ML19208B105
| ML19208B105 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/27/1979 |
| From: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19208B099 | List: |
| References | |
| QA-1173, NUDOCS 7909190057 | |
| Download: ML19208B105 (6) | |
Text
A Mr. G. Fiorelli U. S. Nuclear Regulatory Commission Region III July 27,1979 - QA-ll73 Page 2 Date When Full Compliance will be Achieved Full compliance will be achieved by September 15, 1979.
Infraction 1(b) - Late Responses to Field Audit Reports Corrective Action Taken and Results Achieved The open field audit file has been reviewed to determine which audits have not been responded to within tne specified time period. Efforts are underway to obtain responses by contact with the auditee.
Corrective Action to be Taken to Avoid Further Noncompliance Review of open field audit response due dates will be conducted weekly on a designated day. To facilitate review, a " Response Due" column will be added to the Field Audit Log sheets, and the due date will be noted when the log entry is made.
Date When Full Compliance will be Achieved It is expected that full compliance will be achieved by August 31, 1979.
Infraction Item 1(c) - Errors in Field Audit Log Corrective Action Taken and Results Achieved The Field Audit Log has been reviewed and coding errors and confus-ing entries have been corrected.
It is believed that the log is current and correct from Audit No.166 through 256. The present logging system was adopted with Audit No.166 in March,1978.
Corrective Action to be. Taken to Avoid Further Noncompli3nce It is believed that the coding errors resulted from ambiguous instruct-ion and the complexity of the form itself.
In May,1979, the form was revised and the coding simplified, and errors are now expected to be minimized.
Also, Procedure 18-QAS-04, entitled " Field Audit Log", will be revised to include more explicit instructions for entries in the log.
Date When Full Compliance will be Achieved The Field Audit Log is now believed to be in compliance.
Revision of Procedure 18-QAS-04 is expected to be complete by August 31, 1979.
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Mr. G. Fiorelli U. S. Nuclear Regulatory Conmission Region III July 27,1979 - QA-ll73 Page 3 Infraction 1(d) - Henry J. Kaiser Company Failure to Analyze Recurring Discrepancies Corrective Action Taken and Results Achievcd The cognizant Henry J. Kaiser Company QA Engineer will perform a review of the nonconformance reports in his area of responsibility that have been written during the past six months, to evaluate the adequacy and effectiveness of corrective action.
Corrective Action to be Taken to Avoid Further Noncompliance The results of these analyses will be the basis for a meeting between the Henry J. Kaiser QA Manager and the Henry J. Kaiser Project Manager to determine the need for improvement in training, procedures, equipment, etc.
Subsequently, similar analyses will be performed at intervals of no greater than six months.
The results will be reported to the Henry J. Kaiser QA Manager and significant findings will result in similar meetings.
Date When Full Compliance will be Achieved The Henry J. Kaiser QA Manager expects that full compliance will be achieved by September 1,1979.
Infraction 2(a) - Failure to Observe Audit Schedule Corrective Action Taken and Results Achieved An audit of Kaiser QA Procedure No. 4 is now in progress. A checklist for audit of Kaiser QA Procedure No. 7 is being prepared.
Corrective Action to Be Taken to Avoid Further honcomnliance CG&E QA&S has and continues to augment its staff in an effort to maintain its audit schedule and still keep abreast of other QA activities. During the past 16 months, seven persons have been added, but other QA responsibilities have increased proportionately.
At pre'sent, the addition of another qualified auditor is planned, whose sole responsibility would be to assist in the performance of scheduled audits.
Date When Full Compliance will be Achieved It is expected that full compliance will be achieved by August 31, 1979.
Infraction Item 2(b) - Management Review Corrective Action Taken and Results Achieved 9 ;')
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A management audit has been scheduled for the week of July 30, 1979.
The audit findings will be available for re 3ew by the NRC inspectors.
e Mr. G. Fiorelli U. S. Nuclear Re julatory Comiission Region III July 27,1979 - OA-ll73 Page 4 Corrective Action to be Taken to Avoid Further Noncompliance A second management audit will be conducted within the next six-month period as required by FSAR com11tments.
The CG&E QA Manual, Section 18, will be revised to require semi-annual management audits, consistent with the FSAR.
Date When Full Compliance will be Achieved Full compliance will be achieved with the completion of the second semi-a.inual management audit, which will take place no later than January, 1980.
Infraction 2(c) - Henry J. Kaiser Company Failure to Maintain Audit Schedule Corrective Action Taken and Results Achieved QAP-10, Special Processes, was audited as a part of the HJK Corporate Audit that was conducted July 1,1979, and an internal audit covering welding and nondestructive examination has been completed. QAP-16, Control of Nonconforming Material, Parts, and Components, was also audited as part of the Corporate Audit of July 1,1979.
Corrective Action Taken to Avoid Further Noncompliance It has been recognized that additional personnel were required to maintain an effective audit program by Henry J. Kaiser Company.
A qualified auditor from headquarters staff has teen assigned to Zimmer since April,1979, while a permanent staff auditor was recruited. An experienced auditor has been hired and is expected to report August 1, 1979.
Date When Full Compliance will be Achieved It is the opinion of Henry J. Kaiser Company that full compliance has been achieved.
Infraction 2(d) - Henry J. Kaiser Company Non-comprehensive Audits Corrective Action Taken and Results Achieved The entry level fer perfonning internal system audits is normally the applicable Quality Assurance Procedure which references within the text other supplemental procedures. These documents are reviewed and considered in the planning of an audit, as required by paragraph 3.4.1 of QAP-19.
Past practice did not require the auditor to specifically, 7n tDU
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Mr. G. Fiorelli U. S. Nuclear Regulatory Comission Region III July 27,1979 - QA-ll73 Page 5 reference all supplemental procedures on his checklist.
Corrective Action to be ~ @n to Avoid Further Noncompliance In the future, supplemencri procedures to be audited will be referenced in the audit checklist and the audit report. A matrix of active procedures that relate to each quality assurance element has been prepared and will be utilized for this purpose.
Date When Full Compliance will be Achieved It is the opinion of Henry J. Kaiser Company that full compliance has been achieved as of the date of this letter.
Infraction 2(c) - Henry J. Kaiser Corgny Audit Checklists Missing Cc1rective Action Taken and Results Achieved Five of the seven audits performed without checklists were by the Electrical Quality Engineer, who has since left the employment of Henry J. Kaiser Company. Two audits (No. 349 and 354) were spontaneous audits based on detected deficiencies and were recorded as audit findings and put into the audit system for purpose of corrective action tracking and follow-up.
Corrective Action to be Taken to Avoid Further Noncompliance A training session has been held with all auditors to indoctrinate them in proper implementation of QAP-19, " Audits".
Date When Full Compliance will be Achieved It is the opinion of Henry J. Kaiser Company that full compliance has been achieved as of the date of this letter.
Infraction Item 2(f) - Audit Finding Classification Corrective Action Taken and Results Achieved The findings of CG&E QA&S field audits #217 and #223 have been clearly identified as " Deficiencies" and " Observations", respectively. We plan to review other field audit reports to verify classification of findings.
Corrective Action to be Taken to Avoid Further Noncompliance Procedure 18-QAS-03, entitled " Distribution and Review of Quality Assurance and Standards Audits" will be revised to include a require, t, yg\\
Mr. G. Fiorelli U. S. Nuclear Regulatory Commission Region III July 27,1979 - QA-1173 Page 6 ment that the auditor classify his findings as deficiencies, observations, or suggestions.
Date When Full Compliance will be Achieved Compliance has been achieved for Field Audits #217 and #223 as of this date.
Review of other Field Audit Reports and revision of Procedure 18-QAS-03 is expected to be complete by August 31, 1979.
We trust that this information is an adequate response to your IE Inspection Report No. 79-14.
Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY By h
E, A. BORGMANN SENIOR VICE PRESIDENT RLW:pa
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