The inspectors reviewed the
QA manual requirements against Kewaunees implementing procedures and identified that two
QA manual requirements were not being implemented. Specifically,
QA Program Requirement, 3.1.10, stated that directives and procedures shall provide for analyzing trends of
conditions adverse to quality. Once identified these trends were required to be considered
significant conditions adverse to quality. The inspectors found that
conditions adverse to quality were not defined in the KAP procedures and that no procedure existed for trending. 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.
