ML20204F873
| ML20204F873 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/1982 |
| From: | Chamberlain D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20204F846 | List: |
| References | |
| REF-QA-99900403 NUDOCS 8305020307 | |
| Download: ML20204F873 (17) | |
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ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORI INSPECTION 6/28-7/1/82 INSPECTION NO.: 99900403/82-03 DATES (S): 7/13-15/82 ON-SITE HOURS: 146 CORRESPONDENCE ADDRESS: General Electric Company Nuclear Energy Business Operations ATTN: Mr. W. H. Bruggeman, Vice Pres. & Gen. Mgr.
175-Curtner Avenue San Jose, CA 95125
. . 1 .. - .
ORGANIZATIONAL CONTACT: Mr. A. Breed, Manager, Quality Assurance TELEPHONE NUMBER: (408) 925-2726 PRINCIPAL PRODUCT: Nuclear Steam System Supplier NUCLEAR INDUSTRY ACTIVITY: General Electric Company, Nuclear Energy Business Operations (GE), has a work force of approximately 7650 people with approximately 98% of that work force devoted to domestic nuclear activity.
GE currently has 26 reactor units under construction and 4 reactor units under contract. GE also has approximately 115 service contracts with various clients.
ASSIGNED INSPECTOR: 8w 74 7/s'-
p D. D. Chamberlain, Reactor Systems Section (RSS) Date OTHER INSPECTOR (S): R. H. Burch, Regional Investigator, Region II E. L. Williamson, Regional Investigator, Region II APPROVED BY: 8% P//r/r2.
[ C. J. Hale, Chief, RSS Date INSPECTION BASES AND SCOPE:
A. BASES: General Electric Topical Report No. NED0-11209-04A and 10 CFR Part 50, Appendix B.
B. SCOPE: Evaluation of the General Electric Company handling of a former employee's concerns regarding Mark III containment design issues.
PLANT SITE APPLICABILITY:
Docket Numbers 50-416/417. DESI ATED ORIGINAL Certifici Dy . u dlu R M '
B305020307 830202 PDR GA999 ENVGENE 99900403 PDR - _ - _
l ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/82-03 RESULTS: PAGE 2 of 9 A. VIOLATIONS:
None
- .8. . NONCONFORMANCES: .- , . .--- - - -
Contrary to the requirements of Section 5 of Topical Report No. NED0-11209-04A .
documented instructions or procedures were not utilized to communicate quality requirements relating to the dispositioning of potential design action items. These potential design action items were dispositioned without documented criteria or clearly established reponsibilities for the actions.
C. UNRESOLVED ITEMS:
None D. OTHER FINDINGS OR COMMENTS:
Former General Electric (GE) Employee's Concerns Regarding Mark III Containment Design - The purpose of this inspection was to evaluate GE's handling of a former employee's concerns regarding Mark III containment design issues with respect to 10 CFR Part 21 reporting requirements, and to determine if the GE design process requirements were implemented in the disposition of the issues. The Region IV inspector and two Region II investigators participated in the inspection / evaluation.
l The former GE employee was interviewed and the results of that interview were used as a basis for further interviews and inspection at the GE San Jose office. This report addresses the results of the interviews and inspection conducted at GE.
- 1. The following information/ findings were obtained from the former employee interview (see Investigative Report for more details).
(a) The former employee worked at GE in the Containment Design Subsection.
1
! (b) The former employee discussed a group of containment design issues with the Manager of Containment Design during August 1981.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/82-03 RESULTS: PAGE 3 of 9 (c) The former employee was instructed to formally write up the design issues and submit them for review if he felt strongly enough about the issues.
(d)' k formal memo- listing 23- containment design' issues was submitted
- by the former employee to GE management during September 1981.
(e) Meetings were held with the former employee, employee peers and management, and in late November or early December 1981, a decision was made to place 18 of the items on a Design Action List.
(f) The 18 items on the Design Action List were presented by the former employee and other engineers during a review meeting in January 1982.
(g) The review meeting was composed of a high-level group of engineers and management who reviewed the issues to determine if GE should be spending resources on resolving the issues.
(h) As a result of the January 1982 review meeting, 6 of the 18 design issues were considered as items that needed additional work by GE and 12 items were considered " product improvement items" which required no further design action.
(i) Another review meeting (former employee attended) was conducted in February 1982 to review the six design action items that had been selected for further design action by GE.
(j) As a result of the February 1982 meeting, the six design action items were reduced to two items that required further design action by GE.
(k) The 16 items, that were disposed of as requiring no further design action by GE, were referred to the GE STRIDE project (during the February 1982 meeting) for potential impact on that project. This was done because GE had total responsibility for containment I design on the STRIDE project. The normal GE scope of NSSS supply does not include containment design.
l
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFGRNIA REPORT INSPECTION N0.: 99900403/82-03 RESULTS: PAGE 4 of 9 (1) The former employee stated during the interview that he was not completely satisfied with the disposition of the 18 design action items, but he was pleased that many of the mechanical issues were being addressed by the STRIDE project.
. ~ ~ :- ~ - - -
(m) The former' employee, while discussing another containment issue with a GE licensing engineer after the February 1982 meeting, mentioned that there were 18 other containment design action items.
(n) This discussion prompted the GE licensing engineer to submit a memo (February 1982) to the former employee's supervisor requesting an engineering assessment of the 18 design action items as Potential Reportable Conditions (PRCs) under 10 CFR Part 21 requirements.
(o) The memo from the GE licensing engineer prompted two memos (March 1982) from containment design management stating that all of the 18 design action items had been evaluated with respect to potential 10 CFR Part 21 reporting requirements and none of the issues were considered reportable.
(p) Around March 1982, the work on the GE STRIDE project was stopped and the work that was being done on the 16 containment design issues was also stopped.
(q) The former employee expressed his belief that the 16 containment design issues were never fully and completely addressed by the STRIDE project.
(r) The former employee stated that he was aware of the GE 10 CFR Part 21 procedures wherein an employee would identify a problem via an internal memo to his supervisor. The internal memo would request that an issue be formally evaluated as a Potential Reportable Condition (PRC) per GE procedure NEBG 70-42, Reporting of Defects and Noncompliance Under 10 CFR Part 21 or Part 50.55(e).
This procedure requires that the originator of a PRC be informed in writing if the item is determined to be reportable and the reason for the determination.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/82-03 RESULTS: PAGE 5 of 9 (s) The former employee stated that GE employees were not encouraged to write PRC's and he guessed that they were passively discouraged.
He stated his belief that many of the issues were significant safety issues, but he did not report them formally as PRC's. He chose to-gotthe route thatche went because it was an informal way of bringing these problems to management attention.
(t) The former employee stated that he thought part of the problem was the interpretation of 10 CFR Part 21 " substantial safety hazard" language.
(u) The former employee resigned from GE in early May 1982.
- 2. Results of interviews / inspection at GE - With the former GE employee interview results as a basis, additional interviews (see Investigative Report for more details) and inspections were conducted at the GE San Jose office. Available documentation was examined to verify statements made during interviews and to determine the GE handling of containment design issues up to the time that the former employee resigned. Also, the present actions relating to the contain-ment design issues were reviewed. The following information/ findings were obtained:
(a) The GE scope of work relating to containment design varies from project to project, but they always provide action interface docu-ments and a Containment Loads Report (CLR). Normally the actual containment design is performed by others with GE providing con-ceptual design information. The GE scope of work for the STRIDE project included total responsibility for containment design.
The containment design effort was performed under a subcontract to C. F. Braun, and was controlled by a GE project management group.
(b) The former employee and other engineers in the containment design subsection had been bringing up design issues over the past few years during the GE effort related to Mark III containment design. These items were addressed and many resolved as the work effort progressed.
(c) Beginning in 1981, the Mark III containment design activity was decreasing and an effort was initiated by GE to obtain a complete listing of all outstanding potential design action items.
9
l ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA
, REPORT INSPECTION N0.: 99900403/82-03 RESULTS: PAGE 6 of 9 (d) The number of outstanding issues had dropped to as low as 11 items, but began to rise again in September 1981, with the 23 items documented by the former employee. Also, other issues were added as time progressed.
....... ., m . .s - . .
(e) This inspection was limited to the handling of the 23 issues that were documented by the former employee in September 1981.
(f) Meeting minutes, dated February 12, 1982, address the dispositioning of 18 design action items, of which 14 were from the former employee's list of 23 items. The meeting minutes reflect the dispositioning of the 18 items as the result of a January 14, 1982, meeting and a subsequent Section Managers review held February 4, 1982. The former employee was listed as attending both of thesa meetings.
(g) An Engineering Work Authorization (EWA EAJ76-6S) was issued on March 18, 1982, with the stated objective to resolve 19 con-tainment design issues by the preparation of letters to the Design Record File. Nine of the items were from the former employee's list of 23 items. The items were listed on the EWA with responsibility assigned and scheduled completion dates listed. Of the nine former employee items, one was scheduled for fiscal week 12, one for fiscal week 32 and seven for fiscal week 20. Fiscal week 20 was in the month of May 1982.
(h) Therefore, as of March 1982, the former employee's list of 23 items had been disposed of by placing 14 on a potential Design Action List and 9 on an EWA. The 14 items that were on the Design Action List had been further disposed of by listing 1 item as requiring further design action by GE; the remaining 13 had been referred to the STRIDE project for evaluation.
l (i) The criteria for disposing of potential design action items as either requiring further GE design action or as requiring no further action were described to the Region IV inspector as follows:
(1) Items requiring further GE design action were those generic design issues which had to be addressed to meet existing safety, regulatory, performance, or contractual requirements.
1 I
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/82-03 RESULTS: PAGE 7 of 9 (2) Items disposed of as requiring no further GE design action were either non generic (meaning project specific which could be referred to specific project for resolution), not within GE scope of work,~or. considered potential design / product' improvements, which would not be undertaken without prior customer authorization (these are design improvement items that were not required to meet existing safety, regulatory or performance requirements).
(j) Two memos (March 4 and 5, 1982) were provided which reflected the GE containment design management position that none of the 18 design action items were deemed appropriate for 10 CFR Part 21 reportability.
(k) GE management stated that the items were reviewed with regard to possibly requiring notification of clients or other design firms and it was not considered necessary. There was no documentation provided to clearly verify this review, but meeting minutes for a Project Application Assessment Board meeting held February 24, 1982, were provided which documented that the 18 design action items (including 14 of the former employee's items) were reviewed for potential project impact.
(1) One GE manager and one co-worker stated that they encouraged the former employee to formally submit his containment design issues as PRC's under GE procedure NEBG 70-42 if the former employee felt that the issues were significant safety concerns.
(m) In March or early April 1982, GE work on the STRIDE project was stopped. EWA No. EAJ 50-04 was issued to prepare status letters and collect documentation in order to define work status.
(n) The work stoppage effectively terminated the work on the design action items that had been referred to the STRIDE project for evaluation. However, a memo (April 21, 1982) was issued to document the rereview of the 16 design action items in light of the STRIDE work stoppage to evaluate the need for any additional design action by GE. The determination was documented that no additional action was required on the 16 items.
Thirteen of these items were from the former employee's list.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION N0.: 99900403/82-03 RESULTS: PAGE 8 of 9 (o) As of early May 1982 (time of former employee's resignation) 2 of the original 23 items had been formally closed with memos to the Design Record File. Of the remaining 21 items, 8 were being worked and.13.had.~been,dispositioned.as requiring.no further design ,- -
action.
(p) The former employee apparently never documented that he was dissatisfied with the handling of his issues. Also, GE personnel interviewed stated that the former employee did not verbally express any dissatisfaction with the manner in which his concerns were being addressed.
- 3. Conclusions / findings - The following conclusions / findings are presented as a result of the former employee's interview, other GE personnel interviews, and documentation review at GE:
(a) None of the 23 issues raised by the former employee were ever submitted as PRC's under GE procedures. Apparently no one (including the former employee) felt that the issues were substantial safety hazards as defined by 10 CFR Part 21.
(b) GE addressed all of the 23 items that were raised by the former employee and the issues were either in the process of being evaluated or were dispositioned as requiring no further design action at the time that the former employee resigned.
(c) The method and criteria used by GE to dispose of the 18 design action items were not formally documented; therefore, a noncon-formance (see B above) was issued for failure to utilize documented instructions or procedures to communicate quality requirements as required by the GE Topical Report.
(d) GE provided the Region IV inspector with documentation prior to the completion of the inspection which formally documents the the process / criteria for disposing of potential design action items.
(e) Although the process used to disposition some of the former employee's issues was not formally documented, it is apparent that GE management made a conscientious effort to address all of the former employee's issues and all of the 23 design issues were dispositioned based on peer reviews and management decisions.
ORGANIZATION: GENERAL ELECTRIC COMPANY NUCLEAR ENERGY BUSINESS OPERATIONS SAN JOSE, CALIFORNIA REPORT INSPECTION NO.: 99900403/82-03 RESULTS: PAGE 9 of 9 (f) The former employee was aware of GE 10 CFR Part 21 procedures, but chose not to formally submit any of his concerns as PRC's.
- . . .GE.is now addressing all of.the containment. design issues in support .r of the Grand Gulf project licensing process.
Inspector D, CH4M66RLAIr4 s'$N$: gjfoY i Scope / Module MARK TIP ror4rAINM6NT DOCUMENTS EXAMINED D6 SIGN 15506S 1 2 TITLE / SUBJECT 3 4 1 % DESIGN ACT10H L)ST Vl8/82 2 6 DISPasIT10H oF conrAlamEHT DAL ITEMS Al2/AV2 3 % )NDEX foHTAINMENT ISSUES (cross RUERENc6) S/24/82 4 3 HLSG PROCEDORG Jo-42 R6PORTIH(, of DFfECTS hND 3/2'I/81 A-HONCoMPLIANC6 l)HOGR 10 CFR PART 21 OR PART 50 55(e) 5 S ENGIN6E8iNG work norHORlaATl0N NO. 6A775- 8$ 3//8/92 b Y _MLmo- TVA STRuo6 Pool FNERoACHMFHT STUOY 5/6/6Z
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Document Types: Columns:
- 1. Drawing 5. Purchas Order 1. Sequential Item Number l
- 2. Specification 6. Internal Memo 2. Type of Document l 3. Procedure 7. Letter 3. Date of Document
- 4. QA Manual 8. Other (Specify-if necessary) 4. Revision (If applicable) k
Inspector D, CHAM 668L8]N Docket No.99900403 Report No. gy-o g Scope / Module MARK E coNTAINM6HT DOCUMENTS EXAMINED DE.slGH 15SvES 1 2 TITLE / SUBJECT 3 .4 l3 8 C0HTAINmtHT ISStl6S DRYWELL- To CONTAINrnENT B1 PASS Sb7/82 L6AKA66 - HYDRO (,6N I4 7 M6rno seu g2-8o REsoLorion nf coarArnrtatur otsica &/2/gz 1SSd6 1T-I9. G CENCH6R I.0AD D6FtNIT10H I$ % C0NTAlHrnEHT iss065 - IncomPL6TE cdST0MER/AE D67A 5//7k2 00CornENTS A 50-30I0 l& 1 T M6c/lo - DISPostTI0d of CANTAIHM6HT DAL ITtWIS 4/ZI/72
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- 1. Drawing 5. Purchas Order 1. Sequential Item Number
- 2. Specification 6. Internal Memo 2. Type of Document
- 3. Procedure 7. Letter 3. Date of Document
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Scope / Module r/) ARK $ CONTAINMENT DOCUMENTS EXAMINED oEsrcn >SSOES 1 2 TITLE / SUBJECT 3 .4
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Inspector D. CHAMBERLAN g ll3 f,(j.3 Scope / Module MARK E CONTAINM6df DOCUMENTS EXAMIffED - .
0651GN 1551)f5 1 2 TITLE / SUBJECT 3 _ .
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