ML19254D638
| ML19254D638 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19254D634 | List: |
| References | |
| REF-QA-99900248 99900248-79-2, NUDOCS 7910290256 | |
| Download: ML19254D638 (2) | |
Text
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Union Pump Company Docket No. 99900248/79-02 NOTICE OF DEVIATION Based on the results of an hTC inspection conducted on July 9-13, 1979, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A.
Crite.-ion XVIII of Appendix B to 10 CFR 50 states in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compli-ance with all aspects of the quality assurance program and to determine the effectiveness of the program..
QA Manual Section 20, paragraph 20.2 states in part, "... The Quality Assurance Manager is responsible for assuring that management audits of the complete Quality Control Program are conducted semi-annually. Manage-ment reviews the adequacy of the Quality Control Program by auditing every six months in accordance with a written checklist.
Contrary to the above, a review of the last two (2), semi-annual management audits performed by the QA Manager revealed the complete QC Program was not audited. The written checklist, used by the QA Manager to conduct the audits, addresses just ten (10) elements found in five (5) sections ofatwenty(20)sectionQCProgram.
B.
Criterion V of A pendix B to 10 CFR 50 states in part,'.," Activities I
affecting quality shall be prescribed by documented ins \\ ructions, pro-cedures, or drawings, of a type appropriate to the circubstances and shall be; accomplished in accordance with these instructions, procedures, or drawings...."
Deviations from these requirements are as follows:
1.
QA Manual Section 15, paragraph 15.4, states in part, "... NDE, other than liquid penetrant, shall be subcontracted.... The Quality Control Manager shall approve all subcontracted NDE proce-dures and shall review all personal qualifications for compliance with the Code and the Written Practice.
Procedures, per-sonnel qualifications, Written Practice, and supporting documents shall (be) on file at Union Pump and made available to the ANI."
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2 Contrary to the above, qualifications of personnel performing subcontracted magnetic particle examination on repair welds were not on file at Union Pump, nor were they made available to the ANI.
See Details Section, paragraph E.3.a.
2.
QA Manual Section 12, paragraph 12.4.1., states, NDE procedures are specified on the Process Routing. All results are documented on NDE reports specified in the procedures."
Procedure INSP-3601-0, " Visual Inspection of Welds," paragraph 6.0 states, "A visual inspection report shall be filled out indicating results of this inspection."
Contrary to the above, Process Routings for ASME Section III, Class NF welds on Base to Pedestals required visual inspection per INSP-3601-0. Although the required visual inspection was performed, visual inspection reports were not filled out indicating the results of the inspection. (See Details Section, F.3.a.)
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