Text

Notice of Nonconformance from Insp on 860414-18 & 0714-18
	ML20207S271
Person / Time
Issue date:	12/24/1986
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	;
Shared Package
ML20207S264	List: ML20207S263; ML20207S271; ML20207S287;
References
	REF-QA-99900403 NUDOCS 8703190221
	Download: ML20207S271 (5)
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APPENDIX A General Electric Company Nuclear Energy Business Operations Docket No. 99900403/86-01 NOTICE OF NONCONFORMANCE During an inspection conducted April 14-18; and July 14-18, 1986, the implement-ation of GE's Quality Assurance (QA) program at the fan Jose, California facility was reviewed. This review was in response to allegations submitted to the NRC, from a former GE employee, alleging potential deficiencies in design control activities within GE's Quality Assurance program during the period March 1978 to April 1982. The QA program requirements are discussed in GE Topical Report NED0-11209-04A, Revision 6, dated June 30, 1986, which describes the QA program GE applies to those design, procurement, and fabrication activities involving safety-related structures, systems, and components of nuclear power plants within the GE scope of work. Section 5 of NED0-11209-04A, Pevision 6, requires, in part, that activities affecting quality are accomplished in accordance with As discussed below, several documented instructions, procedures, or drawings.

examples were identified in which procedures were ont adequately implemented.

Based on the results of this inspection, it appears that certain activities at the San Jose facility were not conducted in accordance with commitments made to the NRC. These items are set forth below and have been identified and classified in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C.

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Engineering Operating Procedure (EOP) 42-6.00, Section 4.1.2.e " Independent Design Verification," issued April 30, 1981 requires, in part, that when deferred verification is t:cmpleted, Engineering Services 1 be notified by processing a Deferred Verification Status Change Notice (DVSCN) form that identifies the verified documents, Design Record File (DRF) containing verification, completion date, ard distribution identical to that of the issued document.

Contrary to the above, Panel Module U710 (assembly drawing PL914E989) for River Bend Unit 1, was verified on Revision 3, dated September 7,1982, Engineering Change Notice (ECN) NJ-34893, but no DVSCN was processed identifying to Engineering Services 1 that the deferred verification was completed. The verification was originally deferred on Engineering Review Nemorandum (ERM) No. AML-973, issued December 2, 1980.

(86-01-01) 0703190221 B61224 PDR GA999 ENVGENE 9990403 PDR -

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General Electric's Engineering Operating Procedure (E0P) 25-4.00, Section 2 and Section 4.3 requires, in part, that engineering work authorizations (EWA) j be used to communicate and establish work requirements between engineering and other. Nuclear Energy Business Operations (NEBO) groups. The EWA shall i

define the scope or work reouested, including changes, additions, deletiens, modifications, and options exercised in existing or new work requirements.

Processing services shall control the issuance of approved EWAs and main-tain retrievable EWA records.

Contrary to the above, General Electric was unable to retrieve EWA No.

FE8446, the document which defined the scope of work requested, per DVSCN No. 01706, for the qualification of electrical components to be 1 electrical circuits, on Nine used in nuclear safety related Category (86-01-02)

Mile Point 2, for panel No. H13-P861.

3.

General Electric's corrective action reouest procedure (CAR) MP-5.01, Section 4.2.3.2, requires, in part, that the recipient of a CAR must respond by the reply date requested, or if unable, will negotiate a revised reply date with the initiator.

If the revised date is agreed upon, it will be entered on the CAR document and initialed by the initiator on the Origiral Copy.

Contrary to the above, these procedures were not followed when a GE manufacturing engineer dispositioned CAR No. SJ.57711 twenty-five days after the required reply date specified by the initiator, and a revised reply date was not negotiated with the initiator.

(86-01-03)

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Engineering Operating Procedure (E0P) 42-6.00, " Independent Design Verification" Section 4.1.2.b issued April 30, 1981, requires, in part, notification of Engineering Services 1 by processing an accompanying DVSCN form that identifies the document, the scheduled date of deferred verification completion, DRF reference if applicable, and distribution identical to that of the issued document.

Contrary to the above, this procedure was not followed in that the required DVSCN was not completed and GE's Engineering Services 1 Department was not notified of the deferred verification described in ECN NJ-43120.

(86-01-04) 5.

General Electric Company's Nuclear Energy Business Groups (NEBG) Procedure No. 70-30 " Personnel Proficiency in Quality Related Activities," dated February 28, 1978, Revision 1, Paragraph 2 states, in part, that each new employee or employee assuming a new job assignment using different system procedures, shall be indoctrinated or instructed in the system procedures within three months of the date the employee assumed the assignment.

Contrary to the above, training records reviewed for 3 GE employee indicated the employee was not indoctrinated or instructed in system procedures within three months. This individual attended a QA course fifteen months after assuming a new job assignment, rather than within the required three months.

(86-01-05)

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Criterion III of 10 CFR Part 50 Appendix 8, requires, in part, that the verification or checking process be performed by individuals or groups other than those who performed the original design, but who may be from the same organization. GE's Engineering Operating Procedure (EOP) 42-6.00,

" Independent Design Verification " issued April 30, 1981, states in Section 4.1.1(d)(2) that the Verifier may not be directly responsible and accountable for the design or design change being verified.

Contrary to the above, GE issued Engineering Review Memorandums (ERM),

AMD-1302 and AMC-3035 in which (1) the designer was identified to perform the document review and (2) the assigned reviewer also provided document approval as the responsible ergineer.

(86-01-06) l' i

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APPENDIX B ITEMS TO BE ADDRESSED BY THE GENERAL ELECTRIC COMPANY This appendix contains items in which the NRC requests a response from GE, in addition to that requested for items of nonconformance (Section B) and unresolved items (Section C) of the attached inspection report.

The items referenced in this appendix are contained in allegations made by Mr. Sam A. Milam, III, and formed the basis for a draft report prepared by Mr. Charles E. Stokes, a consultant for the Government Accountability Project.

A brief statement, referencing the areas / items to be addressed by GE, has been included along with a grouping of the applicable sections of the Stokes report.

Documentation generated by GE in response to each item reviewed is to be maintained in San Jose and made available for review by the NRC during a future inspection.

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. Item No.

Description 1

Implementation of Independent Design Verification, Design Control and Procurement Procedures per GE E0Ps and 10 CFR 50, Appendix B.