ML20135E641
| ML20135E641 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/1996 |
| From: | Gallo R NRC (Affiliation Not Assigned) |
| To: | Desopo C ARKWRIGHT BOSTON MANUFACTURER'S MUTUAL INSURANCE |
| References | |
| REF-QA-99901296 NUDOCS 9612110380 | |
| Download: ML20135E641 (4) | |
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December 4, 1996 1
Mr. Conrad M. D'Esopo, Vice President Arkwright Mutual Insurance Company Mutual Boiler Division i
225 Wyman Street P.O. Box 9198 Waltham, MA 02254-9198 Dear Mr. D'Esopo Thank you for your September 20, 1996, reply to the Notices of Violation and Nonconformance that were iss"ed by the Nuclear Regulatory Commission (NRC) on August 23, 1996, as a result of the NRC inspection of Arkwright Mutual Insurance Company (Arkwright) on June 17-18, 1996.
We find your reply to the Notice of Violation satisfactory.
The proposed changes to the Arkwright quality assurance (QA) manual and associated QA procedures are responsive to the identified deficiencies, and, once implemented, should result in full compliance with the regulatory requirements.
Your responses to Nonconformances A (9990:296/96-01-02) and B (99901296/96 03) take issue with the inspection team's findings that form the bases for these nonconformances.
Specifically, you state that Factory Mutual did not notify Arkwright of any technical issues of potential safety significance concerning the services contract with Amer and that Arkwright's QA Manual adequately defined the duties and responribilities of persons performing QA functions and satisfied the requirements of N626 and QAl-1.
You further state that your manual was reviewed and accepted by the ASME during their accreditation survey.
We disagree with your positions on these issues.
Specifically, you stated in your reply to nonconformance 99901296/96-01-02 that Factory Mutual's notifications of Amer's performance "took the form of unsubstantiated allegations with respect to issues associated with working relations."
However, NRC Inspection Report 99901296/96-01 identified specific instances documented in rr ords found in your files where, over a two year period, Factory Mutual notified Arkwright of Amer's repeated failures to comply with ASME Code requirements.
Our review of these records concluded that the reported conditions were sufficiently serious to compromise the concept of third party oversight and the ASME accreditation process.
Your bases for determining that Factory Mutual's " allegations" were unsubstantiated were not presented to the team during the inspection nor were they described in your reply letter dated September 20, 1396.
Therefore, to understand your position on the requirements of Criterion I of Appendix B to 10 CFR part 50, as stated in the Notice of Nonconformance, please provide your bases for determining g' that Factory Mutual's " allegations" were unsubstantiated.
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Mr. Conrad H. D'Esopo With respect to your statements regarding the definition of QA functions in your QA Manual, please note that nonconformance 99901296/96-01-03 was written against the requirements of 10 CFR Part 50, Appendix B and that ASME's acceptance of your quality manual does not ensure conformance with Appendix 8.
The quality requirements of 10 CFR Part 50, Appendix B had been invoked in your service contracts with NRC licensees and are, therefore, required to be addressed in your quality program.
Furthtrmore, your proposal to add the affiliation of Mutual Boiler Division to the title of Managing Supervisor Inspection Services fails to adequately describe the Mutual Boiler Division in its organizational context within Arkwright.
Please provide this information as a part of your response.
With regard to the first part of Nonconformance C (99901296/96-01-04), you have agreed to make the necessary corrections and we consider this issue resolved.
With regard to the second part of Nonconformance C, you state that paragraph 9 on page 7 of 10 of QAP.07 dated June 1996, adequately addresses the NRC's concern about the use of QA monitoring reports.
On the basis of our re-review of page 7 of 10 of QAP.07 dated June 1996, we conclude that page 7 neither addresses the use of QA monitoring reports nor does it have a paragraph 9, or 9 paragraphs for that matter.
Therefore, your position on this part of the nonconformance is not responsive to NRC's concerns and additional information is required.
Please provide this information as a part of your response.
In your response to Nonconformance D (99901296/96-01-01), you did not address your basis for compliance with 10 CFR Part 50, Appendix B.
The fact that Arkwright is an owner of the Factory Mutual organization and that Factory Mutual maintains qualification and training records for employees who were once employed by Factory Mutual does not exempt Arkwright from Appendix B, Criterion XVII, " Quality Assurance Records," requirements that " records shall be identifiable and retrievable." Arkwright is required to maintain retrievable and auditable qualification and training records for all current employees. Also, as identified in Section 3.4 of the inspection report, certain inspector training records that could not be found in the Arkwright files during the inspection were claimed to be located at the Georgia residence of the Managing Supervisor of Inspection Services.
These records should also be retrievable and auditable by Arkwright since the QA program description did not identify any field offices as part of your organization.
We expect that Arkwright will be in a position to retrieve these records and make them available for our review during our next inspection.
No additional information concerning this nonconformance is required at this time.
Concerning your response to Nonconformance E, (99901296/96-01-06), we do not agree with your statement that a nonconformance did not take place. We do not agree that your earlier practice of issuing QAP's to inspection personnel in j
lieu of providing them with copies of your QA manual was a satisfactory method of disseminating the overall QA program requirements.
Section 10.3.1 of your QA Manual, Third Edition, Revision 2, under " Implementation of Manual and Revision," states that "the QA manual shall be implemented by all personnel involved with nuclear inspection activities."
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im Mr. Conrad M. D'Esopo For inspection personnel to implement and receive training (as per Section 10.3.3 of QA manual) in a QA manual that will not be made available to these personnel is considered a nonconformance with the Arkwright QA program.
However, since you have clarified your intent of QA manual implementation by inspection personnel, and controlled copies of the manual have been distributed to these personnel, no additional response is required.
In summary, additional information, as discussed above, is required to close nonconformances A,B, and C.
Please provide this information within 30 days of your receipt of this letter. We will review the implementation of your corrective action commitments during a future inspection.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room.
Sincerely, Original signed by:
Robert M. Gallo, Chief Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation Docket No. 99901296 Distribution:
PSIB R/F RMcIntyre Central Files / Docket Files /PUBLIC' SMatthews T-LfE-f DOCUMENT NAME: G:\\P0TAPOVS\\ARKRES.1 To r:ceive a copy of this document, indicate in the box:
"C" = Copy without
= Copy i enc, res *N" = No copy 0FFICE PSIB: DISP l C PSIB: DISP lC PSIB$ISJ9' l C, DI$PM l l
NAME UPotapovs:smp
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\\'Fi/4/96 0FFICIAL RECORD COPY
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Mr. Conrad M. D'Esopo Edition, Revision 2, under " Implementation of Manual and Revisjon," states that "the QA manual shall be implemented by all oersonnel indved with nuclear insoection activities."
It does not appear reasonjble for inspection y-personnel to implement and receive training (as per Sectj6n 10.3.3 of QA manual) in a QA manual that will not be made availabl o these personnel.
However, since you have clarified your intent of QA anual implementation by 1
inspection personnel, and controlled copies of th manual have been j
distributed to these personnel, no additional r ponse is required.
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In summary, additional information, as discupsed above, is required to close nonconformances B, C, and D.
Please provi# this information within 30 days i
of your receipt of this letter. We will eview the implementation of your corrective action commitments during a uture inspection.
3 In accordance with 10 CFR 2.790 of e NRC's " Rules of Practice," a copy of this letter will be placed in the C's Public Document Room.
S ncerely, 1
4 1
Robert M. Gallo, Chief j
Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation Docket No. 99901296 Distribution:
PSIB R/F RMcIntyre Central Files SMatthews l
Docket Files PUBLIC j
1 DOCUMENT NAME: G:\\P0TAPOVS\\ARKRES.1 To rtceive a copy of,this document, indicate in the box:
"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy i
0FFICE PSIB: DISP lC PSIB: DISP _ l _ G.
PSIB: DISP l C l
l NAME UPdtapovs:smp(iO GCCwalindW qt-RMGallo
/G. I 6,046hh-DATE ll//)C/96 11/2R96 i
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0FFICIAL RECORD COPY
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