The inspectors reviewed the
QA manual requirements against Kewaunees implementing procedures and identified that two
QA manual requirements were not being implemented. Specifically, Program Requirement 3.1.9 which stated that directives and procedures shall provide for the review of
conditions adverse to quality to determine if the conditions are significant in nature. This requirement paralleled
10 CFR Part 50, Appendix B, Criterion XVI, which requires that the cause of
significant conditions adverse to quality be determined and corrective actions taken to prevent recurrence. The inspectors reviewed the Nuclear Administrative Directive (NAD 11.08) and the procedure (GNP 11.08.01) governing the KAP process and found no procedure requirements for identifying
significant conditions adverse to quality. This finding does not directly affect a cornerstone. As a result, this issue was not evaluated with the
Significance Determination Process and was not assigned a color. One non-cited violation was identified.
