ML20008G048
| ML20008G048 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20008G045 | List: |
| References | |
| REF-QA-99900507 NUDOCS 8107020025 | |
| Download: ML20008G048 (2) | |
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Sargent & Lundy Engineers Docket No. 99900507/81-02 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on March 17-20, 1981, and I'
April 6-10, 1981, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as. indicated below:
A.
Criteria III, XV, and XVI of 10 CFR Part 50, Appendix B, require the control and prompt identification and correction of items deviating from, or not conforming to, design criteria.
Revision 5 of the Sargent & Lundy (S&L), QA program Topical Report (SL-TR-1A) states in Section 16.00,
"... procedures require any person who detects an apparent nonconformance to notify the Head, Quality Assurance Division by memorandum... if the Head, Quality Assurance Division determines that a nonconformance does not exist, he so notifies the initiator.
If a nonconformance does exist, he notifies the Quality Assurance Division Auditing Section to initiate a corrective action report.
Nonconformances may be detected during audits, the review process, or by other means."
Contrary to the above, the applicable Electrical Project Engineering Division procedures do not require notification of the Head, QA Division when an apparent nonconformance is identif'ed.
During the design review process, cables on the Zimmer project were identified as apparently nonconforming in that they e.xceeded the design heat load criteria; however, the Head, QA Division was not notified.
Consequently, a prompt determination of nonconformance was not made, a CAR was not initiated, neither was the item effectively controlled or promptly corrected.
This programmatic nonconformance appears to be generic to other projects in the Electrical Division and potentially generic to other engineering divisions.
8.
Criteria XVIII of 10 CFR Part 50, Appendix B, requires the establishment of a comprehensive audit system to determine the effectiveness, of the QA program.
The S&L QA topical report, SL-TR-1A, describes the audit system in Saction 18.00, expanding the description further by committing to the requirements of ANSI N45.2.12 in Section 00.00.
Among the audit i
system requirements in the endorsed ANSI standard are:
Scheduling - Auditing shall be initiated as early as practicable in the life of an activity to assure timely implementation of QA requirements and the effectiveness of the implementation.
Regularly scheduled audits are to be supplemented when (1) significant changes are made in functional areas such as reorganization, procedure development or revision, or changes in scope of work; (2) it is suspected that quality is in jeopardy due to identified nonconformances.
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Summary Inspection on March 17-20, 1981, and April 6-10, 1981 (99900507/81-02)
Areas Inspected:
Implementation of 10 CFR Part 50, Appendix B, criteria in the areas of (1) an evaluation of S&L's performance and responsibility concerning several site related problems identified by Region III personnel, and the effectiveness of S&L's generic corrective and preventive actions in response to l
their internal inspection and audit findings and those of others, i.e. NRC and i
client and (2) follow up on previous inspection findings.
The inspection l
involved 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> on site by five USNRC inspectors.
l Results:
In the two areas inspected there were no unresolved items.
Two nonconformances were identified in one area.
Nonconformances:
Evaluation of S&L's Performance and Responsibility - (1) Con-trary to the requirements of 10 CFR Part 50, Appendix B, it does not appear that S&L procedures in the Electrical Project Engineering Division assure prompt determination of nonconformar.ces and prompt action in controlling and correcting these nonconformances (Notice of Nonconformance enclosure, Item A).
(2) Contrary to the requirements of ANSI N45.2.12, the S&L internal audit system is deficient in a number of areas resulting in a reduction of comprehensiveness and effective-ness.
(Notice of Nonconformance enclosure, Item B).
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