ML19207A928
| ML19207A928 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/20/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19207A925 | List: |
| References | |
| 50-358-79-14, NUDOCS 7908230047 | |
| Download: ML19207A928 (3) | |
Text
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Appendix A NOTICE OF VIOLATION Cincinnati Gas and Electric Company Docket No. 50-358 Based on the results of the NRC inspection conducted May 22-24, 1979, it appears that certain of your activities were not conducted in full com-pliance with NRC requirements as noted below.
Items 1 and 2 are infrac-tions. A full discussion of these items, as well as other examples are contained in the DETAILS section of this report.
1.
10 CFR 50, Appendix B, Criterion XVI, corrective action states in part:
" Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In case of significant conditons adverse to quality measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
Zimmer QA Manual, Section 16, Paragraph 16.4.2, " Construction Site Audits," states "Significant conditions adverse to quality are reported to management and appropriate levels of the contractor's management.
Corrective action is obtained where required."
H. J. Kaiser Company (Kaiser), Procedure No. 16, Paragraph 3.6, states in part:
" Corrective action on recurring discrepancies will be reviewed and analyzed by the QA Engineer responsible for the discipline in question (Electrical-Mechanical-Piping).
After such analysis is made, he will report his findings to the QA Manager for further action."
Contrary to the above:
a.
U. S. Testing Company audited the licensee's QA section on June, 1978. Audit Finding No. 9 was a finding from the December, 1977 audit, and was still considered open after the 1978 audit.
QA&S had accepted Documentation Checklist for door numbers 268, 269 and 270, even though documentation was missing.
CG&E corrective action was inadequate, in that, only the immediate problem was corrected. No review or audit was performed to assure the other documentation checked by this individual was complete. Further, no effort was made to check other documen-tation accepted by other QA personnel.
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Appendix A.
b.
Replies to CG&E QA Section Field Audit replies were not within the period specified for Audit Nos. 179, 197, 202, 203, 215, and 220.
A new CQE/QA&S procedure 18-QAS-04 had been developed to improve c.
the tracking system for open audit items, however, the log still contained multiple errors which had not been corrected.
Status of open items was not clear.
d.
Kaiser QA Engineers had performed no such analysis nor made reports to the QA Manager to preclude recurring discrepancies per Kaiser procedure No. 16.
2.
10 CFR 50, Appendix B, Criterion XVIII, and FSAR, states in part:
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program."
William H. Zimmer Nuclear Power Station FSAR, Section 17.1.18, states in part:
"QA&S maintains a comprehensive system of audits of design, vendor and construction activities. Audits are carried out to verify compliance with all aspects of the Quality Assurance Program.
Audits of QA&S are conducted by a representative of the Vice President at least semiannually for determining the ef fec-tiveness of the QA program."
William H. Zimmer Nuclear Power Station QA Manual, Section 18, states in part:
"QA&S Section conducts a comprehensive system of planned and periodic audits of S&L, Kaiser and GE to verify compli-ance with all aspects of the quality assurance program.
in accordance with written procedures or checklists...."
Contrary to the above:
Cincinnati Gas and Electric Quality Assurance Standards Section a.
(CG&E QAS) failed to audit Kaiser Procedures No. 4 and No. 7 as required by the Zimmer QA Manual, Section 18.
b.
Zimmer FSAR requires a management review semiannually while the QA Manual, Section 18, Paragraph 18.2, states that the frequency of audits is at least annually.
Only one audit was performed in 1978, yet, the FSAR required two.
Kaiser Manual QAP-19 stated in part " Audits shall be performed c.
by a Kaiser Quality Assurance Engineer.
. The site QA Manager
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Appendix A.
assigns a QA Engineer, not directly responsible for the audit element being audited, to audit a quality system element based on Paragraph 3.2.1 which references a scheduled frequency as set forth on Figure 19-1.
The following are two examples of three reviewed elements which demonstrated that they were not audited to the required frequency during the period January 1-December 31, 1978:
Special Processes (QAP-10) each 6 months none in 1978 Control of Nonconforming each 6 months none in 1978 Materials Parts and Components (QAP-16) d.
Kaiser QA records of audit failed to demonstrate that audits were comprehensive.
That is, supplemental procedures for implementing QA procedures were not audited. For example, Special Process Procedures audited in 1978 were limited to a reaudit of welding qualifications, post weld heat treatment and associated calibration.
Calibration and Measurement QAP-13, Paragraph 2.7 states that calibration will be certified against material standards. This part of the element was not audited.
QAP-16, Paragraph 3.3.1, which outlines the disposition of material, was not audited.
e.
Kaiser audit file for Audit Nos. 349, 351, 352, 354, 357, 360 and 369 did not contain checklists.
Seven (7) of sixty-eight (68) were found to be missing.
f.
CG&E/QAS audit findings documented in Audit Nos. 217 and 223 were not clearly classified as a deficiency, observation or a suggestion.
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