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Insp Plan for Ge,San Jose,CA,860714-18. NRC Lists of Required GE Documents,Insp Rept Drafts & Related Documentation Encl
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Issue date:	07/14/1986
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{{#Wiki_filter:- _ 9 v i INSPECTION PLAN FOR , i t GENERAL ELECTRIC COMPANY 6 SAN JOSE, CALIFORNIA July 14-18, 1986

O I. Purpose t

The purpose of this second inspection is to follow-up on specific Design -

Control deficiencies identified by Mr. Sam Milam, III, a former GE Nuclear Engineer, to the Government Accountability Project (GAP). These concerns primarily regard alleged programmatic deficuncies in the Quality Assurance / Control activities at GE's San Jose, California facility. The primary emphasis of this inspection will be directed towards addressing those specific allegations associated with safety-related equipment / services. It is anticipated that approximately 40-50 Design Control allegations will be reviewed to determine their validity. The topic of Deferred Verifications ,

                  ' will comprise the majority of these items-due to the potential impact on safety-related hardware and equipment.

II. Scope , The following specific areas will be reviewed to assess issues identified to GAP by Mr. Milam. , M O403OO98 870323 PDR GA999 m g 99900403 PDR ~ [ 4 , ,;.s , _ , . . .. ,4_'_- _ _ .__(w, " 4 , . _ . ,.. s _ -

1 Design Control l

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              -      Deferred Verifications
              -      EngineeringInformationSystem(EIS)                                                ,
              -      Review of Internal GE Audit (1983) into Deferred Verifications as a result of an earlier RIV NRC Audit Stuitw, SEMKTE:0 RtLEGATeov S CdFP W De9699eM AND WoAK MCOO -

III. Inspection Team R. Pettis (SPIS) Team Leader R. McIntyre (SPIS) P. Prescott (SPIS) Gm5dt,TMT (SMC) IV. Schedule l Inspection to be performed the week of July 14, with an exit meeting scheduled _ for late Thursday afternoon, July 17. Travel will connence on Sunday, July 13, so as to maximize the effectiveness of this inspection. i i i

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1 Docket No. 99900403/86-01 General Electric Company Nuclear Energy Business Operations ATTN: Mr. W. H. Bruggeman, Vice President and General Manager h g. f g 1 l 175 Curtner Avenue pd) San Jose, California 95125 Gentlemen: g, f g yg This refers to the inspection conducted by Messrs. . l.. Pettis, PP9r9 Pesee k

            ?.S. f(LESc.77 and " " "i y . ;, of  this office, on April 14-17,y1986, of your facility at San Jose, California, and to the discussions of our findings with Mr. J. J. Fox and members of your staff at the conclusion of the inspection.

g *h4 8 [ok}edd b h Vm44 This hid49W inspection was f.'A ;;' , allegations,prejeng n=

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the NRC in a letter dated October 5,1985 by the Government AccountpTlitf7FoJEF J (GAP). This letter alleged deficiencies in the Design Control, Quality Assurance / Quality Control (QA/QC) program at GE's San Jose, California facility. These concerns were initially identified by Mr. Sam A. Milam III, a former GE, San l Jose employee who maintained a detailed work record spanning a four year period from March 1978 to April 1982. l

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e />w,6~l 6 mg Afu.) ue,), f 4 4'e N /4!Me Y .( V! et y J 'Y Please provide us within 30~ days from the date of this letter a written Q statement containing: (1) a description of steps that have been or will be (Q taken to correct these items; (2) a description of steps that have be .e y will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed. Consideration may be given L to extending your response time for good cause shown. ( Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, Med NET %et @s#fe::%epPr, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement

Enclosures:

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2. 3 po3cy d NO< U T o o YO3 3- Appendix plit ( inpch M(4 ^._ ::. M; J (

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APPENDIX A

O f DocketNo.99900NL/8601 Vo3 NOTICE OF NONCONFORMANCE gigtv-if;$cy/Y-/2,/ffg, Sased on the results of an NRC inspection conducted on "gnt '_^ '" _

it appears that certain of your activities were not conducted in accordance with NRC requirements.

                                                              " Activities affecting Criterion V of Appendix B to 10 CFR Part 50 states:

quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." i \ & P TlV 8la. tac & 0

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ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA INSPECTION O REPORT INSPECTION N0.: 99900403/86-01 DATES: 4/14-175j 7h-Off,0N-SITE HOURS: p CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operations ATTN: Mr. W. H. Bruggeman, Vice President 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 (GE) Nuclear Energy Business Operations (NEBO), has a work force of approximately 2500 assigned to domestic power plant activity. ASSIGNED INSPECTOR: R. L. Pettis, Special Projects Inspection Section Date (SPIS) OTHERINSPECTOR(S): R. McIntyre, SPIS P. Prescott, SPIS Q. Howard, EG&G P. E5HLEnAv, SMc. o,Douer t( APPROVED BY: John W. Craig, Chief, SPIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE: l A. BASES: 10 CFR Part 21 and 10 CFR Part 50. B. SCOPE: The purpose of this inspection was to follow-up on allegations presented to the NRC by the Government Accountability Project (GAP) a former General Electric NE80 employee. /

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ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE of

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        - C. UNRESOLVED ISSUES:

None. D. STATUS OF PREVIOUS INSPECTION FINDINGS: t The status remains as presented in NRC Inspection Report #99900403/85-01.

                - An evaluation of open inspection findings was not conducted E. OTHER FINDINGS AND OBSERVATIONS:

1. Background Information In October 1985, allegations were presented-to the Nuclear Regulatory Commission (NRC), Office of Inspection and Enforcement, by a letter from the Government Accountability Project (GAP) identifying potentially

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION RESULTS: PAGE f N0.: 99900403/86-01 serious deficiencies in the Design Control and Quality Assurance program at General Electric's (GE) facility in San Jose, California. These programatic deficiencies were identified to GAP by a former GE nuclear engineer who was employed at San Jose during the period 1972 thru 1982. Iurnished a diary-like set of detailed work notes compiled over the period-sr March 1978 thru April 1982 totaling O V cd emner two thousand documents Madurren 8 M /apffeWggeer concerns over the quality of components supplied to GE facilities during this four year period. A consultant for GAP conducted a review and analysis of the information provided @ afl%%/andpreparedareport of the Conceenf This report and the work record were then Poud h AC N

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              / tified by GAP W were not reviewed durin this inspectionj M welllya//msdm b                           y        '

The representative sample of allegations 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.

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ORGANIZATION:' GENERAL ELECTRIC COMPANY

                   -NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT                                     INSPECTION NO.: - 99900403/86-01                      RESULTS:                           PAGE      of

2. Design Control Review of Allegations

a. Allegations - CNV Elementary Diagrams The employee notes in November 1978 that for panel H13 and H22 C. f. Braun the GE system engineers for the CNV plant! drafted by,h..s *1 et Mho.bu &

refused to sign the elementary drawing..Th documentswerefate signed by the C&EE CNV lead engineer. This lack of system review caused later personnel problems. Inspection finding - Since more than one elementary _ diagram can be associated with a panel more specific information is needed, i.e., the actual drawing numbers of the elementary drawings in question. On April 17, 1986, elementary drawing were requested l I for CNV 1 & 2 panels H13 and H22. No drawings were recieved back in time to review for signatures, possibly because no system l number as available to use to retrieve the document. i l GE personnel stated that C. F. Braun was the A/E and the drawing would have been checked or verified by them and only the approval signature to place the C. F. Braun drawing under a GE parts list number in order to track it would be necessary. l

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of There was not statement found to indicate that any personnel problem caused a defective piece of equipment to be shipped.

b. Allegation - CNV Drawing Errors The employee states that many errors were found on drawings for CNV panel H22-P028. He states that CNV reviews were between the panel drawings with little attention to elementary diagrams. :

Inspection finding - Too little information was given to evaluate the problem. It was not clear as to which drawings had the errors (panel, assembly, connection, or elementary), which drawings he had reviewed or what a "CNV review" was.

c. Allegation - Independent Design Varification In July 1979, it was stated that an Engineering Review Memorandum ERM AMC-3602 was sent to Electrical Product Design for design verification and that the reviewer reviewed the document quality instead of performing an independent design verification.

Inspection finding - On ERM AMC-3602 the reviewed marked the area of review as #9-Document Quality after the drawing 14707614-Terminal Board Assembly and signed it off on 7/20/79 (week 7929)

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION

   'NO.:   99900403/86-01                                       RESULTS:         PAGE  of

( after reviewing the isted documents for document quality. All l connection diagrams had an independent design verification 8/1/79 (week 7931). -Drawing 14707614-Terminal Board Assy. and Drawing PL147D7614 were not signed off as being idenpendently verified but the responsible engineer had not assigned a reviewer for these drawings and had approved the completed ERM. The only assigned reviewer noted on the ERM was for drawing 147D7614 to be reviewed for document quality. The respcnsible engineer approved the review 8/2/79 without any type of requested review of the parts list.

d. Allegation - TVA Panels The employee gave the opinion that TVA 18 panel G41-P003 was tested to the wrong elementary diagram. The TVA connection diagram agrees with the Grand Gulf elementary and not the TVA elementary.

Inspection finding - There is nothing in the above statement which would indicate that a panel was ultimately shipped after being incorrectly assembled, tested or quality inspected. A review of connection diagrams for G41-P003 indicated only minor

 '0RGANIZATION: GENERAL ELECTRIC COMPANY' NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA-REPORT                                     INSPECTION N0.: 99900403/86-01                        RESULTS:                            PAGE      of differences in the connection diagrams. Requested copies of the elementary diagrams (rev. before 7846) for review on 4-17-86 but the drawins that came were the latest revision so the connection and elementary drawings were not compared due to time contraints.

e. Allegation - Incomplete ECN's ECN f:J-17584 and ECN NJ-13557, to resolve CAR SJ-56233, were not complete as of week 8016.

He stated that for TVA and Grand Gulf the G41-P003 panels all came from the same connection diagram but that they have dif-ferent elementary diagrams. The connection diagram is difficult to correct due to differert elementary diagrams to the same

                  -connection diagram.

Inspection finding - The ECN's were both issued 4/22/80 (week 8017). It is true that different elementary diagrams can show a panel that would have a connection diagram that would be the same for different plants. This is because the panel is the same for each plant. If the panel should change it would then carry a

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of different drawing number than the other panels. The Master Parts List for the plant lists the correct panel drawing to be used. This information is found in the Engineering Information System. The employee seems to be airing his displeasure with I the complexity of the system without suggesting a fix.

f. Allegation - Elementary Diagrams l

During the week 8020 the employee states that TVA 18 panel H22-P007 was tested to the wrong elementary diagram. Drawing 851E478 was used when drawing 386X994-007 should have been used. The EIS system was not used by the tester. Inspection finding - The test procedure for the TVA 18 panel H22-P007 is TI 2131. This Test Inspection document calls out both drawings 851E478 (GE drawing) and 386X994007 (1121) (CF Braun Dwg 1-121) as reference drawings. This Test Inspection document requires continuity and Hipot tests using connection diagramsm a power check and temperature recorder calibration, but the procedure does not call for any direct use of the elementary drawings. Both drawings were compared and found to have the same information for panel H22-P007. The panel was not tested to the wrong drawing. It is not part of the testers responsibility to use the EIS.

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS

                ~ SAN JOSE, CALIFORNIA REPORT                               INSPECTION NO.: 99900403/86-01                 RESULTS:                         PAGE   of g '. Allegation - TVA Panel Interference Problem It was alleged tat the electrical panel for TVA 21 was shipped-from GE San Jose with a unknown generic interference pcoblem.

The interference problem was causing the terminal screws, on the second row of relays from the bottom of the panel to short against welded vertical unistruts. The interference problem was first noticed on panels for Grand Gulf 2 and C.W.V. (panel #G41-P001). Inspection findings - The NRC inspection reviewed GE's design control procedure section 3.11, " field change control". The procedure states in part that, when it becomes necessary to ship products to the site L-fore manufacturing is complete (ship short) either by NEB 0 or its suppliers, an FDI is issued which identifies the work to be completed in the field. Such FDIs identify the l necessary engineering and quality requirements. The NRC inspector then requested all revisions to the design drawings for TVA 21, Grand Gulf 2 and CNV, all associated ECNs, FDDRs and FDIs were also requested for the subject desing DWGs.

0RGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA / REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of A review of the subject design drawings was performed to assure that the interfercences between the terminal screws and the vertical struts had been elevated. A review of all associated documentation and dates which initiated eachdesignchangewasalsoperformedforthesubjectdesigngdtdau. J h and there were no discrepancies noted.

h. Allegation - Processing of ECRs and ECNs It was alleged that although the product design engineering rt section initiate 3ECRs and ECNs Yese)ae 55-200 requirements of hgineering herating frocedure Qi@PbWf9694,the ECRs and ECNs were not being processed per the requirements of W nufacturing rocedure (MP h J .J g, To satisfy the requirements of MP-2.28, the product desing engineering section would in part, be required to accommodate a change request coordinator, responsible for maintaining a change request log, logging all change request and issueing a quarterly report of outstanding change request.

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 inspector.

ORGANIZATION:: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT. INSPECTION RESULTS: PAGE of N0.: 99900403/86 The findings disclosed that: 1) E0P-55.200 is an engineering procedure used by the product design section for the initiating and processing of ECNs/ECRs. Also, there is no reference made to MP-2.28 in the sections of this procedure. 2) MP-2.28 is a manufacturing procedure issued for use by the NC&ID production-department, for the preparation and usage of a change request to the engineering department for its review and approval. Since no correlation could be made between the two (2) procedures, this allegation could not be substantiated.

i. The following allegations were made with regard to problems identified with the Reactor Mode Switch.

Allegation - There were several references made to the reactor mode switch throughout the allegers daily work record. In May of 1980 the alleger retrieved, from these references, six (6) major items of concern and formally presented the items to GE for their review. GE established a problem review board in June of 1980 to review all the problems identified on the subject reactor mode switch and document a plan to resolve all of the identified problems. ThepotentialproblemswerealsoreportedtoGE'sfafetyand

ORGANIZATION: GENEPAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION / PAGE of N0.: 99900403/86-01 RESULTS: / icensing department and a formal RC file was opened. Although no allegations were made against a specific reactor mode switch, the alleger expressed' concern as to how the formal PRC was closed. At ' Inspection findings - The NRC inspector reviewed the M PRC

               & focusing on the six (6) concerns identified by th alleger with the reactor mode switch and the commitments made by the review board to resolve the problems.

The following is a description of the concerns identified by the alleger to GE. GE's response, and the NRC inspectors findings. Problem 1 - It was observed that parts list PL 386X240 contained "laters" and that there was no plan in place to complete the document. GE's Response - Parts list PL386X240 is referenced on drawing 195B9497. No good explanation could be offered as to why the parts list was established. It does not provide any information necessary to the fabrication, test, or use of the switch. It was agreed to delete the parts list PL 386X240 and the reference to it on the design drawing 195B9497.

m7-ORGANIZATION: GENERAL ELECTRIC' COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of I. Inspection Findings - GE presented to the NRC inspector parts list PL 386X240 and design drawing 19549497 for review. It was noted that the "laters" on the parts list had been deleted. Also the reference made to the parts list on the design drawing "PL issued," had been deleted for the required procedures and the item was considered closed. Problem 2 - After removing the switch neck assembly to install the switch-into the isolation can, it is possible that the switch contacts are desychronized. The switch position, then, does not necessarily provide the intended switch function. GE's Response - In a problem review board meeting it was decided to change the mounting desing of the switch so that it is not necessary to do any diassembly of the switch. Further, it was agreed that a note be added to the nuclear related safety drawing 163C1487 which would caution against any disassembly. i A test requirement for the assembly 163C1487 will be required in a nate on the drawing. An analysis will be made to determine if another seismic test on the assembly is necessary or if a seismic analysis will suffice. The scismic qualification status will be documented on the assembly drawing.

ORGSNIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA

    -REPORT                                                                    INSPECTION RESULTS:                          PAGE    of NO.: 99900403/86-01 Lastly, the switch assembly shall be mounted to the bonchboard
                    . front, using the isolation box as the major support interface rather than the switch neck.

( Inspection Findings - The inspector was presented design drawing

                      #163C1487 for review.                                         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 isolation can. The design drawing also referenced ECN-NJ 21792 which verified the seismic qualification status of the subject switch and this item was considered closed. Problem 3 - The replacement of the four (4) mounting screws is not documented in any procedure. GE' Response - This is not a safety concern since the switch using these undocumented screws is what has been qualified. i

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of Inspection Findings - The NRC inspector did not review the documentation procedure for the mounting of the screws. Instead, any discrepancies noted in the QA reports, which would reflect mounting screw failures during the qualificatin of a mode switch, was requested. GE personnel researched a select number of plants requested by the NRC inspector and no discrepancies were noted. Problem 4 - The screw fasteners in the base of the isolator can become loosley coupled on some assemblies and tend to twist. It is virtually impossible to torque the cover screws to an acceptable level. GE's Response - The base metal tolerance permits this situation to exist occassionally. The material will be changed to a thicker gauge. The screw fastener will be analyzed in the non base material to ensure that an acceptable procedure is in place to provide a high yield of acceptable assemblies. Inspection Findings - The NRC inspector reviewed ECN-NJ 21792 which reflected the design changes made to the mode switch frame and end cap.

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: -99900403/86-01 RESULTS: PAGE 1 of The NRC inspector also reviewed ECN-NJ 21793 which listed the plants that would recieve the mode switches with the design changes. In addition, the qualification records which would reflect any discrepancies with the switches previously shipped to the remaining plants were also requested. GE reviewed a select number of quality records requested by the NRC inspector and no discrepancies were noted. Problem 5 - The switch neck assembly was fractured at least once during the installation of the switch into the benchboard. It was considered by some board members to be fragile. GE's Response - The implementation of the solution to problem

                #2 will prevent stress to be placed on the switch neck at all times.

Inspection Findings - Reference the NRC inspectors findings for problem #2 of the report. Problem 6 - The drawing 195B9497 Rev. 3 removed a note "PL issued" without benefit of an ECN.

ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA

REPORT INSPECTION NO.: _99900403/86-01 RESULTS: PAGE of GE's Response - This is a drafting and documentation problem.

                 "PL issued" should not be on the drawing since there is no p1 for this drawing. A file index is provided but should not be misunderstood to be a lit The real problem here is removal of a "PL issued" from the drawing with an ECN.

Inspection Findings - In an interview with GE personnel it was stated that, the note "PL issued" was deleted from the design w/t drawing as a class (3) change, he procedure E0P-55-2.00. The NRC inspector 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 document, can be made without the use of an engineering change authorization (ECA) or engineering change notice (ECN). i It was decided that although an ECN may have been a more appropriate change for the traceability of the parts list, the procedure l that was implemented would also be applicable. p ga)540 gf ($w hut ~~w / T M A et/ O MA/ C a d A n T / y tr" /t c 7/o w ste- post 7' CAR Jtjo. $,7.f])/(,~~

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t Indoctrination and Training The inspectors also reviewed GE's Engineering Operating Procedures, which define the responsbilities for developing, administering, and conducting Quality Assurance training activities within NEBO. In Qd M addition, personne1'and training records of the allegedere reviewed.t in an attempt to define e,actly what training was completed and the areas affected. o
~~----A_ _m.m_________ ___~~
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of GE's initial training program began in March, 1975 thru the issuance of their QA Newsletter to the Boiling Water Reactor Systems Department (BWRSD). This newsletter was the first in a series of informative publications designed to report useful information, and significant current events affecting BWRSD personnel. The first course " Change Control System," was scheduled for April 7,1975 and was designed to acquaint BWRSD personnel with the proper application of GE's Engineer-ing Practices and Procedures (EP & Ps). In December, 1976, GE initia-ted Nuclear Energy Business Group (NEBG) Procedure 70-30 " Personal Proficiency in Quality Related Activities," which was intended to establish the minimum personal proficiency requirements to be imple-mented within the nuclear anergy business components in support of-the overall QA program as required by GE policy. In October, 1978 GE issued QA newsletter #40 which was the first to ment'.on the issuance of E0P 75-5.00 establishing the GE Quality Assurance Training Program. This procedure stated the individual managers had the overall responsibility for determining the specific , needs of personnel assigned to them. A review of the training records of the alleger revealed the follow-ing classes attended:
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE of Date Topic 6/14/79 Change Control 4/21/81 Audit Training Course 4/30/81 New Quality System 5/26/81 Audits - How to deal with Auditors 6/16/81 Design Record Files (DRF) 9/30/81 Change Control - Reliability Studies 3/3/82 Field Documentation 4/7/82 Design Verificatio . g 6Z%+, tin % Wn E*i jffg/ The majority of the classes were attended whi the alleger was A> g i employed in the Technical Licensing Unit of GE NEB 0jw i _
G EL C IC. LETTER estor's ID: gg.,um: i;;sanAra"': l em7 lhtur e nu e d@(
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Document Ncne: <ss88 #* GENERAL ELECTRIC LETTER p Requestor's ID: I
~~.EILEEN r's Name:~~
~~Document Comments: 99900403/86-01 i l l l~~
~-
~~d Docket No. 99900403/86-01. l~~
~~. General Electric Company Nuclear Energy: Business Operations. 'ATTM: Mr._W. H. Bruggeman, Vice President and General Manager 175 Curtner Avenue San Jose, California 95125 Gentlemen:~~
This refers to the inspection conducted by Messrs. R. L. Pettis, R. P. McIntyre, and P. J. Prescott.of this office,_on April 14-17, and July 14-18,_1986, of your facility at San Jose, California, and to the discussions of our findings with Mr._ J...J. Fox and members of your staff at the conclusion of the' inspection. l This inspection 1was' conducted in response to allegations received by the NRC in a-letter dated October 5, 1985 from the Government Accountability Project'(GAP). This letter and rel&ted documents alleged deficiencies _ in the Design Control, Quality Assurance / Quality Control program at General Electric's-(GE) San Jose, California facility, during the' period March 1978 to April 1982. . Areas examined during the inspection and our findings are discussed in the 4 enclosed report. Within these areas, the inspection consisted of an exami-
~~. nation of procedures and representative records, interviews with personnel, and observations by the inspector. -~~
Y
~~- - , - w._, ,--, ,, - -,,. .,- -,, ..n, , ,n - , - , ,--- - - --. - ,---~~
~~During this inspection, it was found that the implementation of your Q program failed to meet certain NRC requirements y Tlm ..~ a . . . .~~
~~'W es'for . . x. ...-. .~..~~
in the area of deferred verification as described in General Electric Company's Engineering Operating Procedure (EOP) 42-6.00. The specific findings and refer-ences to the pertinent requirements are identified in the enclosures to this letter. 4 Please provide us within 30 days from the date of this letter a written state-ment containing: (1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to pievent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed. Consideration may be given to extending your response time for good cause shown. The responses requested by this letter are not subject to the clearance procedures of the Office of Management anc; Budget as reuqired by the Paperwork Reduction Act of 1980, PL 96-511. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, I Robert F. Heishman, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Prograns Office of Inspection and Enforcenent
~~Enclosures:~~
1. Appendix A-Notice cf Nonconformance

2. Appendix B-Inspection Report No. 99900403/86-01
~~-3. Appendix C-Inspection Data Sheets (19 paSes)~~
Distribution: ' DMB:IE:09 4 VPB Reading , BGrimes JStone . LParker RPettis . JCraig HHiller RMcIntyre
?Prescott VPB:DQAVT SC/VPB:DQAVT BC/VPB:DQAVT RPettis: sam JCraig RHeishman / /86 / /86 / /86 - - - _ _ _ - - - - - - - _ _ - - - _ - - - - - _ - - - 1
' APPENDIX A General Electric Ccmpany Nuclear Energy Business Operations Docket No.- 99900403/86-01 NOTICE OF i;0NCONFORiiANCE Based on the 'results of an NRC inspection conducted on April 14-18 and July 14-18, 1986, it appears that certain of your activities were not conducted in accordance with NRC requirements.
Criterion Y of Appendix b'to 10 CFR part 50 states: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a. type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or. drawings shall include appropriate quantitative or qualitative acceptance criteria'for determining that important activities have been satis-factorily accomplished."
~~1. Engineering Operating Procedure (EOP) 42-6.00, Section 4.1.2.e~~
" Independent Design Verificaticn", issued April 30, 1981 requires, in part', that when deferred verification is completed, notify Engineering Services 1 by processing a Deferred Verification Status Change Notice I (DVSCN) form that identifies the verified documents, Design Record File (DRF) containing verification, completion date, and distribution identical to that of the issued document.
l
~~. -- - - - -_ - .-_--,-r , ,.~~
n Contrary to the above, Panel Module U710 (Assembly drawing PL914E989) for River Bend Unit 1, was verified on Revision 3, dated September 7,1982, Engineering Change Notice (ECN) NJ34893, but no DVSCN was processed identifying to Engineering Services 1 that the deferred verification was completed. The verification was. originally deferred on Engineering Review Memorandum (ER!t) No. AML-973, issued December 2, 1980. (86-01-01)
2. General Electric's Engineering Operating Procedure (EOP) 25-4.00, Section 2 and Section 4.3 requires, in part, that engineering work authorizations (EWA) be used to communicate and establish work requirements with performing engineering components and other Nuclear Energy Business Operations (NEBO) functional components. The EWA shall define the scope or work requested, including changes, additions, deletions, modifications, and options exercised in existing work or totally new work requirements.
Processing services shall control issue of approved EWAs and maintair, retrievable EWA records. Contrary to the above, General Electric was unable to retrieve EWA No. FEC446, the document which defined.the scope of work requested, per DVSCN No. 01706, for the qualification of electrical components to be used in L nuclear safety related Category 1 electrical circuits, for panel No. H13-P861. (86-01-02) g g /g h k
3. General Electric's corrective action request procedure (CAR) MP-5.01, Section 4.2.3.2, requires, in part, that the recipient of a CAR must respond by the reply date requested, or if unable, will negotiate a revised reply date with the initiator. If the revised date is agreed upon, it will be entered on the CAR document and initialed by the initiator on the Original Copy.
Contrary to-the above these procedures were not followed when a GE manufacterin5 engineer dispositioned CAR No.' SJ.57711 twenty-five days after the required reply date specified by the initiator. (86-01-03)
4. Engineering Operating Procedure (EOP) 42-6.00,'" Independent Design Verific6 tion" Section 4.1.2.b issued April 30, 1981, requires, in part, notification of Engineering Services 1 by processing an accompanying DVSCN form that identifies the document, the scheduled date of deferred verification completion, DRF reference if applicable, and distribution identical tc that-of the . issued document.
Contrary to the above, this procedure was not followed in that the required DVSCN was not ccmpleted and GE's Engineering Services 1 Department was not notified of the deferring verification described in ECN NJ.43120. (86-01-04)
5. Criterion III of 10 CFR Part 50 Appendix B, requires, in part, that the verification or checking process be performed by individuals or' groups other than those who performed the original design, but who may be from the same organization.
GE's Engineering Operating Procedure (E0P) 42-6.00, " Independent Design Verification," issued April 30, 1981, states in Section 4.1.1(d)(2) that the Verifier may not be directly responsible and accountable for the design or design chan5e being verified.
Contrary to the above, GE issued two Engineering heview Memorandums (ERfi) in which -(1):the designer was identified to .perfom the docunent review and (2) the assigned' reviewer also provided document approval as the-responsible' engineer. .(86-01-05) C
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~~- Document Name: . - GEt ERAL ELECTRIC COMPA!!Y RPT: 'Requesto5sID:~~
EILEEh . - + Author!s-Name': . E PETTIS 4; .
~~. Document Coments: - 99900403/86-01:~~
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ORGAN 1ZATION: . GENERAL ELECTRfC C0hFANY
. NUCLEAR ENERGY BUSINESS OPERATICNS SAN JOSE, CALIFORNIA REPORT INSPECTION INSPECTION N0.: 99900403/06-01. DATES: 4/14-17; 7/14-17/66. ON-SITE HOURS: 248 ' CORRESPONDENCE ADDRESS: General Electric Company ' Nuclear Energy- Business Operations ATTN: .Mr. W. H. Bruggeman,.Vice President 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 NEBO), has.a work force of approximately~2500 assigned to domestic and foreign nuclear power plant activity.
ASSIGNED INSPECTOR: R. L. Pettis, Special Projects Inspection Date Section (SPIS) OTHER INSPECTOR (S): R. McIntyre, SPIS P. Eshleman, SMC O'Donnell P. Prescott, SPIS Q. Howard, EG&G APPROVED BY: John W. Craig, Chief, 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 inspection was to follow-up on allegations involving deficiencies in the Design Control, Quality Assurance / Quality Control Program at GE San Jose, during the period March 1978 to April 1982. PLANT SITE APPLICABILITY: Multiple plant sites.
ORGANIZATION: GENERAL ELECTRIC COMPANY. NUCLEAR ENERGY BUSINESS OPERATIONS
~~. SAN JOSE, CALIFORNIA REPORT- INSPECTION NO.: 99900403/86 RESULTS: PAGE 2'of A. VIOLATIONS:~~
~~None. B. NONCONFORMANCES:~~
~~~ Contrary to Section 4.1.2.e of Engineering Operating Procedure (E0P) ~ '1.~~
42-6.00, " Independent Design Verification", no evidence existed to support the processing of a Deferred Verification Status Change Notice (DVSCN) identifying that Panel Module U710 (Assembly Drawing PL914E989), for the River Bend project, was cleared of deferred
~~. verification. (86-01-01)~~
2. Contrary to General Electric's Engineering Operating Procedure (EOP) 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 qualification 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 twenty-five (25) days after the required response date specified by the initiator. (86-01-03)
ORGANIZAT10ft: GENERAL ELECTRIC COMPAfiY l'UCLEAR EftERGY BUSINESS OPERATI0liS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 3 of
4. Contrary to General Electric's Independent Design Verification Procedure E0P 42-6.00 Section 4.1.2.e, the required DVSCN, which would have oocumented the opening of a deferment per ECN NJ-43120, was not generated through GE's Engineering Services 1 department.
~~(86-01-04)~~
5. Contrary to Criterion III of 10 CFR Part 50 Appendix B and General Electric Company Engineering Operating Procedure (E0P) 42-6.00, GE issued two Engineering Review Menorandums (ERM's) in which: (1) the designer was identified to perform the document review (ERM-A!4D-1302); and (2) where the assigned reviewer also provided document approval as the Responsible Engineer (ERM-AMC-3035).
(86-01-05) C. UNRESOLVED ISSUES: YkNk &h S hv &rialg lluc{ mot. /g VM DEcAb)q//evos(c t f ns*f feresy d b7 Y WK L f4udC h 3 & N 2%, Mee in bd fa truto? fhij frutr~ sur// bt f r. fs m Y
~~/ $fr skW D. STAT OF P VIOU I PECT DYiGS:~~
The status remains as presented in NRC Inspection Report #99900403/85-01. An evaluation of open inspection findings was not conducted during this inspection.
4
~~- ORGANIZATION: GENERAL ELECTRIC COMPANY.~~
NUCLEAR ENERGY EUSINESS OPERATIONS SAN J0SE, CALIFORNIA REPORT . . INSPECTION NO.: 99900403/86-01 RESULTS:- PAGE 4 of E. OTHER FINDINGS AND OBSERVATIONS: Background Information In October 1985, allegations were presented to-the Nuclear Regulatory.
~~. Commission (NRC),OfficeofInspectionandEnforcement,inaletter from the Government Accountability Project (GAP) identifying deficiencies ~~~
in the Design Control and Quality Assurance program at General Electric's (GE) facility in San Jose, California. A consultant for GAP conducted a review and analysis of this information and prepared a report of the major concerns. This report and the employees work record were then furnished to the NRC for appropriate action. The background information provided to the NRC by GAP was voluminous and addressed a' number of issues. This report documents two inspections performed as a result of these allegations. Additionally, the initial NRC inspections were performed in September 1983 in response to the same basic allegations made by the same individual. The previous NRC review of these issues did not include the background information l (work diary and related documents over two thousand pages) provided to the NRC by GAP. t l
OF.GANIZATION: GENERAL ELECTRIC COMPANY-
~~' NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA ~~~
REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 5 of This report does-not address all of the items raised in the documents. Rather, the~ representative sample of potentiall more significant allegations were selected for review. These items were primarily in the area of Deferred Verification, which formed the basis'of this inspection. The remaining items identified by GAP were not reviewed in depth during this inspection, but will be addressed in the future by the NRC. The representative sample of allegations 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.
1. Deferred Verification

a. Deferred verification is a system in place at GE which allows independent design verification to be deferred until after the design document issue due to incomplete design or other reasons.
This system is described in Engineering Operating Procedure (EOP) 42-6.00, " Independent Design Verification," which establishes the requirements and conditions to be met when - deferring design verification.
a. i 0RGANIZATION: ' GENERAL-ELECTRIC COMPANY NUCLEAR-ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA
~~-REPORT. . . . ' INSPECTION NO.: 99900403/86-01~ RESULTS: PAGE 6 of.~~
GE introduced deferral.of design verification in Addendun _ 4 to Engineering Practice ~and Procedure (EP&P) 5.38, " Design Verification," in December 1975. This stipulated that a tracking system and a status log of deferred verifications must be main-tained._ However, the NRC inspector verified that such a status log was not initiated until May,1977.
~
~~In July of 1977, Engineering Operating Procedure-(EOP) 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) 40-6.00 was changed to (E0P) 42-6.00, " Independent Design Verification." This included a 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 after design document issue, due to incomplete design or other reasons the Engineering P.eview Memorandum (ERM) or Engineering Change Notice (ECN) issuing or apply the document must state:
1. That verification is deferred

2. Reason for deferral

3. A schedule for performing the verification ,
~~0RGANIZATION: GENERAL ELECTRIC. COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA~~
~~= REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 7 of~~
4. The Design Record File (DRF) if applicable

5. The signature of the Responsible Design Engineers and Section Manager authorizing deferral.
Verification status of documents with deferred verification is contained in the Engineering Information System (EIS), a computer data base, maintained by the Engineering Services 1 group. Engineering Services 2 records and tracks deferred and additional verifications in the Work Planning & Scheduling System (WPSS). They are also responsible for closing out completed verification tasks upon receipt of a Deferred Verification Status Change Notice (DVSCH) from Engineering Services 1.- Engineering Services 1 is also responsible for revising verification status of the documents in the EIS. On April 30, 1981, E0P 42-6.00 was issued which superceded the April 4, 1980 issue. This issue required a DVSCN to be processed and accompany the ERM/ECH when a verification was deferred. This DVSCN, sent to Engineering Services 1, included the five (5) requirements, listed above, to be followed when deferring verification. It also included a requirement that when the deferred verification was completed, Engineering Services 1 must be notified by processing another DVSCN that identified the verified documents. Engineering Services 1 l I l
ORGAf;IZATION: GEllERAL ELECTRIC COMPAhY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT -- INSPECTI0f! NO.: 99900403/86-01 RESULTS: PAGE 8 of-then assured.that.the status of the deferred verification was entered into EIS and notified Engineering Services-2 to track. the completion in the scheduling system.
b. F,iver Bend Panel Module Assembly U710 Several documents selected and reviewed from the deferred-verification status log to determine whether deferred verifications are corpleted and verified in accordance with the requirenents of E0P 42-6.00.
' Engineering Review Memorandum (ERM), AML-973 was issued on December 2, 1980 for Panel Module Assembly U710 on assembly drawing 914E989, for River Bend Unit I was reviewed. This ERM deferred verification pending completion of the cable and panel design. The inspector traced the drawing through its revision levels while reviewing numerous ECHs, to detenaine if the verification had been completed.
The deferred verification was completed on Revision 3 of parts List 914E989 Vid ECN No. NJ34893, issued May 13, 1982. No DVSCH was processed as required by E0P 42-6.00, issued April 30, 1981, notifying Engineering Services 1 that deferred verification had been completed.
y
~~, , :a.~~
10RGANIZATION: ' GENERAL ELECTRIC COMPANY-. NUCLEAR ENERGY BUSINESS OPERATIONS SAN-JOSE, CALIFORHIA REPORT. . INSPECTION . NO.: '99900403/86 RESULTS: -PAGE 9 of Nonconformance 86-01-01 was identified as a-result of this review.
~~c. The' NRC inspector reviewed Design Verification Status Change~~
. Notice No. 01706 issued December _19, 1984, as a result of a discrepancy with' electrical panel No.-H13-P861, installed S 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 were to be performed in accordance with . Engineering Work Authorization No. FE8446. EWAs are required:
per GE's Engineering Operating Procedure (E0P) No. 25-4.00 and are used to communicate and establish work' requirements with performing engineering components and.other Nuclear Energy Business Operations (NEBO) functional components. The EWA' defines the scope of work requested, including changes, addi-tions, deletions, modifications and options exercised in existing work or totally new work requirements. The NRC inspector requested EWA No. FE8446 for review. Although GE presented documentation which exhibited a complete follow-up of'the qualification for the electrical circuits, the document required for the initiation of the qualification process, EWA No. FE8446, could not be located. Nonconformance 86-01-02 was identified as a result of this review.
ORGANIZATION: GENERAL ELECTRIC COMPAhY
' NUCLEAR ENERGY SUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 10 of d.- The NRC inspector examined ECN No. NJ 43120 and Design Verification Status Change Notice (DVSCN) No. 02294. ECN NJ 43120.was initiated on March 30, 1983 due to a discrepancy noted with a pressure transmitter (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 qualification requirement and a note was added to the ECN requir-ing that the verification for the iten be deferred until work week 8352(December 1983). For close-out of the deferred veri--
fication on ECN NJ 43120, DVSCN No. 02294 was initiated on January 21, 1986. The NRC inspector noted that this date did not coincide with the scheduled verification completion date specified on the ECN. There was also no evidence that a DVSCN had been generated through GE's Engineering Services I department, to open the deferment as specified in GE's Independent Design Verification Procedure E0P 42-6.00. Section 4.1.2B of this procedure requires notifying Engineering Services 1 by processing , an accompanying DVSCN form that identifies the document, the scheduled date of deferred verification completion, DRF reference if applicable, and distribution identical to that of the issued document. Change Notice A & B were issued in late (November and December) 1903, E0P 42-6.00, April 30, 1981, is the applicable procedure
CRGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSiriESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTI0'l NO.: 99900403/86-01 RESUL15: PAGE 11 of Nonconformance 86-01-04 was identified as a result of this review.
2. Desigr. Control Review of Allegations 3 (GrJTSALG NucjeQL MF 4f[ECA b G !
~~NI CN )~~
a. 6 Elementary Diagrams kPn Allegation - St, allegation involved elementary drawings for panel H13 and H22 for the CNV plant, drafted by the C. F. Braun Company of Alhambra, California. It was alleged that the GE system engineers refused to sign the elementary drawing AWh8d &
Abe> 1Hpt caused personnel problems. The documents were later signed by the C&ID CNV lead engineer. Inspection finding - Elementary drawings for panels H13 and H22 were requested, however drawings were not received in time for a review. GE personnel stated that C. F. Braun was the Architect / Engineer (A/E) responsible for checking and verifying the drawings. - The approval signature by GE would be necessary to place the C. F. Braun drawing under a GE parts list number.
~~\S G un MS VY th" . Sb OY O~~
/
ORGANIZATION: GENERAL ELECTRIC C0tiPANY j NUCLEAR ENERGY BUSINESS OPEP.ATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/80-01 RESULTS: PAGE 12 of t b. [ Independent Design Verification
~~) i l /~~
~~Al gation - In July,1979, an En eering Review MeriIbrandum~~
~~, No. A -3602 was sent to Electric Product Desi'g n for design~~
\
~~verific$tionandthereviewerisallegedto'havereviewedthe ,~~
~~. \~~
~~document quality inste f performing,a'n independent design~~
~~\ l i~~
~~verification.\~~
~~\ \~~
~~Inspection finc On ERM AMC-3602 the reviewer marked the area labelled #9-Document Qgality, after_the drawing 147D7614-I (Term BoardAssemb1)gand signed it ce f on July 20, 1979.~~
~~/ \~~
~~All c ne tion diagfams had\an independent design verification pe.rformed on Aug6st 1, 1979. rawing 147D7614-Terminal Board~~
~
~~Assembly and,0rawing PL147D7614 ' re not signed off as being f independentIyverifiedbuttheresp sible engir.aer had not~~
~~. l /~~
~~dassigned a reviewer for these drawings nd had approved the comple ed ERM.~~
'/ N e only assigned review noted on the ERM was f drawing 147D7614 to be reviewed for document quality. The responsi e engineer approved the review on August 2, 1979. , / -
' 0F.GAf;IZATION: GENERAL ELECT'RIC COMPA!!Y NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 13 of TVA Panels Allegation - Panel G41-P003, for TVA 18, was alleged to have been tested to the wrong elementary diaor'i since the TVA-connection oiagram agreed with the Grr a Gulf elementary and not the TVA elementary. ,
Inspection finding - Based upon the documents reviewed, the inspecto, cculd not determine whether.or not a panel was ultimately shipped after being incorrectly assembled, tested or quality inspected. A review of connection diagrans for G41-P003 indicated only minor differences in the conection diagrams. Copies of the elementary diagrams were requested' for review, but the drawings presented were the latest revision. The connection and elementary drawings were not compared during this inspection. This is an unresolved item. (. . Incomplete ECN's Allegation - This allegation involved resolution of a CAR. ECN NJ-17584 and ECN NJ-13557 were written to resolve CAR
ORGANIZATION: ' GENERAL ELECTRIC COMPANY-NUCLEAR ENEkGY BUSINESS OPEPATIONS
~~~ , SAN JOSE, CALIFORNIA ' REPORT- INSPECTI0f:~~
NO.: 99900403/86-01 RESULTS: PAGE 14 of SJ-56233. However, they were not complete as 'of April 15, 1980. Inspection finding - The ECN's were both issued on 4/22/80. Different elementary diagrams can 'show a panel that would have a connection diagram is the same_for different plants because the panel is the same for each plant. TVA and Grand Gulf - G41-P003~ panels'all came from the same connection diagram, but had different elementary diagrams. If the panel should change it would carry a different drawing number than the other pe.nels. The Master Parts List for the~ plant lists the correct panel drawing to be used and is found in the Engineering Information System (EIS).
~~/ Elementary Diagrams Allegation - This allegation involved testing of panels.~~
Specifically, TVA 18 panel H22-P007 was alleged to have been tested to the wrong elementary diagram since drawing 851E478 was used when' drawing 386X994-007 should have been used and the EIS system was not used by the tester.
0' RGAt!IZATION: GE!!ER' AL ELECTRIC COMPANY NUCLEAR ENERGY EiUSINESS OPERATIONS SAh CCSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/66-01 RESULTS: PAGE 15 of
' Inspection' finding - The test procedure for the TVA panel is Test' Inspection document 2131 which calls out both drawings 851E478 (GE drawing) and 386X994-007 (1121).(C. F. Braun Dwg 1-121) as reference drawings. This document requires continuity $
and Hipot tests using connection diagrams, a power check, and temperature recorder calibraticn, but the procedure does not call for direct use of the elementary drawings. Both drawings were compared and found to have the same information for panel ( H22 n007. Based upon the documents reviewed the panel was tested using the proper drawing. Additionally testers are not required to use the EIS. g . TVA Panel Ir.terference Problem Allegation - An electrical panel for TVA 21 was allegedly shipped from GE, San'Jcse, with a 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 welded vertical unistruts. The interference problem was first noticed on panels for Grand Gulf 2 and CNY (panel
~~#G41-P001).~~
Inspection findings - The NRC inspector reviewed GE's design control procedure section 3.11, " Field Change Control." The b
ORGANIZATION: . GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 .RESULTS: PAGE 16 of procedure states, in part, that when it becomes necessary.to ship products to_the site before manufacturing is complete (ship short) either by NE50 or its suppliers, a Field Deviation Instruction (FDI) is issued which identifies the work to be completed in the l l field. Such FDIs identify the necessary engineering and quality I ( requirements. [ The NRC inspector requested all revisions to the design drawings ) for TVA 21, Grand Gulf 2 and CNV, in addition to ECNs, FDDRs and FDIs for the subject design drawings. A review of the subject design drawings was performed to assure that the interferences between the terminal screws and the vertical struts had been evaluated. A review of all associated documentation and dates which initiated each design change was also performed for the subject design drawings and there were no discrepancies noted. O Processing of ECRs and ECNs d Allegation - Although the product design engineering section initiates ECRs and ECNs, per the requirements of Engineering Operating Procedure (EOP) 55-2.00, the ECRs and ECNs were
OhGANIZATI0t.: GENERAL ELECTRIC COMPANY
. NUCLEAR EliERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT IllSPECTION N0.: 99900403/86-01 RESULTS: PAGE'17 of allegedly not being processed in accordance with the require-ments of GE Manufacturing Procedure (MP) 2.28.
To satisfy the requirements of MP-2.28, the product design engineering section would in part, be required to accomodate a change request coordinator, responsible for maintaining a change request icg, logging all requests and issuing a quarterly report of all outstanding change requests and these requirements were allegedly not being met. 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 inspector. pucleay hh d hsYavetJATton DMSiovi (MC ETD) The findings disclosed that: 1) E0P- 5.200 is an engineering procedure used by the product design s ction for the initiating and processing of ECNs/ECRs. Also, there s no reference made to 11P-2.28 in the sections of this procedure. 2) MP-2.28 is a manufacturing procedure issued for use by th i roduction department, for the preparation and usage of a change request to the engineering department for its review and approval. < Since there was no correlation between these two procedures, this allegation was not substantiated.
s' Y ORGANIZATION: GENERAL ELECTRIC COMPANY HUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 18 of i e 4 lh fon. f I% /
f
$ . ERM Review hy //pm .p 4.,[,e. //e.4*(-MOL j - s,?S,d,,,,,,t;g&eIB,defpr sf & De' *"O OfY~G"Y :
~~Allegat}on ?f!b.'? _. .omm inv . we ecv.c. A elqce g ,$v huAd 154 ,W. -..oprh.. ,n**w$ 4H V .... ui.c 6u uc u rcvIEW OT~~
~~' ' ~ ' I l, ^.. ^ % ~^ ' rgcu irk Iu A& defofnL}Ie00Cumens~~
~~(/tr re ,~~
- . . . . . . ...m., .~3,, .c icn. & N$D inspector performed a review of ERM Inspection Findingsd. twkic lA AMC-3602 i peResponsibleEngineerhadspecifiedaDocument Quality review (#9). V. Woldow provided c. review of seven (7) documents. Some of these comments were technical in addition to the document quality review as specified. The overall quality of the ERM document was not good with no reviewer assigned for seven (7) of the documents. The responsible Engineer identified Item 23 as a missing element of the parts ,$ list.pThe ERM was approw.i on 8/2/79 by both the Responsible g 44/ .4",
~~Engineer and the Engineering Manager. No Deferred Verification was noted poweverfthepartwasidentifiedandaddedtothe~~
~~/M ddl8F[4 g E design package shortly thereafter. Another item of note is the / l17fy title of this ERM of " Terminal Board" which is not a specific 4~~
title for this type of part in a power plant. The allegation was not substantiated by the review of the documentation.42m e t ~ h <stofd fievlof &y Wl pQ, Ms. /Y J 0 74/ Y 96sM& O
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~~;0RGANIZATION: . GENERAL' ELECTRIC-COMPANY . ' NUCLEAR ENERGY BUSINESS OPEPATIONS~~
SAN JOSE,~ CALIFORNIA JREPORT- . INSPECTION NO.: :99900403/86-01 RESULTS: -PAGE 19 of
~~.Potentially Reportable Condition (PRC)L - nab (blN/~~
Allegation -- A review of e work record provided by'the-alleger for. week 8110, discusses the QA procedures for Drafting.and Material control for open safety-related design
~~' deficiencies for RPS panels C71-P011.~~
Inspection Findings - The inspection of PRC file 80-31 revealed that a panel replacement for the RPS equipment'is in progress for the Clinton plants while the TVA plants identified for these panels have been cancelled. The deficiencies were reported to the NRC g January 15, 1981. WN Design Review Report 79-06 was examined as the initial identi-fier of these items as deficiencies'to be reviewed. Concerns were expressed by GE staff members-during the reviews for a means to prevent these type of oversights in the future, and the following plant procedures have been modified:
1) E0P 42-5.00 Engineer Requirements Document Release Revised 2/12/82

2) EIP 6.60. Preparation of Engineering Instructions for Release to Manufacturing 9/30/82

3) QAP 7.28 Shipping Inspection issued 5/14/82
ORGANIZATION: GENERAL ELECTRIC CCMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIF 0iiNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 20 of The items in question were reviewed and reported to the NRC and corrective measures identified prior to the installation of the panels. In addition the procedures in the design process were modified to prevent future problems of this type. Electric Metallic Tubing (EMT) Allegation - This item concerns drawing 175A9666 Revision E, Tubing, EMT which stated the tubing was unavailable for 15 years prior to the identification of this fact by the alleger. The part characteristic which is no longer available was an interior coating of glyptal to the tubing. Inspection Findings - Engineering Change Notice was issued 1/8/81 to review the requirement for glyptal inside the EMT tubing. The reason identified for the change was the unavail-ability of the material, not an acceptable reason for a product change as this part is utilized in Nuclear Safety Grade assemblies. Design Record File A00-891 documents tlie phone call which identified the unavailability of the product and it's elimination as a product by a GE division. A check of the purchase records prior to 1980 identified the purchase of the tubing with glyptal coating. The QC receipt inspections did not specifically indicate the presence of the coating but
ORGANIZATION: GENERAL ELECTRIC CCfsPANY N- pa #ebl,$Jos,p N ) v.;, lay HUCLEAR ENERGY BUSINESS OFERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 21 of the tubing " finish" was verif ed. Either the glyptal coating was never required or it was emoved from the design without proper engineering analysis.Il nufacturing engineers /without recourse to the original engineering design requirements j tn the design creditability for the panels r:x S: :Wwsu 4 If, question .' The allegation was substantiated, however the requirement Tor the material is not identified nor is it clear if the material in fact was supplied from inventory.
~~. Open Corrective Action Report (CAR) on TVA gf [gd-ItwasallegedthatpanelnumberTVA-21H22-P006wasshippedwithan open Corrective Action Report (CAR) No. SJ-57711.~~
Inspection Findings - During the inspection the NRC inspector examined CAR he. SJ-57711. The CAR was a document used by GE's manufactaring department to record discrepancies noted during the manufacturing process of electrical panels and associated components. k$ corrective action procedure MP-5.01 Section 4.2.3.2 requires j 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
CRGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSIllESS OPERATIONS SA!! JOSE, CALIFORNIA REPORT INSPECTION 140.: 99900403/86-01 RESULTS: PAGE 22 of will be entered on the CAR document and initialed by the initi-ator of the CAR on the Original Copy. DuringtheexaminationofCARNo.k7711,theNRCinspectornoted that the CAR had been dispositioned by the recipient twenty-five (25) days after the required reply date specified by the iti-WG ator. The disposition also stated in part tha , screws which were used to make the electrical connection for panel No. k TVA-El H22P008 had to be forcibly removed 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. Nonconformance 86-01-03 was identified as a result of this review.
~~. Elementary Drawing Review I~~
~~( a) An allegation was mad cor.cerning he fact that elementary drawings provided by C. F. Braun were not signed by GE employees to n.ife the design. Wrthok~~
~~/ I.48t//~~
Inspection Finding - The inspector p.-f;...~. ... .... t.r mun v, ERN-AMD 1302 and it's associated Elementary Diagran 828E536AK titled "High Pressure Core Spray System" which
ORGANIZATION: GENERAL ELECTRIC COMPAliY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 23 of C ORAUN revealed the design adequacy was verified by D. F. Saaw.
^
7' ;n with GE employees providing " engineering spot check" @ and " application" reviews. drawing reviewer expressed concern over the identification of the individual who would be responsible for the drawing status but no specific answer was provided. Inspection of the drawing title block and the ERil assignment blocks revealed else=9WMmmrtttm that the individual who was the designerj C. F. Braun was also listed as the reviewer for this drawing, which has a Nuclear Safety Related Division 3 label. Several of the GE employees interviewed indicated that C. F. Braun employees were trained in the GE procedures for safety related design documentation require-ments by a C. F. Braun program J.i l ...; monitored by GE. L _) pG Verification of this program was not :tt S 'l M ;:.IP ~7
/M #f %M. 5l:i a a u.a.. . ., i $3 7.1i :d :2 27 Il- C . C .~. C . . u, mi s tub .
m d f r th The allegation was rifi:u;a u" . : '.'~: '::S' :t +'^ - k avbutiic H Ld vrr . fA? $$ / N N&Y WW 0 b) An allegation was presented that CNV Panel H22-P028 was reviewed with little attention of reference to the - appropriate elementary diagram. l
ORGANIZATION: GEhERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 24 of A review of ERM-AMC 3035 j dated October 11,1978; identified several review comments but pecifict ..... _. refer-enced to elementary diagrams. ' JJ. . 3. . . . . . ...._
.t' Review comments were noted in June and July while the responsible engineer was not assigned until October. TP.: ;;; . . . .'. TE W M sign-off occurred the same day as the assignment of the _
~~responsible engineer, the reviewer of the assembly~~
~ . .,s drawing e. .. . ... , ,... = W K all documents in the ERM. The Interface review was refused by the assigned reviewer with no comment as to the reason for thi action r$et Ad4 or assignment of another reviewer.Tho corrnents wer provided by the " system application" reviewer. e ERI'/
howwr was was passed on as approved tut,no comments e available except from the sponsible wAS Jygineer. The quality of the documentation knot satis-factory since GE E0P requirements for ev ew not provided. f The question of adequate review to the other interfacin - we5 designs A not resolvable from this information. This N/k reviewwasidentifiegap of nonconformance ".- b^e't ' 4 M allagation was notG 'i h O t:.L . .. _ as the detail reference documents were not identified on the review l i documentation,i;..&_,rnoreferencetoelementarydrawings d l
~~/provided.~~
A/@-
e-l ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY EUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 .RESULTS: PAGE 25 of Nonconformance No. 86-01-05 was identified during this part of the inspection.
3. Reactor Mode Switch Allegation - There were several references r:ade to the reactor mode switch throughout the allegers daily work record. In May of 1980 the alleger retrieved, from these references, six (6) maior items of concern and fomally presented the items to GE for their review.
GE established a problem review board in June of 1980 to review all M problems identifieI with the M reactor mode switch and document a plan to resolve he identified problems. The potential problems were also reported to GE's Safety and Licensing hpartmentandafhlPotentiallyReportableCondition(PRC) file was opened. Although no allegations were made against a specific reactor mode switch, the alleger expressed concern as to how the fomal PRC was eventually 9 ::d. If[oftf/od# l Inspection findings - The NRC inspector reviewed the PRC file focusing on the six (6) concerns identified by the alleger mehmehemosentor N and the commitments made by the review board to resolve the problems.
ORGARIZATION: GENERAL ELECTl!IC COMPAllY NUCLEAR EHERGY BUSIhESS GPERATI0f'S SAN JOSE, CALIFORNIA REPORT IllSPECTION NO.: 99900403/86-01 RESULTS: PAGE 26 of The following is a description of th,e concern _s_ identified by the alleger ptI [ GE's r onse and the NRC inspectors findings.
~~/L - c.~U~ s f ' N.'~~
Problem 1 - It was . parts list PL 386X2 0 contained y "laters" and that there was no plan in place to complete the document. GE's Response - Parts list PL386X240 is reference on drawing 195B9497. No geet explanaticn could be offered as to why the parts list was established. It not provide any infonnation necessary GE gJe the fabrication, test, or use of the switch. M-wes agreed to delete the parts list n. acoJ6 and the reference to it on design drawing 195B9497. Inspection Findincs - GE presented to the NRC inspector parts list PL 386X240 and design drawing 19549497 for review. It was noted that the "laters" on the parts list had been deleted. Also the reference made to the parts list on the design drawing "PL issued," had been deleted per the required procedures and the item was considered closed.
, n ,, s iJ1M ws*f Problem 2-4$fterremovingtheswitchneckassembly install the switc olation can, it e e switch ,
contacts s e desynchroniz . ~ ..-'- nne +han d^^s p . .. W wb p.,;u.s< zk n h<m a % A e k .N/~~t & " .
_ , , , _ , 4 - u- - u -- - r,a e
~~' fearg " s %.ae -~~
~~nn g n,_ p a--,nw c~~
~~P 7 4on: n <re l- k'Sc A !%vday kosip q It.e p ,+ e4 y~~
~~.A2)k '~~
~~du 9sse~~
~~$M w urk ny j a$~~
~~as.9 y.a ms.n-9~~
~~5. AW s # d orcam a w &~~
~~.2 d d e d y A s.~~
~~L B,p s e 4sa d M ~~< g au4- m-c cv ,, g nr, 4 W& & Hcm+ or rl a-pena s f 117 ~ f A+/f' cE.~~
~~< ns a xa ess4ky g A r. . x 4 a n a p u dgr, x A. M, 4 c l[Ledssv_ . M <u du,A <rkM Pf~~
ORGANIZATION: GENERAL ELECTRIC COMPAliY HUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTIO!! NO.: 99900403/86-01 RESULTS: PAGE 27 of
~~' ' ' ~ ~ ~~~
GE'sResponse-Inaproblemreviewboardmeeting'ItwasdecidedTo changethemountingdesignoftheswitchsothatitisnotnecessaryI GE [yM/.g, " -- - , l'--- "; d the swi tch. Further, h agreed that a note dded to the nuclear related safety drawing 163C1487 which/ j would caution'against any disassembly. x ...c g x 11 Atestrequirementfortb's9ssembly163C1487willberequiredina
% / / note on the drawing. An anal is will be made to determine if f i anotherseismictestonthe'assetky..isnecessaryorifaseismic ! 'i N ./r . // - analysis will suffice. The seismic quali.fication status will be .
~~documented on the assembly drawing.~~
'> 'N Lastly, the switch assembly sham be mounted to the bfachboard front, . u..JJ Ne 's sing the isolation box as the major support interface rat'her than the switch neck.
~~InspectionFindings-TheinspectorwaspresenteddesigndrawingMO, _~~
/ft163C1487forreview. Incorporated on the drawing was a note which 0" t 4 statedjonotuse/usedrawing#18CC0835. The referenced design draw- )
ing 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 isolation can.
ORGANIZATION: GENERAL ELECTRIC COMPA!!Y l'UCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 28 of The design drawing also referenced ECN-NJ 21792 which verified the j seismic qualification status of the subject switch,
~~~ .. ~- .u- -~~
~~As s stis~'T 4_ A'~~
~~,A cfFM cowh/~~
ugs g//erJ-N M A~. c4r /. ws Problen3-{%ereplacement6fthefour(4)mountingscrewsynot documented in any re, pewbe GE' Response - @ not a safety concern since the switch using these undocunented screws is what has been qualified. Inspection Findings - The NRC inspector did not review the documen-tation procedure for the mounting of the screws. Instead, any discrepancies noted in the QA reports, which would reflect mounting screw failures during the qualification of iode switch, was requested. GE personnel researched a select number of plants requested by the NRC inspector and no discrepancies were noted. Zh wtf ellffY Problem 4[-[escrewfastenersinthebaseo solator can h/r#rG~ Bettme loose g on some assemblies and tand.to twist. It W#f - kvirtuallyimpossibletotorquethecoverscrewstoanacceptable level.
._ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __l
CRGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSII;ESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 29 of GE's Response - The base metal tolerance p +s this s tuation to ll m 66 $"[f& C44*fIvf MdMY exist occasionallyy -
~~-"1 will " -M..g_ to a thicker gauge.~~
he screw fasteneQ M jin the non base material j ' " !' lthw h k /f g g M ) [ esser.e esSu d M an acceptable procedure is inr#4Lplace M of acceptable assemblies. Inspection Findings - The NRC inspector reviewed ECN-NJ 21792 which reflected the design changes made to the mode switch $ frameandendcap,g$wid Th: "": ' :r % also M ECN-NJ 21793 which listed the plants W that would receive the mode switches with the design 4 changes. In addition, the qualification records jwhich would reflect any dis-crepancies with the switches previously shipped to the remaining plants were also requested. GE reviewed a select number of quality records requested by the NRC inspector and no discrepancies were noted. Z+ wat eNtfdW Problem 5 -pe switch neck assembly was fractured at least once during the installation
~'
into the benchboard,
y ORGANIZATION: GENERAL ELECTRIC COMPANY HUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 30 of GE's Response - The implementation of the solution to roblem #2 will prevent stress to be placed on the switch neck at all times. Inspection Findings - Reference the NRC inspectors findings for roblem #2 of the report. ,,
~~.Q yog gllgA/ AMb EN#- * - " ' ' ""~~
~~Probl em 6 - f .. ... M "'""^ ' ^' 1. yes ls Y& I 54e~~
/.M 3' GE's Response - This is a drafting and documentation problem. "PL pris &sr issued" should not be on the arawing since there is no for this drawing. /) filp index is provided but should not be misunderstood hkAsf tobeafk: The real problem here is removal of a "PL issued" fror.
the drawing without benefit of an ECN. Inspection Findings - In an interview with GE perscnnel it was stated that, the note "PL issued" was deleted from the design drawing as a GE class (3) change, per4 procedure E0P 5-2.00. The NRC inspector oA 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 document, can be made without the use of an engineering change authorization (ECA) or engineering changenotice(ECN).
I o ORGANIZATION: GEt:ERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAh JOSE, CALIFORNIA REPORT INSPECTI0t; N0.: 99900403/66-01 RESULTS: PAGE 31 of GE
~~+ Mees decided that although an ECN may have been a more appropriate change for the traceability of the parts list, the procedure that was inglemented would also be applicable.~~
W Allegation - In the minutes of a problem p review board meeting, it was W C4 redes pointedoutthatpanelsforKuo-SheggandCc.t:-tsNuclearPlantsare of the " pre-compact" design with the riode switch mounted on the vertical surface of the benchboard. In this design, the rear support unistrut can become torsionally twisted causing excessive force to Le applied to the neck of the switch. The review team recommended that a two (2) hole unistrut be used to prevent the mounting support S*'TCM
~~- : t; ; ;;t, ' r- t " " " ~ ;~~
fvt,w hecw hy Twt $120 The review of the new panel design was assigned to the alleger and his conclusion was that the rear support structure will not reliably provide front support for the reactor mode switches used in both plants [ referenced. It was recommended, by the alleger in a formal letter written to the problem review board in flovember 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 stress on the switch neck. Inspection Findings - A copy of this letter could not be found in the formal PRC file, or any rebuttals by GE to this letter. There was
F l ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORMIA l l I REPORT INSPECTI0f' NO.: 99900403/06-01 RESULTS: PAGE 32 of I
~~/vMofk also no evidence in the ile which 1 ,% g u any attempt made by GE to followup on the concerns or recommendations made by the alleger.~~
The NRC inspector expressed these concerns in an interview with GE personnel. During the interview, the NRC inspector was presented a formc1 letter addressed to the alleger dated December 1980, fron a member of the problem review board. GE personnel stated that the subject letter is GE's rebuttal tc the allegers findings and conclusions. It was further stated that, if the alleger renained dissatisfied with the determination reached by the review board, he could have requested a review of the PRC by the manager of the Safety andLicensinghepartmentasstatedinpartybyGENEB0 j Procedure 70-42, Section 4.3. The NRC inspector was unable to find any evidence of such a request M F by the alleger. g f Within th 6 area of the W ., no nonconformances or violations were identified nor were any of the above allegations substantiated.
4. Indoctrination and Training The inspectors reviewed GE's Engineering Operating Procedures, which define the responsibilities for developing, administering, and con-ducting Quality Assurance trainin5 activities within NEBO. In W
I, ORGANIZAT10!i: GENERAL ELECTRIC C0f;PANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 33 of addition, personnel and training records of the alleger and several other employees were reviewed in an attempt to define exactly what training was completed and the areas affected. GE's initial training program began in March, 1975 thru the issuance of their QA Newsletter to the Boiling Water Reactor Systems Department (BWRSD). This newsletter was the first in a series of informative publications designed to report useful information, and significant current events affecting Bk'RSD personnel. The first course " Change Control System," $ scheduled for April 7,1975gwas designed to acquaint BWRSD personnel with the proper application of GE's Engineering Practices and Procedures (EPLPs). In Decerr.ber,1976, GE initiated Nuclear Energy Business Group (NEBG) Procedure 70-30
" Personal Proficiency in Quality Related Activities," which was intended to establish the minimum personal proficiency requirements to be implemented within the nuclear energy business components in support of the overall QA program as required by GE policy.
l In October, 1978 GE issued QA newsletter #40 which was the first to 4 mention the issuance of E0P 75-5.00 establishing the GE Quality Assurance Training Program. This procedure stated the individual - managers had the overall responsibility for determining the specific needs of personnel assigned to them.
ORGANIZATION: GENERAL ELECTRIC C0hPANY liUCLEAR ENERGY BUSINESS OPERATI0fiS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/86-01 RESULTS: PAGE 34 of of4f!S A review of thegtraining records m.. ~ me aise A revealed the following classes attended: Date M e lWY Topic of T4wW( h*SI 6/14/79 Change Control 4/21/01 Audit Training Course 4/30/81 New Quality System 5/26/81 Audits - How to deal with Auditors 6/16/81 Design Reccrd Files (DRF) 9/30/81 Change Control - P.eliability Studies 3/3/82 Field Documentation 4/7/82 Design Verificction The majority of the classes were attended while the alleger was employed in the Technical Licensing Unit of GE NEBO, durina the period October, 1980 thru April 30, 1982p the allegers last day ofworkatGE[d*Tc46.
5. Training of Subvendors A[ - It was alleged that during the October 1981 time period, an individual working for Omtec, a subcontractor performing work for GE, had diffi-culties working with GE's documentation and deferred verification
ORGANIZATION: GENERAL ELECTRIC COMPANY liUCLEAR ENERGY BUSINESS OPERATIONS SAh JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 35 of ge n a > b isSt* system. The areas noted by the alleger oftheMasterf Parts List,gk of understanding GE's documentation control system and verification status. The alleger also questioned the training 1 this incividual received on the weege of GE's Engineering Information System (EIS). Inspection Findings - During the inspection, GE informed the NRC inspector that this individual had been employed by GE from January 1977 through September 1981 prior to accepting a position with Omtec. The NRC inspector was also presented a training file for this individual, dated Feb through September 1980 which included Field kcumentation,hesign hcord ble, I h ange @ontrol and k sign kerification h /s#f , i l GE also stated that they do not have separate training procedures l for subvendor employees. GE howevery does require that subvencors whohaveemployeesutilizingthevariousGEsystems7Addr infonn GE to insure that the employees receive the required training in theff vital areas. A listing of subvendor employees who had received training in these various areas was presented to the NRC inspector for review.
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UNITED STATES g/pnneuq[g g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 {%f -
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~~Docket No. 99900403/86-01 ._ General Electric Company -~~
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Nuclear Energy Business Operations ATTN: Mr. N. L. Felmus, Vice President and General Manager 175 Curtner Avenue San Jose, California 95125 Gentlemen: This refers to the inspection conducted by Messrs. R. L. Pettis, R. P. McIntyre, and P. J. Prescott of this office, on April 14-17, and July 14-18, 1986, of your facility at San Jose, California, and to the discussions of our findings with Mr. J. J. Fox and members of your staff at the conclusion of the inspection. This inspection was conducted in response to allegations received by the NRC in a letter dated October 5,1985 from the Government Accountability Project (GAP). This letter and related documents alleged deficiencies in the Design Control, Quality Assurance /Qcality Control program at General Electric's (GE) San Jose, California facility, during the period March 1978 to Ariril 1982. Areas examined during the inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector. During this inspection, it was found that the implementation of your QA program failed to meet certain NRC requirements, specifically in the area of deferred verification as described in General Electric Company's Engineering Operating Procedure (EOP) 42-6.00. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter. Please provide us within 30 days from the date of this letter a written state-ment containing: (1) a description of steps that have been or will be taken i to correct these. items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and
~~preventive measures were or will be completed. Consideration may be given to l extending your response time for good cause shown.~~
The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as reuqired by the Papemork Reduction Act of 1980, PL 96-511. i
Z APPENDIX A General Electric Company Nuclear Energy Business Operations - Docket No. 99900403/86-01 NOTICE OF NONCONFORMANCE ~. Based on the results of an NRC inspection conducted on April 14-18 and July 14-18, 1986, it appears that certain of your activities were not conducted in accordance with NRC requirements. Criterion V of Appendix B to 10 CFR part 50 states: . " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings snali include appropriate quantitative or qualitative acceptance criteria for detennining that important activities have been satis-factorily accomplished." ,
1. Engineering Operating Procedure (EOP) 42-6.00, Section 4.1.2.e " Independent Design Verification", issued April 30, 1981 requires, in part, that when deferred verification is completed, notify Engineering Services 1 by processing a Deferred Verification Status Change Notice (DVSCN) form that identifies the verified documents Design Record File (DRF) containing verification, completion date, and distribution identical to that of the issued document.
Contrary to the above, Panel Module U710 (Assembly drawing PL914E989) for River Berid Unit 1, was verified on Revision 3, dated September 7,1982, Engineering Change Notice (ECN) NJ34893, but no DVSCN was processed identifying to Engineering Services 1 that the deferred verification was completed. The verification was originally deferred on Engineering Review l (86-01-01) i Memorandum (ERM) No. AML-973, issued December 2,1980.
2. General Electric's Engineering Operating Procedure (EOP) 25-4.00, Section 2 and Section 4.3 requires, in part, that engineering work authorizations (EWA) be used to communicate and establish work requirements with performin engineering components and other Nuclear Energy Business Operations (N functional components. The EWA shall define the scope or work requested, including changes, additions, deletions, modifications, and options exercised in existing work or totally new work requirements. Processing services shall control issue of approved EWAs and maintain retrievable EWA records.
Contrary to the above, General Electric was unable to retrieve EWA No. FE8446, the document which defined the scope of work requested, per DVSCN No. 01706, for the qualification of electrical components to be used in nuclear safety related Category 1 electrical circuits, on Nine Mile Point 2, for panel No. H13-P861. (86-01-02) _j
3. General Electric's corrective action request procedure (CAR) MP-5.01, Section 4.2.3.2, requires, in part, that the recipient of a CAR must respond by the reply date requested, or if unable, will negotiate a revised reply date with the initiator. If the revised date is agreed upon, it will be entered on the CAR document and initialed by the initiator on the
~
Original Copy. Contrary to the above these procedures were not followed when a GE manufacturing engineer dispositioned CAR No. SJ.57711 twenty-five days after the required reply date specified by the initiator. (86-01-03)
4. Engineering Operating Procedure (EOP) 42-6.00, " Independent Design Verification" Section 4.1.2.b issued April 30, 1981, requires, in part, notification of Engineering Services 1 by processing an accompanying DVSCN form that identifies the document, the scheduled date of deferred verification completion, ORF reference if applicable, and distribution identical to that of the issued document.
Contrary to the above, this procedure was not followed in that the required DVSCN was not completed and GE's Engineering Services 1 Department was not notified of the deferrina verification described in ECN NJ.43120. (86-01-04)
5. Criterion III of 10 CFR Part 50 Appendix B, requires, in part, that the verification or checking process be performed by individuals or groups other than those who performed the original design, but who may be from the same organization.
GE's Engineering Operating Procedure (EOP) 42-6.00, " Independent Design Verification," issued April 30, 1981, states in Section 4.1.1(d)(2) that the Verifier may not be directly responsible and accountable for the design or design change being verified. Contrary to the above, GE issued two Engineering Review Memorandums (ERM) in which (1) the designer was identified to perform the document review and (2) the assigned reviewer also provided document approval as the responsible engineer. (86-01-05) 1 l 1 1 l
General Electric Company In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. Should you have any questions concerning this inspection, we will be pleased to
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~~discuss them with you. Sincerely, Robert F. Heishren, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement~~
~~Enclosures:~~
1. Appendix A-Notice of Nonconformance

2. Appendix B-Inspection Report No. 99900403/86-01

3. Appendix C-Inspection Data Sheets (19 pages)
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS, SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 6 of 20 Nonconformance 86-01-01 was identified as a. result~ of this review. .
b. The NRC inspector reviewed Design Verification Status Change Notice 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 were to be performed in accordance with Engineering Work Authorizati n (EWA) No. FE8446. EWAs are required per GE's Engineering Operating Procedure (E0P) No.
25-4.00 and are used to comnonicate and establish work require-ments with performing enginearing components and other Nuclear Energy Business Operations (NEB 0) functional components. The EWA defines the scope of work requested, including changes, additions, deletions, modifications and options exercised in existing work or totally new work requirements. The NRC inspector reauested EWA No. FE8446 for review. Although GE presented documentation which exhibited a complete follow-up of the qualification for the electrical circuits, the document required for the initiation of the qualification process, EWA No. FE8446, could not be located. Nonconformance 86-01-02 was identified as a result of this review.
b. The NRC inspector examined ECN No. NJ 43120 and Design Verification Status Change Notice (DVSCN) No. 02294. ECN NJ 43120 was initiated on March 30, 1983 due to a discrepancy noted with a pressure transmitter (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 I qualification requirements and a note was added to the ECN requir-l ing that the verification for the item be deferred until work week 8352(December 1983). For close-out of the deferred veri-fication on ECN NJ 43120, DVSCN No. 02294 was initiated on January 21, 1986. The NPC inspector noted that this date did not coincide with the scheduled verification completion date specified on the ECN. There was also no evidence that a DVSCN l had been generated through GE's Engineering Services 1 depertment, to open the deferment as specified in GE's Independent Design
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 7 of 20 Verification Procedure E0P 42-6.00. Section 412B of this procedure requires notifying Engineering Services 1 by processing an accompanying DVSCN form that identifies the document, the scheduled date of deferred verification completion, DRF reference if applicable, and distribution identical to that of the issued document. Change Notice A & B were issued in late (November and December) 1983, E0P 42-6.00, April 30, 1981, is the applicable procedure. Nonconformance 86-01-04 was identified as a result of this review.
2. Design Control Review of Allegations

a. TVA Panels Allegation - Panel G41-P003, for TVA 18, was alleged to have been tested to the wrong elementary diagram since the TVA connection diagram agreed with the Grand Gulf elementary and not the TVA elementary.
Inspection finding - Based upon the documents reviewed, the inspector could not determine whether or not a panel was ultimately shipped after being incorrectly assembled, tested or quality inspected. A review of connection diagrams for G41-P003 indicated only minor differences in the connection diagrams. Copies of the elementary diagrams were requested for review, but the drawings presented were the latest revision. The connection and elementary drawings were not compared during this inspection. This is an unresolved item. (86-01-07)
~~b. Incomplete ECN's Allegation - This allegation involved resolution of a CAR.~~
ECN NJ-17584 and ECN NJ-13557 were written to resolve CAR SJ-56233. However, they were not complete as of April 15, 1980. Inspection finding - The ECN's were both issued on 4/22/80.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 8 of 20 Different elementary diagrams can show a panel which would have a connection diagram that is the same for different plants, because the panel is the same for each plant. TVA and Grand Gulf G41-P003 panels all came from the same connection diagram, but had different elementary diagrams. If the panel should change, it would carry a different drawing number than the other panels. The Master Parts List for the plant lists the correct panel drawing to be used and is found in the Engineering Information System (EIS).
~~c. Elementary Diagrams Allegation - This allegation involved testing of panels.~~
Specifically, TVA 18 panel H22-P007 was alleged to have been tested to the wrong elementary diagram since drawing 851E478 was used when drawing 386X994-007 should have been used and the EIS system was not used by the tester. Inspection finding - The test procedure for the TVA panel is Test Inspection document 2131 which calls out both drawings 851E478 (GE drawing) and 386X994-007 (1121) (C. F. Braun Dwg 1-121) as reference drawings. This document requires continuity and Hipot tests using connection diagrams, a power check, and temperature recorder calibration, but the procedure does not call for direct use of the elementary drawings. Both drawings were compared and found to have the same information for panel H22-P007. Based upon the documents reviewed the panel was tested using the proper drawing. Additionally testers are not required to use the EIS.
~~d. TVA Panel Interference Problem Allegation - An electrical panel for TVA 21 was allegedly shipped from GE, San Jose, with a 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 welded vertical unistruts. The interference problem was first noticed on panels for Grand Gulf 2 and CNV (panel
~~#G41-P001).~~
Inspection findings - The NRC inspector reviewed GE's design control procedure section 3.11. " Field Change Control." The procedure states, in part, that when it becomes necessary to ship
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 9 of 20 products to the site before manufacturing is complete (ship short) either by NEB 0 or its suppliers, a Field Deviatitn Instruction (FDI) is issued which identifies the work to be completed in the field. Such FDIs identify the necessary engineering and quality requirements. The NRC inspector requested all revisions to the design drawings for TVA 21 Grand Gulf 2 and CNV, in addition to ECNs, FDDRs and l FDIs for the subject design drawings. I A review of the subject design drawings was performed to assure that the interferences between the terminal screws and the vertical struts had been evaluated. A review of all associated documentation and dates which initiated each design change was also performed for the subject design drawings and there were no discrepancies noted,
e. Processing of ECRs and ECNs Allegation - Although the product design engineering section initiates ECPs and ECNs, per the requirements of Engineering Operating Procedure (EOP) 55-2.00, ECRs and ECNs were allegedly not being processed in Eccordance with the requirements of GE Manufacturing Procedure (MP) 2.28.
To satisfy the requirements of MP-2.28, the product design er.gineering section would in part, be required to accommodate a change request coordinator, responsible for maintaining a change request log, logging all requests and issuing a quarterly report of all outstanding change requests and these requirements were allegedly not being met. l Inspection findings - An interview with GE personnel and a review l of procedures E0P 55-2.00 and MP-2.28 was performed by the NRC inspector. The findings disclosed that: 1) E0P-55.200 is an engineering procedure used by the product design section for the initiating and processing of ECNs/ECRs. Also, there is no reference made to MP-2.28 in the sections of this procedure. 2) MP-2.28 is a manufacturino procedure issued for use by the Nuclear Control & Instrumentatien Division (NC&lD) production department, for the preparation and usage of a change request to the engineering department for its review and approval.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA 1 l REPORT INSPECTION ' RESULTS: PAGE 10 of 20 NO.: 99900403/86-01 1 Since there was no correlation between these two procedures,
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~~this allegation was not substantiated.~~
f. ERM Review Allegation - The alleger states in July, 1979, Engineering Review Memorandum No. AMC-3602 was sent to Electrical Product Design for Design Verification. However, the reviewer is alleged to have reviewed the document 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 a Document Quality review (#9). V. Woldow provided a review of seven (7) documents. Some of these coments were technical in. addition to the document quality review as specified. The over-all quality of the ERM document was not good with no reviewer assigned for seven (7) of the documents. The responsible Engineer identified Item 23 as a missing element of the parts list. All connection diagrams had an independent design veri-fication performed on August 1, 1979, the ERM was approved on 8/2/79 by both the Responsible Engineer and the Engineering Manager. No Deferred Verification was noted, however the part was identified and added to the design package shortly there-after. Another item of note is the title of this FRM of
" Terminal Board" which is not a specific title for this type of part in a power plant. The allegation was not substantiated by the review of the documentation since the only assigned review noted on the ERM was for document quality for drawing No. 14707614.
~~g. Potentially Reportable Condition (PRC)~~
Allegation - A review of the work record provided by the alleger for week 8110, (March, 1981), discusses the QA procedures for Drafting and Material control for open safety-related design deficiencies for RPS panels C71-P011. Inspection Findings - The inspection of PRC file 80-31 revealed that a panel replacement for the RPS equipment is in progress for the Clinton plants while the TVA plants identified for these panels have been cancelled. The deficiencies were reported to the NRC on January 15, 1981.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 11 of 20 Design Review Report 79-06 was examined as the 1.nitial identi-fier of these items as deficiencies to be reviewed. Concerns were expressed by GE staff members during the reviews for a means to prevent these type of oversights in the future, and the following plant procedures have been modified:
1) E0P 42-5.00 Engineer Requirements Document Release Revised 2/12/82

2) EIP 6.60 Preparation of Engineering Instructions for Release to Manufacturing 9/30/82

3) OAP 7.28 Shipping Inspection, issued 5/14/82 The items in cuestion were reviewed and reported to the NRC and corrective measures identified prior to the installation of the panels. In addition the procedures in the design process were.
~~modified to prevent future problems of this type,~~
~~h. Electric Metallic Tubing (EMT)~~
Allegation - This item concerns drawing 175A9666 Revision 2, Tubing, EMT which stated the tubing was unavailable for 15 years prior to the identification of this fact by the alleger. The part characteristic which is no longer available was an interior coating of glyptal to the tubing. Inspection Findings - Engineering Change Notice was issued 1/8/81 to review the requirement for glyptal inside the EMT tubing. The reason identified for the change was the unavail-ability of the material, not an acceptable reason for a product change as this part is utilized in Nuclear Safety Grade assemblies. Design Record File A00-891 documents the phone call which identified the unavailability of the product and it's elimination as a product by a GE division. A check of the purchase records prior to 1980 identified the purchase of the tubing with glyptal coating. The QC receipt inspections did not specifically indicate the presence of the coating but the tubing " finish" was verified. Either the glyptal coating was never required or it was removed from the design without proper engineering analysis. If this method of design change control is utilized by manufacturing engineers, without recourse to the original engineering design requirements, the design creditability for the panels may be in question. The allegation was substantiated, however the reouirement for the material is not identified nor is it clear if the material in fact was supplied from inventory.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 , RESULTS: PAGE 12 of 20
~~1. Open Corrective Action Report (CAR) on TVA .~~
Allegation - It was alleged that panel number TVA-21 H22-P008 was shipped with an open Corrective Action Report (CAR) No. SJ-57711. Inspection Findings - 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. 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 reouested, or if unable to, will negotiate a revised reply date with the initiator. If a revised date is agreed upon, it will be entered on the CAR document and initialed by the initi-ator 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 required reply date specified by the initiator. The disposition also stated in part that screws which were used to make the electrical connection for panel No. TVA-21 H22P008 had to be forcibly removed 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. Nonconformance 86-01-03 was identified as a result of this review. J. Elementary Drawing Review a) An allegation was made concerning the fact that elementary drawings provided by the C. F. Braun Company were not signed by GE employees verifying the design. Inspection Finding - The inspector reviewed ERM-AMD 1302 and it's associated Elementary Diagram 828E536AK titled "High Pressure Core Spray System" which revealed the design adequacy was verified by C. F. Braun Company with GE employees providing " engineering spot check" and
~~" application" reviews. A drawing reviewer expressed~~
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 13 of 20 concern over the identification of the individual who would be responsible for the drawing status'but no specific answer was provided. Inspection of the drawing title block and the ERM assignment blocks revealed that the individual who was the designer, for C. F. Braun, was also listed as the reviewer for this drawing, which has a Nuclear Safety Related Division 3 label. Several of the GE employees interviewed indicated that C. F. Braun employees were trained in the GE procedures for. safety related design documentation requirements by a C. F. Araun program monitored by GE. Verification of this program was not performed during the inspection. The allegation was substantiated and resulted in an item of nonconformance. b) An allegation was presented that CNV Panel H22-P028 was reviewed with little attention of reference to the appropriate elementary diagram. A review of ERM-AMC 3035, dated October 11, 1978, identified several review comments but none specifically referenced to elementary diagrams. (Allegation comment) Review comments were noted in June and July while the responsible engineer was not assigned until October. It was noted that the approval sign-off occurred the same day as the
~~. assignment of the responsible engineer, and the reviewer of the assembly drawing approved all documents in the ERM.~~
The Interface review was refused by the assigned reviewer with no comment as to the reason for this action or assignment of another reviewer. In addition, no comments were provided by the " system application" reviewer. Later, the ERM was passed on as approved, however, no comments were available except frcn the responsible engineer. The quality of the documentation was not satisfactory since GE E0P requirements for such review was not provided. The question of adequate review to the other interfacing designs was not resolvable frcm this information. This review was identified as an item of nonconformance, however, the allegation was not substantiated as the detail reference documents were not identified on the review documentation, and no reference to elementary drawings was provided.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 14 of 20 Nonconformance No. 86-01-05 was identified during this part of ~ the inspection.
3. Reactor Mode Switch Allegation - There were several references made to the reactor mode switch throughout the allegers daily work record. In May of 1980 the alleger retrieved, from these references, six (6) major items of concern and femally presented the items to GE for their review.
GE established a problem review board in June of 1980 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. Although no allegations were made against a specific reactor mode switch, the alleger expres-sed concern as to how the formal PRC was eventually dispositioned. Inspection findings - The NRC inspector reviewed the PRC file focusing on the six (6) concerns identified by the alleger and the commitments made by the review board to resolve the problems. The following is a description of the concerns identified by the alleger, GE's response, as referenced in the Problem Review Comittee file, and the NRC inspectors findings. Problem 1 - It was alleged that parts list PL 386X240 contained "laters" and that there was no plan in place to complete the document. GE's Response - Parts list PL386X240 is referenced on drawing 195B9497. No explanation could be offered by GE as to why the parts list was established. It did not provide any information necessary for the fabrication, test, or use of the switch. OE agreed to delete the parts list and the reference to it on design drawing 195B9497. Inspection Findings - GE presented to the NRC inspector parts list , PL 386X240 and design drawing 19549497 for review. It was roted that the "laters" on the parts list had been deleted. Also the reference made to the parts list on the design drawing "PL issued," had been deleted per the required procedures and the item was considered closed. ,
~~. l l~~
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA 4 REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 15 of 20 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 being positioned in a different spot other than that observed by the operator. GE's Response - In a problem review board meeting GE comitted to the following action:
1. Revise the mounting design of the switch so that it's disassembly would not be required.

2. Add a note to nuclear safety related drawing No. 163C1487 cautioning against disassembly.

3. Add a test requirement note to the drawing also.

4. Perform an analysis to determine if another seismic test on the assembly would be necessary or if a seismic analysis would suffice.

5. Document on the assembly drawing the seismic qualification status.

6. Mount switch assembly to the front of the bench board using the isolation box as the major support interface rather than the switch neck.
Inspection Findings - The inspector was presented design drawing No. 163C1487 for review. 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 isolation can. The design drawing also referenced ECN NJ 21792 which verified the seismic qualification status of the subject switch. As a result of this action, GE considered the item closed. Problem 3 - It was alleged that the replacement of the fcur (4) mounting screws was not documented in any procedure.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 16 of 20 GE' Response - GE stated this was not a safety concer.n since the switch using these undocumented screws is what has betn qualified. Inspection Findings - The NRC inspector did not review the documen-tation procedure for the mounting of the screws. Instead, any discrepancies noted in the QA reports, which would reflect mounting screw failures during the qualification of the mode switch, was requested. GE personnel researched a select number of plants requested by the NRC inspector and no discrepancies were noted. Problem 4 - It was alleged that the screw fasteners in the base of the isolator can become loose on some assemblies and tended to twist. It was virtually impossible to torque the cover screws to an acceptable level. GE's Response - The base retal tolerance permitted this situation to exist occasionally, however GE suggested changing the material to a thicker gauge. In addition, the screw fasteners in the non base material, would be analyzed to assure an acceptable procedure is in place to provide a higher degree of acceptable assemblies. Inspection Findings - The NRC inspector reviewed ECN-NJ 21792 which reflected the design changes made to the mode switch frame and end cap and also ECN NJ 21793 which listed the plants that would receive the mode switches with the new design changes. In addition, the qualification records, which would reflect any discrepancies with the switches previously shipped to the remaining plants, were also requested. GE reviewed a select number of quality records requested by the NRC inspector and no discrepancies were noted. Problem 5 - It was alleged that the switch neck assembly was fractured at least once during the installation into the benchboard. GE's Response - The implementation of the solution to Problem *2 will prevent stress to be placed on the switch neck at all tires. Ins)ection Findings - Reference the NRC inspectors findings for Pro)1em #2 of the report. Problem 6 - It was alleged that a note "PL 1ssued" was removed without benefit of an ECH on drawing No.195B9497, Revision 3.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORMIA REFORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 17 of 20 GE's Response - This is a draf ting and documentation . problem. "PL issued" should not be on the drawing since there is n'o parts list for this drawing. A file index is provided but should not be misunderstood to be a parts list. The real problem here is removal of a "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 (3) change, per GE procedure E0P 55-2.00. The NRC inspector 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 document, can be made without the use of an engineering change authorization (ECA) or engineering changenotice(ECN).
! GE decided that although an ECN may have been a more appropriate change for the traceability of the parts list, the procedure that was implemented would also be applicable.
Allegation - In the minutes of a GE problem review board meeting, it was pointed out that panels for Kuo Sheng 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 support unistrut can become torsionally twisted causing excessive force to be applied to the neck of the switch. The review team recommended that a two (2) hole unistrut be used to prevent the mounting support switch from becoming twisted. The review of the new panel design was assigned to the alleger and his conclusion was that the rear support structure will not reliably provide front support for the reactor mode switches used in both plants referenced. It was recomended, by the alleger in a formal letter written to the problem review board in November of 1980, that 4 ' the switch frame be securely attached to the front of the panel in which the switch is mounted, thereby removing any possibility of stress on the switch neck. Inspection Findings - A copy of this letter could not be found in the > formal PRC file, or any rebuttals by GE to this letter. There was also no evidence in the file which indicated any attempt made by GE , to followup on the concerns or recomendations made by the alleger. __y.~m _ _ - _ , . - . _ . . , _ , . - . _ _ , - _ - - _ _ , _ _ . . . , _ _ _ . , - , . - _ _ . _ - . - - ~ _ _ _ _ _ _ _ - - -
ORGANIZATION: GENERAL ELECTRIC COPPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 18 of 20 The NRC inspector expressed these concerns in an inte:rview with GE personnel. During the interview, the NRC inspector was presented a formal letter addressed to the alleger dated December 1980, from a member of the problem review board. GE personnel stated that the subject letter is GE's rebuttal to the allegers findings and conclusions. It was further stated that, if the alleger remained dissatisfied with the determination reached by the review board, he could have requested a review of the PRC by the manager of the Safety and Licensing Department, as stated in part by G5 NEB 0 Procedure 70-42, Section 4.3. The NRC inspector was unable to find any evidence of such a request made by the alleger. Within the area of the reactor mode switch allegations, no noncon-formances or violations were identified nor were any of the above allegations substantiated.
4. Indoctrination and Training

a. GE NEB 0 Employees The inspectors reviewed GE's Engineering Operating Procedures, which define the responsibilities for developing, administering.
and conducting Quality Assurance training activities within GE NEBO. In addition, personnel and training records of the alleger and several other employees were reviewed in an attempt to define exactly what training was completed and the areas affected. GE's initial training program began in March, 1975 thru the issuance of their QA Newsletter to the Boiling Water Reactor SystemsDepartment(BWRS0). This newsletter was the first in a series of informative publications designed to report useful information, and significant current events affecting BWRSD personnel. The first course " Change Control System " scheduled for April 7, 1975, was designed to acquaint BWRSD personnel with the proper application of GE's Engineering Practices and Procedures (EPAPs), in December, 1976, GE initiated Nuclear Energy Business Group (NEBG) Procedure 70-30 " Personal Proficiency in Quality Related Activities," which was intended to establish the minimum personal proficiency requirements to be implemented within the nuclear energy business components in support of the overall OA program as required by GE policy.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 19 of 20 In October,1978 GE issued QA newsletter #40 which was the first to mention the issuance of E0P 75-5.00 establishing the GE Quality Assurance Training Program. This procedure stated the individual managers had the overall responsibility for deter-mining the specific needs of personnel assigned to them. A review of the allegers training records revealed the following classes attended: Date Attended Topic of Trainino Cnurse 6/14/79 Change Control 4/21/81 Audit Training Course - 4/30/81 New Quality System 5/26/81 Audits - How to deal with Auditors 6/16/81 DesignRecordFiles(DRF) 9/30/81 Change Control - Reliability Studies 3/3/8? Field Documentation 4/7/82 Design Verification The majority of the classes were attended while the allecer was employed in the Technical Licensing Unit of GE NEBO, during the period October, 1980 thru April 30, 1982 - the allegers last day of work at GE San Jose,
b. Training of Subvendors Allegation - It was alleged that during the October 1981 titre 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 a11eger were in the use of the Master Parts List, and a lack of understanding GE's documentation control system and verification status. The alleger also questioned the training this individual received on the use of GE's Engineering InformationSystem(EIS).
Inspection Findings - During the inspection GE informed the NPC inspector that this individual had been employed by GE from January 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 1970 through September 1980 which included Field Documentation. Design Record File, Change Control and Design Verification courses completed.
ORGANIZATICF: GENERAL ELECTRIC COPPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA 1 PEPORT INSPECTION NO.: 99900403/86-01 RESULTS: PAGE 20 of 20 GE also stated that they do not have separate training proce-dures for subvendor employees. GE however does require that subvendors who have employees utilizing the various GE systems, inform GE to insure that the employees receive the required training in these vital areas. A listing of subvendor employees who had received training in these various areas was presented to the NRC inspector for review. No nonconformances or violations were identified during this part ' of the inspection, nor were any of the allegations substantiated. 1 I L
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Inspector Q. D. Howard Page L of L NAME(Please Print) _ TI*ftE(Please Print) ORGANIZATICN(Please Print)_ D. Hugh Currie Mgr, QA Recordd & Inspection NSOA_ __ N. A. Metras SR QCE NSQA Site Support l lJ.Cintas Principal Engineer , EDE ; l R. K. Waldman y' l Principal Engineer EDE _ lJ.J. Fox z[Sr.ProgramManager GE QA0 g . l C. W. Hart lPrincinalEnaineer I Router - senket West lG.Stramback Safety Evaluation GE Safety & Lfeentino l e l Pr$ grams Manager ' l K. Dawley - lMgr.PlantDef& Release NSQA I - '"IConte ! I ': I . l . 1 [:l I
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General Electric Company In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, Robert F. Heishman, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement
~~Enclosures:~~
1. Appendix A-Notice of Nonconformance

2. Appendix B-Inspection Report No. 99900403/86-01

3. Appendix C-Inspection Data Sheets (19 pages)
Distribution: DMB:lE:09 VPB Reading RStarostecki BGrimes JStone LParker RPettis JCraig HMiller RMcIntyre PPrescott RHeishman VPB:DCAVT SC/VPB:DQAVT BC/VPB:DQAVT RPettis: sam JCraig RHeishman
~~/ ./86 / /86 / /86~~
~~Document'Name: GENERAL ELECTRIC COMPANY RPT Requestor's ID: TERI Author's Name: PETTIS Document Connents:~~
~~99900403/86-01 e ~ -~ - . -- -.,n-- . - + , , . , . < - , ., ,- ,, ..,--..,,-,-,.,e-,, . _ , , , , , , ,,.e. --.---~...---..-,,-y., -mm---m wv..,.,,,-,~~
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~~Document Name:~~
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~~GENERAL ELECTRIC LETTER~~
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~~Requestor's ID: TERI~~
~~' Author's Name: I PETTIS )~~
~~Document Comments 99900403/86-01. , . d t b~~
~~... .. # - 3, I~~
~~GENERAL QUESTIONS for i Mr. Sam Milam III A l~~
~~. A.~~
The following questions relate to the work record of Mr. Sam Milam III during [ his employment at GE San Jose, specifically the time period from March 1978 t to April 1982, which correlates to Mr. Milam's work record. ,
~~1. The NRC has in its possession the following documents, as furnished by ;~~
~~the Government Accountability Project (GAP): ,~~
~~a. A report prepared by Mr. Charles E. Stokes for the GAP entitled~~
~~"'eneral Electric's Record in Nuclear Safety" (81 pages).~~
~~b. A package of ERM's and ECN's changed after your signature while' under Mr. C. L. Cobler 3/31'/ 80 to'10/24/80, (approximately 1" thick).~~
4
~~c. Work records covering the following periods while employed at i~~
~~General Electric (several thousand pages).~~
~~1) 3/2/78 - 3/29/80 CW ~~~
ii) 3/31/80 - 10/24/80 iii) 10/27/80 - 5/31/81 /h C iv) 6/1/81 - 10/30/81 IF . es l v) 11/2/81 - 3/31/82 b M (A).s Y vi) 4/1/82 - 4/30/82 vii) Deferred Verification Memoirs viii) NRC search of publi docume.nt files' . 0!^. Y , Y' ' YP'k'r E.
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i ; h kyouhaveanyotherdocuments,inadditionto p those already furnished to GAP or contained in your work record, that may effect the safe operation of a nuclear power facility, either domestic or foreign? hh NgdG k-
/ 2. Please describe your present position? h L/ f O R., - /#
M. j 3. Have you reviewed the report prepared by Mr. Charles E. Stokes for GApy 9,b ach #A ~4Gtj yo w wwY N Wea ref pened 3/7/ - V//L
/ 4. What was your capacity (job description) while employed at General Electric San Jose before and during the time frame correlatin to your w recor .
Y,
% h gn [dWT Yb 6/UVlC W l 5. + M 1y discuss the method used by eneral Electric to control deferred y O 'f h*'
er f cations?' PN [2dlud M # '
6. Are you aware of any component or activity within General Electric which may involve a high number of deferred verifications?

8. Do you have any knowledge of a component shipped to a domestic or foreign -
~~nuclear power plant containing a known defect? D~~
~~-_____._________._______________.____________________________________g_______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~~
~
j j 9. Are you aware of any instances in which a Potentially Reportable Condition (PRC) was not properly evaluated by General Electric as required by 10 CFR Part 21, and also General Electric procedures? If so, please be specific as to the nature of the potential deficiency and the disposition taken by General Electric. l la, yO^ 0 m b(DJ'Ilf JYY
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EAsr WES 7 /wGS T 75mg '. ArnNrlan - t L. fsrns Je (m -6m) . TYPE OF TILICOPltX '3 'd @/d5 -
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TELECOPltX TILIPHONE NO. - YN - 72 M _ MD VfRIFICATlON TILIPHONE No. Y9 2 - _ FROM C b M /1 C 6 E # Y TELEPHONE Wo. 5 8' 1- I' COMPANY C' '
~~' TYPE OF TILICOPIEi!~~
TILECDPitR TIL! PHONE NO. . VERIFICATION TELEPHQNE NO. __ b' TOTAL P AGES (extfuding tr:Esmittel sheet! OATE E RETURN ORIQlNAL YES NO NAME b
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O b a ,a 9 NESO AUDIT INSPECTION QD NOWARD Intra * =tio_n . L This inspection (4 Nuclear Energy Busines/14-17/86) s Operations of San Jose, Calif. wasof the General Electric Com initiated by some concerns raised in a work record kept by an ex-employee during the time period of 4/78 to 5/82. findings willreport. inspection be included in the Section E portion of the fiThenal following E. Othew yindinss or ca==^nts: for the CNV plant drafted by C F Braun1. The employee notes in No . refused to sign the elementary drawing., the GE system engineers later signed by the C&EE CNV lead engineer.The documents were system review caused later personnel problems.This lack of Resolution Since more than one elementary diagram can be the actual drawing numbers of the elementary drawings inas question. 1 & 2 panels OnH13 4/17/86 elementary drawing were requested for CNV and H22. time to review for signatures, possibly because no systemNo drawings we number was available to use to retrieve the dooument. GE personnel stated that C F Braun was the A .
.would have been checked or verified by them and /E and onlythe thedrawing approval signature to place the C F Braun drawing under a parts list number in order to track it would be necessary.GE There was no statment found to indicate that any personnel problem caused a defective piece of equipment to be shipped.
for CNV panel H22-P028.2. The employee states that many errors were foun He states that CNV reviews were between the panel drawings with little attention to elementary diagrams. Resolution problem. Too little information was given to evaluate'the It was not clear as to which drawin had reviewed or what a "CNV review" was.(panel, which drawingsassembly, he connecti -
3. In July 1979 (week 7929) it was stated that an Engineering Review Design forMemorandum design verification ERM AMC and that the -3602 reviewer was sent to Electrical Prod reviewed the document design verification. quality instead of performing an independent a
e
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~~F t t maeolution review me #9-Document Quality after the drawing 147D7614on ER~~
~~-Terminal Board Assembly and signed it off on 7/20/79 (week ,~~
7929) after reviewing the listed documents for document quality. verification 8/1/79All connection diagrams had an independent design (week 7931). Drawing 147D7614 -Terminal Board Assy. and Drawing PL147D7614 were not sittned off as being independently verified but the responsible eng;,neer had not , assigned ERN. completed a reviewer for these drawings and had approved the The only assigned reviewer noted on the ERN was for drawing 147D7614 to be reviewed for document quality. The responsible engineer approved requested review of thethe review parts8/2/79 list. without any type of tested to the wrong elementary diagram.4. The employee gave the o The TVA connection diagram elementary. agrees with the Grand Gulf elementary and not the TVA manalution \ indicate assembled incorrectly that a panel was ultimately shipped after beingThere is of connection diagrams, tested or quality inspected. A review for G41-P003 ind differences in the connection diagrams.icated only minor the elementary diagrams (rev. before 7846) Requested for review copies on of 4-17-86 but the drawings that came were the latest revision so the connection time constraints.and elementary drawings were not compared due to
~
SJ-56233 were not complete as of week 3016.5. The ECN NJ-1758 He stated that for TVA and Grand Gulf the G41-P003 panels all cane fromelementary different the same connection diagrams. diagram but that they have The connection diagram is difficult the sametoconnection correct due to different elementary diagrams to diagram. Roselution The ECN's were both issued 4/22/80 (week 8017). It is true that different elementary diagrams can show a panel that would different have a connection diagram that would be the same for plants. each plant. This is because the panel is the same for different drawing number than the other panels.If the panel should chang used. The Master Parts List for the plant lists the correct panel drawing to be System. The employee seems to be airing his displeasure with the complexity of the system without suggesting a fix.
~~"""""""" too Eco w .; i . x -BW ? %- - ^ - - - _.~~
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6. During the week 8020 the employee states that TVA H22-P007 was tested to the wrong elementary diagram. 18 panel Drawing 851E478 used. was used when drawing 386X994-007 The EIS system was not used by the tester.should have been .
Resolution TI 2131. The test procedure for the TVA 18 panel H22-P007 is 851E478 (GE drawing) and 386X994007(1121)This Test Inspectio as reference drawings. (CF Braun Dwg 1-121 . continuity and Hipot tests using connection diagrams, a pow check and temperature recorder calibration, but the procedure does not call for any direct use of the elementary drawings Both drawings information forwere panelcompared and found to have the same H22-P007 the wrong drawing. The panel was not tested to It(Engineering is not partInformation of the testers responsibility to use the EIS System). l r00 E00 'ON 8W51 c! 9293 tr180 93'Mer0 l - i_ _ _ _ . .
MET W. DOCUMENTS EX AMINED IleSPECTOR: Q. D. Howard MRT W. PAGE 1 0F 1 E SCOPE: b k hh 90CIS H T 10. REV. DATE DOCIS U T TITLE /5LBJECT
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1 DWG h28E256SA 16 1-31-85 ' Fuel Pool Cooling & Cleanup System - Elementary (GE) Oi 10-30-79 Fuel Fool Cooline & Cleanup System - Elanentary (C. F. Braun) 2 DE 386X994-034 1 851E478 4 2-26-79 Rod Centrol and Information System - Elementary (GE) 3 DWG 10-18-79 Rod Control and Information System Elementary (TVA) (C. F. Braun) n 4 DE _ 386X994-007 1
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m PROC T12131 4 10-1-79 CRD Tery Recorder Panel - H22-P007 5 5 II-PA-002 10 9-13-79 Panel Product In Process Inspection - -, 6 PROC en 7 PROC II-PA-003 7 11-20-79 lifre Continuity Check 8 PROC TI 1646 4 3-10-78 Dielectric Strength Test (Hipot) 9 PROC BWR EDP (GE) 103 1-12-83 Engineering Operating Procedures I l h I a
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OWG - DRANING 1154 - INTERIIRL PO S LTR - LETTER l SPEC - SPECIFICATION - PROC - PROCEDURE gue - GA pennunt - P.O. - PunotASE ENDER ,
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04/22/06 08:46 EG&G 8D. TSA&B to. CO3 006 f PERSONS CONTACTED L Company GE - NERO ' Dates 4/1a.17/nx ; Docket / Report No. _ _ _ _ Inspector Q. D. Howard Page l of L NAME(Please Print) _ _ TITLE (Please Print) _ ORGANf7ATt0N(Please Print)_ f D. Hugh Currie Mgr, QA Records & Inspection N50A_ N. A. Metras SR QCE NSQA Site Support J. Cintas Principal Engineer EDE R. K. Waldman Principal Engineer EDE J. J. Fox Sr. Program Manager GE QA0 C. W. Mart _ Princimal Enoineer Router senkoc Wa<t ,.
4. Stramback Safety Evaluation GE Safety a l_feentino g ', "
~~'l Programs Manager K. Dawley Mgr. Plant Def & Release NSQA~~
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~~- N i b~~
~~DRGANIZATION: GENERAL ELECTRIC CO. SAN JOSE CALIFORNIA REPORT NO. INSPECTION DATES 07/14/B6-07/18/86 PAGE 1 of 3~~
~~' INSPECTI6N BASIS AND SCOPE '~~
A. Basis: 10CFR Part 50 Appendix B and GE EOP 42-6.00 . B. Nonconformances: Contrary to Criterion III of Appendix B to 10CFR Part 50 and General Electric Co. EOP 42-6.00'and ANSI N45.2.11, Quality Assurance Requirements f or the Design of Nuclear Power Plants, GE issued two ERM's in which (1) the designer was identified to perform the document review (ERM-AMD 1302) and (2) where the , assigned reviewer also provided document approval as the ' Responsible Engineer (ERM-AMC 3035). . E. Inspection Findings and Other Comments: , An allegation was made concerning the fact that elementary drawings provided by C. F. Braun were not signed by GE employees to verify the design. (See report sec.1.7) , The inspector performed an investigation of ERM-AMD 1302 and it's
associated Elementary Diagram 828E536AK titled "High Pressure Core Spray System" which revealed the design adequacy was verified by a C.F.Braun Co. employee with GE employees providing ,
~~" engineering spot check" reviews and " application" reviews. pne '~~
drawing reviewer expressed concern over the identification of the individual who would be responsible for the drawing status but no , specific answer is provided. Inspection of the drawing title block and the ERM assignment blocks reveals the information that the individual who was the designer for C.F.Braun was also listed as the reviewer for this drawing, which has a Nuclear Safety Related Div. 3 label. Several of the GE emotoyees interviewed indicated that the C.F.Braun Co. employees were trained in the GE - procedures for safety related design documentation requirements by a C.F.Braun program which was monitored by GE. Verification of , this program was not attempted at this time. This item is identi-fled as an item of nonconformance. The allegation was verified for this sample look at the documentation. An allegation was presented that CNV Panel H22-P028 was reviewed , with little attention or reference to the appropriate elementary diagram. (See report sec. 1.9) 1 . e t 8 ' e g e g 4 g y g 9 9 *4* 4
Page 2 of-3 .! A review of ERM-AMC 3035 dtd. Oct. 11,1978 identified several review comments but no specific comments were referenced to ,
~~' elementary diagrams. (Allegation comment) Review comments were noted in June and July while the. responsible engineer was not' ,~~
assigned until October. The approval sign-off occured the same day as the assignment of the responsible engineer. but the reviewer of the assembly drawing signed for the approval for .all documents in the ERM. The Interface review was refused by the - assigned reviewer with no follow-up as to the reason for this l action or assignment of another reviewer. No comments were , provided by the " system application" reviewer. The ERM was passed on.as approved but no comments are available except from the Originator-Reviewer-(Approval) Responsible Engineer. The quality of the documentati on is not satisfactory since GE EOP . requirements f or review are not provided. Inaddition the dates of assignment and approval sign-offs indicate all was not working well in this work area. The question of adequate review to the other interfacing designs is not resolvable from this information. This review was identified as an item of nonconformance. The allegation was not verified by this review as the detail reference documents were not identified on the revi ew documentation, however no reference to elementary drawings is provided. An allegation was expressed as a cencern regarding the review provided to ERM-AMC 1302 by V. Wdidow as a review of the document quality rather then a design review. (See section 1.11 of the report. , i An inspector performed a review of ERM AMC-3602 which revealed the fact that the Responsible Engineer had specified a Document Quality review (#9). V. Wold /odfprovidedareviewofseven (7) documents and some of these comments were technical in addition to the document quality review as specified. The overall quality of the ERM document is not good with no reviewer' assigned for seven (7) of the documents. The review was scheduled to begin 7928 ( GE calendar notation ) with a completion date of 7923
~~- thus a goal not achievable. The Responsible Engineer identified a missing element on the list (Item 23 of the parts list).The ERM ,~~
was approved on 8-2-79 by both the Responsibile Engineer and the Engineering Manager. No Deferred Verification was noted, however the part was identified and added to the design package shortly thereafter. Another item of note is the title of this ERM is
" Terminal Board" which is not a specific title for this type of part in a power plant. The allegation was not confirmed by the review of the documentation. ,
6 In 8 e , g - r i . a
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~~Page 3 of 3~~
-7 A review of the work record provided by the alleger-for week 8110 E item 4 a- comment regarding the. QA procedures , f or-Drafting . provides and Material control for open safety related' design.
deficiences f or RPS panels C71-P011. - l The inspection of PRC file 80-31. revealed that a panel. replace; ' ment for the RPS equipment is in progress for the Clinton plants while the TVA plants identified for these panels 'are now canceled. The deficiences were reported to the NRC 15 Jan 81. Design Review Report 70-06 was examined as the initial idendifier ; of these items as c.ficiences to be reviewed. Concerns were expresed by GE staff members. 4 ring the reviews for a means to prevent these type of overs r in the future, and the following plant procedures have been modified
1) EOP 42-5.00 Engineer Requirements Document Release Revised 2-12-82 .'

2) EIP 6.60 Preparation of Engineering Instructions f or i Release to Manufacturing 9-30-82 ;<

3) QAP 7.28 Shipping Inspection issued 5-14-82 .
The items in question were reviewed and' reported to the NRC and ' corrective measures identified prior to the installation of the panels. I ddition the procedures in the design- process were . modified to prevent future problems of this type. An allegation was presented concerning drawing 175A9666 Rev.2, Tubing, EMT which stated the tubing was unavailable for 15 years prior to the identification of this f act by the alleger. The part characterestic which is no longer available was an interior coating of glyptal to the tubing. The question of what material was ' supplied with the panels prior to 1980 was presented. 8 9 An inspection review identified that an Engineering Change Notice , was issued 1-8-81 to remove the requirement for glyptal inside the EMT, Tubing. The reason identified for the change was the , unavailabilty of the material, not an acceptable reason for a product change as this part is utilized in Nuclear Safety Grade assemblies. The Design Record File AOO-891' documents the phone call which identified the unavailability of the product and it's elimination as a product by a GE division. A ' check of the purchase records prior to 1980' identified the purchase of the tubing with glyptal coating. The QC receipt inspections did not - specifically indicate the presence of the coating but the tubing
" finish" was verified. This review indicates sloppy engineering since either the glyptal. coating was never required or it was y ~
removed from the design without proper engineering analysis. If this manner of design change by manufacturing engineers without ' recourse to the original engineering design requirements then the design creditablity for the panels remains subject to questions. The allegation was verified, however the requirement for the material is not identified nor is it clear if the material in fact was supplied from inventory. 3
~~.s, *-~~
~~3.* .~~
~~..s_ _ ,- - 1 . )~~
F f W. &#- 7- w-sc Allegation: , 4 Sec 1.7 Elementary drawings provided by C.F.Braun Co. were not signed by GE system engineers to verify the design. Oberservation: The investigation of ERM-AMD 1302 and it's associated Elementary Diagram 828E536AK titled "High Pressure Core Spray System" revealed the design adequacy was verified by a C.F.Braun Co. employee with GE employees providing " engineering spot check" reviews and " application" reviews. One reviewer expressed concern over the identification of the individual who would be resposible for the drawing status but no specific answer is provided. Inspection of the drawing title block and the ERM assignment blocks reveals the information that the individual who was the designer for C.F.Braun was also listed as the reviewer for this drawing which has a Nuclear Safety Related Div. 3 label. Several of the GE employees interviewed indicated that the C.F.Braun Co. employees were trained in the GE proceedures for safety related design documentation requirements by a C.F.Braun program which was monitored by GE. Verification of this program was not attemptyd at this time. Allegation: . Sec 1.9 CNV Panel H22-PO28 was reviewed with little attention to the elementary diagrams. Observations: A review of ERM-AMC 3035 dtd. Oct. 11,1978 identified several review comments but no specific ccmments were referenced to elementary diagrams. Review comments were noted in June and July while the responsible engineer was not assigned 'until October. The approval sign-off occured the same day as the assigment of the responsible engineer but the reviewer of the assembly drawing ' signed for the approval for all documents in the ERM. The Interface review was refused by the assigned reviewer with* no follow-up as to the reason for this action or assignment of another reviewer. No comments were provided by the " system application" reviewer. The ERM was passed on as approved but no
, comments are available except from the Originator-Reviewer-(Approval) Responsible Engineer. The quality of the documentation is not satisfactory since GE EOP requirements for review are not provided. Inaddition the dates of assignment and approval sign-offs indicates all was not working well in this work area. The question of adequate review to the other interfacing designs is not resolvable from this information.
1
~~-ee.~~
~~h *'~~
/WL 7fv/t1i- , 5 .n, p Allegation: '(
~~Sec 1.11 . J A- concern was expressed regarding air [eview to.ERM~~
~~- V.Waldow whichprovidedareviewoft}edocumentquality rather AMC-3602 by [~~
~~then a design veification. j~~
~~r. .~~
~~Observations i' ' t~~
~~'A. review . of ERM AMC-3602 rdeals the ' Responsible Engineer '~~
specified a Docutaent Quality eevitid(#9) . V.Woldron provided a- o review' of seven?(7) documents and so.7e'of these comments 'were technical. The overall' quality of the ERM document is not good g( with no' reviewer assigned f or sever %(?) of the documents. The @ review was scheduled to begin 7928 (GE calendar notation)-with a it completion date of 7923- thus a goal .not achievable.. The
,e Engineer _ identified a missing element on, the list- [ . Responsible (Item 23 o ,f the parts list).The ERM was approved on; 8-2-79 by ~
G both the .Respsibile Engineer and the Engineering Manager. No ; Deferred Verification was noted, however the part was identified- s! and added to the design pac'tage shortly thereafter. Another item 4 of' note is the title of this ERM is " Terminal Board" which is not . a specfic title for.this type cf part in'a power plant. . $ 1. Allegation l Work record week B110 item 4 provides a comment regarding QA
~~, procedures for' Drafting and Mater $al control reqerding open _,~~
~~i safety related design deficiencis'for RPS panels C71-PO11. ;; o~~
, Observations: 4 +, O Inspection of PRC file 80-31 revealed panel replacement is in " , progress for the,Clinton plants while2 the TVA plants identified f for these panels are now canceled. The deficiences were reported . ,(R 'fto the NRCthese 15 Jan 81. Design Review Repor,t,79-06 was examined and p ;.
~~3 .~~
# revealed items as deficiences '>to be reviewed. Concerns O were expresed by.GE staff members during the reviews to prevent fy
~~(. these type of overs the future and the following plant L~~
^
~~procedures have been,ites in modified l: r~~
~~1) EOP 42-5.00 Engineer Requirements Document Release Revised~~
~~2-12 ,~~
2) EIP '6.60 Preparation of Engineering Instructions for Release to Manufacturing 9-30-82 _

3) QAP 7.28: Shipping Inspection issued 5-14-82 l
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~~. = = . , .~~
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r k , i-Allegation: Sec 2.29 A design change to 175A9666 Rev.2, Tubing, EMT was identified as the tubing was described in a phone call as not manufactured for 15 years prior to 1980. The concern was over the identification of a generic part used in many GE panels with a glyptal coating requirement for the inside of the tubing. Was the tubing supplied prior to 1980 or were these requirements ignored? ' Observation: . An Engineering Change Notice was issued 1-8-81 to remove the requirement for glyptal inside the EMT, Tubing. The reason for the ~ change was the unavailabilty of the material, not an acceptable reason for a product change as this part is utilized in Nuclear Safety Grade assemblies. The Design Record File ADO-891 documents the phone call which identified the unavailability of the product and it's elimination as a product by a GE division. A check of - the purchase records prior to 1980 identified the purchase of the tubing with glyptal coating. The QC receipt inspections did not specifically indicate the presence of the coating but the tubing
" finish" was verified. This review indicates sloppy engineering since either the glyptal coating was never required or it was removed from the design without proper engineering analysis. If f- this manner of design change by manufacturing engineers without recourse to the original engineering design requirements then the 'o design creditablity for the panels remains subject to questions.
~~4 I 1 J 1 1 l l f w a~~
~~. e & w +.g -e + c - w - e g~~
~~F" t B. DOCUMENTS OBTAINED DURING INSPECTION l~~
~~!1 Il I~~
~~i r i J f - 1_ l I l l l l l i}}~~

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