ML20205Q581

Notice of Nonconformance from Insp on 830829-0902

ML20205Q581
Person / Time
Issue date:	10/21/1983
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20204B851	List: ML20204B845 ML20205N473 ML20205N709 ML20205N726 ML20205N755 ML20205Q379 ML20205Q422 ML20205Q438 ML20205Q506 ML20205Q518 ML20205Q568 ML20205Q581 ML20205Q591 ML20205Q739
References
REF-QA-99900403 NUDOCS 8704030573
Download: ML20205Q581 (3)

Text

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APPENDIX A General Electric Company Nuclear Energy Business Operations

-Docket No. 99900403/83-03

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NOTICE OF NONCONFORMANCE Based on'the results of an NRC inspection conducted on August 29-September 2, 1983, it appears that certain of your activities were not conducted _in accordance with NRC requirements as indicated-below:

Section 5~of Topical Report No. NEDO-11209-04A, Revision ~4, dated December

-1982 states, in part, "Occumented instructions, procedures, and drawings are utilized to communicate quality requirements throughout all-phases of design, pu. chasings manufacturing, and construction. Activities affecting quality, including methodstof complying with 10'CFR Part-50, Appendix B, are delineated, accomplished, and controlled by such documents as policie*,

procedures, operating instructions, design specifications, shop drawings,-

planning sheets, test and-inspection procedures, and standing' instructions.

Nonconformances with these requirements are as follows:

A. Sections'4.1.2 and 4.4 of Engineering Operating Procedure (EOP) 42-6.00, "Indep'endent Design Verification," states, in part, ...

"b. Notify Engineering Services 1 by processing an accompanying Design Verification Status Change Notice (DVSCN) form that identifies the document, the scheduled date of deferred verification completion, l

DRF.ceference if applicable, and distribution identical to that of 1 the issued cocument . ...

"a. Based on DVSCN input, notify the external user about the deferred verification status of applicable design data, together with schedule for verification and any limitations on the application of data or product hold requirements. This notification may be waived-for non-important to safety transmittals with the approval of the responsible projects department or services department General Manager.

"b. Based on the DVSCN completion input, notify the user that the design verification has been completed . . . ."

Contrary to the above, design verification of Nuclear Control and

• Instrumentation Division design documents are being deferred without implementation of controlling procedural requirements. This is evidenced by the following (River Bend project):

-4 F704030573 870323 . .

PD:t GA999 ENVOENE 99700403- PDR n

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1. -Verificationsson five design documents (828E536AA, 828E537AA, 184C5467, 851E225AA, and 828E239AA)_were deferred and no evidence existed that the DVSCNs were processed.

2. No' evidence existed that the project had been notifying external users about the deferred verification status of applicable design data; e.g., information on four DVSCNs, DVSCN00206, DVSCN00239, DVSCN00240, and DVSCN00251 was not provided to the customer nor was the notification requirement waived.

' B. Section 5.7.1 of NEDE-20586 states, " Establish measures to assure that purchased material,. equipment, and services, whether purchased directly or through suppliers and subtier suppliers,' conform to the procurement documents." Implementing Procedure MP5.07, " Deviation Disposition

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Request," states, "The supplier initiates the need for a DDR when it is determined that a nonconformance to a GE technical requirement exists.

The request from the supplier shall be transmitted through the GE~ buyer who' requests the DDR form from QA records center."-

Contrary to the above, GE did not request that Rosemount, Inc. issue a DDR-when Rosemount notified GE that they could not meet IEEE 323-1974 environmental requirements imposed on Purchase Order No. 282-X8G55.

Consequently, GE received and accepted purchased equipment that did not conform to the procurement document.

C. Section A1.1 of Appendix A to GE E0P 65-2.10 states, in part, "an important to safety item is any specific component, assembly or subassembly necessary to assure: (a) the integrity of the reactor coolant pressure boundary . . . ."

Contrary to the above, control rod drive (CRD) system clamps supplied by GE on all BWR-6 design plants were not classified as essential components (important to safety); even though there was no assurance that their failure would not cause a loss of integrity of the reactor coolant pressure boundary.

D. Section 2.3.7.1 of GE BWR Quality Assurance Manual states, in part,

" interfaces between NEB 0 and external organizations performing work affecting quality of design are identified in writing . . . systematic methods are established for communicating needed design information across external design interfaces . . . ."

Contrary to the cbove, GE did not communicate needed design information to S&W that the CRD clamps supplied by GE were essential or nonessential components or whether they could be considered as ASME qualified items in the analysis of the CRD piping system.

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- E. Paragraph 4.2.c.3 of Engineering Operating Procedure-(EOP) 42-10.00,

" Design Record Files" (DRF), dated June 23, 1980, requires the establishment and maintenance of the DRF index, Form-SD-005, or equivalent.

Contrary,to the above, the DRF index or equivalent was not established and/or maintained for DRF Nos. A00-1160 (SAFER 01) and A1002 (GESTR08);

e.g.,(1)'A00-1160, the date entered and author's name were missingLand.  ;(

(2) A1002, the date entered was. missing ~.

. F. Paragraph 3.3.2 of Supplement A dated August 1, 1979, to E0P 42-1.00,

" Introduction-Technology and Design Control," states that mathematical

. analyses are required.to be prepared and documented so that a technically qualified person can review and evaluate their accuracy without recourse to the originator. {

l Contrary to the above, an analysis contained in Section 8 of DRF No. A00-1160 was not prepared and documented so that a technically

' qualified person could review and evaluate its accuracy without recourse {

to the orignator; e.g. , the identification of the purpose, references,

'date, originator, reviewer, etc., were missing.

G. Supplement A dated August 1, 1979, to E0P 42-1.00, " Introduction-Technology and Design Control," designates a functional specification as a design document subject to the requirements of E0P 42-6.1C, " Engineering Document

' Issue and Application." Paragraph 1.1 of'EOP 42-6.10 states that a

. systematic review is required prior to the issue and application of corporate numbered engineering controlled documents.

Contrary to the above, the functional specification for the computer

program SAFER 01 was not controlled in accordance with E0P 42-6.10; e.g.,-(1) there was no identifying number, (2) there was no revision number, and (3) the identification and signature of the originator, reviewer, and approver were missing.

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