ML20154N020

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Notice of Nonconformance from Insp on 851120-22
ML20154N020
Person / Time
Issue date: 03/13/1986
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20154N017 List:
References
REF-QA-99901038 99901038-85-01, 99901038-85-1, NUDOCS 8603170175
Download: ML20154N020 (2)


Text

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4 APPENDIX A 3M Company 99901038 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on November 20-22, 1985, it appears that certain of your activities were not conducted in accordance with NRC requirer.1ents.

A. Criterion V, " Instructions, Procedures, and Drawings," of Appendix B to 10 CFR Part 50 states, in part: " Activities affecting ouality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances ar.d shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions...shall include appropriate... acceptance criteria for determining that important activities have been satisfactorily accomplished."

Section 1 of the 3M QA Manual states, in part: "the Ceramic Material Department...is supported by documented policies... procedures and instructions that prescribe and describe those... activities affecting the quality of product and services.. .."

Contrary to the above, no documented procedures or instructions had been written to assure that the activities of the 3M computer code program were performed and controlled as prescribed by documented procedures. The computer code program is used as part of the services for supplying cable ampacity derating values for NRC licensees (85-01-01).

B. Criterion II, "0uality Assurance Program," of Appendix B to 10 CFR Part 50 states, in part:

...the program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained...."

Section 2 of the 3M QA Manual states, in part: "the...QA program is... formally controlled through the following general measures:

... Provisions for indoctrination and training of personnel...."

4 Contrary to the above. 3M did not adequately provide indoctrination and i training for personnel performing activities affecting quality. A random sample determined that three out of ten personnel had not received their required indoctrinatien or training (85-01-02).

C. Criterion I, " Organization," of Appendix B to 10 CFR Part 50 states, in part: "...The persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems...Such persons...shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule...are provided...."

99901038

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- t, Section 1.0 of the 3M QA Manual states, in part: " ... Reporting directly to the Manager, Ceramic Material Department are: ... Quality Assurance Manager..."

Contrary to the above, the 3M CA Manager does not have sufficient authority and organizational freedom, including sufficient independence frem cost and schedule. Examples of this, as of November 22, 1985, are (85-01-03):

1. The QA Manager reports to the 3M Production Manager instead of the 3M Ceramic Department Manager, as required by the QAM.
2. The annual 3M personnel performance evaluation for the QA Manager is initiated and completed by the 3M Production Manager.

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