6

,11:

jl l

l l

l

!lll!i !. \\lI l!I!

i

Phan%

DOC.U MEMTS EXAFilhlED gg 7g ruseectoe :

I. TEM TyP OF D oCO M EMT ^) O.

R EV -

DATE DOCUME. aft TntC[.SogJccr no.

tuoc.

WORK 12 Ecog.D wegg. gig 3 13 LETTEY2 To 8.Kostos41 (-l prrs )

'74 (fTTER L, SAN To $ :'NAMFotD FSAR 12.- 3 1-8 l

~7 E

17. 8i LETTEe To A Kastcw (3 PGS)

~k FISCAL C4LEWDAR 19 R2-7~/

\\A/ORK REcoR.0 w;K SloJ-. ( 1 P(r5 )

~7F AP9LLE9 TIME LIST 8153

'] $

g )_

QtitcK LETTER RE: Q49 MApuAt go.

RO 1- ?- &2-LETTEY.To SAMToS 2l MEMD l 8 2-LETTE(2.TD M. A NCi Aux (6 PGS )__

~

32-LETTER WORK 9EcotD

&2@

23 l 91-LETTEYL TRANSsiTYirMr foucM 30.6 84 Pbt.tc4 i

TO Aw etEuvr Exptcyggi@rssi APPLIED TIME LLST w t. 9 2 o.2--

_E it g.tos 86

\\Al0RC REcotD w Y-Ecko4 Ts~1 98 POLicu ueo 611 (Rev it /21) l 17-8.L NEBo secrisTQAriod FodM 1-I s-82--

FMPuNEE tutt6 tim klo. 2- ( 6 94ces)

F I-2,l-R2-LETTOLTo L,3AMTOS @_6, MILAm 9O

PALTT C)OC.U MEM IS EXAMlWED mc4e 8er InseecTon :

peg tyP. OF DoCO M E^iT ^> O.

REN DATE DucvME.UT TITLC [ sur33en7 NO.

(D O C,

l-t R-EL Pc 1 ep oE6Astunord teTw(1.(3ed) 9i l-If-R1-Gaox con)

Q J.-

LETTER OM ' GhM6 E REQUESTS (2_[ PGS)

D 94 2 FA(4 NctrE-Tufo cw 21%% A A

(_Z.3 firs)_

cLivTo,a cooesrious w co4cicqTios c?S (2-96-S 1 &L INDiviDv4<- L4 tort 9g.o RLE 1-11-91_

Appue9 nu r u sT we 9.to4 i

ct'l lNotts 4EcorvD wK fr A o s 97 I-2.0-82.

CLAtificArtorJ OF EX.EW9T % EF o(LH W E 99 h PPtt M A L 3no G, t9&a.

l l 00 RC-19 8 6-M-g1 QA PRocGDORES SHEET

__ L.QL bLICd l 92-66 GRfATA AMD ADDENDA S4EET.__

l g J.

(Vopgsp PegTS USTOMN6e$ (6 Pa) 1 to2-10 3 l-Y7-8%

LETTER TD S He@eV FRoM S MJLAM (3PcJ)^

104 Ro w 2.o..u. 0-7 l 8.2 A99 tie 0 TMEusr wK E205 2 - J - D-.

LETT6k. To H,TR(94 FRoM S. MILM1 10'3

l 1

)s '

)s I

o s.

A q' k( )5, W

l Me i

rr P

)

2 l

s E. p r

o c

(

f p

j S

L e

(2-a M (3' 0 (4' W

i

%a A

c 6

I 3

P R

A 7

j Tc_

E F

o )

S 4

n o

T r

)

n F Y

i' o

E 4d "

(r e

J A

o 3

6 M

e e

i Pq B

M 5

t (

N

)

7

(

e o

o 1

v. u U

9 M g

E W

-0 P,

i; R

E t

c

/

r S

L s p

M F

L u p L

[

A 2

S s

e C

T g

g. 8 t

E p

6 E

S S

O f F

e i

4 M-R V

s 4

L r B R H T o

v L

T w

0 I

t c (

X F

6 E

O "

u O

i T

P 9

c A

T R c B T

o M

t S C r W A

T p

t 9

s 9N g

~t s

T T

T N

d e

i M

u a E A s

L o

L S S 4

6 i

u t

M s

L o

D M

A D S c r

c o

F u

2 o

0 e & E E

6 2

E e A c

E E

Y b

1 c

U a

s o (0 n F N

R a

M T

T 9

L R

R 6

0 u

T D D

0 Q S t

c u

r R

v i

i I

C G

u o n 9

G s E o

E "

e E.

E g

T N' i

c R T M

O t

W c g

C N

o T

T o

w D

9 9f D

c C

F R

b 4 9 r

o e

c R

s T

i A

S t

I A

o u

E e

W 5 E 5

M P

p w E D

a X

J o

u i

T i

E F

F t

R 1-t t

p e

d o

A T

s K

t

(

O A c

o f

4 E

o C

A E X K

w p

2 A

W G L

F P

L C

A G G E 1

i L

1 E

S m

)

L L L L L L L T

D L R

P r

9 9

2 L f

D 2

P f

9 9

N 9

9 E

I fr 1 o

o 0 0

o l

M N

o

- r 1

1 2

[

1 t

t 1

t i

I E

R 2'

1 I

2 t

b 2

1 O U

1 1

C_

4 O

D O

4 D

'c M

L P

1 J

3 L

2 i

E

^

T l

0 4

T l

M 9

t 9

IE 1

1 1

W 1

M E

C 9

.o O

N 0

2 o

A M

10 D

w 1

E f

['

C A

A R

W w

P P

.R i

0 t

9 E t W o

f T I

- ' k' f t l

r y

c 7

E e o o a

L L P f as l[

M

'i l 9 0 n

2' 3 4 5 h l

2 } )1 E

1-f 9 0 I

i 0 o (0 1

l 1

1 l

1 1

l l

i l

1 I

1 1

1 l

I

[

(

fft

pg DOC _ U MEMTs ExAMINIED mae lo,e II INeectoe :

11EM 7yP.OF DoCO M EAIT o O.

REV-D(tTE DOCUMEMT TnLC[.sur53tT._,T NO.

ED O C,

2. 4 1 - ? L AP9uGD TlME UST wK hD 7

~

113

\\%

WORK REcofLD

&)08

~

2.-W-PL

c5 FcD UPDATE 11 6 2.- l4-71, Recs FCD t%

t-ti-8L Se_p sumetuMce op GA Worices trl leg 2-l 1 - 82_

o4 tJoric65 08 2-\\q-n-AP9uEn TumE LLST kiv 9. LOT DA woty REcobo 7<109

\\%

1- % - & 2-REVIEW OF 9&ofbED f2ev, op Eof 6f-S.o 131 Z &1.

AfpuED TIME tasr wK. Elo(Qffs.[,

ISL

/

)

wodK. RecoED WK ELIO

\\33 3-I- R2-LeTrer_7t> R ecreTo BeM s.MiteM IM

\\

[3 Pir3)__.

3-l-fL UET1E12.To Kosw FRou s. Mil 4m (Ip/r )

s OS

~

3-4 RL.

(t 95)_.

1%

APA,iED TtHF uar fr240 l?f/

WORK REco60 WK &2.II 19; 7 3-8-&L RET RiE\\/AStuTi OF VERIEicariotJ l

13 9 OEcotDS

( L 045

i I

8, i

2 N

R, s$ej t_

m h =1 4

5 5

fi e

as 2

a s

a e

a o

a 6

8 d e r r d j x 3 O g

^

? b a

0 3

2 $ 3 2 a 2 M d a

g s

g 4 g u o

u m

s <

e a S h h O

S E 3 gC a 4 2 g

m n

m 8 +e N

5 Sa r a

% Q w o 4

tu q, Q

+

b)

W

=

d 3

1 0 I

J s

$ g h g

{ g $

g 6 0

2 5

g

%.d8 8 8 8 8 $ d 6

a 9 *3 w o o

4 a

1 2

2

'5 h$ $ $ h $ $

$ $ k N E S i

au s

*a a

n a

s d

o a

2 e

g h t f s l

L U L A n t

E t

i 3

a A A

e r A

A A a

r m O

D;,

o

.. '?

2 s

E ?

E 9 L i

t i

i i

i

, 6 v l

I p,

v t u a

g g cl y y tJ f

%S l

[

j i

[

l I

l i

i 1

l-

! -l 2

p3 k s k k h__M E t b E N

PAer3 Doc.o MEwTs EXAMINED mae _L e i-

& kTTi$

Inspect ce.

re.m

,y e. o r poconeer,oo.

eco -

oemE occune uT rnec / suwecr 90.

DOC, Wou. decoco ccuse. sneeT t

19frL GE PtfcAL caese Ad.

I 1

D 34I-RL REGUe3T f=og. WEW deVLTioW 'oF PWA C2_ pa) 4 +gt PAgxias-RansiT (z.Pc-5) 4 C

Appuet) Time usr ww. e2 4 R.C-OS5-

~6-M-PL GE EMATA 4 ADDENDA SHEET (LPG-3) f:>

4 -C-RL LeTwrt To S. mil 6M Nom T. BEA LL.

'7 6-r4L temrtno esetowees (z.96-s) fr 44-9L sm o to (Ar pecs s4e sitam 9

^

26 0-f> "

(O

%-9L LUrtgrLTD N,CuRflE F4oM S. 4IcAM (t

~ i 2_

e, j$tgie.s 4_w et.

N MDDLESoM

~^

6-M1-

_ _ l_ _ _. -

l c-9-Et K.60sssa g.

qa-91 oc_ $ ro Fusiocr. Poucy Is k-l U-91 LETTL'rt IPA: 'UMAuTHog.ited IkTSiwATuad

)h c w ees (zp6-s) 4-1 ML XOloK Coq oF-Aboud l}

W m

=

W W

1 S

L T

d L

[3g r

t o

M A

> )

L

)

e s T

o 1

c M

r P

g T

A d '

n +

A F

D e

A C

9

-3 L

4 u c T )

m I

c A

F t

N E

5 o

H d

o P R

d I

e s

)

r 5

R 1

E i

4 G

r

/

$ (

A 5

1 V

T M

A c.

C D (1

)S 6

P J

e F

t (r

t n

M t ]

o k E fr 5 7

D t

D

% W r

e o

P Y

g M (

f S

g t T T l A

6 P

T L

v T a

~

D u

I u

a J

b A

4 S

L E

e H

U t

6 &

M E

E 6 f

J m

b t

g Q

A S

o L

o G

u T

L c

t F

a E d

I c

M o

1 1

D V D T R

I t

M M P O

M c

D o

T A

o p c

E L

t a-d e T (J

P A

L t

g T

C R

o 2

E e S % M X

E r

T M u 3

T R r

T E

T E G

(

E T

2 E

E E

S 9

e E

I L

E l u E N

t L

I E

5 m

L 7-r 2

2 L

L 3

T p

N 9

E g

o 7

R 8

9 E

1-n 1 3

lI 9

8 u

M eu 1

2 2

2 4-1 4 4 4 3

S e

U 8

C OD o

e T

e g

n r

i

~

o m

c-7 o

D 2

1 FoC e

O c

aD

~

r y

e 7

m s

m n

I e_ O

)

3 4

5 2

3 o t

t J

t rN

.~

L 2

J 2

6 I

l i

jIf lffl fl l

Ij

~

$ S )s L~

L T

u E r

E E

T c

t A c p

A A

4 e

d S T (2 b

b 5

T l

s r

e T c o

S p

p

(

T i_

W A d[

o o

re R

1 E

e e

z o

1 M t a

m e

P h

Io e

J-o g

i l

f s

0 N 1

u g

2 C

J c

1 g

r T

r.

M l

8 r 9 T m l

u o

e 2

v J

O s.

E y s D

o a o

1

)

r R' )5 t

t E

e L 4

A

/

M R K

L m

x.

T r

M w 4 f

A S a V A a y (r S E)

I Ct W A A

e D

T W R T

(

i t

1 p

V s s

2 i

n o

C s S

G o e o v

u V 3 E N

P v

A E s r

T W n

l t

t 4 p P

K F

6 A

E o

r R. o

( W s

o i

g c

M 3 e W o

1 T

K m L & o e

J i

T k n

S I

F J

T D C

t R

c c

A A

H W g

o I

e E

R c

D a

c o T I

h R

o f c S D T

E V

Y E

i a

M E

i D

o T N r o

f 4

p u

V E

c i

t M E v c v d

1 c

c

i t

i R

E T

J a

D M

o D

s E T T

t G

2 e

i T

v A

i i

r R

t s T R n

l D

E V

T p

u L

M i

t c v c

A f

F R

2

. E a

9 E c W-A c u o N K u

E x

E 0

g R

K L e

t D

1 l

i M Q R R

4 R

C t t E 0

D b

e F

(o 4

o o

9 O E e

o g

V o

E 2

E E

W G W

L G A L

W w

c

(

l

\\

D s

E H-1 T

F 0

l I

l 1

-8

& T 2

D w

8 ff e

6

- l-4 4

m V

- 4 4

1 1

I 2

E r

g-

-9 9

9 0

o u

R

(

1 l

coD O

)

t f

4 7

o l

b

(

e 0

M S

n 9

u IT c

T o

K r

D 6

b I

3 bE 2

W 1

k FOt 4

c P. o L

c y

o t

p i

i T

y k

t r

c o

e P

PS N

M I

W0 1 3 4 6 6 7

0 on 9

8 9 1

_3 4 5 (

1 1

l i

1 (

(

1 1

I Il1ll j

l

ni i

-l t

g m

k 3

+

m e s m a 6 6 a

V, E

.a_

C H dI l-9 c.

o d

d 6 W L J

y. J v-o d 1

i=k w

}-

n a

o n

g S

$ j $ $

I g % d N

a o

g a

u 3 b o

'd

+

b d b D M d 8 2 u

y w

4 v

v o c

+~ q 5

g S

O

.O 3 j

P g,

j s

e 0 9 m w

u.

r p

3 g g

2 t

o g f s a t 8

t o i H E j s e fd

?

w e g

o*

r_ g e.t i

i r

v s

u 2

2 s

a m

e e l F 6 o o 8 I

o d

6 2 1

r 8

w 2

o 2

2 4

4N

$ 6 3 N k 3 $ U E d

5 M d 4 M I r t yd 5 5 $ $ j $ @)3 m 2 ! $ $$ $3 W

E a

a a

a y

4

? d o

~

m 2

f l

T b l

l D

o O d t h k

m h

V O

O o

2 lS c

l I

(

}

l l

\\

k

{

I I

a g

g j

P I

t t

i i

t i

i t

iji i

i i

t i

r i

o - i n, e + tn a g

A c e u a r % e m

w o ac e-p2 a c( y g 4 4 4,4 g p fic g p p p I

~

Pept.rgE Docu MEu T5 EXAMIhlED pgaeLe _t

(

I.NsPecT OR :

3 tem m j P. O F DOCUMENT M o.

ROJ.

DATE DOCUME.MT T nLC [,su rsgg7; _7, NO

POC,

'b'7

-i-1 14-FL DVSod (2f6-5) i i

38 3-l% 81.

Gw (r. DEFE RieD VeRificarl'ofv(FP(rsY Wo(llL MCofLO 8213 i-r SA 2

~l-I- 8 3 NitC MEMO 40 4[

1-l-93 (2 pes )

~

1 -Il-D 41 10 4 S-83 4udf op Degeneobw 43 ULWLtF \\chTuoH (30s-5) 6-25 R3 DEFE7/AeD UERIsc4TtdrJ (3p(-3J 4L 4T W R-L%-98 DETERWD DESI(rM VL% FICATsota OF Ex.TG7aJAL TEAfdSM PTTALS (MS) di fr3 (3A MeS>sterreR ll-7-fr3 S. H IL AM MOTES

(

L$

P(r5 )~

4']

11-7-93 LETTER _To S. MitAM FRodi ED Fn26SToqE 48 _ _-

l N

(2.-lc-93 S.wAm uorres (4 c4cesJ 1 C40ms) 11-3 -2 3 0A AfExteT1ER C8 daces')'

~

60 I-4-94 S. HIGem 5 raoTES (Fr Paces )

5I I 8 4 LEML4L Feou S'-M1b AM 'To G fEfeSmrJE_

S2 1 Fr4 S Mices uoMS (1 LF6-Q.

ta

e

)s_ [s

=

m w

4 e

c 6A a

L P

A 6 i

a (1

'l1' y

y 5

l h

a d

S S,(

Tm e

S u

w A

s c

M

. P

[

o iT 4

r E

L T f

t A

4 L

i T

c s

t T

L R

i 6 F s

A i

T 9

E A

a D

~

D A.

P E

s J

J E

E V

T W

E N

M 1 L D

U I

C E E A

M O

A R

r C

l D

A S

R c

x 0 u E R 2

D x

l c

M9 F

(

E R

e 9 A e R l

V D

I

(

s E

T T

A 3

D 4

w g

e M

V N

E 7

R u

7 c

3 oD O

)^

I D

M UC O

D 0

R r

O e

b T

Y C

l E

d e

n m

e 2

w PS m

M o

N I

4 S

G 18 g

1 5

S G 55 e

e,

Doc _ u MEwTs ExAMItJED mag b.2 usbdrot:

12.%Tt,ssk i

Fos's 4 Ecw'S CHANGE D AFTER. '

1 i

I' GT69ATu AE

-N idM TyP. OF DoCdMEMT C O.

'RdV-DATE DOCU M E.M'T T GLC [.su r53etT ho.

I

' Poc.

I i

to 4-81 LETTr-(L1D ALL PDE s:rAFF AND 4

l l

I U9iT M GR1 Ft.oM W. EAARENriME -

I Cous2 smEFT S-R80 GE C4LewbAR.

Dr i,

ii (gg EtJrr(peazio6-cWoe t ernce (ecs )

J

~

NT-I820A La Pax CecioC ( 4f65)

Si iETCM NT- (8XD-Q A N 9 E~t ( 4 905) 6i i"i N THitaos PiuoT etocx. (s ecs) 431-174 9 U!

UTruT9 Sox (n P6s) 8I i"

kiig3J9 (9RJ-FtscA L 04L69 DA A-9 MI9C i

to, i MISC l H.

( sp LETet1b %v POE 4 Og4Pn06 peg &

i P :

fhM

w. u. 6AageNTise (z. P&s.)fl I

i I

6 MILAMS N D TL5S otJ ECA>'S,67NS @s EMGlWOEgnJer hview HmorMN

Ii i

I F

' E Rft1 AM L - 7A47 l

i Cesma aeanc.sssrem 1'

(3965)_

(b l

! EtM 4MLt1A M drCru - REMoni SMTInwM VB ASSV.(IRrf)~

u

, eco

'95-12 no 4-iMo cMues To eca 's- (s pes)

)

5 i.

i

6 ECW NT-\\WBF REMars s@ rom Pus'(SPGs)

DOC _ U MEhl7s ExAMIhlED Pace bor b i

1 95 CT OR.'

htem 7yP.or Docone"T o o.

edu.

90.

poc.

DocuMExT Tate /sur$3ccr ognE 0;

I O 81 Do cum ENT CwTKoL flEGOL' S T i$!

'ECW N T L114%

'T'U bid 0

(&OG5)

ALUM 8tJUM TFE

( 6 P&S )

?,:

' ECrJ 43L n 44-)

FNCLosoRE V6 %

( 6 PGS )

3oi i EctJ pj'_ ll gjkl 2' ali ECH id7 !!8i35 NSS SuuToH'-

C.8PGs)

I PLATE, TEM 9ow Mo9,Tott. C 6 PGs)

'1Li FoJ N S ; Ifs 1 %

PILTd,. DEMirJ CodrAct ( 6 PCr8 )

2 'b

ECtJ pT,I%L44 6'NclosuGE VS%DP

( 4 PGS')

24 ECrJ RT-l1245 A SS Y,

( [o Ptr5 )

26!

' ECt4 iNd-- I & 249 Nss S4uTor-f

( 6 Pres )

24

. td ps-It9 M6 i

I i

t i

t DOCU MEMTS EXAPilhlED maq l,._3

Issh. 5 toe: ;12 h6TTIS sR.

PDR SuDTECF %A4 CH'MCr I,,

i k'o? ; /[cc{

,ep.05E D "'" E^' r o.

occu me.uT mt.c /.5uwsecr si F66 '84 SuosEcr 8estcen>cr 14 Tne R16cic DocoMENT Room (Por2 )

~

I StStioGrtAPAicAL ret 4,tet/A L-i S%m (6g.s)

(E pg)

PDk CowT2cuSD TITLE SEARCH IM G-9 I

( cts ) vocAsut.4(6/

(191 P6-9 )

OSt p_C. 4 t'll 3 -If-86 Docog@J f Do QLicMTro[fEGd6STS 3l J

l I

i i

i 4~766D1 bk.T 46D 16, 3 2.2_,

i a

l

'D - IS-K M 'lo"134-Der 4 322,.35.1, 4/ C. ojo 4

i-l l

l l

2 1c,~7. 2 1 o l

"l l

I' 2-ll-76.

~4739 $D Dict # # A

'f b,

i3 l

i" 3 85~

M lot)O Dr.-T A 372., of o, IST,21o.

i

~7 i i

3-8-86 4 7 33bs Der 4 SD h23. 4403n.h>6~

b 4

D-003, Mi,2.7/. WD l

3-13-Rf 4 ~70633 Dr.-T i

6 i

9'

,t LLW of RsncroR. PLAMT S

[ 7 pGs)

I i

Oi

!4 lH S-t -80 DESIGrJ VET 2.lFicATioN STMTS ( $PGSI i

H i

Ts-(c1-80 FLooe_ ecs I s, C7PM) fil N

i' l

GRAAJ D 6 toc # 1

( 4 006)

F 2.-g?

%Posep sinn Actioas to inatove 3!

Nmc i

l l

ApfD MA JO TM N DIESEL GEN Ert47DF-.

Ort _1 ABiterY.

(~2.4 PG d

--n-a n

v a

=

u =p R c ei g a =

4 4

m m

k g e

c x g

o, y

g' 8 J

m a,

n E r t d J o!

E N

,s.a a 2 s

f p o

8

$ 8 g s 6 5 sa a e g $ 2 %g n

s c.

v s

us p

y%

5 h

N w

z q

f t g g r4 e s a

s c

=

v

=

2 0o < 8 3 9 m s 4

V g h y a v r r % % *g } Eg2 O g 2

gd M g t p s 8 If k

$ 5 h 5

E

'[

2 n y k s %g b s d

y 3 "I3 b e a g z

t a-4 3 3 M 4

f 1

d M 0

t s y i 5

$wp$ t~ in 3 -5 w

g a c

s a s H & J\\ h 3 x %

.S it.

s

! $ 3ss a

% M h

&, d 9%h ?2 h

1 s

s g s

i w

~

p 9 h k 7 1

h 1 7-N d 8 T N g)

E L

d 4 4 N 2 A i ooA &

4 m

l 3

o 5

9.

M D

o h

2 e g "a

l-5 A b $

3

.f }A g o q o Qg $ f f,G 3

3

+

j a t i i

me s gg e

._. g 4 9 K -.. m 5 g g g g %,co e W, c D

M a-p y

W 4:

Wr w W &

W

$U Y b b b Y

.b Y b b b Y h $ $

b Y b b

_e_

9 s

g g _ g g my.g y_,

.--. p

l l

/r

=

N p[ge e

=.

i.

s 3

f )

u ep e a s

h m.

c P

i e

b (4 W

ice g

J S.)s a

S m

u g

u 6

e e

s.

b E R 6

1 T

M

[

c r

C 4 (3

g w

c e

L R

n s.e e.

u m

ue e.

n s

nw e.

M C T

Fo A

T u

t G

t 9

D JA E

E-D ETo N

M N

U A

/

I C

R a

u.

4 e

M O

G L

r D

A T

W X

L L

4 E

P 9

E K

M C e

S E

2 T

)

l h

3 f 8 D

f i

E F

9 1

M VE l

f u

R b 9 S

.c 1

oD O

8 7

)

^

o 1

2 9

T 0

1 1

o 9

1 E

9 4

M 7

2 O

4

~5 8 C

7 5

o 4

0 a 8

D b

4 o 4 F

1 11 90 s c 1

P A

l 1

8 M c F

I 0

2 j

e A

E M

0 P-T T

y C

7 L

L T

L EPS N

M 1 M M i i w

I E

TI' 3

b cQ 9e, ped Fbfh% DOC _U MEhlTS EXAMIhlED mag. f, a

~

i i

I 45PECT OR.',

h j

l

'4 i

ITEM TyP. OF DocumENi u o.

Rev.

ogTE DocumE.os rnt_c /.su r$3ccr wo.

poc.

it/f/st R-G..s k To-R %L;//o c L g %.,t tiP 2 & -

I I:

the>

er/ 'A F -.Ibsf,Ne. % 8.4 c.['En E'~.k fl rlc h

do 1 Rd.R!- /d.2 y

o. w o h: Ws l

i rilan/a ( % E Rc l k A e d m A Y c, N ik o

I c e d c ~,) A J c k.., rno..f.4.~1,eml%

1 I4 Nelei l

i

, u-N I~ <d 5

EtM 9 / 3-sAk-SsoV't-I II/a/Fo 5 m.,4s f

b:

Bud

'll 3 - SAM "ao 50 - I

'2/'7/n

& Ec k R I3 - s hsu -- s i t t - (

I e, p

s t= c d l / 3 ; ch. M - % U/ - d_

3/i2/fr/

/

,4 c.

u" * ** ~ N/b ~un o. r t o o d Ih 2

i 13l' Nk 11/o l

s/ic/st

/,,e, f/o 1 I 3 tSM M #/ /J -I

[/h'@[

c. /e,
.# e w m~.4/e uor.>w.9od
/(w Idd llbl C
34 6
s a
171 Pc M cA 3 cd sw - ei r 3 - /
3#s?st %n O <s 0/c 3 (8
ye a
</ t 3 -sn th - c II 3 shs/sr s'
't c
(9 Lc c tJ
'l J a '.s Anw - 8/ / 4 -/
v/6/st
9. ec.,,ce s
- < t, gs
j/o=p14eJ I
/
,j*
l' l.,
6 4
r' 4
2 3
cl'~
. r>
u dl I_
f 63 D'
[)
J j
C t.
FJ a
C-76
' Ll/
-b i'
O e
O C
f 2
f( <'-
-j a
.J r
e r
n
=
v
., n 9 y u
3-ij d
p'% d l4
)
9
/.
d,
4 q j
t n
p r
s 3 n
u a
6 r
1,
'I 1,
~y.
j s
o 2
s o
y
i
.Z
l J
y u) 6
~
_ 4 2
g 4
s 9
u 1
3 J
q a g H
v c
i d e E
o 4
5 4
u b h 2
20 0 b '$ Od b
uJ fu g n e s a n 6 & n g r aj y-4,yg q
'S ?
M 9 w 4'4 b 5 $ $ $ w
- S i m
u; I. _ ~
_g.
=
o U
)f y
~ >.c e
s s
d 4 7 Y
'T 'f d
o T
rt s
2 i
n. o..
o c
[J G
g n 0
2
n es et %
t 5
3 M 2D 3 g s *.* 5
's G W
a
~
I y,
i 4
-(
g 4 1 6
f.-m g <P g.a K -c s -<s <
o g, <o <on o.f. _n e e m m
o n
. _,.. _e r
., g M
h M M N
M M
M N
M N
8
-J @
c.,
p p 0-
~M s
. 3 g
T c-g- g-e o--
a--
7 c.) u uV-o
\\
O Y ]
~2 2
.0, ~2 2 $~~Z
--- 3
(
_}.
$ @ f fd.t d 3 3 S S S A k 2 2
v S ffi % d RAR M R $ $5 M S$3f5El
DOC.U MENTS EXAMIhlED l
me3 e d-
' I9seecroe :
It N TEM TyP. OF DoCUMEdT M O.
REV.
DE DOCU M E_MT mt_C [.su r53et i-3 E'c Id 9 /2, -SAM
'Er / 3V-I fM/M/
2 <r s,1
'bwe N5 0,
c e
f$
L[v
'7/ts/st
%lw L Cco *c-ll se. CR 't t 3 'AM -bt sb - I
~
brl!
LMv
<bv c w A 4 *'e//'s Aede i
7N>/6/
S u ca.
t U2 Lt,V i
b[i3/ tit 8,las b Lem '
CRCt 13 -SAN-s ic/2-/,
/ >3
/
v e.
d)
Lk lo/21/5/ N fax It' dc6Lh v s C R ci t3-SA*- 5 I '/3-/ i r
g: -
.h thy iI/5/GI hrlc n Y CR ctI3-% k-% I < 5'I 18s m
VR
$~5?
C.S O - %II 7'f Ii/t?l71 be 6 arc lc' kN'%
C R 'lI 3
S/W -WIEI. Iy v e-r b
L4v if/24/61 sdes d A.i ye c R il3 ">Am -s i </J~ /, /, q k-I.
eg/ci/st A.'
b Akc4vwhi, ve km,y ka6 I>c,
% c>i i
9 f
N8
.t4v l
n/as/6f A L s b oi k kell',e A 1,~.1 U L rL. I u fog F~ u'~ b Fle d v ik9 eced !
91%'sAE <iriVfr-3
<< />-5/8/
aou CD nsk
,In/a ik L. sk,1,. A,f ws
~
e
'>bc/s> s1k b shdLId c,ut L.<m.h 41% Ns, /c, Mi M?
~
d 113-shig UL$?
Jh3/h
?nss R
ec s3 eu ra ciiisk-shra 24 4,
7,;s e
i l
t h
Mb#M D
(. '
A I
f
i 2
0
.e.
g i
kd i
?
sa a
.p~gp ? ]
3 >12 31 4
-lv s G<
p s.
+
r dfc T20. t2 A
gg U
J
~
~
n 4
is a m
a E 4 3
-] ~% r$43-g{
4 1 Jn 1 y
~
5 are 4
o T6 a1
}
f
~5 r
r
$c,.
E v
E+ 5 3 fe d" dp '2 3 -
5 j ji i
ES j 4 j!p 4
5 2
-1 9
F 9 #s e 4 f
as_
E b.?
to a
o s
6
%e ir B
43 3' 4 a
5e='
a p pB e g =a#
4:
In h t
swE a
cr e
.c hrs _-{ I M
1 q e
e t a.2
}
3%L s
o P
hl 'd us as12 :
t s L h 22 u Ja !
t
,o g w'
..r o
ogh'LJ.d, ! a-togj 1 F}
l.L
}.Q
~2 ~j W
E s
3 %, 3 2
n-r g~p go 2 ed j i 4M $9 -hg$ 3f 32 1
y
.=
q g.f_;
+
2 t
a.b 3-d 7
.u o 3 t' 9 x
j.3
J
.D j 3
J-A*
g 4
v3 e m
a 4.141 u s a w @' 5 5s iS
@d 6@d d 3 o%;i g.
( j e 1 'c opi b 9 2 r
L E
E g
r
-2 ft gs
., j D
r w z
E E
.E.
'g 3 7 )
e I r a ? 3 1
?
Y P 2 P y 7 s.E F y
a s
s o
_g a
3
-g y 7 w w p
7 g
g O
i
-m O
W e
J 3 $
s w
s
, o a
l Y,
5 2 y a
g
(
<1 4
C a
Emm 8 d
4 W $ ee253W 2
I-J 4 W ! E58!1 i
=sv g
m S
o 6 g
d y d s 5%!EE y
O.
e E
Fig b !.t D t b b b h * ' ', ' ' '
E Bild Ei s.
o - a es a
m r m a c v s
4 a
.-,a
=
4 f
Y as r
h & Q)
E f
X Q d e
g c
c.e c -
)g O '
p x.
v v-
+
y n
@@,h 5
b 5 g s -
0 0
i}
S W 0 8 9 s g si n g
c
~
b3a p a
a en a n M
l t
d 9
W 1-52y 3 *
{-
i s=~
g 7 2 t3 g
A e
I 9
9 e
g y
h *t.g 2
c 5
3 3.
1 9
f i
e s
'o f y u
u u
o ;! d N E 4
U E C r.T (J @
N j
m u
a e
g s
8 #
l
'i ~j 1 1 J 1
D J^
1 V 3
c jt 2
E rc a
1 g
.p j
34,s s
e v
h.
.[1 s a 4 u y s w 2 a x
s a
9 Ed h
g M.y g l i
W g
g 5 15 3 3 e o 8,
t e s
c. t a
as c
_,s td 5 $N S $5 $1*)M $ $ $
5 I
3 2
E r a
a e s
=
=
s a x
z o
=
s w
a w gg
- O
-m O
W W
\\
\\
\\
E I
amm=
$ oEEEN g ESS[1
j
% is!sE g
.. pg s
r on
$ gamegs g!
!5g n # w - c E cc sij g G $ b e
s s
-o e
s
.,-+---4 O-E.'
-Q
$'b$
4 c
cW c-r
)c. c.a m W v
h dt O d V
6 o
o 2
j d
si y
3p y
i 4
a s
7
~
fe e^
3.
E'.ht 6r,N&.
5 s'
~
1 -
e
=
o s
+
m g
C c_y/
.2 a s c
n q
v
} d.h 4
d' *
"i d
.d;6 l3 dj3 N }Mi
,i
~
+
h
!!C !
$f j h
ess a
m u rr q
1:
c E"'
J
'J 3 j
+-
C n
0
.c. g. G s f
J d
g
[
~5 f r.
Yk E
fkk
-9 A
E h t s h
)
h 5 J
4J F+
-t a
w s2 pe z
g y
er J
w w
3B 4s e s e 1 7
'je d
e 5
5+b*Tk5. h 'h
-5 h
Tg d.e[h6
$c d 1
Jg ?
{.c 2 t 1 c
x g
e AT'4 3 2* A 5 u
i op C 0 t
g h
4 au L a*g E
h e
s e
=5 t
=
2 1 E.$
_E I 8 5, [ S 2
3 2 a s a
e 2 e s
75 i3
~2 M
PJ
'J s 's 7 3,o o
8 H
Em O
c W
N 5
2 E
rd 5
l M
,s e
a amm=
h b
c I =h8 1
20v v
E db
$ $5b5!
g gE gp 3
c rs s-
.egLg Ii r
s. r o
N e a to a r ys 3 e o c m
.c 9
e en e w s o n o
DOCKET NO.
DOCUMENTS EX AMINED INSPECTOR:
REPORT NO.
PAGE h 0F T
SCOPE:
NN DOCUMENT TITLE / SUBJECT DOC (MENT NO.
REV.
DATE Al fl1hf Work. OrdRr - Pe ador Co*+rol bBM) p4p<pj
\\
4h Sl@ LEO 6E GA ha 6ktw, kn3- @(no; hihe(odent BB T. o.*A.
Bob \\e4 hw om 23. Mode sur4cA +400M9
\\\\fOkIO hm 4.R.CMrd L-t.r ee '. 9.x Modt GADittk. i( Lyo 5% 4 Cofrutit.s Wa.ste.A3 illd\\lTO I4 na,d
.i s
i 6
@Ork. DCard kr LottL TO %
Qr b 3.*44 b.C.T y lo<
- R_x.
Made, bu>ittA.,
talslTo guaou u etc rcom m.m. a rrm t.. b m. b ao m L% d I
3 c.w. +a.c+
b blSlKo Enm 5. M.
Crom bdaf., O rtctMacy Nepw% of (etity oo Y
ullllTo Rs. Hnd <. Mk Y
0CL. OlorO hr 05 TOCI\\
~
i 50 ldert hcard 4ar taetk 1101
[Q cod To b.B.Ft.,rgoso n Frem e.G. h. tweed ' P ILC 10 - 5l 5/JNiI Err,txst - 4ee adA.ihnu e.1 *ta6 n n b Maae $1ijdcL v
TYPE OF DOCUMENT DWG
- DRAWING INM INTERNAL MEMO LETTER SPEC - SPECIFICATION LTR PROC - PROCEDURE QAM
- QA MANUAL P.O.
- PURCHASE ORDER
i
.g t
l y-
]
~o d
M d
9M 4,
4 s
.3. '.i e
o o
M I~
g d 4 i 1 J l
[Ajo N
u, n
o f t s R'
A N
<~
~a y
V T
e g
y f ~i v-J n
i k.
1 s
3n g
3 d
N y
j 7
b
~
4
~4 u
9 M d
]
'.~
8
'd e
r
^
?
i
-+
i o
9 c
,0 7 r 1 y
r c.
o b
h I
. )
[-+J h
N 0
o tv
, ~7 v.
3 2
O
, n g 3
/ /g J
't c.
[.
h 9d S
d
/
2 u)
J iP J]
~
u.)
1-Y N *)
b E
C-f sc g
f 8
2
~
~
a N
C 3 2 t
3 -j 's.d
'a n.
o H
c v
z I
O 4
/e.
J A
d-7 +
U ro
2 d d
'J, 4
w
.p q
q J
-.~
L Y
w g.
5,r N
Y a
k
+t e
/
1' 1
4 a
i L
c:
u
.s e
g.)
p
.i a
x e
w g
a 3
s a
a a
z
[j d
k
[
d
^
V
[
/
g..
~
E
.k b
k
.s c
3 s
r 0
7
'S $
$ -S Y S
$.g 2
m u) 1 L
3 a
a V
O O
o d
2 u
s g
w/-
U/
6 v
d l
N b
h 0
d
,b c
s 1 b o
s a
e e
4 d
4 Q) 5'_
g
~~ \\
g c'
j
- -} _j -..g 2 4 u tu y j l
i 9
c 4,
t o-i W
O d
O Ng J
\\
-s
)
1
_f.
2
...Z._[4 F
d
~
u
+
Ifk 0~- C; O h
~1
.J A
o r
E l
2 l
t t_
i j
I y
i y
i l'1 3
g a
t_1 u
C 1,
.I-
s
. ?, -.:-
.1 pj
.4 u
s a
rl d
0.'<
')
/
~
2 D
4 l'
J Lv n
O J
l
~
u J
3 v.
A 9
e
-3 m
Cs ',
A
+
n N
(
th 2 k.D k k"
.h
'?
n c
-u n
m S
<7g j 4
N w
~
a z
o a
M L
Y-
.f h
>O N
6 Q
g
.O V
~
.$ ^
i. 6 rt 6 f> j e f
.b 6
+aa o
z3 0
0
)n.!
e v
+
D 2
h r
w t r J a
W d d 5
3 d
{
J 2
_3, A q 7
pg 4 4 4 e
H u
t t
n s
g a
o 5
O Q
Q,t j -f a
e b
5 0
7 a
o d.
j g
o y
t X
f i d
i 1
~
.a a
f a
W
'9 b b ~b b.p l l -l $
d a
3
+
w o
o o
a 2
>$$ 4
%a 9
p E
x 4
3-o w
r _~ _g_
U t
o O
O o
2 l-
. 3 t,
V O
O 4
4-Nae g-e
.Er-m h-s 4m wE oO s
i 4
/ J s
s O
F
-e 4
.__k_.
d.d.N
...J..
d h __._Eg
....G02
-r 3
f
.h
e o
(
1 e
a L
5 3
3 y,
r e
J A
~
11 g
U' L t A.
?
J A
5 Y
E f
~}
I d 4 9 5 g
t s
ed c.. s r y.
y,.
r-s e
3 es
u.,.
> s e
4 7
ve ~2 ce g-z- 2 2
c 3
i c
r' <
.O n. ~
p 2
> o r
1 r
3 2e
.o
.e u
7 M
P v
o 2
[
g
=p q
3 o s c
,p r
~
Ho g.,
e i
n o
e b o
4 a
s sa-e o.
1,.
z r c i
m v
o e
em a
%v 3. '
e s :
e
.e m
Ps c
2 2
es8w e uc oG c s
pr s e
<- t
=
v
?>t a-s
<U <=
,E
$t P<
i e -
g[ S N
i s
e
^ r; s
ea c
e 9
'2 I
O dj v3 3~,.)D Q
j n
-V a
d y"
C t
a J
w d
9,s O'
a g
g.
t q
ga z
W d e3f 3
2 W
s e
o
e. s, 2
e 9
.J *"
D r' W E
k 2
f.
L u
J Su c
A o
-1 m
dO,3 _' k e h y
,3,Y Z
8 WW ^$ j
^i s
q.
J.
o u
J 9
,[
d 2
JV 0"
U J -@~ 3
{y U
v a w >
2 2
e
,a s
u, 2
s d ~.. dO z d
G
-o
[
O 6
.W w
w n
<Yw e
s o r g
x OF o
E h
$[
O w-a c-a 1
a v 5j wi O
M W
w y
i q
c e a
o U
P W
2D wN y
w a
d st D ib d 5
3 ! *J 5' s H $ l 5;g5
!!e 5
0 os 3
s s
s m-ZW
~
}
es s
o w.
N o
=
1 i
50 i
O O
u l
l 8
<r 5
8
$r a
u sw{
s~
a g
=
g O
g c
.Bw4 t
,!N H
-,s-I I2 W 5B955 9
o 8 $ e s. =.
m-
==
w m a. o a g
v o
y y
=
=
s
=
g y-
. m s g o.
m
?. E&te 3
ca e v v s3 p e e.- o s
c_ar_
5,.
=
e m
I r
s
~.
.-.-,,,,-,,n.
,..-----,-_,n--
,-,.--.,,-__.,,,---a
._,.,-..,,-.--m
-e,,----,-
--w,~-. - ~
g a.g T
-g C
4
(
't 6
z e
7 7
g Ut IS 34 g
T I
3
)
A m
I 1
s A'
)
m e
4
)
A t
P T-u m,
s (g
E 4
5 t
s 3
z e
g C
r 4
4 3
z q
g t
k
/4
(
7 7
F m
t 1
t su c
- 4, 5
u 1
)
6
(
3 0
rE.
~
i v
4-4 z
t P
w T
)
4 t.
2 5
T f
2 i
t p
C w
)
I MO 5
w e
~
o 2-sn f
s i
(
).
N C
)
s w-wp E
3 z
t 2
J 4
S 2
m e
e UR B
5 6
c.
(
3 T
s 7
s 8
1 N
O E U
v E
o e,
MP s
G G
S a
j 5
b 9,
2 P
[
j t
E A
/
l e
s 3
2
(
R P E
T a
T-
,s e
z y
m e
T s
L A
m, W
(
u 2
(
t c
b r
)
o e
a T
s h
T
't 2
i s
i L
'G s
e t
I 1
C p
t w
T L
7 2
i e
6 c o
C F
~
s e
L 7
J a N
S n
H e
Eq p
E T
)
i D
E 4
4 n
w v
s T.
e R
5' 3
t F
F F
V M
5 t-s m
x-
^
v E
U l
O D
A ).
T 1
E c
t s
)
i e.
o C
t T
N O
'n C)
C T
J T)) )D y R T n D e
m
m. )w)
W D
A MtT T
m w,o E) t s
t C
I 6
y m,a 5 A
'I l-6
+
C z-s 9
.s m1 l
ms M
y o
U 1
c A
t t
F)
F r
m 4
c e
o t %
t u
a u
o
C o
o ss V n
't W
A f
(
m )T 7 F)
(
2 f (n-a >m 7
e I
4 e
e t
f X
W o
L n We P
V t
u t
n v
e w; g i
M v
n Oe i
T 1
O
)
G Po P
v P s E
r E
oT P
e s
w P5 u
E
(
LL em m
t L
S M9 D D
R )~-
2 c(
<-e U'
T D m
G M
(
F-Y E.
"5 E
z E-2 C
u K
s L
k S
4 I
V(
a C
C M
m e
c T -
t.
t d
I A
s 0
v G
t u
G A(
f W
~
Lb e
s NR c5 v
t W
L' W
S
(
RE G
D' y
L ET
/
TT NE IL
.M s
e E
3
(,
u, T
2
,r A
MR D
1 NT IL V
E R
ON T
L o
N E
a t
M
'I t
i r,
R a
e i
t c
t N
E C
g O
D e
0 I
R c
0 T
O o
AEL T
CRAE N
GI UUS E
NFDNA M
IIEAH U
WCCMC R
FT C
AEO R
O RPRAU ON y
f t
D DSPQP E
p EM r
g e
F R
Pt g
O O
YC T
T0 g
C
0 E
CC GEOMO.
E E
P WPRA Y
g P
P I
p b
0 y 3 d
,\\
9 T
DSPQP p
S O
M g
2 7-7 Z
Z 7
g N
C E.
f Tm I
S I
I i1!
l l:l!ll
n DOCUMENTS EX AMINED DOCKET NO.
i INSPECTOR: R. (oeettA REPORT NO.
SCOPE:
PAGE 3 0F ITEM virE OF I
art.
00CISENT 00CIMENT NO.
REV.
DATE DOCUMENT TITLE / SUBJECT M * '";9 " "m * ' C ' * )
5 'T 5 7--
2#1 ccc o t -2 4-a.,
ce s ee srn caza Ct- '=d C 444 90lIUsE** @ Fox, b,Euw 2 7 / l%r) tg
't
~
,99rnmAst6;
,Wece L m n.asy cce_ we n z g (g.,g g g
z y ( i s,.1)
, wc44 semg n.c wam g
wecx so.om e-)
re w wz so (iwr.)
j f
3t(ise+r) if
/ wx<4 semmuy evt.
s,, wu 3g
,AJesc su rn m Art) t=c.r wem 3t ( i wr) 9
,e
%c :. semmuy t-c r., sveus,:. B (2 sm) cuvt.
Wiw:
54 ( 2 sm )
m ee n se,n m Ast6j er e,
i, g
se m m e ) m c c,<ut e 3 r ( tser) wc5 g
cu s w-> m A 9 rert ww 5 s., ( t s*T)
I e,
4,cca A menruty erg wea 37 ( i der) s, MO tert 4 T. s. T rawc r co s i_.o itsT i,
r,-
l 4
(o,r,n tw PowT nJ Di r Akas m:. s.e. m uacu re i:
s-.o. T e T j
g "A.> 3 6t T. (MJ th 3'e r exit sn cu7 4>c, 9 e e,. c.s t',#n s
i
TYPE OF DOCtMENT DWG
- DRAWING INN INTERNAL MEMO j
SPEC - SPECIFICATION LTR LETTER PROC - PROCEDURE QAM
- QA MANUAL P.O.
- PURCHASE ORDER w -
L
_p
~
)
)m,)"
v n
)
)
m e-
)
)
r q
w, )m,)m, F
)
s
)e m )u, a
0
)
n m
2 n
w
.z t
s o
(
t T
(
3 g
A.
(
(
(
a e
s O O T
s s
2 t
C 2
3 3
z (o
N4 N
m' 6
o i
E 2
3 z
(
(
(
(
(
g.
T T J
4 4
4 4
E R B
(
(
(
~
5 7
K O E U
5 C P G S
8 0
4 4
3 4
w-ti a
4 c
e O E A
/
3
'3 4
4 4
m a-u D R P EL a
w t
n r
e e
T Fs w
t c
t xf "
t a
e r
I e
w a
a T
e w
m.*
w w
p w
i e
T w
~
T. e W a.
N n
D E
t.
o t
c.
f e
c "-
c W
m t.
E c.
A a t
E c
lC c
o W
He y e
t N
O F
r c
D c
s y
7 y
M
/*
y y
y y
y v,
A M
I J
Y g
M cm m
r c
a S.
a m
A A
^
a m
m m
m c
m q
m w
m
~
x D
n.
m w
a X
7-e 3
5 s
O v
o s
o s
s E
s s
s m
M E
t 1 M
r x
o L
S A
i
<e s
u.
x c.
e.
c N
u c
c t.t a
c c,
A C
1 rr v
T e
a c
T e
ce w
w w
4 RE N
9 w'
u w
w w
L Le e
NR t
ET TT E
NE M
g IL E
i U
T g
i C
D i
A i
MR NT O
IL V
E D
R g.
7_
ON M
TN
't a
E M
l e
L R
C u
O N
E O
D D
m I
R w
T O
AEL T
CRAE N
GIUUS E
NFDNA IIEAH WCCMC R
FT lC AEO R
ON O
RPRAU E
o E
i, D
DSPQP D
R rI c.
~
i F
O C
c uO O
T R
C D
E E
E CC P
P P
GEOMO.
g g
(5 g b
g Y
WPRA q
3 4
5 S
O M
3 4
5 1
T DSPQP N
C E
I S
Tn d
4 4
A 4
4 5
5 5
Iu 3
j;
h l
ll :{i l
i!
l ji l
.[
4
{
a I
l j
g t
3 c; g g
r7
.~ c a
u t'
t e
,, ~
u r
s
~
I-c 1
o a
~
e v
2 n
e r
e e
n,.
s c o,
n e
w n
n
~
F l.
E.
's
~
^ to
^
Y 9
5 6
e e
.a' O
m m m
1 w
o g
t,
.e e
,s g
w u-n
..i-a n
n.. v v m a
3 j
e s
n v s-2 v
u u'
~
~
~
C
=
~,
~
~
s r.
s a
, 9 ff
'+j -
e o s v
,. o v
'D m
c-p 9
2 i i
i l
i L
M 3-w L
6 8
a i
p 8:
9 e
a r
s 5
3 2
3 pd j
G 3
2 2,
3 Q z
o 2
3 3
3 J
3 3
p 3
g y- -
z 3
~
1 i
q s.
o
=
e v
3 3 e
h 2 {
'd f' f b
lo 'U Y
Y $
d-L-
U T 2
$a 2
j w
i uj 2
^
T (
? {
N [ { { (
b f,
h t
c i
1 t
e H
v y
y c
[
T.,
.j g
E-E i; ' )
7 r-f I
r
,C ( :.
[
O j
v N
3 su {
w j-O 3
I
,i 2
[
4 E
~ 2
0v,3 s
s c
e A
O-0 2
Y Q
y
.k 2
J. c b b.,
b, D Y N
0
)
1,
}
r 2
.a a
a a u a
u Y
}
O Y
Y b
3 E
g
~O 2
.3 W
O
.~
c 8
.~
4 e
2 p
U-N
)
1 g
O D
o 3
l'i 9
s
.~
b 3
w H
~
~
J a
=
q O
[
~
0 O
P D
B cc u.
oO W
O O
N
.O M
s W
y J
s s
=
y e
Q f
j E
i a
t-4 e-O!- ed tov T U N
N3 Ia $ fe O
o~ ed O v sn 3
,3 a o
,3 o o e ne r-r r r n s
a
.I J
)
!ij r,
~
f r,y v.
x
?
L M.
9
s n n. n.
S F
2 a
w u
c 2
t r.
OP
' A Tu z'
5 7
a, ny 3
a 3
i7 T
"v t#
2 2
1 rc "S
"G a 7
- A t
o 7 j
T-2 X n
3 3
1 i ot v
' n.
m y
7 ec i
4 k.
Du Na
)
c s
o c
u r
Tt
" c.
o 4 7-a s
c 3
E J
- A )
e n
2 C g y
w w
i o,
t
+,-
J e 0t e c
r m
9 G
5, b
't i
6 7m i
b w 5 o
4 w
A s 4m 4
c i
s n
P u
?
A 4t v
z u
w V T
~
- m.
(
m a-s 7
S. 'w "e
T Ct 3
i J ts s A. w
/
. (
T
m. N' h e o
e r
r s.
3 4
2 i
s u
<t.
v.
5 s
t,
. 'E FM N
~D tc D
g 2'
e e
b v
L s.,
s i.
(
t a,
L w
e e
h.
a
(
r T
g H.
I o.
m
M t'
m.
e n
y o c
w. E c
I a
W7 m2s e
c. w u t
v E
'2 t
(
7 O
" A.
e 0,
e e
T 7
p t
u
-t P u
t A
s W
's L
T>
Y.D P
7 u/
s v.
c 4
a,.
n M
o$
U. b E
N C
e s
o w
w.
V S
c c
. 1 a;
a 8
s w c,u c
y w
(>
0 n
g o
t n
t F
e g
2 r
r 4
t
~
4 u
m W
~e v
^
y y
t e
c g
C4 tr *o w
g d0 y
ct
, F 84 t
b m
ii u.
A A
y
)
c m 86 T
- 0 T A. c c
7 0
0 c.
t 1
4 1
c A
\\
a r
^
c c,
(
t c,
c as T
tu s
a. F i
e.
G A 3 L
aA m
n
,~
c
.v.
"m,P C
0i M
o E 6 m
c v,
~
e 4
c' s.
0 m
ev C
r e
t c
p
~6 d% s r.i r
W N
c s
c w "
a.
c S
{'
7T A
z e
s r
c x
c a
t a
A nC
(,
e x
T "d
iv T
i,in T T
o e
a
+
G 6wsC T
t s
c.
e, eJ h
i a
4 v,i
.~
p w.
r w"
o, n
o, e
,m r
3 NC cm c
(
E
<.t " e.s M
Mv u.
a.
g n
w i
W W ow
. 7? c k
C s
t c,
o u
u.
O E
'2 e
u s
K v
V o "
N e
w u
'P w
=.
/
D.
S t
e E E
LC Ci cs c
c t
s i
s t
L T
D w
)
e w
s M
M c.
f 8
r Ev t
k e
e a
i t
'z u
R e.
e i
c
(
o D
O
x T
us
~t-E r
m ti m
i, f,
e A
u t
if t
I-c E
o U
E D
R
(
e c
s R
F,
Oc R.
P. o o
O D
C 7
0 ag s
4 i,
T y(
(
e, e
i E
9 PS M
M.
E.
I' O
g o
g y.
y 7 g
g g g 7
q, 4
g 7 N g
L T
g 8
a0 d b)
S q
q q 4 g
~
fl' tIl l
llI
w t
1.k,k
-4 i
c-e
.~
r
.4
/
{;;. $,
f T
.g
'r' e
~#
e.
n F-E
's f3 6'
o 4
i-f
., i f
4 j
t-o s,-
3
e.. p
.f, - Q 6
y p
eJ
e tv s
e.
P-l l_
r 2: y v,e c+
a c.
2..
r; sr a
.~
5, o
}
O e
e e F
3 9
', f g'M 4 y,,
',; 6 4
7, j
i-Ti t
E-W'
}-)
r-9 3
s i i
J
^
3 i - n 't y
v..
=
?
O' g
?
e i>
t, c
e yn
/-
8 n
-w V
a s
3
.a k
> -~
??.,$ 3*
k
[ [e 7
3 t.
2 b, J S
hi-5 O
q'.4 i.t e
7 g 5 3
+
y
' ?
e !
{c u
+
e e
a v
v o
- w U
[3 j
<~
D v a
o o
y
-)
,j, 4
6:
's 5
3 3
9 e'
t
< r c'
0 0'
u;.
L, t-.
b
0 a
e
.a 1A a
's 1-a t-r-
i-3 2
,2 4
's v
'v -
1
'o c 9, E
1..
6 24 pr g
-0 D'-
3 1-p 2
o 3
t s
S i s
z 2
3 h'k hb
!r I l-f
{
h, 1 :,
}'
td b
0 2
e u.
+
3e a
2.
Ej y
13 y
'd Y
3 t'. y, w
u t.,
s f
d' 5
I-
<c.
.3 t
!,e
~
e g,
9 p
a e-e 4
s j ;'j s t -(
2 q
il) d 5
g 2 h,42 e
gg a
2 y
3 14 g
gg e 3e T-1,
=
2, 2
E.
G y
a
,, 1 N
'i dS i! f E
%$ 7 ",
f-l 8
3 E
w
? 7 F
e re 0 0:
3 st Ju s ey 7
?
i g
o e
o x
2-
.w oa )-
d.
E GV d,, 3 Q.
5 2
d 9
2 R.; i lj i.
p 2
~
s ]u
~
o
.s N
O V
r x.
~.
c w
n a
p)
P ej d P
t-k g) p h-I" l~
[
I
?
?
UU Y *'
2' 2
5
$~ *--
)$, G i,.'
A g
Q T) d4 C
lll
)
y
~
5 E 'y
$2 TE *4
?
s u
_3,hb,d (9
D
&,, ?-
WX U b
W 5
M rs
,t -
'u'.
a w
.o
~. >,,
4.
.e s-g J.
d h
,/
2 Je J' J t,
J t.
J U
3 JA Je v
J Je u,
o' M
v 2
e a
s
'3 d
3 2
O
[
f. 'f r'
c,,2 s
O
~
~
~
y ul N
Y D
G e
.d v
O O
o 2
p N
5 t
l
^
=
~.
~
W O
s
~
~
H w
o O
3 O
o OU l
d O
o Ng O
i Y
c4 2
.O t-v
=
k 2
s e v u i r_
o a
pa s e
e a
~,n y m a r
_ j ~_.
m, o 2
.o o
o a
o a.o o
}-4 q.
g_
~
.p w-w
-w
-w--
da )
p Li g
I a
in r
) [,V
'd
'43 o
~
t 5
2 4
?)
.my
,e A
a~
E' I h
a
'I I
ame 1
.a d-c!
e
!?
l
?
51
- y- - s?-
$;.t- $9 l.
. u, 6
a e
i
@f I
U
$. 34
(
N
3 d
m 7'.
Fw o y
J O J.
O s
O n
^
cf C.'
7 _.
6_
Q 4-2-
p I.f E.. --.
E s
in f,,
p
- i, e
p
-)
It'.
O O 9
0 5;
Y i ry $
kU ]i 3
' [t E 5' (i 7
h UF 5< C g
d t
3 5;
ug N
ne a
. gr -
ti n a
e 2
N v
t N r.
3 a,'
r
.C p
d,*
br
g N 6
v v
i 1
,' N N
r -
ik h-g -
(g
~E
8 N
l g
1 g
2
+
W ov v a
$e w a
s u
a Y
a o c 3, Y
J 1
s$.
gt a
g n
- A e2 a
e a s
.,. t y
y vu v
, s,.c. o 1 u
v a
=
t o -
p.o o
c l
o T
s 2
ia
?-
v" 4* aO 3>
a8 5
3 p,3
,, r e
ve 2
si e
- a e
1 V
2 0
s N
s so-l Q, 2
h K
8
c..
rn
.v s
s a...es, a.
~l
?
e u
-> e w
2
<* f c
z.e n v~
2 t
p-2n
'2 a
E'
i
~
?3 ~a d "
3
?a k
$: ? f f.
y
$C n
3 n
- n
s e$ 'a N. '
a H
U
$n 2. f"?
%G 4's G 3
.e
~
2 x
0 ab e
et e
1 se t
g g
5 o
e ' I-i O'
i
[a j j-$ [.
j}.} j j 7 f.,f
<[
.j lJ ef f3 b f O
I e-a
. n e.
a v
2 4
7
+,
wE <' u s- ; 3C V
-Y n6 ye t
a b
O$ 'l g
v 0-4
,j 3
e. i., i
{. j (a$3 y,$ j il 2
2 g
2 E
f O
d E
$2 dE 1 N
h, 2 S e. 8 be(s,j t a u ea 2
2 O b 0
s,2 2
.1 as y
1 3
O W
y E
0
.2 UJ c.
~
~'
-^
~
,~
e 7
t O
O o
2 j
5 W
-{.
e E
3
~
a
'J J
h, tu O
9-n G
O o
j.
,n Cf.
u. d-o W
O
~
N C
O(
(Q
?
~'
t
=
=
=
~
i g
e o
t E
2 O
-: ed A T f S 1-1 fO p
3 W
p q \\n c
g.,g 6c c c c o m 2
~
o
~
o v o
~3
~
v
~
y H
e I...,,,,,,,,
4
~,.
e u
$f
~
}
?.
-d M
.h
'i r G
D
{>
Y' L
e v
t-I f
o 3
b}
f
$N 5
f s
e r*
z e. Wl.
h..
o
=
^
2 f
. gp p
er e
b
^
~
)
-r 4 A ;
3 0
N jaA;,
y 1 :
r i n :
E v ep n : :. m
}-
c.,i A N
v wc ea u
o e#
j.<! "_
E s$ $
<ti
.Y 0 g f6.!
y$
I p
e-S M
.3
-s u
m 2 4 r
e
'4 e
>e sv 3, t,e a
l' y
r e
J
.a 3
t, b~
2 Z'
I?
L
'2 b..
W T sa F
i l
h 9
(#
3 3
3,.
3 m
5 9
y 4 '8 Q
$., e f;
2 9
2 3
'a eJ
-a J
e-4 r'
53 b V
I 2
,)
c)
$d d
en 7
9 Y.,
hh al E' f
?,. $9 f
,?
U N {
T 'S 2
u,. 4 $
b5 1
e 2
r e
- a
., o p o:
o
.n p
t r
5
-',{ [
wy
$c [
gf $
5 g{ ff[
f yf E
g d
rw
.a g
g aw E,
(
J
~
r s
a e
, ca s
c Q,
~
e u
g, f
)
h 2
si.
s
.y '$
s j
a
^
h f{ A 5
o $
)
f, gj
's J
G b
5
${ !
4 t: e, E, - ? ;0 g 3
M
.2 f 1,
)
2
'd
I
~s 1
~1 9'
3 4
0 y'
j 9
2 e
. E d*
d' ebc ca. 5 a F1 %
je; ':;-
?
'3
?Q t' r J
3 3
s ty 1 it en Jv 5
a
.2 m 5
Jr s+
[
id i
O J
2 y
UJ
.c s
I h.h O
O O
s' 2
's 3
us y V
d
~
O O
o t
I a
4 b
c-
~
L.
v 3
~
d 1.
k Q
g o
u
,V gei o
e u.
od 01 O
o Ng C
V 7~
G
=
O r
v
=
=
a k
E I
3 M
,o v
,3 r-
-p c-0
3 y
uJ d
'9 e-vip [ h
p i. Ip c
p T
T T'4 T
T T
T v
v m
ts' 2 o
l
r--
^
e i-
.g b
q
?-
k l
5$o f
'[
~
q e
g'-
=c b
c~
,ji
.2 5
t-sr i
b'
-a 2
w s.
?
C.
2
?,
' w.:
r f
4
'3 O
V
-l-f~
e t!
p w
Q v.
c p;
a t n;
a m
r i t *9 5
,6e ac to l -
s e
ti 3
w
.n y e- --
f,.'=
n
,s 4
~
%r r
c1 1 a
h
>?
g*
p 1
f, E,
$ d gd f C
.{, 2h g hf v$ ^
3
^
ne ed i
S c,, a g
e.
p,,.?
n te o e
t
-a t.
n
.a 3
,n.. > -
-o-G 5
,5
4 C-H3 b<
?.-
5% n'
'?
c 3
-U N
c o
~
t, Ib u ~.
?. O 2
p, f a
'" da 3
V P.
?,
d ys gg t
i J
t 4
d t-
~"
h-4 '_3 j
?
g*
3 2-
~z
=
p 6.,
~
. rr
-.f
.n S h 4
o e
9
-oy.
5' Y.
I O
11.
C,
.n c
.y
x 2.
w a.,
Y U<
J L' 6 ve g3 y
' 2%
f
< g T
ty
( I.$ d
,, C
~
?
90 h
s-Q
2 Tg d S I$
3 M
p
j(3 '2 (d 3y J
I,,
E y
3 5 2 e
2
.c:
5 2 E { D: e c
cw 4
o or de fe i" S i
2 I
E( 'I O
' 2 I
3 ?,
d H
$6 b
E3 4 5$
4
,?
s.y l(
3 2
=j "$ <
. 2 E
d
?
o e
mi {a p g. '8 H
-8 Es e f
J; f i
83 f v a 2
a 2
2 5-o 39 p
o g
g a %a g { or
'i
<s t cc s o
ou r
-a c-a; o
v.g 4
g e! 2i O f E
y cg
.. k P W (T n 3
c
. [ p, g
u r
p a
u s,
..w I
- y g3
"$ d.[,
2 -
F.h g
5 g
p 9
L.Bd 'i I
W y hi <e j'
,3
$ j I'
d 2,
69 1
u 3
1< n n s v
g aE
'c c
?x o g.a a v5 3
0) db d6 AE
.J '
a5 a
(
of 3
EA 2 1:
E O e-
=
O d
l' 2
3 W
C
f, 2
?gh
=
=
=
=
~
.7
.,l.
.~
D
. 14 1
m.
a L
g w,
O O
o 2
l-8 rd s
C
<N b
._b_
e a
o
=
E h
2 U
4 y
p Q
b e
U uV o
W O
2 O
Ng Q
~-
~
~-
f-2~
c3.
O F
g
}
LU 4
6-1 E
A c-O N r0
'Q if S P O
')
M r0 N
fj 'to c
g.n
s '
H D
.9 3 3 s
a s 8 3
3 s>C #
r,,
r,..C _r r-a
I
.C -.
r E
l 4
i l
((}
i r?
A l
C
'O l
3 I
l c.
.o
?
i I
et
'o t
I 1
I L
4
i; j
E l
g 3
it l
1
' wl o
a 4-i iJ g
f l
n i -f l
,, 4 :
a 10
c
3 l4 j
g
,iu l
t i
ld i5 i
i
.$ 3 e
!?
i d
fC
]ld r.> !
'E 14 c
-i E
N I
?
e.
w I
(
C.
g C.
+>
p d-lo Sq
-j b
. ;f C
o y
p,'
e d
O CI 5
E 3
y C
z I-vd 5.d_
9, x
W e.
l o
y I
, y {r l
rh P[' t d'-
1
,2 t
e yw 1
5 s
l v
3
$(W of s
3 s i r,
i 2
y b
V O Og f
$ f% i n;,%
ha sD
'C 0
l k
5 l 1.1,,
2
ou lo
?
' t1 A
b n
e
2 a
s, hs gu I
d b
1
'3 '2 9
f 10 v
2 s
n 1
n g
.; n u
t b '0
~
9 a m
c e
H f
Ey V
+
e d
d n
E 8
u e
Q N
h.I h
J E
k s
,3 e
a
, i_
4
?
i _
[
g N 1
7, p
+
~
)
% s{$5
s
$ g,,
j 3
ha f.2 -s.
W U
,n md 2
o c S$ 5 8 d a
5
'J 1
^
d *i g" r
Bu 4:)
2
=
3 2
d I
P h o
3 r1 I lE g f
i d
d 2
y o,
t.;
F r
w p
<.f P
u 2
,u b f
,%a f
g f
h
~. 1 "d,e s e
.e E
g e
.g 1
ah{.j g
i F
fit i !i !
y 3 i c
$ 't e
e u.f J
JJ A. -
),*3
<f a
Er
$" f- $n k J
J
's.
A A
c3 <
d a
n e
(X G 3> u {
t' '9 J
6 G
J E
C,
<A u
p v
s 9
h 0- [
h T
"5 UI 2
4l9 a
A of hs jf3 7 2f J E3
-r
.p 3
l4 f!
i) $g, 3 1 jI gl $g i
1 2
3 1
4 g'!
8 'g g" 'j 0
Jy A
.O
'a y
oa 9
.- c 3
ee 3
J o) 03 3
^
g-O o
2 We 3
g W
w
.p w
4 b
C s
3 A
a 3
s s
8 1 l l 9
Y l
g l
l D
k f
y e
x s
e
~
G s
I s
q g
g g
.s 2
~
N N
1' Ae h
Y
.gJ 0 v..,1 CE 393
>2 d
O2o
2. u.g3 g,.
g*
o E
O C 20ug0s C
o3 q
r
~s cw c
~
~-
G' O, o y
hy d
~
k C@ud d
V C. Cf 0"E y
O ge 4 0
..,,i 1 a
.a l
N,d euaa I
CEOC H@
i2, S I l9 M
rA Tj ig 3 p
.p c-c-
Q C, w c o c-C*0C O
F F t-o3 fa 9 r
ao 9 9
0 p 9 9
~
e e
l
?
J i
j g1 d
2 I
e A
ej l~n n
e l
J j.
u a
t i
e t
i h.
[
.s i
i w
e I ~d
'd lf.
l I
k Ihl r t rJ l l
l
N
)
D l
3 D I I
3l
'j i
'g r
i a
.i i
g
~
T d 5
I O
i I'
U.
a d
E 2 Q~
4.
C s 6 4
G 3
r
~
p I et 2 g
3 E,' S E*
e, l
t
'A e w i()
g kl L
w-
s t
h h & sb "Y
b S
i
\\
d N
/
8-Oikg
] 'o ! "
b'.
1 4
19 I
ow o
lN 2
L-E
r. 5 =e.l 4 i t! w
,A
./
S-14 e
g
^
3
^
,0 p
t N
C.
N b pr ^-
g n
a a
o o
t c
J e
5.V h
C
[
Ce Y
n E
N
^
V
? g#
1 a
')
')'.
N t
N
^
r Eg m
m v
E O
U j3<5 3
k 2
Id g
e e
G g
g s0 0 7 io C & d.
1 O % k O
o J
3 u
e J
3 3
0 i
7 e
%j
> t'
y
+t
)
.)
e
'Q p
J 4
J o
p C '$
3
~
2 lgJ C5
,Y D #e h
E b
f c
'3 )
J 's 3 gl N
a '-
a 3 9
C cl
2 gC 2
n.
t a
-0 $l,'J f
L t..g fA u
6-3 "ji 2
c. @
v ' u-e e
r 3k W i_
f, h
y
~
'V J",
a
~
0 3 v
C g.6
~
-U M
9 3 }e {$
t 9,8
)
e t
w g.
tv -}t si gI
d d g
E7 a
.{2 g
f
,j k f^
b, hk 0
fa k-y 5
l
{
n O
U I
n' f V I * *^
u g o'l $e i
^
g df
?
3 E-W 2d r
!,S
&f 8-3 i
a i
-> r 4% (.s 'j 0
1".3 3$
1 r
~B Y t n.
u i
'S 2,.5
^
[r 3
dw pg j
s pw 4
Y e
o M
O f ta f
C '* O w
v G
et
" C 7,
f L
N j3 3A qh. j j j ] p4 2
r$
l.1 d
5 f
O
,s Q
0 cg ut W
P w
w-g v.
_~
4
,~
~
+
W A
'?
.~
y s
s y
8i II a.
of b.
1 E
-.a E
k u
=
&a
~
3 D
=
2
~
g
,@p$
z o
k
~W ! 2
'O!.
Ca d !f G M 3 *J 3, e
m u, o 2 o.
1 is o
l&W eo:
0=,
r*s C 30 C
of G
c. ta t
~
o G@ug d-y g s o, W
%8 V
c, q $
L I
ie et '
g
$C 0
V C"O Hy g.j g
'gn 9
p c-l o,},
c<
2 7Eks0
,,,,9 p
N f.
y tp g w CO N o 7 g.
e.
c-e-
e oi o a
o o
i
~ -
g N
N N
N g
g e
,-wv.-n,=wes,-i--w
--=v r--v---
r w-w w
w
-,,e
l l
~
A E
l i
'5 i
l l
-I
~.
1 l
.J9 [
?!
I i,,$ )e i
J-i 2
I I
' Ni i
l'9 G'p!
I
$i._
t 2
l I
i j< M i
3
?
l al i
i$
I I
E d;
I! d lid !
j i
u Y
2 I
d T
$ L
(
oi O
e r
i l
o 0
e, 3 e
e I'
'3 o
J J
v
~
N o
6
- Vk<
l
f. d f
e k
(
, A F
i i
4 k
t'.
O d
$l f
'I d I
$w n
b of W
^
8 re u
g 0
g 0 80 M
6 o Sl
?
t0 ad.3'& 'g A f o?
t i
8ss e
e G
'^
{3 T
p c
?.
I; ; H r
e e 2
2 f s
2 t
a g
c 4,
p 1 p
a t
a y
c
+
d 7
{
,js c-r d s 4
In 9 dT 3
r T
N J
n
?w s a C
d " w d
A P 8
4 g v
L e
p a y d
r pt s
, l 6 il 00 G
<(D1 G
I-
'I 4 2 3
.a
-t 3 p 2 H g e b o-y g
1
.n 1]
7
'y ee d
J a C
o O
+
[.o #d Ad
{1 y !
3 E
., a s P
v 3
p J
o d
tv 9
2 st J
?>
J 2
0-e h F
j-E- 6o d$I S ' g,
}
$ )[! h C,0 $
j' p
W
\\
d, d$
2 j
3 q
3
.5 z
.n,0. l d s
$ e. g.
2 I p,s w,
4 J -
e i
s3 I
y ed e
t#. B r, d
a

ed t-cw l d i
d..
% O.
>'c e
o o -
p 3
t
'y i
C
<g
$ "d g9 t'
d
.h l-l 3
eg v
.[ $
b' k.
jr r3 j ':P l
J b
{6If v. [, ' 2 pd v-oE W
.s s
.w n
f I
e3 f p-2N g
0 E
3 ej v' E V
a t
3 ga
'3 fe{E 2
-f g
-t E
&c @- f.t g
<* (
o e
5 2
y s.
p?'2 g
h 1 1
5 6
A i i 45 l"4fY$s!s b s I f$ lQ u~
F 5
h A
i
? h,l s
s O
7 f
3*
J J J^ /\\
3 J o J v) JJ 2
3 Ol
.)
i w
W 3:
i e
s g
r
,~
u 4
w a
q J
'I eiII 9
f W
q Y
>~
ry
^
.J tl g
1 fl I
f4 6o e
Nh
z k
~
fz 6
2
~-
o be i
k
&f "QJ2t e2 CWdW C.
o92o33 0
C2oc 2 h. gg g o =.
2 C
um O
e sv g
$$o g o s:
0
'N 7*$gdh
$ua
~
~
~
g in l
8h te vb=c A fo !i >r o
e-0 e
N,; ENW N
r 4;
3 r
o e
'3 3
y" ' N
~
o o
o N
N N
N N
N g
g N
N N
rd N
ItJSPECTo R k- [oRRGi A po cygr_T 83 0.
SCOPE DOCOME PJTS Ey At4idE D RcPosti tie.
PAGE /3 o s:.
[/j" D M gy 0*'go,s a r stsv. l pr%TE TtTLE / sus.3acT n
i SEE 2.tvy>
LEnet 70 C.w. nWi.T f 2+ -s. "A m TE 4 -e s-So 77I bO
2i5 n %
Ssi3 h m m mSuna RepotT Si-f 5. A. m. IE 9-L7-N o.v c..s r* T C t-o.
C DC s y 'u( 8' vet *
2 A r < du 777 i,
DVE TD %.s Pl.irig_\\,,_ _,,,1&w.,_, s w t 1 L_w tr t3'j,,p,7 As _ v,5-0 tu g
G P_c.g,,,5,c~ t iL ti,,_
t to3 C i 4 67 I ] 5 HT"> )...---
UD eg s.
Dv.W IPTeorv SaWW ( Oc,e m s)
~5 7 7-7 's t-oit en cJG S w. T'c u
. Goo I C sat >
t, le 3
+-3I A<r ' i. 4 G s c.
oc.,*lo3c14f,1 DwG Ao txiv s 15s060 Lc Cg Fot m oos S w i fr 4 (D6-c.*fuSLi4f,1GooW gy 1
Fir 3CrT; I' OPE C reb k' (ct.(.
Osite_ "cowiw Te '. 4 'S-f,o I u
54 FevLJ REteyTED Miipw s LeC\\ (4-7 oo 7gg e<
8-P/5,CL - 8M00G S v. TC 64 PRO'Jt:'g_ ? Il oPG C(lktrt4.
PV,GP lbg NO)C _ (2 3 o(_,,,
OLAwc FCCm S " OG(rC4 PT lou o 6~
Pev0ucT STAtu's [~2 sitT',- )
g7g
.f i,
tvoit k- 08c ott /9tA swvi,vq C/hto / ptA,vio s,Jc, C thed Izquisa da, e t-c oto vv.t,5($3,g}
1. 2.3
,,[ ort 44 t3 - P(au3 ' m o0E Stst TcH
" ljo3 C l4's' l p C '2
( k.uo-5 Hex,G pth> 7tt t-)
Ddea54 ('6'*N MWT / 'w'" C't04 / PLA'"d 8'* G CA'50/PLA'wa'*C C 4Y2') h Nu 22o i,
i g
geco,to / i sHn tvrm / Fet2_
tw.>oe sw iria e (,3 C i 4 -A ci 00'2.
-evo set-vG i,
s.
'e
'TC5T IsvST8ocrione ( T r 22.44 T 24 S H T*'a t* tit. K vu - s e4t>> cs H t 5 - Pk o 3 (2 01c tr,r2.
7g Co,wTitot L-66 32J,x_g D A 6 [ '> Th. Pkt A>w), OAp ".)It')/j.oj,,cyag., /%wgr,
's '
e, G. A. TtsT DIVT*4 5REE'r / PiloitT.T- - l<Vo.5H1euri '_' f / I4 'S - P(re b P EMC ros? < c,vp4. t.
2 O m. p. t. H t"4 - 9(,oS / DwG ~32 6 v So_pAi5 c co 2,
( 7 sr4Ebn Tuh_1.J -E,1 6,q,_,,,
Le iTum. TV Let Cc6Let v' d+ w G A en T E 4 -1 T- % o 2Sn s i..ug,,7.
c g%cg, to u c,v s ( t w rs p o t,,J n artwt rowie ten,g.3 igt,qc. ),,,..._
e va,t a su m m omt *] cut sven4 son p (ssn,Q s
7
[ ovre_<r n(- 5. A.,n. IIs 8%m> tt
sid. -ore a e o.v kvu-sav=q ( o t - A>o i o,pouyy__ o [, _
$sp*m ari.w ei>. w., s -
w,wo ev t isac e n ( n +r') ( ce ; t~ em ( vm.ma-n e v=w teu cc >t.at i.
tu s e.,
s.,m e.
'z. 5 *>
(4 -= s. tot ccv)c txmi,c, sig - oc s - ( sia.-
2 u aso.d.
1 i
Tvre or noc:
D5J r. - DRAh!ING LT R - L.ETTE R SPEC-SPEct rtC Af tod PRO-PtocEDuRE l
tts-qistiANOAL.
i,,
n..,.......-
o - q c noconcur
l i
i
'e d
h i
1 t
t f a
.?
l.
k l
Pj 0
I 10 tJ l'
ll d
I g
I
$i i
El I
t
'o it i
c i
h' b
g O
j
r-d 3
y
.j r
ig C
f yl 2
p O
o o
Nr i
g3
'el r o
e N
,3 $
C e
d 3 '7 3
8' N
N r
z p, v
o.
s s-v a m H
0 e
t
'^
D j
4 n
5' Ikl
?
2 E 9
NN k
5M ef k3 0 U l tb 3v 5
Uh 79 3
l.
G 0-l 0 c -
o$
h
.$. c c3
$E b
j h
h i
tF s4 u
a'.r--
t e
s.
J p
> c p
O ey
'. P $
3e n" id r
" O h$
5
{e
'{
(
5
'n o
e o t-c e
e et E 5 E 5* 34 E3
}
W$ t, r
~
Y h Dh$
c) t1 ? b J
EC kE I
y
?
e V
L 4
o W
{g y
or oL 3
k 9$
C '_
j 4
% )c,$
H O
g M
>f 4
4e c-c 3 c
~)
3 2
o w
.u SP 3
4 O
$g S 3
=
'O t
9 o
a.3
'2 g
E a. ji } v[
v yV z.
2 t
g e
1
)4 S
i-b 3
ul it h d;l 0 *> h p i ut
% N f.
6} g8 3y i
a E f
..g o
$ C d
h 3g 2 f T
fl U $l h r$
f Yp f $
3 2
r K
C wh 1
d n
3 3
3 2
s 5,2 d yu ~5 -
.2 g
g g
t- ' d.o.;P Ls. E, d%
9 4
l4 o I,
-2 d
e v v J
"5 ;
- Y Y
5 3
yy a
3 1
. G.
M 3
3 S E* a.,
w R-e g,;
W 2
a9 2
w
/
=
y a
S e
C vs
.n 1 3
3 o
Je l
O d!0' m
$'% d I-0 (i 1 OS {
e y
~
'O C,
c d E r
h I( l5 y
0 Y $@ E id E
~
h ys 2
g LO a
tu u
y 4
u J u
5 d
y
.k, 3b $
3 jJ
.p 3 I d A$ N
'h c
W 0
i r
a Z
D a
d ac e'
~
o j
H 2
9 f dy 5
r Eg ue 4
2 dd v-2y o
9 -
{,4 4
3E "3 gT %k N E3 $$
'h t Ul O c$ fj )2 o
0-ej O
Jv C4 3 d%
3r 3J 3%
3 3S Js a
a w
W
$3
p
^
O C
2 W
l 81 : 1II l
e
?
W k
g u
2 p
{d J
g l
W 2
2 Q
$1 $2 7
(
,N o
o kt
~Q.J '3 1 g
e scr o *,
h 2
0
- Co:
Es O
O 70 gCs b
d
$ $ u g n) $ '
h
}
~
~
'V C.
g y y; emn r I ; 3h=A 8
H e 2
o c-3 m
r H
(
-l g
,o 4
u 3
w g
g (0
g 0
T T
q q
v v v
g N
fu N
N N
N N
p N
ca N N
N
,._...-...m
,.,.m.
_,_y
l
'l h
r I
r l
A!
l x-
'[
i l
s' '
.7 I
i i
ei i
i l
0 i
1 i
o
$a l
l' I
l 1
a I
2-j l-i I
o!
N j!
iO
., Y l
t J
u-svl 1
l
C; e
3 2
ir b
o r-e 3
a
~
a p
^
g
-3 o
4 s
o u
e' $
l e
ay, t p 't jd Jn:
^
r e
a v i
o p
p c'A A l< p b
yw a
i 3t 2
u gW s
ygg
,2 ;
V i
V l-1-
6Ag aw h
b
f5 0
UC
'P osuf
~
,,-~
3.35 a
q. 9 2;
a,> 4y J o e1 3
3 r
'J e
e s
N f O
J g P T
C
)
C fp 2
r
y. o 0 % C O'
~3 w c 1
r-e o
I k
I%
5 d,D.
d
(
h.
i
^
E E3 2
s e 2=
a 0
e 1
.s p
n gC s
~
j i
?.,.
to w
c J
0
', ~ -
.)
g'# '
6 'o
's d
4 e
v i a 2
v
< 1 8
a-
> o a
g f,,
k3 C J S
s v
eo c4 o
4
. ul.S r
ID
,n o
u.
f C. p u5 u.
o E d N
u. 1 t
e vi
.s J
t 9 *>
n
-t 0
3 f
i
$^ 'd dm O
5 g D
$ '{
dy( 34 '5 2
U
'h W
4 3
Q3 t'
A e
f t-i 8
3 ul o,f3leg d
gi do j g.x g a, c g p,
Py E 34 29
I C
V 2
-o 3a eu5 t.>
2
c. +
3-ea l 'a 7> P, o
$ 'e
$ u.
c p
2
+2 c
g{
1 w
jSa r '0' *a 0
?
a2 I
y.$
47-fe 0 y.o.@b d-d V
't.
2 3
d u.d'd{, 2 uf E. ;. 6-d e l ;
- 2 o
is S*
- i
+ 1 21 ;
o $j e
A u; e
e o o n
y os 8g O
f$
t
J G
W G
a-u e
p 4 e4 c-a u
4
,y v
.v o
2 a
c a
V-.},
a u
g' - y p -
W p
yt4 a
pQ F, g>
=
j u
y ;g u,g i
+-
i.
2 e
Z g>
p, p us p
o L
g&
ga g *= 3 gl W 27 g
'u et r
+
o e
o e
2
.a m
4
,o e2 tn #
0t
h e
m j
ye 2" "a > 0 2'
d#
0 "p 3' '
7.,
e
> J) s) e, g
,a e,
o a
+
u
g, W
3 ->
O J*
J #
W
,D w
W p
w i
E o
O 2
.~
a a
y 81Il l l
1 d
I
.a i
4 w
\\
r U
z f~ ro
~
u Y
y
~
~
~
a 1
o d
2 o
k'
\\,,s 2
2 GW.J 2 -
i E
o g.e.?
cu I
E i
.a 2_ u.o 2 3 p.
0 b
e e:
O
? $$w$ %
a 1
\\
q O
u sruto
~
%g a
e U
o cogget V W l
L it i l i
0 r
$d d,*C c
t l
rsgeo f
g' O
N O
T l?nl@.7 c-o j*
3 e
e r
g e
.o w w
w s
s w
N N
N N
N N
N N rJ C4 N
N N
N N
(
a INSPEcTo R
k. (oEEEiA po cg,g,y,4o, scope DOCOMENTs EXAMidED Rcrostr t4e.
PAGE I6 0 5:
_3 c
o4T do.
W.
MTE TtTLE / sus.3acT 5 W ITLM ECN - 000U.nGMi' RE W LTl'c m.s QE90,t "i"-
3 '. J, CeqNQ 3-if-00 Q
2(o3 RCC D
z t3 t-h 66 g, say,3 taoce 12ec y.z o roa_ sveu<. f',cz / ( 5 Sim.)
~
~~
y i,
u Is 4
DOct. nt*wT I e TT2,(.tiou % /%o Gritn;u,,A, oc riv' "1 2(c5 o L
c eoes oz. ( i s.a r. ) % n c uw t n.me-. t sevina. e,ac,t t u n,vesc3 EN G '" E6' ' < "'NCs E N dic E-
7 [ ? Stm. ) t - '<, J > dy ocu C <t. A F F 2W EcA 7 'i e t o S - 3 t
LDu 4 s,w CER., ecq c 64 <bv c. 6. 'v c Tit te
( t sm,) DRf Nc. t4 :I -T
~)
7g 19 96 C alkW 11 ~2.
t - lb-d o 0
e, se (09t t3 C C-t v,vng. Q t.c ut p ' l' cst t.tb ic 6)27 W rt'H C ubn rn ew, t.it e rTLu W M A20s,n ( 5 sa rs. )
LE. Tier.. T o (2. t_, H rlw LCp t^ l2 6, rn ; C. t-. C6 O L_t'R
I - { - d o 7g Su b 7tLT : ELL's eww).ts.Tuz,C Hitu C t: A Sec., T af (l Sui)
" " " * '" D '5'" " " * " 2 6 ( 4 $"Ts )
2%
[ PrNtct.!$ s'ri, net _,b e__ /No @ ** woe- % TL5s e.Tnely))
sozy ( 9,,ns.)
6,,cu.
resecw e o.t wes.
m, i,
e, LETTEt2. TD.
O. t. $ Pe-a et y F Ru oy SA rw III - Portr oe t. W <<;
.2t h t-0 F ort
.p 7 im soz<L__ s ueer. erec c m.r,.c.
ee =>uts _.,ew ( e c e _u z.>g, e z.n )
y e,
(o g2 R E C T a u'e otrione i
&wLnT N 5 3 - %eil F oe. G ~5 (o - Poo 2.
Gw Gi -', T 161(, 7 A 8's G o o 2.
( G et./wo Cs u cF T )
sg R E5E>trec e4 i2 Ec cr.0, C A n2.
S 3 - S(,M 2 [ 7_ 5e+T5) s.
i, tvv.t <. 12i;cust o Coit sva x. r,c19 { Ehmtg M o,v9 }
e p9 e,
er O
LcTt6pt m enig e twu i 47-fx F R o..
T) Lt.X Nb
'200 JCtr : ( ar TIL c e ssw,c, g S q
w,yie,c th_r
.a<>
F o L ** ciri<. f v 3 O ( t *ia r,)
i, TYPE OF DOC -
-4 DWG-DeftW eMG LT R - L.E T T E R.
SPEC-SPECt CIC ATeod pro-ProcEOueE
gtt - q t% H AN O A L CD - q c DocunEdr n
r>.ic. ei nc e n-
a It3SPEcTo R R. Cocce_rA po eg,,,7,3o, StoPE Docot1ENTS EX At4 t d E D R crostr ele.
e n s e l'7 os:
1sent
(tr. o s:
pocoewwr W.
DnvE TtTLE /508.)sCT us.
oog.vete*4T Wo.
T*)
Z'lV)
GL R.D u
l-SO-%
' ' ' C
'I
..L 2%
e, se G.E., NcCLtWL ENot4'f D* V.S t ou - m e*wTut.y Sr%Ashi.8) Fv=iTl6u(G v De
( 'b 5 hts.)
Fct 4%
-- --. >ccs m g?uG R.
g u
I, se ES & fr Pc '> tTJ o n, M P P L* (<Wi ost, tDvQ ssvc!V.'.fL__.7 / :', l 60 I
gay e,
s, ss
'U
D 10 s Ov&1 O PG m E>u e RE.CcLD - S. A m. EC
[G SetT5. h e,
W o rtK CEcc o f'oit.
W t'Ut tk 3 ) ( t 5=+T.)
e.
i, LeTTDL ro r (1-5. TCHewSoy ** G M C. L. Cc 6LG2. ts 5-60 263 svaNtt: oesia,v v en s ce umd,u wocie t2CC wtO PcTt. w arv To3l[65st15) ie
I 7g4 g,etTez, Frtvm S. A. m. UI.
TO C. L, Co 6Letz. i', - l-t o 265 5vs: (.ar. IIt cH Augc >
wods4 C EtutLO F-1> R WCW Mi (l MT, WT4) ll )
v 2 ##
<Z
\\=
rt W"w ' '# i \\ ~P'
'f # * * * *"*5
( *i' S"D-)
=
v t CTTOL Tt : c. L. c ork.ert. Pam
5. A. m. 'tzt i. z. 6 - t' o go seis m r aev n. & c - = u o, n,%rmw.~e.
sv o. emmR.O.s,m),___
e,
o. A. Ne>es terruz S
1-Po ( 2 sitv,. )
ggcg Gu0e t4 CECcto Ftyt L* W y. % 33 ( 6 sg. my,q Ogsg l g gq g 1
(E I">
F< ce Pt **&T ouv>
E *c (t. c i%= NoTit'tr *?
Dx. I. O. S I Z D 7ti to l
gql s
( 7 Sttw.T
'e LcTTLrrt. : TV -P-Pg. % nr6 A Tio F r.3 3
5. et m. 'UE 3.i3. t v i
I gq L 8,
l
%; Tar ovc(I. c, i o. 9 ec. ev 30 s
( 2 3 4 r5 )
TYPE of DOC:
Dwr, - DPAd oNG LT R. - 1.E T T E R.
I SPEC-SPECt 8"IC ATeod pro-ProcEOueC att - Q A TMH O A L 1
I o - q c ooconswr -.
u
ijjIl1l I
l
)
_)
, r I
t, 7
=.
s,.
i n
C t
a t
c.
i s.
~
N I,
_ m.
I T
cv t.
7 v
r
_ o c
v F
o x.
'l F.
i
(
N
_3 s
o
(
e 2
L)
(
v o
r
_ c 2
(
b i
F bn C
7 T
d eS a,-
,0 7
o,
w c
T 4
5 q
5
.r e
t (2
. m..E r\\
S T
S T.
1 2)
I L
I o
r 4
mue
?
c c e
t x
e 2 e M
i m n m
se r
1 T, m i
ea
)
o I
. 2s T.
cps 6e L_ -
Z a
y.-
w u
oen
. _ D.
i E
s S (t \\'
A
f. c Z.
C yt 3
a o
DRp n,
_}
5 t
T.
r
) 5 u
i 9) m, (s I
1 T _ n, T
4 T.
T 6
A n
s i
m c_
4 u
4, o?
s T
a 3
i5
'c S
e A-L a msi 4 c C4 L
c 4
s I
5 F
a o
I '>
s
).
uc c
s3 5 A m,
(
O 0
I o
4 s
M w
D F
o 5
c
. a E
(,
2 I
(P H
- C Ug n(
5
(
a w G
(
5 e.
i I
2 r u
m _c 2
0 w
t t.
A.
e.
r T,
s y
f) t ' 6, 4
T Fe2 2, )
34 4,
, E
( T) m t
o e e
F w
s. c c
i a
L O y m
^
p c
e s
a 7
. r o
e f c
%g 4
3, 4r r
E
?>
?S ot a
4n
, wF 3 v o
u y
J 2 u
- a e
i S
te Bs o
wU 2
s wn.s qw w, Z
u 6 i F F
o n
L m
K >T.
D s
0 e
s m t
F E s"
t i
c 2
x o
R r L-t
+
e E W. W o
y(
v r
2
^
E
/
<" i *
.ne w
(,v
+
t P /
C g
F v
c L
?.
s P
o 7
Z d
C
,, a GP t oi y_ Cs
6
'r s
C T w
v l
u OS ' - 4 s <>
a.
W o
c ) 5, w
4
.L s
e s
e c *.
r c
I i
e 3
w
i. cS V
6 e
A P v7 t
T i c.
u y2 I
L s
o%
t A
c c.
T I
H c 4
O o
t t
(
i no c
X D p. C' v
t C t etr u cis c, o
- T E
c F
s-F p A F *s
. u E.
e T
P D **' o' x i
i 4
DT
'v c
e
's 4
D,,,
A G
LA o
4 a
L.
y E 5 c
O n
( <
8 o
r E,
O e
E F
.t S
C C v t.
S T
r e
c z
t o eC P
CO t
.v s%
o
i g Gb t
c c
f T
O.
c N
'w 3m om i
w t
r D
c -
b S
e T
oR t l3 t
t 7
6 v
i N
T) o-T,
r 2
c rE 5rGt Ta E.
c T.
E E *S n L 6
.EI t
e E F A2 2*
T i
y tC tu M
2 tA n
F 4
W s
L I
T i Nm t
.c c
f e
c.
c t
O b-
"2 oi I
e c) o 5' us i
s t. a4 i C T ci cE n
ET 2f e c
XC E L
C
'6 C' (
T T
a f
s T
T r r i i s
T v
x T
T O
r 4
K e
'J T T T s d 6 e
u r
L% S(
O s
C :a oN eI E 'o C
W (f L
G(
w o
s cE T
D n
vE i
Ls L
L Lr L
t r
2 i
1 R.
c E
E c-T m
w i,
t, 4
T e
e s
e E.
D 4
L i
V.
A E
1 R
T 8
T s
L Z
(
r
S e
e e.
r o
a C
w.
2' t-e d
.o M
o w
.T e
c fE1.W t
N ARA E t
GCul t
r t u I
w C MFONc O
.s
.n o.
tEAo R
I I
D Wcc M D, o
u e
fEo%c T
u c.
(
e u
F PPrf c
so C
i, e
O DSPQg E
uo EP P S o n.
E e.c gD Eot N c P
o3 IS nw 3
4y G
G6 q
dip rat Y
D g5 (o
_T DSPqg ri C
g c,
c C
4 O
0 0
2 2
p 2
2 2
3 3
3 3 3 3
3
,l jl
INSPEcTo R R. Cocett A scu_T 90.-
St. OPE DOCOME*4TS E)( At4 s d E D RE m rrh.
pasE 14 o s:
l".
MMy
nsar nav.
OmE Tine / sos.3scT w
se:. ITm LcTTu Tos F. Sic R 18mht. F F6M 3gb EC W I-D0 %
T. E en ggt a.
M g 'i-2 -t o Sun. >vs 5 P L2wth du ruvm oo2s ( l S HT. )
2 13 wcee izeccco Pc5t "Le<- evy7 (4 3ag +z sm,. cup.p h/.pm m %)
309 4.
LETTER nu r c.
. co6to Tb r sa.m.E 9 -io-So 3iO s is. Fata '>noe oesidiu c e^ua n t,
i Wcc #4 9Eccsto F 0ft. W E'aiN 90 56 ( Ca s>4 TS. )
f
~
t, 8
LOTOL TD, O STE s 6$resw( LesT isumown ) r p,w 3.E. Covi7tg 9-M-$g r
.S u S 7e::t T -
DC5td., (2evstDe Ecyt enooc waTie+ #ars M, in o D,
n@o w e s $ cio (cPy 0F Pe s i,T-ovT To LEE, P ee,t.) W h e-
'i-rf-f,o C C,0 L.e ST.
i, i,
e, intyso ru t er t*szcw 5 rym (ei 64 4
wi ATin.+to cocoe.r. Atr.om Reus. 30
5 Y4ded. T 9 0c t y si
toe,].
Faz w p c, ItuPV,Ls 9-#5-3g se le LETTER Tb 3. C tavTA5 o
5 v o i Q)=_CL._14p_fd t h. Fl?rt Tsc't N t,
LeTevt tn DisT>t a c vsb ( LesT l-C c woED F g sw
'J. f. Ca.vht3
<} - i 7. go its c.
5o(5 : Desada ( e iniekt h G Vs Ew ' S D. P ert At t.
VotT. P/tyo.s E
T m an u To: S. A. ns,. R F r$sm. C. F. Pi tfle h - 8 5-4 0 wee ><. +ovi ( t sar.) 1_
DivC 5 M
( ~2 Sms.
F_e?.
To n.5 P(O_,peu s,
e, Woc Recco r oz 3gg
- ~ ~ ~ " ' ~ ' -
LeucV. RErotto fcit WEEx So40 ( 55ms.)
t,
~
~~"
i, e,
LOTb1 to ideo Poti27 F Rrm C.7- ( u Bt.C
i-3 BO g
I S.c5 : D E7.-
tv a.T e t.
Iv w o.tn /6 77 l' ( l s wT.)
yg G o cn Lt. m t. Tn. s.a.or 'in pa.m venuoc.um;
i-4. co
't Dwo.
Des ( J @ t M tem C ev t/. / f Sr*T. l E.NQ #7.. CHQ, ycr. ( ? ) ( ok'(7tELTiuru ll) r Cru A'3-IB22./
7-? T-St.)
i g{
TYPE OF DOC:
.a OsJG - DRfW ING LT R - L.ETTE R.
SPEC-SPEtt FIC AT40*I peo-ProcEOueE qatt
'48%tM Mt)AL.
QcD - gC OccunoJr
\\
l i
l.
i j
e i
i I
l i
i I
c f
l i
.1,,
j 1
J e
r I
l i
i o4 l
l 94 i
l l
l (1
A.' +r i
i i
C 7
i
.e o
2jo
- l I
k N
4 2
l j vw l
j ofd F
.o EEE
.1 I? I I
d o
(
7
.?
o g e a
g 4
j e
O S
k w
N c.<
3 g
-1 5
E a
I
\\
2 f
i; 12 x
6-ul G$
0 te l
ew C tJ 2w o5
{
he t3 a
c ne 4
O W
N 6
E W>
a T
O
~
~
a
i, o l
l I
a
-s
[r e
e G
d 4*N h
li s.
o o
4 y
1 o
4.J "J Sgg W

O M 3 "J I
$ 2u02 3 E
O
15EEc E
8 o
s
~
El e a ggav a w ya.
i>,ii e
w
,o
,i A e
'I$fCEO s
coEew
."'N'N>
I jw i
r0 in O
.-.,,-n,,, -,.
,, ~ ~ - -
-n
i i
l4 l
l
.i T
I' g
}
g e
'2' I
i i
e, i
y
-l si q
q d
B
\\
\\
J t
s>
cq
' N' li i al i
a
' g/.g/
6 f
c-l A t
p u
h;
! 6-dg i, n i
4 l
i i
~
t g
-b q
x t
G L
o
\\
)
~t L
n G $
2 j
.-(
ci E f
)
J m
. q.
a c-I
.~(
'f Ml
}
l y]g es x
to v
c-x 1
J J
L4 fi T
2 i
n
$w i 8!
0Wg
[,J3
!U f1 m
1
(' f M
m 0
F m
gs2 C-2 A 0
[
fL
<e T
O s'
b M(
0 b
0
't y
cr; p
u C2 4 2
c, F
w.
)
rd' d^
p t.
~
a L'
0 r 3 s
v o
0
'h M
u b V
O 3
$ >a i
g s
e W
Ig
^
j O
-(1 )2 v
3 ut a
dj s
u u
4 P @
2 -?
r3 1
C n l
y C
> a:
4 1
~
d g
y
-)
9 8' d j
q k
E E 5 A
$ A j k 2
'=4 E
b A 5
b i
i
{2 k
~2 3
! lv D
o i
)
8 0 j@
L 3
b d
- 3
.s o
i Ll\\c I
%o o
o g
4 A <o S
o G
w w
Yv e w 0
e A
k l 2 7
<S k Y h
s a
itill I
i I
at t
d
j l
O 2
1 F
23 Ebr cynog o 2uo2s a
a E 555 u s.c $ c g
o, j
J 4
h y
8 h
5 O
O cm o
to
-+
co
+
uJ 18 4
j 2
2 o G@ggd '
V 2o A
Y L
i 2 e, g,, ':,: c, l
5 If j
l 2
76 V
y H
l i
i w co W a
i i
,,y
.,m
,-,--m..v--,__--,,s.
w -
s h'
i si GE ALLEGATIONS
.Approximately three man-months expended to date.
VPB reviewed over 2000 separate documents of Mr..Milam (alleger) in-addition to GAP's consultant report.
Concerns raised are.very general and surround potential deficiencies in the QA system at GE, San Jose, during the period 1978-1982.
GAP summarized alleger's concerns into approximately 170 items falling basically into two areas: Design Control and Deferred Verification A review of the documents submitted thus far reveal no immediate safety problems exist.
One week inspection, performed at GE April 14-17, produced no violations or nonconformances. Approximately 15 of the concerns raised by the alleger were reviewed and none were substantiated.
VPB conducted an interview with Mr. Milam during the same week under a sworn deposition. Again, Mr. Milam stated he had no speclfic safety concerns, just generic problems with GE's QA/QC system in the past
\\
s m
e%~
s
,[
,']
9.
p VPB OPTIONS i
Turn all documents submitted to NRC to GE
- 1.'.
Have'.GE respond to is'ues raised s
Individually?
Generically?.
Real time or 1975 time frame?
VPB audit GE's response 2.
VPB conduct comprehensive 1-2 week inspection in several key-areas,1.e., Design Control, Deferred Verification, Part 21 and Training.
h Inspection to be general and will attempt to umbrella major concerns raised by GAP and the alleger. This will eliminate the tedious and -time consuming effort by VPB to address each issue identified.
Place all documents currently in NRC possession in PDR. Strike all references regarding allegers personal matters, if any, while at GE.
1 Respond in writing to GAP's October 5, 1985 letter.
i t
l e
D
^'
g****7*
4 6
F
a
,g a f
4 e e a
w 9
t
-. ~..
~
e L.
R1B-1
~
7 INSPECTION PLAN 4
for GENERAL ELECTRIC COMPANY SAN JOSE, CALIFORNIA I.
. Purpose To review and close-out over 170 allegations made by a former GE nuclear engineer to the Government Accountability Project (GAP) regarding alleged deficiencies in Quality Assurance / Control activities at GE's San Jose, California, facility.
The primary emphasis will be directed towards addressing those allegations associated with safety-related equipment / services.
II. Scope Six major categories will be inspected to completely address the issues identified to GAP by the alleger:
1.
Deferred Verifications 2
2.
Reactor Mode Switch 3.
Change Requests (CRs) 4.
Engineering Change Notices (ECNs) 5.
.EngineeringReviewMemoranda(ERM) 6.
Misc. and General Items t:
, e ) [_ j; _,, _
.,___,___e c,,__
T-;-pv- +. ____
j; u
, -r III. Inspection Team Make-up
R. Pettis (SPIS)
'R.McIntyre(SPIS)
P.Prescott(SPIS) 2 Consultants in the I&C Area
team leader IV. Schedule It is anticipated that several trips to San Jose will be necessary to completely address the issues raised to GAP.
In addition, a trip to the Los Angeles area will be required to meet with the alleger. A tentative schedule to accomplish this is as follows:
i March 31-April 4,1986 Initial Inspection at GE April 7, 1986 Meet with A11eger in Los Angeles Based on the results of these two visits, subsequent trips to GE will be scheduled.
<r.
,j
~
3-r V.
Areas to be Examined As a minimum, the following areas will be reviewed:
1.
GE Topical Report 2.
GE QA Manual 3.
GE Engineering Operating Procedures It should be noted that the emphasis will be on procedures in effect during the time frame between 1078 and 1982, which represents the period in which these potential deficiencies were referenced.
e t
e 4
e 6
4
_

ML20205N709

Text

Response

Navigation menu

Search