ML19210B993
| ML19210B993 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/05/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19210B988 | List: |
| References | |
| 50-498-79-13, 50-499-79-13, NUDOCS 7911130121 | |
| Download: ML19210B993 (3) | |
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1 50-498/79-13 50-499/79-13 APPENDIX A NOTICE OF VIOLATION Based on the results of the NRC inspection conducted on August 6-10, 1979, it appears that certain of your activities were not conducted in full com-pliance with the conditions of your NRC Construction Permits No. CPPR-128 and 129 as indicated below:
A.
Failure to Follow Procedure -
. r Maintaining PDM QA Manuals
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10 CFR Part 50, Appendix B, Criterion V requires that activities 2ffecting quality shall be accomplished in accordance with instructions, procedures, or drawings.
Pittsburgh Des Moines (PDM) QA Manual, Sec; ion 12 requires that the manual shall be reviewed semiannually or more frequently by the QA Com-mittee to keep the manual current with Code Addenda and L)M construction and QA procedures.
Contrary to the above:
The PDM QA Manual did not appear to have been reviewed on a semiannual or more frequent basis that it was not current nor adequately controlled as exemplified by the tatlowing:
1.
Section 12, " Manual Revision and Distri;ution," does not describe how supplements are to be integrated into the manual after receipt.
2.
Section 13, " Audits," does not state Lead Auditor and auditor qual-ifications requrements nor does it describe how they are qualified.
3.
QA Manuals No. 67, 132, 152, and 177 were found deficient in several areas such as missing sections, different supplements, a superseded procedure and an unauthorized memorandum imposing additional re-quirements.
This is an infraction.
B.
Failure to Follow Procedures for Conduct of PDM Site Audits 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be accomplished in accordance with instructions, proce-dures, or drawings.
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PDM QA Manual, Section 13.0 requires that:
annual or more frequent audits be performed at each construction site; deficiencies and cor-rective actions be brought to the attention of responsible managers; audit results be reviewed by responsible management; and reaudits be performed to assure correction of deficiencies.
Contrary to the above:
1.
Annual or more frequent audits at the construction site were not performed in that the QA program was not completely audited in 1976.'
2.
Deficiencies and corrective actions were apparently not brought to the attention of responsible managers in that corrective action statements have not been signed off by management since 1976.
3.
There is no evidence that audit results have been reviewed by responsi-ble management to determine required corrective action.
Reaudits were not performed to assure correction of deficiencies.
In one case, recurring deficiencies were identified in 1977, yet the deficiencies have not been corrected to date (August 16, 1979).
This is an infraction.
C.
Failure to Delineate Organizational Change in the PDM QA Manual 10 CFR 50, Appendix B, Criterion I requires that authority and duties of persons and organizations affecting safety-related functions of structures, systems, and components shall be clearly established and delineated in writing.
Contrary to the above:
A new position that had been established between the PDM Division QA Manager and the PDM Site QA Manager was not delineated in the PDM QA Manual.
This is a deficiency.
D.
Failure to Maintain Completed Audit Checklists in Audit Files 10 CFR 50, Appendix B, Criterion XVII requires that sufficient records shall be maintained to furnish evidence of activities affecting quality.
Houston Lighting & Power Company (HL&P) Procedure QAP-5B requires that completed audit checklists shall be maintained in the QA audit files.
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Contrary te the above:
The QA file for audit ifL-60 contained two incomplete audit checklists.
This is a deficiency.
E.
Failure to Destroy or Stemp a Deleted QA Procedure 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be accomplished in accordance with instructions, proce-dures, or drawings.
Brown & Root Procedure ST-QAP-2.2, Attachment 6-D requires that super-seded QA program documents must be destroyed or stamped " void" or " super-seded".
Contrary to the above:
Brown & Root QA Manual No. 19 contained Procedure ST-QAP-5.12 which had been deleted per a " Summary of Revision" dated October 13, 1973; however, the procedure had not been stamped " void" or " superseded".
This is a deficiency.
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