ML20236G623
| ML20236G623 | |
| Person / Time | |
|---|---|
| Issue date: | 06/10/1987 |
| From: | Robert Pettis, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236G568 | List: |
| References | |
| REF-QA-99900403 NUDOCS 8708040328 | |
| Download: ML20236G623 (29) | |
Text
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ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERAT10NS e
SAN JOSE, CALIFORNIA REPORT INSPECTION INSPECTION NO.: 99900403/87-01 DATES: 04/06-9/87 ON-SITF H0!!RO 109 CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operations ATTN: Mr. N. L. Felmus, Vice President -
and General Manager 175 Curtner Avenue 3
San Jose, California 45125 ORGANIZATIONAL CONTACT: Mr. J. J. Fox, Senior Program Manager TELEPHONE NUMBER:
(4081 925-6195 NUCLEAR INDUSTRY ACTIVITY: General Electric Company's, Nuclear Energy Business-l Operations (GE NEB 0) is engaged in furnishing engineering services for domestic and foreign nuclear power plants.
ASSIGNED INSPECTOR:
(.
IN~f7 R. L. Pettis, Special Projects Inspection Section Date l
(SPIS)
OTHERINSPECTOR(S):
R. P. McIntyre, SPIS P.
SMC O'Donnell q
bbM Q> Ja 12.s o (o 8 7 APPROVED BY:
U.Potapovs, Chief,SP(5,VendorInspectionBranch Date INSPECTION BASE 2 AND SCOPE:
A.
BASES:
10 CFR Part 21 and 10 CFR Part 50.
B.
SCOPE: The purpose of'this follow-up inspection was to review allegations involving potential deficiencies in design control activities within the Quality Assurance (QA) program at GE San Jcse, during the period March 1978 to April 1982.
In addition, the status of previous inspection j
findings was reviewed.
PLANT SITE APPLICABILITY:
Potentially multiple plant sites, including River Bend, TVA Units 17-22 (identified by GE as cancelled), Perry 1/2, Nine Mile Point 2, Hope Creek 1/2, Grand Gulf 1/2, Limerick, Clinton, and Susquehanna 1/2.
s70s04032s s70612 PDR GA999 ENV9ENE 99900403 PDR
ORGANIZATION: GENERAL ELECTRlC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALIr0RNIA REPORT INSPECTION wn -
RFSUITS*
PAGF 2 of 17 A.
VIOLATIONS:
None.
B.
NONCONFORMANCES:
Contrary to Section 4.1.2.(a) of GE Engineering Operating Procedure (EOP) 55-2.00, " Engineering Change Control," Engineering Change Control (ECN)
NJ-17436,. dated June 2, 1980, was initiated without a technical evaluation to:
(1) delete the requirement for glyptal coating of GE Electrical Metallic Tubing (EMT) because of unavailability; and (2) delete the notation " Approved Vendor: GE Company, Requires Engineering Approval."
(87-01-01).
This item of nonconformance was previously identified in NRC Inspection Report No. 99900403/86-01 as unresolved item (8C-01-10).
C.
UNRESOLVED ITEMS:
None.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Nonconformance (86-01-01)
Contrary to Section 4.1.2.e of GE E0P 42-6.00, " Independent Design Verification," documentation was unavailable to support the processing of a Deferred Verification Status Notice (DVSCN), on ERM AML 973, identifying to Engineering Services 1 that Panel Module V710 (assembly Drawing PL914E989), for the River Bend project, was cleared of deferred verification.
A further review of documentation conducted by GE and reviewed by the inspector indicated that independent design verification of Panel Module U710 had been deferred initially on Engineering Review Memorandum (ERM) AML 973, dated December 2, 1980. On May 13, 1982, ECN NJ 34893 was issued, which applied only to design changes made on that ECN and did not clear iSe deferred verification, as evidenced by the verification statement on the ECN. GE performed a search in February, 1985 to identify all unverified documents on River Bend 1, which identified assembly drawing PL914E989 as unverified. As a result, DVSCN No. 02202, dated March 26, 1985, was written to clear
'the deferred verification on all the.ce design documents including Panel Module Assembly U710, drawing PL914E989, Revision 4, as required per GE E0P-42-6.00. This item is closed.
t
ORGAN 1ZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALI 0RNI A REPORT INSPECTION Nn -
RFSUITS PAGE 3 of 17 i
2.
(Closed) Nonconformance (86-01-02) i Contrary to GE E0P 25-4.00, Sections 2 and 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. C1706, for the qualification of electrical components to be ured in nuclear safety-related Category 1 electrical circuits, for panel No. H13-P861.
EWA FE-8446 referenced on DVSCN 0'706 was verified by the inspector to be an erroneous number. The act.al document which authorized the qualification work for components associated with the panel is Project Work Authorization (PWA) 5447KG, dated April 26, 1985. which authorized the qualification of the same relays listed on DVSCN 01706 by part number.
DVSCN 02409, dated April 25, 1985, cleared the deferred verification from DVSCN 01706. The inspector reviewed both DVSCNs which now include the reference to PWA 5447KG, as recorded on DVSCNs 01706 and 02409, dated January 21, 1987. This item is closed.
3.
(Closed) Nonconformance (86-01-03)
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. 50-57711 25 days after the required reply date specified by the initiator, and a revised reply date was not negotiated.
A review of additional documentation for CAR No. SJ-57711 confirmed that the noted reply date was not in accordance with GE procedure i
MP 5.01.
A review of Rework Records RR004, RR011, RR022, and RR029 associated with this CAR indicated correction to the specific condition noted. This correction was accomplished on June 7, 1980.
The affected p:n61 was accepted for shipnant to TVA-X21 (cancelled plant) on June 17, 1980.
CAR SJ-57711 was signed off by the responsible design engineer on June 25, 1980. This delayed sign-off had no effect on the quality of the product since the problem identified on the CAR was already resolved on Rework Record RR011.
A drawing change to the connection diagram was noted for other GE plants utilizing the same panel.
GE's nuclear panel manufacturing operations at San Jose have since been discontinued. This item is considered closed.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPEPATIONS SAN JOSE. CALI70RNIA l
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RFStflTS PAGF 4 nf 17 4.
(Closed) Nonconformance (86-01-04)
Contrary to Section 4.1.1.e of GE Engineering Operating Procedure (E0P) 42-6.00, " Independent Design Verification," the required DVSCN, which would have documented the opening of a deferment per ECN NJ-43120, was not generated through GE's Engineering Services 1 department as required.
The NRC inspector reviewed additional information as provided in GE's respont,e to this nonconformance. Although the required DVSCN necessary to close the deferred verification was not available during NRC inspection No. 99900403/86-01, it was produced by GE during this inspection.
DVSCN 01010 was issued on January 25, 1984, j
as a result of an October 1983 internal GE Quality Assurance Audit.
j This audit of deferred verification identified that DVSCNs had not i
been issued for some deferred verifications that were already documented on approved ECNs, ERMs, and conditional rele.ases.
The GE documentation reviewed also identified that when items were released for manufacture or shipment prior to cumpletion of equipment qualification, a conditional release was required in accordance with i
GE E0P 42-5.00, dated February 12, 1982.
The approved conditionsi shipment release for Transmitter 18807360P017 was noted as being i
recorded on a Product Quality Certification (PQC) dated June 9, 1983.
The inspector verified that part of the corrective action resulting from this audit was to revise E0P 42-6.00 (December 5, 1983) to eliminate the redundant requirement for DVSCNs for items with
)
incomplete equipment qualification. As a result of the 1983 audit, j
the necessary corrective and preventive action related to this nonconformanca was accomplished. This item is closed.
j l
5.
(Closed) Nonconformance (86-01-05)
Contrary to Criterion V of 10 CFR Part 50, Appendix B and GE Nuclear Energy Business Group (NEBG) Procedure No. 70-30, Revision 1, Paragraph 2, training records reviewed indicated Mr. Sam A. Milam, III attended a Quality Assurance (QA) course 15 months after assuming his new job assignment, rather than within the required 3 1
months.
j A review of documentation supporting GE's response to this item indicated that attendance at a formal QA training course within three months of assuming a new job assignment is not required by GE i
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS 3AN JOSE. CALI:0RNIA REPORT -
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Procedure 70-30.
Rather, the procedure assigns managers the responsibility to ensure that each employee is instructed and indoctrinated in the procedural requirements applicable to the work assigned.
Formal QA training courses were developed by GE to assist managers in executing their responsibility for training or indoctrination of assigned employees; however, participation in these courses was not and is not mandatory.
According to Mr. Milam's manager at the time he assumed his new job assignment in 1978, Mr. Milam was initially assigned to a lead engineer who was responsible to instruct and indoctrinate him in the use of procedures and forms related to his assigned work. Design documents assigned to Mr. Milam had to be reviewed, signed, and dated by both the responsible design engineer and the independent design verifier, in addition to being reviewed by the responsible design engineer's manager.
Following these reviews, the documents were submitted to Engineering Support Services (ESS) for processing and issuance in accordance with established procedures.
Engineering Services' responsibility was to perform various checks on the quality of the documents it reviewed. As stated by GE, when any of these levels of review indicated errors or deviations from procedural requirements, this information would be fed back to Mr. Milam, either directly or through his manager. This iterative process of continuing on-the-job reviews and feedback ensured that Mr. Milam and other design engineers were adequately trained in the use of procedures and forms related to their assigned work. As a result, GE recognized this on-the-job training to be sufficient to instruct and indoctrinate design engineers in design documents suct as drawings, ERMs, and ECNs.
This item is closed.
6.
(Closed) Nonconformance (86-01-06)
Contrary to Criterion III of 10 CFR Part 50, Appendix B and GE E0P 42-6.00, GE issued Engineering Review Memorandums (ERMs),
AMD-1302 and AMC-3035 in which:
(1) the desi to perform the document review (ERM-AMD-1302)gner was identified
- and (2) where the assigned reviewer also provided document approval as the responsible engineer (ERM-AMC-3035).
(1) A review of the QA procedures of GE and C.F. Braun (subcontractor to GE) and interviews with GE staff members determined that Braun was given full responsibility for the design of this panel utilizing Braun QA procedures. These procedures were (1) based upon GE's QA program and (2) monitored by GE for conformance and implementation. The designer who also performed the l
ORGANIZATION: ~ GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALI:0RNIA REPORT INSPECTION Nn -
RFSulTS-PAGE 6 of 17 document review for ERM-AMD-1302 appeared initially to have reviewed his own work efforts, but, in fact, he reviewed comments that resulted from GE " spot check" and an " application review" of the ERM and associated drawing. The subject drawing was later approved for issue by Braun personnel on. November 11, 1977, with all signature blocks signed and dated by Braun personnel.
Subsequent to the completion of the design, L
independent. verification, and checking by Braun personnel, the drawing was transmitted to GE for approval and issuance, which occurred'on November 29 and December 30, 1977 respectively.
(2) On ERM AMC 3035, Mr. Milam provided review and comments and signed as the independent design verifier on July 5,1978.
Mr. Milam's comments were resolved by Mr. R. D. Thompson who signed as the responsible design engineer the same day.
ERM AMC 3035 contains a comment made by a lead systems engineer, i
dated September 27, 1976; however, this comment had no effect on the previously completed design verification. This comment was resolved on October 4, 1978, by Mr. Milam, who at the time was the responsible design engineer. This ERM was approved by Mr. Milam's manager on October 5, 1978. GE explained that the 3 months between Mr. Milam's signing as the independent design verifier and the signing by the responsible design engineer was the result of a reassignment of Mr. Milam's job responsibility, which was not noted on the ERM itself.
Based on the inspectors review of actual signatures and dates recorded on the ERMs and on the drawings for items (1) and (2) above,-
the designers, verifiers, and the checkers were independent. This item is closed.
7.
(0 pen) Unresolved Item (86-01-07)
GE Engineering Practices and Procedure (EP&P) 5.38 Addendum 4, dated December 1975, required that a tracking system and status log of deferred verifications be maintained. The inspectors verified during the NRC 86-01 inspection that the first entry was made in the status log for deferred verifications in May 1977. At that time, it could not be determined whether verifications had been deferred before May 1977 since the status log did not contain of any deferred verifications prior to that date.
During the April 1987 inspection, GE provided additional documentation (several ERMs deferring verification from three separate work units within GE) that indicated that deferred verification activities were l
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUS 1 NESS OPERATIONS SAN JOSE. CALIFORNIA REPORT INSPECTION RESULTS:
PAGE 7 of 17 NO a
initiated as early as November,1975. Although documentation did not exist to support the inclusion of these documents into the l
status log, GE stated that they were incorporated but subsequently 1
transferred to the Work Planning and Scheduling System (WPSS) for scheduling and tracking to completion. The only documentation produced by GE during the inspection, to verify completion status of these documents, was a computer run from the Engineering Informa-tionSystem(EIS),datedApril4,1987,whichindicatedthat272 documents presently exist in the system as "U" (unverified).
GE's position was that since the drawings referenced on the ERMs produced during the inspection were absent from this list, they must have been verified.
It was also pointed out by GE that the WPSS scheduling records prior to 1980, which would have demonstrated the documents tracking status and eventual closure, have been eliminated from the system data base. As a result, documentation does not exist at this time to support the overall tracking status of these documents including the clearing of the referenced deferred verification.
GE committed to perform an extensive review of deferred verifications from inception through May 1977 to positively demonstrate closure of di design documents produced during this period which contain deferred design verifications. This unresolved item will remain open pending completion of this review and will be reviewed during the next inspection.
8.
(Closed) Unresolved Item (86-01-08)
A determination as to the correct elementary drawing used as a basis to test Panel.G41-P003 for TVA18 could not be made during the previous NRC inspection.
Additional information produced by GE was reviewed during this inspection to identify documentation used by GE to test Panel G41-P003 for TVA18. The Quality Assurance Test Data Sheet for this panel, dated December 30, 1978, identified connection diagram No.
865E859 and elementary diagram No. 386X994-034, to be used with test instruction TI 1200, as applicable. Specific documentation was unavailable to indicate which elementary diagram had been used to test the panel, because the elementary drawing was not a specifically referenced item on the test data sheet. The connection diagram contained information for both TVA and Grand Gulf panels; therefore, the inspector performing the test had to select the appropriate information. A review of the rework records for this panel did not i
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ORGANIZATION:
GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS 1
SAh JOSE. CALIFORNIA i
REPORT INSPECTION Nn -
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PAGE 8 of 17 identify any misapplication of the elementary diagrams. This item is closed.
9.
(0 pen) Unresolved Item (86-01-09)
GE's Problem Review Board (PRB) stated in a letter dated June 13, 1980, that a new reactor mode switch should replace those previously shipped and that the design changes required were to be documented via a Field Disposition Instruction (FDI) document.
The FDI referenced by the PRB was not available for review during the previous NRC inspection.
GE's response to this unresolved item stated that the correct reactor mode switch is installed in all boiling water reactor (BWR) plants.
This installation was initiated as a replacement in BWRs in late 1983 and 1984, based on a GE product improvement redesign and the issuance of NRC Information Notice 83-42. Because this product improvement redesign is not the original issue that unresolved item (86-01-09) addressed, this item will remain open pending a further review of the 1980 upgrade data and the 1983 product improvement redesign. This unresolved item will remain open and be reviewed during the next inspection.
10.
(Closed) Unresolved Item (86-01-10)
The resolution as to whether Electrical Metallic Tubing (EMT) incorporated glyptal coating on the inside diameter, as specified by GE, could not be determined during the previous inspection. This tubing is primarily used by GE in the construction of nuclear power plant control room panels to house related cables.
The inspectors reviewed GE's response to this ur. resolved item in a letter dated January 27, 1987.
The response indicated that the glyptal coating, as specified on GE purchase part drawing 175A9666 issued May 24, 1967, was not incorporated in EMT supplied to GE, nor does the absence of the coating present any safety problem since all conduit supplied and used by GE was of the seamless type with very smooth surfaces on both the inside and outside.
j Receipt inspection records reviewed during the last NRC inspection revealed that only the electro-galvanized external finish had been j
inspected and not the presence of glyptal. During these discussions, GE could not provide an explanation, nor could GE clearly explain the purpose for specifying such coating on the purchase part drawing.
However, discussions narrowed down the possibilities that glyptal i
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q ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALIFORNI A l
REPORT INSPECTION RESULTS:
l PAGE 9 of 17 NO a
)
had been specified to either aid the cable pulling operation through the EMT or to prevent corrosion of the inside of the tubing. As a result of the many questions surrounding the use of the glyptal I
coating and absent a complete and comprehensive technical justifica-I tion for its removal ia 1980, as required by GE E0P 55-2.00, this unresolved item is elevated to an item of nonconformance.
(87-01-01) l 11.
(Closed) Unresolved Item (86-01-11)
Specific review requirements provided to the responsible engineer at
{
the start of the project for panel compatibility with other system
{
elements could not be determined during the previous NRC inspection j
for ERM-AMC 3035, dated October 11, 1987 for CNV Panel H22-P028.
I When this ERM was issued in October 1978, no means was provided to indicate what information was available to the responsible engineer as to the design basis. Mr. C. W. Hart, engineering manager at the time, approved this document without a system interface review, as evidenced by " Review Refused" in the signature block. Mr. Hart indicated that his review was inappropriate, because the responsible engineer, Mr. R. D. Thompson /Mr. Sam A. Milam, had the required information before the panel design. This particular ERM has misdated entries and out of sequence comments; however, the support documentation does not indicate hardware problems for this panel.
During this period other ERMs were examined and the interface reviews were performed with "no comment" entries. This item is considered closed.
E.
OTHER FINDINGS AND OBSERVATIONS:
Background Information
]
i As stated previously, NRC Inspection Report No. 99900403/66-01 did not 4
attempt to address all of the items raised by the alleger and the consultant for GAP, Mr. Charles E. Stokes, but, rather, a representative sample of potentially more significant allegations was selected for j
review. Howevar, all allegations received by the NRC are in the process i
of being addressed and will be documented in future inspection reports.
1 Previously, the area of deferred design verification was addressed, which represented the allegers major concerns (as noted during an NRC interview l
with the alleger in April 1986). This inspection report primarily focuses i
on the follow-up of items of nonconformance and unresolved items identified in NRC Inspection Report No. 99900403/86-01. This was J
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERAT10NS SAN JOSE. CALIFORNIA REPORT INSPECTION Nn -
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PAGE 10 of 17 accomplished in part by a review of GE's responses to such items (GE's letters to the NRC dated February 5 and March 5, 1987) in addition to a formal review of all documentation supportive cf the GE response.
In addition, several other allegations from Mr. Stokes' summary of Mr. Milam's work record'were reviewed during this inspection.
The representative sample of allegations inspected is summarized below, along with the results of the NRC review of each item. The inspection was comprised of personnel interviews, examination of applicable files, records, and procedures. References to nuclear power plants identified as TVA (17-22) represent cancelled plants. The section references below have been restated verbatim and correlate directly to those listed in Mr. Stokes' report; they do not constitute an NRC interpretation of such allegations.
1.
Engineering Review Memorandums (ERMs)
Stokes Report Section 1.6 "In the first week of November 1978, the following line was part of an entry:
Bill Millard said either he would sign the ERMs or I (Sam) could forge his signature to them."
(Clarification added by Mr. Stokes.)
Inssection Findings - During the inspection, a discussion was held witi Mr. Millard, in the presence of Mr. Barton Smith, GE Counsel,
(
at which time Mr. Millard denied any such statement about " forging" his signature. Mr. Millard stated that it was common practice for Project Managers (PMs) to authorize other individuals to sign for them in instances where, for example, logistics did not permit the PM easy access to sign such documents. The NRC inspector reviewed the responsibility given to the PM as outlined in GE E0P 42-6.10, Section 4.8a, to determine the significance placed on the PMs approval of such documents. The PM has the responsibility to approve ERMs for the purpose of authorizing the application of the specific document to the assigned project and to supply project information to the initiating responsible engineer as requested.
The PM is not responsible for verifying or checking the technical i
adequacy of the document, because this has already been done by the l
design engineer and the verifier. Because specific detail was not i
available as to the ERM referenced by Mr. M11am's work record entry in November 1978, the inspector was unable to verify whether Mr. Milam signed his own name in lieu of Mr. Millard, or whether Mr. Milam " signed for" Mr. Millard. As a result of this review, this item will remain open.
i l~
ORGANIZATION: GENERAL ELECTRIC COMPANY l
NUCLEAR ENERGY BUSfNESS OPERATIONS SAN JOSE. CALI:0RNIA I
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PFStil TS -
PAGF 11 nf 17 l
1 2.
Elementary Diagram Drafting Effort Stokes Report Section 1.7
" Continuing with a problem of a similar nature on November 14, 1978, a letter to C. W. Hart on the subject
]
of the CNV connection had an interesting paragraph.
It seems that q
the CNY elementary diagram drafting effort was subcontracted to an outside firm, the Power Division of C.F. Braun & Company, in Alhambra, California. When completed, the diagrams were provided to the General Electric System Engineers for signature. The System i
Engineers felt that they were not being given sufficient time for d
review and refused to sign the documents. The documents were later l
signed by the C&EE CNV Engineer, without review."
j j
Inssection Findings - During the inspection, discussions were held l
witi Mr. C. W. Hart, Mr. Milam's supervisor during this period, who J
stated he had never received the November 14, 1978 letter.
In
)
addition, specific examples of insufficient review times could not l
be identified from the comments contained in the ERMs or the discussion with Mr. Hart. As a result, this item will remain open.
l 3.
Clinton Interlocks Stokes Report Section 4.3 "On 6-10-81, Mr. Milam, when investigating an open item concerning the safety related status of Clinton recirculation flow control valve interlocks, determined that interlocks exist for feedwater pump trip with low reactor vessel water level and for high drywell pressure in the design specifications for the following referenced projects: Clinton, Zimmer, and LaSalle.
The interlocks definitely exist in elementary diagrams for Zimmer and LaSalle, but he could not find out positively that they exist for Clinton. Mr. Milam passed the information on to George Strambach, who was with the NRC, at the Peoper Tree Lounge." (Emphasis added by Mr. Stokes.)
Inspection Findings - The NRC inspector reviewed Clinton Reactor Recirculation System elementary Drawing No. 851E700 AC, Sheet 12, Revision 0, dated August 11, 1980, and Sheet 14, Revision 0, dated September 21, 1979, and verified the existence of the referenced interlocks. This item is closed. A discussion was held with Mr. George Strambach of GE concerning the statement regarding the Pepper Tree Lounge. Mr. Strambach stated that this referred to a technical meeting held between members of the NRC and GE staff for the purpose of discussing NRC Chapter 7 Safety Evaluation Reports
ORGANIZATION:
GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERAT10NS SAN JOSE. CALI:0RNIA REPORT INSPECTION RESULTS-PAGE 12 of 17 NA for future GE plants. The meeting was held at the Peppertree Inn meeting room, with approximately 50 attendees, during the period June 8-10, 1980.
4.
Grand Gulf Control System Issue Stokes Report Section 4.21 "In Mr. Milam's work record for FW8141, (week of October 5, 1981), it was stated that there had been another Grand Gulf Control system failure question."
(Clarificationadded)
Ins 3ection Findings - A review of the allegers work record associated wit 1 this item identified the following entries:
a/wk 8136 - Grand Gulf Control System Failure Analysis b/wk 8137 - Discussion of Failure Analysis for Grand Gulf with sign-off problems c/wk 8138 - Received more work sheets from Bechtel Engineer (Grand Gulf) d/wk 8141 - Responded to another Grand Gulf failure question l
The above references related to GE responses to control system failure questions in an NRC Letter dated April 16,1981(from R. L. Tedesco, Assistant Director for Licensing (NRC) to Mr. J. P. McGaugby of Mississippi Power and Light). Mr. Milam's entries give a summary of his day-to-day work activities, which involved problem resolution, as assigned him by his supervisor.
This item is closed.
5.
River Bend Excluded Equipment List Stokes Report Section 5.13 "Mr. Milam's work record includes a nonapproved form titled PWA No. 1229LD, Revision IJ for River Bend.
This document, which is dated February 5, 1982, was caused by an excluded equipment list which was sent to the utility, Gulf States Utilittes. Company, by the NRC.
The second page of this document states that there is no controlled tracking system for vendor identification of these devices and that a complete item by item search of the entire River Bend database would be necessary. GE felt that the scope of such a search was 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
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ORGANIZAT10N: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALIFORNIA
'l REPORT INSPECTION NO.: 99900403/87-01 RESULTS:
PAGE 13 of 17 to be so deficient that plant safety is seriously in question.
GE neither admitted nor denied that this equipment was installed at River Bend."
Inspection Findings - The NRC inspector reviewed a letter (RBV-1643) dated October 30, 1981, from the Stone & Webster Engineering Corporation (SWEC), agent for Gulf States Utilities, requesting that GE confirm that none of the listed equipment is being used by GE in any safety-related component on River Bend. This list of excluded equipment was generated by SWEC based upon a review of defective equipment identified by the NRC as a result of inspections of nuclear power plants, vendors, and published reports. A review of GE's February 22, 1982, response indicated that GE does not exclude equipment from use based upon lists of equipment found defective by the NRC.
GE's response also indicated that the SWEC list did not contain information concerning the nature of the defects and environmental conditions necessary to evaluate the equipment's exclusion from use. Also, as individual problems are encountered, investigations are undertaken by the manufacturer and if necessary, the affected haraware is modified or replaced.
The GE revwwer, Mr. Sam Milam, had stated that no controlled tracking sys'.em exists within GE for vendor identification of these devices.
This statement refers to the fact that to confirm the use of this equipme,'t, a complete item-by-item search of the River Bend data base would be necessary and would only apply to the control and instrumentation scope of equipment supply.
As a result, GE stated in their February 1982 response to SWEC that at the present time a research program of this magnitude was not necessary. GE also indicated to the NRC inspector that SWEC did not provide additional correspondence after it received GE's response. This item is considered open pending NRC's review of a sample of GE's actions on affected hardware.
6.
Unresolved NRC Items Stokes Report Section 5.14 "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 NRC team assignments would be as follows:
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALI 0RNIA REPORT INSPECTION Mn -
RFSill TS-PAGF 14 nf 17
" Chamberlain 1.
Review and close out, if possible, the nonconformance 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 instructions.
2.
Follow-up regional request for investigations:
a.
Check allegations received by Region V that GE has furnished technical publications with technical, as well as typographical, errors. Subjects are control rod drives, control systems, and fuel handling platforms.
b.
Check allegations by Isa Yin of Region III, who accompanied LaSalle on LaSalle's 1961 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 10 CFR 50.55(e),
d.
Inspect the situation report 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).
2.
Termination of wiring in termination cabinet junction boxes (PGCC reported by Grand Gulf).
3.
Incompatible design documents with actual hardware ("as shipped" panels did not match "as shipped" drawing reported by Grand Gulf).
4.
Inadequate circuit separation (separation of Class 1E and non-1E in accordance with Regulatory Guide 1.75.
Reported by GrandGulf).
5.
Incorrect assembly of cable connectors.
\\
ORGANIZAT10N: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERAT10NS SAN JOSE. CALIFORNIA L
REPORT INSPECTION Nn -
RFSULTS-PAGE 15 of 17
" 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.
It is easy to see why GE started the Deferred Verification program when the NRC defers verification of noncon-formances from inspection to inspection or longer."
l 1
Inspection Findings - A review of NRC inspection reports indicated that the items raised by Mr. Stokes had been closed. Mr. Stokes' statement on the status of items assigned to Mr. Foster is incorrect.
Mr. Foster fomally resolved items 2, 3, 4, and 5 during NRC Inspection No. 99900403/82-01 in Februar.v 1982, 5 months after the 81-03 inspection, although it appears from the report numbering sequence (81-03 vs. 82-01) that 1 year had elapsed between inspections.
Mr. Foster's remaining item (No.1) was the subject of a GE Quality Assurance action item, as stated in paragraph E.5.2 of NRC report 82-01.
GE was to (1) verify that Series 20, type Pb20 electro-switches had not been shipped to other plants and (2) determine how the configured switch had been shipped initially to Grand Gulf, Unit 1.
During this review, GE opened Potentially Reportable Condition (PRC) File No. 60-46 to examine switches for Clinton, Unit 1 and Grand Gulf, Units 1 and 2.
NRC inspection 83-02 (May 1983) determined that another safety-related Series 20 electroswitch, GE Part No. 272A8005, may also be affected, however, a review of the PRC file at that time did not indicate that this part had been included in the evaluation.
NRC Report 83-02 also stated that Illinois Power Company filed a
-10 CFR Part 21 report on April 17, 1983, with NRC Region III. The report indicated that deficient Series 20K electroswitches had been supplied as basic components in various panels furnished by GE for use at Clinton, Unit 1.
The report also stated that GE will perform the revisions of any design documents affected. The NRC inspector reviewed the PRC file again during NRC inspection 84-01 (March 1984) and determined that the defective switches were checked and, replaced and the GE NEB 0 inventory cleared of all defective switches. This subsequent review of PRC 80-46 also considered the previously omitted switches in the evaluation.
With respect to Mr. Chamberlain, items 1, 2a, Eb, and 2c also were closed during NRC inspection 82-01 (February 1982), 5 months after they were identified in NRC inspection 81-03.
Item 2d, which I
1
.1
ORGANIZATION: GENERAL ELECTRIC COMPANY 1
NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALI 0RNIA REPORT INSPECTION wn -
pFStil TS -
PAGF 16 nf 17 resulted in an Item of Nonconformance during NRC inspection 81-03, was closed during NRC inspection 82-02 (June 1982), 4 months after it was identified. This item is closed.
7.
Unauthorized Signature Changes l
Stokes Report Section 6.2 "Mr. Milam wrote a letter to W. M. Barrentine on April 14, 1982 about unauthorized, post signature changes.
In this letter, Mr. Milam states that R. L. Reghitto made an authorized change to ERM AML-2997 without Mr. Milam's knowledge and in direct conflict with specific instructions."
Inspection Findings - A discussion during the inspection with Mr. Barrentine, in the presence of Mr. Barton Smith, GE counsel, l
inquired as to what actions were taken concerning tnis subject.
l Mr. Barrentine stated he had not received Mr. Milam's letter of April 14, 1982. He also stated that he was not aware of anyone else who might have known about the letter and also might have acted on it in his (Mr. Barrentine's) place while he was on business travel.
As a result, this issue will remain open.
8.
Letter to Management Stokes Report Section 6.3 "On May 22, 1982, Mr. Milam wrote Mr. Barrentine a letter and included a copy of his work record while working for Mr. C. L. Cobler.
In this letter, Mr. Milam requested Mr. Barrentine to read about the on-going underworld of C&ID and says he tried to communicate some of these things to Mr. Barrentine 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 uncontrolled bootleg activity we all know so well.
"Mr. Barrentine was the manager of the Nuclear Control & Instruments-tionProductDesignOperation(NC&ID)or(C&ID). He was Mr. Hart's, Mr. Cobler's, Mr. Reghitto's, Mr. Strambach's, Mr. Koslow's, and Mr. Wortham's supervisor. Mr. Milam had been notified of his layoff when this last letter was written and his reference to form 38 had to do with the constant threat of layoff if you did not go along with the system. He did not."
(Emphasis added by Mr. Stokes.)
ORGANIZATION:
GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE. CALI:0RNIA REPORT INSPECTION Nn -
RFSULTS-PAGE 17 of 17 Inspection Findings - A discussion during the inspection.with Mr. Barrentine, in the presence of Mr. Barton Smith, GE counsel, inquired as to what action was taken by Mr. Barrentine when he received Mr. Milam's letter and work record, which document problems Mr. Milam felt existed within the Control and Instrumentation i
Department (C&ID). Mr. Barrentine stated he never received the letter nor the portion of Mr. Milam's work record while he was assigned to Mr. C. L. Cobler.
He did state that if he had received information concerning problems within C&ID, he would have met with the managers and throughly researched the issues. Mr. Barrentine also stated that a Potential Reportable Condition (PRC) evaluation of Mr. Milam's concerns would have been initiated if warranted. As a result, this item will remain open.
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