ML20207S287
| ML20207S287 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1986 |
| From: | Jocelyn Craig, Robert Pettis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207S264 | List: |
| References | |
| REF-QA-99900403 NUDOCS 8703190240 | |
| Download: ML20207S287 (44) | |
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{{#Wiki_filter:- _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ __ , 8 ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION INSPECTION N0.: 99900403/86-01 DATES: 4/14-18; 7/14-18/86 ON-SITE HOURS: 248 CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operations ATTN: Mr. N. L. Femus, Vice President j and General Manager 175 Curtner Avenue San Jose, California 45125 ORGANIZATIONAL CONTACT: Mr. J. J. Fox, Senior Program Manager TELEPHONE NUMBER: (408) 925-6195 ( NUCLEAR INDUSTRY ACTIVITY: General Electric Company Nuclear Energy Business Operations (GE NEB 0), has a work force of approximately 2500 assigned to domestic and foreign nuclear power plant activity. ( ASSIGNED INSPECTOR: b- [2 $4N R.'L. Pettis, Special Projects Inspection Date Section (SPIS) OTHER INSPECTOR (S): R. McIntyre, SPIS P. Eshleman, Consultant P. Prescott, SPIS Q. Howard, Consultant APPROVED BY: b_ s ~ M1- Sb Jbhn W. Craig, C)ief, SPIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE: A. BASES: 10 CFR Part 21 and 10 CFR Part 50. B. SCOPE: The purpose of this inspecticn was to folicw up on allegations involving potential deficiencies in design control activities within the Quality Assurance (QA) program at GE San Jose, during the period March 1978 to April 1982. PLANT SITE APPLICABILITY: Petentially multiple plant sites including River Bend , TVA Units 17-22 (identified by GE as cancelled), Perry 1/2, Nire itile Point 2, Hope Creek 1/2, Grand Gulf 1/2, Limerick, Clinton, and Susquehanna 1/2. 8703190240 861224 PDR GA999 EMVGENE 99900403 PDR
a . ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 2 of 25 A. VIOLATIONS:
- None.
B. MONCONFORMANCES:
- 1. Contrary to Section 4.1.2.e of General Electric (GE) Engineering Operating Procedure (E0P) 42-6.00, " Independent Design Verification",
no evidence existed to support the processing of a Deferred Verifica-tion Status Change Notice (DVSCN) idertifying, to Engineering Services 1, that Panel Module U710 (assembly Drawing PL914E989), for the River Bend project, was cleared of deferred verification. (86-01-01)
- 2. Contrary to GE Engineering Operating Procedure (E0P) 25-4.00 Section 2 and Section 4.3, GE was unable to retrieve Engineering Work Authorization (EWA) No. FE-8446. This document defined the scope of work requested, per DVSCN No. 01706, for the ouclification of electrical components to be used in nuclear safety related Category 1 electrical circuits, for electrical panel No. H13-P861.
(86-01-02)
- 3. Contrary to 10 CFR Part 50 Appendix B Criterion XV, and GE Corrective Action Request (CAR) Procedure MP 5.01 Section 4.2.3.2, a GE manufacturing engineer dispositioned CAR No. SJ.57711 twerty-five (25) days after the required reply date specified by the initietor, and a revised reply date wn not r.egotiated with the initietor.
(86-01-03)
- 4. Contrary to Section 4.1.2.e of GE Engineering Operating Procedure (E0P) 42-6.00, " Independent Design Verification," the required DVSCN, which would have documented the opening of a defermert per ECN NJ-43120, was not generated through GE's Engineering Services 1 department. (86-01-04)
- 5. Centrary to Criterion V of 10 CFR Part 50 Appendix B and GE Nuclear Energy Business Group (NEBG) Procedure No. 70-30, Revision 1, Para-graph 2, training records reviewed indicated a GE employea's attend-ance in a QA course fifteen months after assuming a new job assignment, rather than within the required three months. (86-01-05)
- 6. Contrary to Criterion III of 10 CFR Part 5n Appendix B and GE E0P 47-6.00, AMD-1302 GE issued and AMC-3035, Engineering in which: (Reviewwas
- 1) the desigrer Memorajdums identified (ERM's),
s
- ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA
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REPORT INSPECTION N0.. 99900403/86-01 RESULTS: PAGE 3 of 25 to perform the document review (ERM-AMD-1302); and (2) where the assigned reviewer also engineer (ERM-AMC-3035)provided (86-01-06) document approval as the responsible % C. UNRESOLVED ITEM: 1. GE Engineering Practices and Procedure (EP&P) 5.38 Addendum 4, dated December 1975, requires a tracking system and status log of deferred verifications be maintaired. The inspectors verified that the first entry was riade in the status log fer deferred verifications in May 1977. It could not be determined whether or not verifications had been deferred prior to May 1977 since evidence did not exist in the status log of any deferred verifications entered during the period December 1975 thru May 1977. This item will be reviewed during r. future inspection. (86-01-07) 2. The determination as to the correct elementary drawing used as a basis to test Panel G41-P003, for TVA18, could not be determined during the ir.spection. (86-01-08) 3. GE's Problem Review Bcard (PRB) stated in a letter dated June 13, 1980, that a new reactor mode switch should replace these previously shipped and that the design changas required were to be documented via a Field Disposition Instruction (FDI) document. The FDI, refer-enced by the PRB, was unavailable for review during the inspection. This review will be performed durirg a future inspection. (86-01-C9) 4. The resolution as to whether Electrical Metallic Tubing (EMT), incorporates the use of glyptal coating on the inside diameter, as specified by GE, could not be determined during the inspection. This review will be performed during i future inspection. (86-01-10) 5. Specific review requirements for panel compatibility with other system components could not be determined during the inspectior for ERM-AMC 3035, dated October 11, 1978. (86-01-11) D. STATUS OF PREVIOUS INSPECTION FINDINGS: The status remains as presented in NRC Inspection Report No. 99900403/ 85-01. An evaluation of open inspection find 4rgs was not conducted during this inspection.
6 ' ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 4 of 25 E. OTHER FINDINGS AND OBSERVATIONS: Background Information In October 1985, allegations were presented to the Nuclear Regulatory Commission (NRC), Office of Inspection and Enforcement, in a letter from the Government Accountability Project (GAP) identifying deficiencies in San in the design control and Quality Assurance (QA) program at the GE facility Jose, California. A consultant for GAP conducted a review and analysis of this infornction and prepared a report of the major concerns. This 'eport and the employee's work record were then furnished to the NRC for appropriate action. The background information provided to the NPC by GAP was voluminous and addressed a number of issues. This NRC inspection report documents two inspections perforred in response to these allegations. The initial NRC inspections were performed at GE, San Jose in Septen.oer 1983 in response to allegations which were the same as the basic allegations made by GAP to the NRC in 1985. The previcus NRC review of these issues did not include the background information (the alleger's work record and the report prepared by fir. Charles E. Stokes, a censultant for GAP) provided to the NRC by GAP in March 1986. A chronology of the major milestones is as follows: October 21, 1983, NRC inspection at GE in response to allegatfors nade by a former GE employee. November 21, 1983, GE responds to NRC Inspection Report No. 90900403/ 83-03, dated October 21, 1983. October 5,1985, letter from GAP which highlights concerns raised by the alleger and the GAP consultant; requests NRC/ GAP meeting. October 29, 1985, NRC responds to GAP letter and requests all pertirent information, specific allecations, and censultant's report be sent to NRC for review. Between October 29, 1985 and February 1986, discussions were held anong GE, GAP and NRC to work out details to obtain NPC access to allegers records held by GAP. February 1986, NRC inspection team reviews records at GAP's Washington, D.C. office (approximately two weekd .
a . ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS _ SAN JOSE, CALIFORNIA REPORT INSPECTION RESULTS: PAGE 5 of 25 NO.: 99900403/86-01
- March 10, 1986, Proprietary Information Agreement executed between GE and GAP relating to non-prosecution of the alleger and non-release of documents considered proprietary by GE.
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- March 1986, NRC receives records from GAP.
- April 1986, telephone conversation between Mr. R. Pettis (NRC) and the alleger to set up interview in San Jose, California, during the week of April 14.
- April 16,1986, NRC interviews alleger in San Jose.
- April 14-18, 1986, NRC conducts first inspection at GE, San Jose.
- May 6, 1986, NRC sends alleger copy of transcript for review and correction, where applicable.
- June 1, 1986, alleger responds to NRC letter of May 6 by sending corrected copy of interview.
- July 14-18, 1986, NRC conducts second inspection at GE, San Jose.
- October 2, 1986, telephone conversation between Mr. R. McIntyre (NRC) and Mr. A. Jackson of GAP concerning GE inspection results and status of resolution of allegatiers.
- October 8, 1986, telephere conversation between Mr. J. Craig (NRC) and Mr. A. Jackson of GAP concerning GE inspection results and status of resolution of allegations.
- October 24, 1986, GAP sends letter to NRC requesting information concerning NRC's action to resolve corcerns raised by the alleger.
- November 4, 1986, copy of corrected transcript sent to the alleger by NRC.
- Decenber 2, 1906, GE representatives performed initial proprietary review of allegation docenents at NRC in Bethesda, MD.
This report does not address all of the items raised by the alleger and Mr. Stokes. Rather, a representative sample of potentially more signifi-l cant allegations were selected for review. These allegations were primarily in the area of deferred verification, which, represented a large
. s ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS
- SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 6 of 25 portion of the alleger's concerns. The remaining allegations were not reviewed in depth during this inspection, but are a part of the NRC's O
continuing review of this natter. The representative sample of allegations inspected are summarized below, along with the results of the inspection of each item. The inspection was comprised of personnel interviews, examination of applicable files, records, and procedures. Note that references made to nuclear power plants identified as TVA (17-22), in the inspection report, represent cancelled units.
- 1. Deferred Verification Introduction Independent design verification is the process of reviewing and substantiating a design, to provide controlled, independent, docu-mented confirmation that the design meets its requirements. Stated simply, independent design verification is confirmation of design adequacy performed by somenre other than the person responsible for the design.
Deferring verification is a GE process by which items such as design, quelification, and manufecturing changes can be deferred until after design document issue due to incomplete design or other reasons. This process is presently described in GE E0P 42-6.00, " Independent Design Verification." Section 4.1.2 of this E0P establishes the requirerents that must be followed when deferring design verification. The process of deferring verification has evolved over a period of time. GE initiated deferral of design verification in Addendum 4 to Engineering Practice and Procedure (EP&P) 5.38, " Design Verification," in December 1975. This stipulated that a tracking syster and a status log of deferred verifications must be naintained. However, the NRC inspectors verified that such a status log was cet initiated until May, 1977, as evidenced by the first deferred verification entry. Unresnived item (86-01-07) was identified during this part of the inspection. In July of 1977, E0P 40-6.00, " Independent Design Verification" replaced EP&P 5.38. This procedure had the same provisions as EP&P 5.38 concerning the tracking system and status log for deferred verification except they were to be maintained by a different group. This E0P remained basically the same until April,1980, when E0P
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA
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REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 7 of 25 40-6.00 was changed to E0P 42-6.00, " Independent Design Verification." This change included Section, 4.1.2, " Deferring Verification," which established the guidelines to be followed when deferring verification. % This section also stated that when verification is deferred until i after the design document is issued due to incomplete design or other reasons, the Engineering Review Memorandum (ERM) or the Engineering Change Notice (ECN) issuing the document rust state:
- 1. That verification is deferred;
- 2. The reason for deferral;
- 3. A schedule fer performing the verification;
- d. The Design Record File (DRF), if applicable; 5.
The signature of the Responsible Design Engineer's Section Manager euthorizing deferral. Verification status of documents with deferred verification is con-tained in the Engineering Information System (EIS), a computerized data base, maintained by Engineering Services 1. Engineering Services 2 records and tracks deferred and additional verifications in the Work Planning & Scheduling System (WPSS). Engineering Services 2 is responsible for closing cut completed verifice. tion tasks upon receipt of a Deferred Verification Status Change Notice (DVSCN) from Engineering Services 1. Engineerirg Services 1 is also responsible for revising verification status of the docunents in the EIS. At this point in the process of deferring verification, e DVSCN was only required to be utilized when completing a deferred verification. On April 30, ?81, E0P 42-6.00 was issued which superseded the April a, 1980 version. This E0P required a DVSCN to be processed and accom-pany the ERM/ECN when a verification is deferred. The DVSCN, sent to Engineering Services 1, was required to address the five (5) reouire-ments, listed above, to be followed when deferring verification. It also included a requirement that when the deferred verification was ccmpleted, Engineerino Services 1 must be notified by processing another DVSCN that idertified the documents which were verified. Engineering Services 1 was responsible to enter the status of the deferred verification into EIS and notify Engineering Services 2 to track the completion in the WPSS. E0P 42-6.00 was revised December 5, 1983. effect. Among other items, this revision further This revision is still in defined the role of the DVSCH when opening and closing deferred verificaticn.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPEPATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 8 of 25 When the hRC inspectors attempted to review specific allegations concerning documents being unverified or released with incomplete deferred verifications, the NRC inspectors were informed by GE that % to accomplish this review ERMs, ECNs, etc., must be tied back to design documents in the EIS. This would necessitate a review of essentially every revision of the design document including all ECNs, etc. Due to the magnitude of the review required for each allegation, the NRC inspectors reviewed a limited number of issues concerning deferred verification. completion status Theoninspectors the EIS. were able to view the current document designation "C" when complete and verified.This status is indicated by the This information informs the EIS user that the document is not in an unverified status but does not include any of the document history. GE stated apartdocument's the from the EIS.revision history is maintained in a separate file The following are several examples reviewed within the area of Deferred Verification. These examples did not ccnstitute formal allegations made by the alleger, but were chosen by the NRC inspectorsverifications, deferred based on the alleger's overall concerns involving
- a. Rive- Bend Panel Module Assembly U710 Several documents were selected and reviewed from the deferred verification status log to determine whether selected deferred verifications where completed and verified in accordance with the requirements of GE E0P 42-6.00.
ERM AML-973, issued on December 2, 1980, for Panel Module Assembly 0710, on assembly drawing 914E989, for River Bend Unit I was reviewed. completion of the cable and panel design.This The inspectorERM deferred v reviewed the drawing through its revision levels while reviewing numerous completed. ERMs, to determine if the verification had been associated It was determined that ceferred verification was completed on Revision 3, of parts List 914E989, via ECN No. NJ34893, issued May 13, 1982. GE could not provide the DVSCN that was processed, notifying Engineering Services 1 of the completion of the deferred April verification, as specified in E0P 42-6.00, issued 30, 1981.
o . ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTICH N0.: 99900403/86-01 RESULTS: PAGE 9 of 25 Section 4.1.2.e of this E0P requires notifying Engineering Services 1 by processing a DVSCN that identifies the verified ) documents, DRF containing verification, ccmpletion date, and distribution idertical to that of the issued document. Nonconformance (86-01-01) was identified during this part of the inspection.
- b. Nine Mile Point 2 Electrical Panel The NRC inspector reviewed DVSCN No. 01706, issued December 19, ,
1984, as a result of a discrepancy with electrical panel No. H13-P861, installed at Nine Mile Point Unit 2. It stated, in part, that the panel contained components used in nuclear safety-related Category 1 circuits which were not qualified and that the qualification for the circuits was performed in accordance with EKA No. FE8446. EWAs are required by GE's E0P No. 25-4.00 and are used to communicate and establish work requirements between engineering groups and other GE NEB 0 functional organizations. The EWA defines the scope of work requested, including changes, additions, deletions, modifications and options exercised in existing or new work requirements. The NRC inspector requested EWA No. FE8446 for review. Although GE presented documentatior which demonstrated a complete follow-up of the cualification for the electrical circuits, the document required for the initiation of the qualification process, EWA No. FE8446, was not available during the inspection. Nonconfon.ance (86-01-02) was identified during this part of the inspection.
- c. Linerick Pressure Transmitter The NRC inspector reviewed ECN NJ-43120 and DVSCN No. 0?294 ECN NJ-43120 was initiated on March 30, 1983, due to a discreparcy noted with a pressure trarsmitter (Model No. C41-N004 ABC) which was selected to be used in the standby liquid control system at the Limerick Nuclear Plant. The ECN specified that the pressure transmitter was not qualified to the applicable requirements and a note was added to the ECN requiring that the verification for the iter be deferred until work week 8352 (December 1983). Close-out of the deferre& verification on ECN-NJ 43120, DVSCN No. 02294 wat initiated on January 21, 1986.
. s ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 10 of 75 The NRC inspector noted that this date was beyond the scheduled verification completion date specified on the ECN. GE could not j produce the DVSCN that had been processed notifying Engineering Services 1 of the deferred verification as specified.
GE E0P 42-6.00, issued April 30, 1983, Section 4.1.2b, requires that Engineering Services 1 be notified by processing an accom-panying DVSCN that identifies the document, the scheduled date of deferred verification completion, DRF reference if. epplicable, and distribution identical to that of the issued document. Nonconformance (86-01-04) was identified during this part of the inspection. The following examples comprise selected allegations from the work record of the alleger and the GAP consultant.
- d. Engineering Infermation System (EIS)
Allegation - The alleger stated that EIS is relied upon in all sections of GE and by vendors to trace the status of a document and to open documents tied to a particular reference. The alleger further stated that this system is designed to maintain only the most current document information and does not maintain a permanent record which can be used by QA to verify past actions. Inspection Finding - GE stated that all past revisions of EIS are microfiched and archived for future reference when the EIS is periodically updated. The alleger is correct in stating that the EIS maintains only the most current document informa-tion. However, the EIS was designed to maintain current design information and was not intended to maintain a permanent record. This allegation was not substantiated.
- 2. Design Control Introduction Design Control is a process whereby the design of structures, . -tems, and comparents is controlled within the various design orcanizations at GE to assure safe and reliable performance of, products and services to be supplied. The design control processes are documented in prac-
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 11 of 25 tices and procedures which establish the responsibilities and inter-These practices and procedures include requirem % activities to be carr.ied out in a planned, controlled and orderly manner with appropriate quality requirements and standards specified in the design dccuments. The following review of allegations include issues which would be classified under the area of design control,
- a. TVA Electrical Panels Allegation - Panel G41-P003, for TVA 18 (cancelled), was alleged to have been tested to the Grand Gulf elementary diagram.
Inspection Finding - Based upon the documents reviewed, the inspector could not determine whether or not the panel was properly tested. A review of connection diagrams for G41-P003 for Grand Gulf and TVA 18 indicated only minor differences. Copies of the elementary diagrams were requested for review, but the drawings presented were the latest revision which did not allow for the comparison during the inspection. Unresolved item (86-01-08) was identified during this part of the inspection.
- b. Elementary Diagrams - TVA 18 Allegation - It was alleged that electrical was tested to the wrong elementary diagran. panel No. No.
Drawing H22-P007 851E478 Was used intead of drawing No. 386X994-007. that the EIS system was not used by the tester.It was also stated Inspection Findiro - The test procedure for the TVA panel is This document requires continuity and Hipot tes tion diagrams, a power check, and temperature recorder calibra-tion, but the procedure does not call for direct use of the elementary drawings. Both crawings were compared by the NRC frspectors and found to have the same informatier for panel No. H22-P007. Based upon the documents reviewed, the inspector concluded that the parel was tested to the proper drawing. In addition, the test procedure reviewed does not ren W e the personnel for drawingperforr:ing the continuity tests to reference the EIS informaticn. -
o \ ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS
- SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 12 of 25 This allegation was not substantiated.
} c. TVA Panel Interference Problem Allegation - An electrical panel for TVA 21 was allegedly shipped from GE, San Jose, with an unknown generic interference problem. The interference problem was causing the terminal screws, on the second row of relays from the bottom of the panel, to short against vertical unistruts within the panel. The interference problem was first noticed on panels for Grand Gulf 2, TVA 21, and panel No. G41-P001 for the Centrale Nuclear de Valdecaballeros (CNV 1 & 2). Inspection Findings - The NRC inspector reviewed Section 3.11 of GE design contro' procedure, " Field Change Control." The procedure states, in part, that when it becomes necessary to ship products to the site before r.anufacturing is complete (ship short) either by NEB 0 cr its suppliers, a Field Deviation Instruction (FDI) is issued which identifies the work to be completed in the field. Such FDIs identify the necessary ergineering and quality requirements. The NRC inspector requested all revisions to the design drawings for TVA 21, Grand Gulf 2 and CNV. In addition the associated ECNs, FDIs, and Field Deviation Disposition Requests (FDDRs) were also requested for the subject design drawings. A review of these drawings war performed to determine whether the interferences between the terminal screws and the vertical struts had been corrected. A review cf associated documentation and corresponding dates on which design changas were initiated was also performed for the subject design drawings. Based on this review, the interference problem was found to be satis-factorily resolved. This allegation was not substantiated.
- d. Prncessing of ECRs and ECNs Allegation - Although the product desigr engineering section initiatos ECRs and ECNs per the requirements of E0P 55-2.00, ECRs and ECNs were allegedly not being processed in accordance with the requirerents of GE Manufacturing Procedure (MP) 2.28.
. t ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS
- SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 13 of 25 Inspection Findings - An interview with GE personnel and a review of procedures E0P 55-2.00 and MP-2.28 was performed by the NRC j
inspector. MP 2.28 requires, in part, that the product design engineering section would be required to accommodate a change request coordinator, who would be responsible for maintaining a change request log, log all requests, ard issue a quarterly report of all outstanding change requests. E0P-55.200 is an engineering procedure used by the product design section for the initiating and processing of ECNs/ECRs, and contains no reference to MP-2.28. MP-2.28 is a manufacturing procedure issued for use by the Nuclear Control & Instrumentation Division (NC&ID) production department, for the preparatier and use of change reauest to the engineering department for its review and approval. Since there was no correlation between these two procedures, this allegation was not substantiated.
- e. ERM Review Allegation - The alleger stated in July, 1979, that ERM No.
AMC-3602 was sent to Electrical Product Design for Design Verification. However, the reviewer is alleged to have reviewed the docenent for quality rather than performing an independent design verification. Inspection Findings - The NRC inspector performed a review of ERM AMC-3602 for which the Responsible Engineer had specified only a document quality review as identified on drawing No. 14707614 as Item No. 9. Seven documents associated with this drawing which included several technical conments in addition to those relating to document quality were reviewed. The responsible engineer identified Item No. 23, on the dre. wing, as a missing element of the parts list and also noted that all connection diagrams had an irdependent design verification performed or August 1, 1979. The ERM was approved on August 2, 1979, by both the responsible engineer and the encineering manager. This review indicated that deferred verification was not required. The part was identified and added to the design package shortly thereaf ter by GE.
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ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS
- SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 14 of 25 The allegation was not substantiated by the review of the docu-mention since the only review required on the ERM was for
) document quality.
- f. Potentially Reportable Condition (PRC)
Allegation - A review of the alleger's work record by the NRC inspector, for week 8110, (March, 1981) discusses the potential for open safety-related design deficiencies in RPS panel C71-P011, as outlined in a June 4, 1980 GE letter. QA proce-dures for Drafting and Material Control were referenced in the work record as the possible cause of the deficiency, which resulted in GE's opening of a PRC file to review the concerns raised. Inspection Findings - The inspection of GE's PRC file 80-31 identified that a panel replacement for the RPS equipment was in progress for the Clinton plant while the TVA plants identified for these panels have been cancelled. The deficiencies outlined in the June 4, 1980 letter were reported to the NRC on January 15, 19Pl. Design Review Report 79-06, dated October 16, 1979, was reviewed by the NRC inspectors and determined to be the initial identifier of these deficiencies. The NRC inspectors r.cted that concerns were expressed by GE during a review of this issue involving a means to prevent these types of oversights from occurring in the future. GE later concluded in its review that QA procedures did not violate established procedures ard practices. However, as a result of this review the following procedures were revised:
- 1) E0P 42-5.00, " Engineer Requirements Document Release,"
revised February 12, 1982.
- 2) EIP 6.60, " Preparation of Engineering Instructiers for Release to Marufacturing," dated September 30, 1982.
- 3) QAP 7.28, " Shipping Inspection," issued May 14, 1982.
The items ir question were reviewed by GE, in 1982, and later reported to the NRC with corrective treasures idertified prior to installatier of the panels. Procedures used in the design
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTICN NO.: 99900403/86-01 RESULTS: PAGE 15 of 25 process were also modified to prevent the identified deficiencies from occurring in the future. g This item is considered closed,
- g. Electric Metallic Tubing (EMT)
Allegation - It was alleged that EMT, supplied by GE Conduit Products, and others, had been used by GE for over 15. years without regard to the fact that the GE specified glyptal coating was unavailable from any supplier. Inspection Findings - This item concerns glyptal coating which is used as an interior finish for EMT, to aid in the overall pulling of cable thrcugh the conduit. The NRC inspectors reviewed drawinn No. 175A9666 Revision 2, which is a part required for panel fabrication, and related correspondence which stated that the tubing was unavailable for fifteen years prior to the identification by the alleger. An ECN issued January 8, 1981, indicated a review by GE was necessary to renove the requirement to use this glyptal coating inside the tubing. GE could not produce en engineering evaluation to support the change which they stated was necessitated by the unavailability of this ma te rial . This may be an uracceptable reason for this type of product change, since this tubing is utilized in Nuclear Safety Grade assemblies. Design Record File A00-891 was reviewed and reveals a 1980 telephone conversation which identified the unavailability of this material and its elininetion from the product line of the GE Conduit Products facility. Purchase records, prior to 1980, identified the requirement that the tubing be coated witt, q1yptal, however the only evidence available for review was recorded during the QC receipt inspection phase under the catecory of " tubing finish." However, the NRC inspectors deter-nined that the QC receipt inspection did not verify the presence of glyptal coating. Tbc NRC inspectors determined that the glyptal coating was in fact a GE requirement before its remcyal from Revision 3 of the drawing. The determination as to the incorporation of the glyptal coating in EMT for panels fabricated ard used by GE could not be determined from the information reviewed during the inspection. '
, s ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS:
PAGE 16 of 25 Unresolved Item (85-01-10) was identified during this part of the inspection. g h. Open Corrective Action Report (CAR) en TVA 21 Allegation - It was alleged that panel number H22-P008, for TVA 21, was shipped with an open Corrective Action Report (CAR) No. SJ-57711. Inspection Firdings - During the inspection the NRC inspector examined CAR No. SJ-57711. The CAR was a document used by GE's manufacturing department to record discrepancies noted during the manufacturing process of electrical panels and associated components. Shipment of panels with an open CAR is acceptable since an FDI may be written to incorporate design changes after the panel has been shipped. GE's corrective action procedure 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 to, will negotiate a revised reply date with the initiator. If a revised date is agreed upon, it is entered on the CAR document and initialed by the initiator of the CAR on the Original Copy. During the examination of CAR No. SJ-57711, the NRC inspector noted that the CAR had been dispositioned by the recipient twenty-five (25) days after the reovired reply date specified by the initiator. The disposition stated, in part, that the deficiency identified on CAR No. SJ-57711 was corrected by forcibly removing the screws used to make the electrical ccnnection for panel No. H22P008. This was performed so that the panel connections would comply with the applicable design drawings. The disposition also stated that the panel had been shipped prior to the resolution of the CAR. This allegation was not substantiated since the shipment of panels with open CARS is allowed by GE procedures. Noncon-formance (86-01-03) was identified as a result of the failure to negotiate a revised reply date for CAR disposition.
- i. Elementary Drawing Review a) Allegation - It was alleged that elementary drawings provided by the C. F. Braun Ccmpany were not signed by CE employees verifying the design.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT ~ INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 17 of 25 Inspection Finding - The inspector reviewed ERM-AMD 1302 and associated Elementary Diagram 828E526AK titled, "High Pressure Core Spray System," which revealed that design
% adequacy was verified by C. F. Braun Company with GE employees providing " engineering spot check" and "applica-tion" reviews. Several of the GE employees interviewed indicated that Braun employees were trained in the GE procedure for safety-related design documentation require-ments by a program ronitored by GE. Verification of this program was not performed during the inspection.
The allegation was not substantiated, however, inspection of the drawirg title block and the ERM assignment blocks revealed that the same C. F. Braun designer was also listed as the reviewer for this drawing, which has a Nuclear Safety-Related, Division 3, label. Nonconformance (86-01-06) was identified during this part of the inspection. (b) Allegation - It was alleged that CNY Panel No. H22-P028 was reviewed with little attention or reference to the appro-priate elementary diagrams. Inspection Finding - A review of ERM-AMC 3035, dated October 11,1978, (for CNV Panel H22-P028) identified several reviewer drawings comments but no reference to elementary was present. The alleger was identified as the originator of the ERM and also was identified as the Assigned Reviewer for "Ir. dependent Design Verification." The reviewer who was identified for " Interface Corpatibility" and presumably would check the compatibility of this panel to the elementary drawings, indicated a " Review Refused" in the signature block. made 9 of the 10 review comments noted on the The ERM.The a Responsible Engineer was assigned on October 4,1978, after l providing comment resolutions on July 5, 197E, to the design verification comments. The alleger /ERM originator / independent design verification reviewer provided ERM Approvel as the Responsible Engineer on October 4,1978.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 18 of 25 Unresolved Item (86-01-11) was identified due to a lack of information (specific review requirements fer panel compatibility with other system components). In addition, % Nonconfomance (86-01-06) was identified durire this part of the inspection since a single person originated the ERM, acted as the assigned reviewer and performed the sign-off as the "esponsible engineer.
- 3. Reactor Mode Switch a.
Allegation - There were several references made to the reactor made switch throughout the allegers work record. In May of 1980 the alleger retrieved, from these ceferences, six ma,inr items related to the reactor mode switch and formally presented the items to GE for their review. As a result of the alleger cencerns, GE established a Problem Review Board (PRB) ir June of 1980 in accordance with pro-cedures, to review all problems identified with the reactor mode switch and document a plan to resolve the identified problems. The potential problems were also reported to GE's Safety and Licensing Department and a Potentially Reportable Condition (PRC) file was opened in accordance with the requi re-ments of 10 CFR Part 21 Section 21.21. The NRC inspector reviewed the PRC file focusing on the six items identified by the alleger ar.d the ccmmitments made by the PRB to resolve the problems. Tt.e followirg is a description of the cencerns identified by the alleger, GE's response, as referenced in the Problem Peview Committee file, and the NRC inspectors findings. Problem 1 - It was alleged that parts l'st PL 386X240 contained inccmplete information necessary for the fabrication of the reactor nede switch referenced on desigr drawing 195B9497
. 5 ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA
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REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 19 of 25 PRB Action - As a result of a review performed by the PRB, it wes noted that parts list PL 386X240 is referenced on drawing 195B9497. GE could not offer an explanation as to why the parts list was established. The parts list did ont provide any % information necessary for the fabrication, test, or use of the reector mode switch. GE agreed to delete the parts Ifst and the reference to it nr the referenced drawir.g. Inspection Findirgs - The NRC inspector reviewed both. the parts list and the design drawings referenced. It was noted that the reference made to the parts list on the design drawing "PL issued," had been deleted in accordance with the required procedures and the item is censidered closed. Problem 2 - It was alleged that after removing the switch neck assembly to install the switch into the isolation can, it is possible that the switch contacts may become desynchronized. This may result in the switch beine positioned in a spot other than tnat observed by the operator. PRB Action - As a result of a PRB review, GE corrmitted to the following acticr: (a) Revise the mounting design of the switch se that it's disassembly end use of the 4 mountino screws would not be required. (b) Add a note to nuclear safety-related drawing No.163C1487 cautioning against disassembly. (c) Add a test requirement note to the drawing. (d) Perform an analysis to determine if another seismic test on the assembly would be necessary or if a seismic analysis would suffice. (e) Document on the assembly drawing the seismic qualification status. (f) Mount switch assenbly to the front of the bench board using the isolatien box as tFr major support interface rather than the present switch neck.
o ' ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA
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REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 20 of 25 Inspection Findings - The inspector reviewed design drawing No. 163C1487. Incorporated on the drawing was a note which stated, "Do not use/use drawing #188C0835." The referenced design drawing displayed an alternative mounting design and % wiring configuration so that it would not be necessary to disassemble the mode switch before its installation into the isolction can eliminatina the use of the 4 mounting screws. The design drawing elso referenced ECN-NJ 21792 which verified the seismic qualification status of the subject switch. As a result of this action, the item was corsidered closed. Problem 3 - It was alleged that the 4 mounting screws, which hcid the switch neck to the body of the switch, were replaced per an undocumented procedure. PRB Action - As a result of a review performed by the PRB, it was decided that the implementation of PRB action 2 (a) eliminates the use of the four mounting screws. - Inspection Findings - Refer to the NRC inspector's findings for Problem 2 above. Problem 4 - It was alleged that the screw fasteners in the base of the isolator can may become loose and tend to twist on some assemblies. It was also noted that it may be impossible to torque the switch cover screws to an acceptance level. PRB Action - As a result of a review performed by the PRB, it was noted that the base metal tolerance permitted this situation to exist occasionally, however the Problem Review Board (PRB) suggested changing the material to a thicker gauge. In addition, the screw fasteners in the non-base material, would be analvzed to assure an acceptable procedure is in place to provide a higher degree of acceptable assemblies. Inspection Findingt - The NRC inspector reviewed ECN-NJ 21797 which reflected the design changes made to the reactor mode switch frame and erd cap. In addition, a select number of qualificatinn records, which would reflect any discrepancies with the switches previously shipped to the remaining plants, were requested and no descrepancies were noted.
o % ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 21 of 25 Problem 5 - It was alleged that the switch neck assembly was fractured at least once during the installation into the bench-board. ) PRB Action - As a result of a review performed by the PRB, it was noted that the implementation of PRB action 2 (f) will prevent stress to be placed on the switch neck at all times. Inspection Findings - Refer to the NRC inspectors firdings for Problem 2 above. Problem 6 - It was alleged that a note "PL Issued" was removed without benefit of an ECN on drawing No.195B9497, Revision 3. PRB Action - As a result of a review performed by the PRB, it was noted that this item is a drafting and documentation problem.
"PL issued" should not be on the drawing since there is no parts list for this drawing. A file index is provided but should not be misunderstood to be a parts list. The PRB stated that the main issue was removal of the note "PL issued" from the drawing, without benefit of an ECN.
Inspection Findings - In an interview with GE personnel it was stated that, the note "PL issued" was deleted from the design drawing as a class three change per GE E0P 55-2.00. The NRC inspectors reviewed this procedure which states, in part, that, administrative or nontechnical changes to engineering controlled documents that do not affect the technical content of the docu-r:ent, can be made without the use of an Engineering Change Authorization (ECA) or Engirecring Change Notice (ECN). After reviewine the procedure, the NRC inspectors concluded that, although an ECN may have been a nore apprcpriate method for the traceability of the parts list, the procedure that was imple-mented would also be applicable. PRB Additicnal Concerns - In a letter dated June 13, 1920, the PRB stated that the rew reacter mode switch assembly should replace those previously shipped and that the design changes required were to be documented via a Field Disposition Instruc-tion (FDI) document. The plants affected were: Cofrentes,
. o S
i ORGANIZAT10N: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 22 of 25 Kuosheng 1&2, Perry 1&E, Hope Creek, Grand Gulf 182, Leibstadt, Susquehar.na 1&2, and Clinton. CNV 1&2 and TVA were to be corrected in the Control end Instrumentation Department prior ] to shipment. The FDI refererced by the PRB was unavailable for review during the inspection. Unresolved Item (86-01-09) was identified during this part of the inspection.
- b. Allegation - In the minutes of a GE PRB meeting, it w'as pointed out that electrical panels for Kuosheng and Cofrentes Nuclear Plants are of the " pre-compact" design with the mode switch mounted on the vertical surface of the benchboard. In this '
design, the rear scoport unistrut can become torsionally twisted causing excessive force to be applied to the neck of the switch. The review team recommended that a two hole unistrut be used to prevent the mounting support switch from becoming twisted. The review of the panel desigr was assigned to the alleger and his conclusion was that the rear support structure will not reliably provide front support for the reactor modo switches used in both plants referenced. It was recommended, by the alleger in a fornal letter written to the PRB in November of 1980, that the switch frame be securely attached to the front of the panel in which the switch is mounted, thereby removing any possibility of strees on the switch neck.
- Inspection Findings - A copy of this letter was not available in the formal PRB file. The NRC inspectors discussad the alleger's recommendations and the absence of the alleger's letter frcn the PRC file with GE personnel. During the discus-sions the NRC inspectors were presentad a letter from a member of the PRB, dated December 5, 1980. The letter stated, in part, that the PPB believed that the problem review and the subse-quent design review, to which the alleger was a major contributor, adeouately addressed the problem and documented the solution.
GE further stated that, if the alleger remained dissatisfied with the determination reached by the review board, a review of the PRC by the manage of the Safety and Licensing Departrent, as stated, in part, GE NEB 0 Procedure 70-42, Section 4.3, could have beer request by the alleger. However, in GE's respcnse to the alleger, thi; venue for further review was not discussed.
ORGANIZATION: GENERAL ELECTRIC COMPANY - NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 23 of 25 l Within the area of the reactor mode switch allegations, no non-conformances or violations were identified.
- 4. Indoctrination and Trainino A review of the alleger work record indicated a potential deficiency in the area of QA training of Centrol & Instrumentation Division (C&ID) engineering personnel. In addition, during an NRC interview with the alleger, statements were made which indicated a resistance among C&ID personnel to tign up fcr such classes. It was also stated tFat GE NEB 0 managerent did not encourage assigned personnel to participate in such classes since it took them away from their job duties.
As a result of these statements, the NRC inspectors reviewed GE's E0Ps which defined the responsibilities for developing, administering, and conduting QA training activities withir GE NEB 0. In addition, personnel and training records, of the alleger, were reviewed in an attempt to define what training was comp 1nted,
- a. GE NEB 0 GE's employee training program began informally in March,1975 thru the issuance of their CA Newsletter to the Boiling Water Reactor Systems Department (BWRSD). This rewsletter was the first in a series of informative publications designed to report useful infcrmation, and significant current events affecting BWRSD personnel.
The first course " Charge Control System," scheduled for April 7,1975, was designed to acquaint BWRSD personnel with the proper applicatfor of GE's Engineering Practices and Procedures (EP&Ps). In December, 1976, GE initiated Nuclear Erergy Business Group (NEDG) Procedure 70-30
" Personnel Proficiency in Quality Related Activities," which was intended to establish the minimum personal proficiency recuire-ments to be implemented within the ruclear energy business groups in support of the overall QA program, as required by GE policy.
This procedure also states that each new employee or an enployee assuming a rew job assignment using different system procedures, shall be indectrinated or instructed in the system procedures within thrae months of the date the employen assumed the assign-ment.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REFORT - INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 24 of 25 In October 1978 GE issued QA Newsletter No. 40 which was the first to mentior the issuance of E0P 75-5.00, dated June 16, 1978, which formally established the GE Quality Assurance Training Program. % This procedure stated that individual managers had the overall responsibility for determining the specific needs of personnel assigned to them. A review )f the alleger's training ree.ords, by the NRC inspec-tors, indicated that while under the supervision of Mr. C. W. Hart, (Radiation Monitors Engineering Unit), during the period March 20, 1978 thru March 29, 1980, only one OA training course was ettended. The course entitled, " Change Control" was attended by the alleger on June 14, 1979 almost fifteen months after transfer from a GE group respons,ible for performing advanced fuel design calculations to the C&ID Department. Nonconformance inspection, (86-01-05) was identified during this part of the
- b. Training of Subvendors Allegation - It was alleged that during the October 1981 time period, an individual working for Omtec, a subcontractor performing work for GE, had difficulties working with GE's documentation and deferred verification system. The areas noted by the alleger were in the use of the Master Parts List, and a lack of understanding of GE's documentation control system and verification status. The alleger also questioned the training this individual received or the use of the GE EIS.
Inspectier Findings - During the irspection, GE infomed the NRC inspectors that this individual had been errployed by GE, frcm Jaruary 1977 through September 1981, prior to accepting a position with Omtec. The NRC inspector was also presented a training file for this individual, dated February 1978 through September 1980, which included the completion of the following courses: and Design Field Documentation, Design Record File, Change Control Verification. GE aise stated that they do not have separate traiaing proce-dures for subvendor enployees. GE however does require that subvendors, who have employees utiliHrg the various GE systomr.
. o ORGAN 1ZATION: GENERAL ELECTRIC COMPANY HUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 25 of 25 inform GE to insure that the employees receive the required training in these vital areas. A listing of subvender employees who had received training in these various areas was presented ) to the NRC inspector for review.
The allegation was not substantiated, and no nonconformances or violations were identified in this area of the inspection. i s
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g n 1-31-851 Fuel Pool Cooling & Cleanup System - Elementary (GE) b'DWG 828E256BA 16 g 2? DWG 386X994-034 1 10-30-79' Fuel Pool Coolina & Cleanup System - Elementary (C. F. Braun) Rod Control and Information System - Elementary (GE) b DWG 851E478 4 2-26-79 I Rod Control and Infonnation System Elementary (TVA) (C. F. Braun) }(; IW'4 DWG _ 386X994-007 1 10-18-79
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. PROC TI2131 4 10-1-79 CRD Temp Recorder Panel - H22-P007 E
I[I6' PROC' II-PA-002 10 9-13-79 Panel Product In Process Inspection . )l
-7 II-PA-003 7 11-20-79 Wire Continuity Check PROC 1i l Dielectric Strength Test (Hipot) l8 PROC TI 1646 4 _3-10-78 -!
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