ML20244D765
| ML20244D765 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/05/1985 |
| From: | Devine T, Garde B GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Asselstine J, Palladino N, Zech L NRC COMMISSION (OCM) |
| Shared Package | |
| ML20141C582 | List: |
| References | |
| CON-#189-8110 2.206, NUDOCS 8604070276 | |
| Download: ML20244D765 (7) | |
Text
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dOVERNMENT ACCOUNTADIUTY PROJECT 1555 Connecticut Awmue, N.W., Suite 202 (202)23
,y Woshington, D.C. 20036 W r~ri c &vien T /
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October 5, 1985 f
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Documna 6 CEavicE BRANCH secwnac j
Honorable Chairman Nunzio Palladino M V /
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Honorable Lando Zech 4
Honorable James Asselstine Honorable Thomas Roberts gg Honorable Frederick Bernthal
. I~M U.S. Nuclear Regulatory Commission Washington, D.C.
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Dear Commissioners:
The Government Accountability Project (GAP) has identified potentially serious deficiencies in the Design Control, Quality program at General Elecric's Assurance / Quality Control (QA/QA) facility in San Jose, California.
The programmatic deficiencies The deficiencies have been identified by a former GE engineer.
potentially impact GE components supplied to all power plants utilizing GE equipment.
GAP has been in contact with GE regarding this matter for We had hoped that GE would have been able to over a year.
identify and correct the internally reported problems.
We also expected that, by now, GE would have voluntarily reported the Unfortunately, GE continues QA/QC deficiencies to the Commission.
to insist that it has almost no records indicating any possible deficiencies in its Design Control and QA/QC program, except
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The with respect to problems already confirmed by the NRC.
former GE engineer had, howerer, provided detailed reports notifying his super & oes of numerous actual and potential We now lear the.c there has been yet another violation violations.
In light at GE -- destruction of nuclear safety-realted documents.
of GE's failure to notify the NRC of what we believe are potentially Part 21, we l
serious generic problems reportable under 10 C.F.R.
ara doing so.
GAP consultant Charles Stokes conducted a review and analysis of the information provided to us, as well as an in-depth review of evidence of problems at five GE plants which would have, or did, stem from the QA/QC breakdown reported to us.
Mr. Stokes has prepared a report of his research and assessment The report is an analytical summary of the GE of the allegations.
engineer's disclosure regarding programmatic and specific deficiencies since 1973.
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!s Additionally, the. report demonstrates the NRC's inability to successfully audit the GE project.
The regulatory history of five plants was studied to determine (1) whether the problems identified at GE have manifested themselves at plant sites and (2) whether or not either GE or the NRC traced actual problems back to their generic source.
Our investigation indicates that the regulatory audit systems failed to detect the programmatic design control deficiencies, and failed to follow through s' successfully in monitoring' corrective action even after confirming violations.
In fact, the report documents numerous examples of design-related deficiencies, such as (1) knowingly building products differently than indicated by the construction drawing; (2) performing a review of drawing quality (layout, readable) without verifying the accuracy of information on.it; (3) alterations of design documents by GE staff who did not appear on the document i
(many ECNs); (4) documents signed indicating they were reviewed when they were not; (5) incomplete testing of components, such as the Reactor Mode Switch; (6) labeling errors (a part would have two names); (7) duplicate labeling errors similar to (6) above
. but where two different parts have the same name; and (8) i shipping equipment to power plants with known defects.
l Other examples of system problems are: (1) appropriate training not being implemented for new employees; (2) a routine program environment that discouraged individual initiatives to verify legal' compliance, and encouraged a "let someone else check l
1 that aspect" attitude; (3) inadequately documented procedures I
combined with incomplete or no training (ICER' codes); (4) a computer tracking system which erased prior information when new information entered, destroying the chain of records (EIS); (5) use of a computer 't' racking system for safety-related components when~the computer covered by the Quality Assurance program, system was not covered by the Quality Assurance program (EIS);
(this (6) use of unverified documents to verify a document (7) generic l
practice was routinely encouraged by canagement);
such as a OA
' structural weaknesses tainting the entire program, manager reporting to production; and (8) the practice of Based on our deferring verification on safety-relate'd equipment.
j discussions with GE, we fear that only the last deficiency has been addressed with any serious corrective action.
That effort only occurred after NRC confirmation of the 11' legal deferred Furthernere, our client has convinced us verification program.
that the remedial program was seriously incomplete.
We propose that a meeting be arranged as soon as possible with representatives of the Office of Nuclear Reactorthe Quality Assurance /
Regulation's division on GE's reactors,and representatives of the Division of Ouality control branch, Engineering, the Division of Safeguards, and the Office ofwhich Investigations.
We will present our consultant's report, O
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is both extremely technical and lengthy, to the personnel to whom the Commission refers this matter.
If necessary, we will also make the consultant and the alleger available to the NRC fo'r a
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more detailed discussion.
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This case has the highest priority at the Government
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Accountability Project.
To a significant degree this year GAP 1
has curtailed its initiatives at plants under construction l
because of our growing concern that generic quality assurance
- breakdowns are currently endangering public health and safety at operating GE plants around the country.
We hope that the NRC will treat this matter as seriously as we have.
Sincerely, 1
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Billie Garde, Director Environmental Whistleblower Project 0+LA-Thomas Devine, Director Pu,blic Employees Project
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