ML19270H121
| ML19270H121 | |
| Person / Time | |
|---|---|
| Issue date: | 04/09/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19270H109 | List: |
| References | |
| REF-QA-99900317 NUDOCS 7906230033 | |
| Download: ML19270H121 (4) | |
Text
Cooper Services, Incorporated Cooper Energy Services Docket No. 99900317/79-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on March 19-23, 1979, it appeared that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
Cooper Energy Services' corrective action response letter of March 15, 1978, states in part, "To prevent recurrence... a computer program will be implemented to cross check all items that have been desig-nated ' critical,' to verify that a QC/IP number has been input to the system by Methods personnel.
(sic)
"... Preventative action will be implemented on or before May 31, 1978."
Contrary to the above, the computer program to verify that a QC/IP (Quality Control Inspection Plan) number had been entered in the sys-tem for critical parts, was not implemented until after October of 19'78.
B.
Cooper Energy Services' corrective action response letter of March 15, 1978, states in part, "The corrective action system procedure will be revised to more efficiently administer corrective action measures...
Preventative action will be implemented by June 30, 1978."
Contrary to the above, the corrective action system procedure (QCP-10-4) was not revised until September 14, 1978.
C.
Criterion XVI of Appendix B to 10 CFR 50, states in part, " Measures shall be established to assure that conditions adverse to quality, such a.; failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Paragraph 5.1, item 19. of Quality Control Procedure No.10-4, Revi-sion 1, dated September 14, 1978, states in part, " Issue a reminder form (QCP-10-4C, Exhibit C) to the individual or department who last received the CAR, if the CAR has been held up for a period of time exceeding thirty days."
Contrary to the above, reminder forms had not been issued when CARS (Corrective Action Requests) had been delayed for more than thirty (30) days; as indicated by the following:
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. CAR No./Date Reminder Form Issued GC-1135/10-11-78 1-17-79 GC-1128/9-21-78 1-17-79 GC-1144/11-3-78 1-17-79 GC-1171/2-6-79 No reminder form sent as of 3-23-79 This is a repeat deviation.
D.
Criterion XVIII of Appendix B to 10 CFR 50, states in part, "A com-prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance pro-gram and to detemine the effectiveness of the program... Follow-up action, including reaudit of deficient areas, shall be taken where indicated."
1.
Paragraph 5.2 of Quality Control Procedure No.10-5, Revision 3, dated March 21, 1977, states, "An Audit Schedule (Exhibit B) and an Audit Status Report (Exhibit C) shall be maintained by Quality Engineering at Grove City, and all designated audit groups.
These foms shall list all audit activities to be perfomed in all three plants, the scheduled dates for perfomance of each, the results of initial audit and of subsequent re-audits."
Contrary to the above:
Audits had not been performed within the scheduled dates, as evidenced by the following:
Loc /Cklst Scheduled Perfomed MV/ADT-17 3-20 thru 4-10-78 5-9-78 GC/ADT-6 4-5 thru 4-15-78 5-2-78 GC/ADT-4 10-25 thru 11-5-78 11-15-78 GC/ADT-18 10-25 thru 11-5-78 Not performed as of 3-23-79 GC/ADT-5 11-5 thru 11-15-78 11-30-78 2.
Paragraph 5.4.1 of procedure No.10-5, Revision 3, stat as, "A deficiency detected during a quarterly, biannual, or annual audit requires a reaudit within approximately three weeks of the original audit, but shall not exceed twenty working days."
Contrary to the above, reaudits of deficiencies detected during annual and quarterly audits had not been performed as scheduled, as evidenced by the following:
Loc /Ckist/Freq R_eaudit Req'd Perfomed GC/ADT-1/A 9-22-78 10-30-78 GC/ADT-11/Q 3-24-78 5-16-78 MV/ADT-13/Q 4-17-78 5-9-78 GC/ADT-10/Q 4-10-78 5-9-78 GC/ADT-15/Q 9-22-78 Not perfomed as of 3-23-79 This is a repeat deviation.
E.
Criterion V of Appendix B to 10 CFR 50, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, pro-cedures, or drawings."
Paragraph 4.4.1 of Quality Control Procedure No.10-1, Revision 4, dated May 11, 1978, states in part, "The Inspector who perfoms the operation designated by the Inspection Plan shall enter the requasted response... Required response to inspection operations is specified by the Inspection Plan and shall be provided as specified...."
Contrary to the above, the required response designated by the Inspec-tion Plan, of recording three (3) actual dimensions was omit ed in favor of using Xs on the completed Inspection Plan 32-10ID3 for P/N KSV-32-2A#1, S/Ns 8C2001 through 8C2012.
F.
Criterion VI of Appendix B to 10 CFR 50, states in part, " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. Theu measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
ihe first paragraph of Section 3 of the Quality Assurance Manual, No. QAM-1000-1, Revision 6, dated February 25, 1977, states in part,
" Measures are employed in accordance with applicable written proce-dures to control the issuance and changes thereto of documents which prescribe activity affecting quality.
These measures assure that all documents such as drawings, specifications, procedures, and in-structions are... reviewed and approved for release by authorized personnel; and are distributed to and used at the locations where the prescribed activity is performed."
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4_
Contrary to the above, written procedures had not been employed to assure that Quality Control Procedures and Quality Control Inspection Plans are reviewed and approved for release by authorized personnel.
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