ML19281A776
| ML19281A776 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19281A768 | List: |
| References | |
| REF-QA-99900505 NUDOCS 7904040269 | |
| Download: ML19281A776 (3) | |
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Ebasco Services, Inc.
Docket flo. 99900505/79-01 fl0TICE OF DEVIATI0tl Based on the results of an tiRC inspection conducted on January 15-19, 1979, it appeared that certain of your activities were not conducted in full compliance with flRC requirements as indicated below:
A.
Ebasco Topical Report ETR 1001, Section QA-II-9, paragraph 2.10
" Audit Records," states in part, " Records generated during audit preparation, performance or follow-up shall be retained for all audits in accordance with the applicable requirements of Section QA-I-6 (QA Records)...."
Section QA-I-6 cescribes the Ebasco system for the control and maintenance of ( A records that is consistent with A11SI f145.2.9.
Contrary to the c cove, records of internal audits and management audits are not being retained in the QA records system described in Section QA-I-6; instead these records are being retained in Ebasco departmental files and only Quarterly Summaries are being entered into the QA records system.
t B.
Ebasco Topical Report ETR 1001, Section QA-II-9, paragraph 3.4,
" Management Audits," states in part:
"A committee chaired by the Consulting Quality Assurance Engi-neer is responsible for conducting audits of Ebasco Materials Engineering and Quality Assurance functions to determine com-pliance... This auditing shall be accomplished on an annual basis in accordance with Ebasco procedure E-58...."
Implementing procedure E-58 (now redesignated A-45) states in part:
" Evaluation and follow-up of audit corrective action will be made by the Committee Chairman.
He will... confirm that nonconformances are resolved and that corrective action, when necessary, is accomplished.
The Audit Committee Chairman shall be responsible for maintaining all records, files and corre-spondence. The Chairman will maintain a system (log) whereby status of all outstanding deficiencies can be readily ascer-tained...."
Contrary to the above, the following requirements were not met:
(1) There is no record that follow-up and closure (indicated as required) were performed for the 1977 audit findings.
790404 o % 9 (2) The 1976 management audit report was not maintained by the Audit Committee Chairman.
(3) The system (log) for status of deficiencies is incomplete and out-of-date; status of outstanding deficiencies cannot be readily ascertained from the log, e.g., there were no log entries for 1974 through 1977, and the log indicated 1978 findings as "open" when in fact they had been " closed."
C.
10 CFR 50, Appendix B, Criterion XVIII, " Audits" requires that
" Follow-up action, including reaudit of deficient areas, shall be taken where indicated."
Ebasco Quality Program QA Manual for Waterford Unit 3, Procedure QC-7, "QA Audits - Internal and External" (applicable since February 8,1977),
paragraph 2.9 states:
" Audit Follow-up - Follow-up action shall be performed to:
(a) Assure that written reply is received (b) Assure that corrective action is identified and scheduled (c) Confirm that nonconformances are resolved and that correc-tive action, when required, is accomplished."
Procedure ME-QC-P.14 (applicable from June 20,1975-April 29,1977),
paragraphs 4.2.6 and 4'.2.7, states:
Resolution of Deficiencies - The supplier / contractor will be given a specified -ime, usually 30 calendar days... to resolve any deficiencies noted in the audit report.
" Corrective Action - All corrective action submitted to Ebasco QA Engineering Department by the supplier will be reviewed prior to its acceptance. This review will consist of a follow-up facility survey and/or an evaluation of written procedures as determined by the Supplier Evaluation Group l e a de r. "
Proceaure QA-P.9 (applicable since April 29,1977), paragraphs 7.0 and 11.3, states:
" Conditional Satisfactory status - Corrective action is required.
Vendor is required to respond within twenty calendar days....
A follow-up audit shall be performed... when a vendor has been deemed ' Unsatisfactory' or ' Conditional Satisfactory' and has submitted a satisfactory response."
Contrary to the above (as applicable by date), audit follow-up and resolution of deficiencies have not been performed / documented as follows:
(1) No vendor response and no follow-up audit to confim corrective action for:
(a) Audit dated February 26-27, 1976, of ACF Industries - WKM with 12 findings (Supplier has current ongoing work on Main Steam Isolation Valves and Control Valves (Level Pressure and Flow) for one project).
(b) Audit dated February 14, 1978, of Lunkenheimer with 8 findings and status " Conditional Satisfactory" (Supplier has current ongoing work on safety-related stainless steel valves, 21" and larger, for one project).
3 (2) No follow-up audit to confirm corrective action for:
Audit dated November 24-25, 1975, of Lunkenheimer with 3 findings and status " Unsatisfactory."
D.
In letters of response to previous inspection findings dated April 28, 1978, May 23,1978, and August 10, 1978, Ebasco management committed to corrective and preventive actions to be completed at various sub-sequent dates. All actions relative to these previously identified deviations were to have been completed by December 31, 1978.
Contrary to the above commitments, the committed corrective and preventative actions were not completed on five (5) of the six (6) previously identified deviations reviewed during this inspection even though their completion dates were to have been from August 1978 to December 31, 1978.
(See DetailsSection I, paragraphs B.l., B.2., B.3., B.5., and B.6.
for additional information.)