ML20210R802
| ML20210R802 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210R796 | List: |
| References | |
| REF-QA-99900601 NUDOCS 9709030384 | |
| Download: ML20210R802 (4) | |
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'l NOTICE OF NONCONFORMANCE Hartford Steam Boiler Inspection Docket No.: 99900601 and Insurance Company Hartford, CT Based on the results of an inspection conducted on July 14 through 18,1997, it appears that certain of your activities were not conducted in accordance with NRC requirements imposed on you by your customers, or with the requirements of The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code) that are applicable to your activities under the scope of your Certificate of Accreditation.
A.
Criterion XVill, " Audits," of Appendix B to 10 CFR Part 50 requires, in part, that a comprehensive system of planned and periodic audits shall be carried out to verify all aspects of your quality assurance program and to determine the effectiveness of the program.
Engineering Services Manual (ESM) Chapter 4400, " Audits," states, in part, in Section 4421, that the Quality Assurance Manager is responsible for annual audits of the Regional Manager, Engineering Services (RMES) activities and that the Internal Audit Department shall audit the activities of the Home Office (HO)
Englaeering Services (ES) department ASME activities, Contrary to the above, 1.
Hartford Steam Boiler and Insurance Company (HSB) could only provide documented evidence that one audit (November 1995) of HO ES activities had been performed during the last five years. The HSB Quality Assurance Manager (OAM) stated that the internal Audit Department no longer conducts audits of HO ES ASME activities and no other HSB organization or department has been assigned that responsibility, 2.
HSB did not perform the annual audits of RMES activities for San Francisco (1996), Atlanta (1995), and Northeast / Philadelphia (1994 and 1995).
(Nonconformance 99900601/97-01-01)
B.
Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50 requires that measures shall be established to assure that conditions adverse to quality are promptiv identified and corrected.
ESM Chapter 4300, " Control of Nonconformities," states, in Section 4310, that this Chapter outlines the requirements for the identification, documentation, and disposition of nonconformances to the ESM, supporting procedures or instructions.
9709030384 970829 PDR GA999 EECHART 99900601 PDR
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- Section 4340, states, in part, that the RMES/QAM shall have a nonconformity report prepared whenever a nonconformance is identified.
Contrary to the above, 1.
Nonconformity reports were not issued to document, correct, and disposition the six audit findings that were identified and documented as part of the November 1995 Internal Audit Department audit of the HO ES ASME activities.
2.
Nonconformity reports were not issued to document, correct, and disposition all of the audit findings identified during the HO ES QAM audits of RMES.
The inspectors determined there was only one instance (1996 Atlanta regional office audit) where the RMES used a nonconformity report to document and disposition the audit findings that were identified during the OAM's annual audit of RMES activities. (Nonconformance 99900601/97-01-02)
C.
Sections 1-1, "The Authorized Inspection Agency," Subsection 1-1.2, " Duties,"
Paragraph 1-1.2.4 of ASME QAl-1-1995, requires, in part, that the agency shall establish and implement an internal program which shall provide assurance that those of its employees holding the positions of supervisor or authorized nuclear inservice inspector (ANil) perform work in accordance with the requirements of Part 1 of this Standard. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout the life of any agreement covering ASME Code Section XI work, in accordance with these policies, procedures, or instructions.
Contrary to the above, 1.
The ESM, which documents the requirements necessary to perform ASME Code and engineering service activities, did not include or reference the
" Engineering Service Audit Checklist" used by the HO ES QAM to perform annual audits of the RMES activities.
2.
The " Engineering Services Audit Checklist," which is used by the HO ES QAM to perform the annual audits of RMES activities, did not include any provisions for reviewing the disposition and corrective actions implemented for findings identified during past audits of RMES activities.
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3.
No implementing procedure existed to control the internal audit process, and the ESM did not include guidance for conducting quality activities such as documenting internal audits, audit findings, and their closure.
-4.
National Board forms NB-71 and NB-178, " Audit Verification Re' ord," are c
t referenced in Sections 4471 and 4475 of the ESM and used by HSB as the method to notify the National Board of complotion of required audits, but are not included in Section H, " Forms," of the ESM.
(Nonconformance 99900601/97-01 03)
D.
Section 1-2, "The Authorized Nuclear inspection Supervisor," Subsection 1-2.2,
" Duties," Paragraphs 12.2.6 & 1-2.2.7 of ASME QAl-1-1995, require, in part, that the ANllS shall audit the performance of each ANll under his supervision on a planned and periodic basis. Each ANil actively engaged in Section XI Code 4
inspection shall be audited at least twice a year at the site to which he is assigned. The audit shall be recorded in writing and shall contain a written comment regarding the status of each item audited.
Contrary to the above, -
1.
The HSB ESM did not include provisions that require the RMES to
' document and adhere to a schedule of two annual audits of each ANil.
2.
The audits conducted by the Atlanta region RMES of the assigned ANil performance did not contain written comments regarding the status of each item audited. Documented objective evidence consisted of a check for either satisfactory, unacceptable, not observed, or not applicable.
(Nonconformance 99900601/97-01-04)
E.
Criterion V, " Instructions, Procedures, and Drawings," of Appendix B to 10 CFR Part 50,' requires, in part, that activities affecting quality be prescribed by documented instructions caprocedures and be accomplished in accordance withm e
- these instructions.
Section C-5," Experience," of Appendix C," Qualification of Lead Auditors,"to the ESM, permits 9 points maximum " experience" to be credited towards lead auditor qualification and states that time spent in various activities will be awarded points on a reasonable basis in line with ANSI N45.2.23 and NOA-1, Appendix 2A-3. This section of the ESM also contains a provision to score one (1) point maximum for each full year's experience classified as " Industry" with other companies ifit meets the requirements of Paragraph 2.3.1.2 of ANSI N45.2.23 and Paragraph 2.2 of Appendix 2A-3 of NQA-1.
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Section 2.3.1.2 of ANSI N45 2.23 states, " Experience (9 points maximum).
Technical experience in engineering, manufacturing, construction, operation, or maintenance, score one (1) credit for each full year with a maximum of five (5) credits for this aspect of experience." Section 2.3.1.2 continues by providing guidance on scoring additional points for specific nuclear, quality assurance, and auditing experience. Similar provisions are contained in NOA-1.
Contrary to the above, two lead auditor candidates were credited the maximum of points (5) for 5 years of work experience towards lead auditor qualification without any objective evidence that the experience provisions contained in Section 2.3.1.2 of ANSI N45.2.23 or Appendix 2A-3 of NQA-1 had been met.
(Nonconformance No. 99900601/97-01-05)
Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN Document Control Desk Washington D.C. 20555, with a copy to the Chief, Special inspection Branch, Division of Inspection and Support Programs,
' Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a
" Reply to a Notice of Nonconformance" and should include for each nonconformance:
(1) a description of steps that have been or will be taken to correc+ these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventative measures were or will be completed.
Dated at Rockxille thisMNay ofWp 6, Maryland 97 4
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