ML20211G933

Notice of Violation from Insp on 860908-10

ML20211G933
Person / Time
Issue date:	10/30/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20211G921	List: ML20211G916 ML20211G933 ML20211G953
References
REF-QA-99900768 NUDOCS 8611040333
Download: ML20211G933 (3)

Text

.0 APPENDIX A Westinghouse Hittman Nuclear, Inc.

Docket No. 99900768/86-01 NOTICE OF VIOLATION During an inspection conducted on September 8-10, 1986, the implementation of the Westinghouse Hittman Nuclear, Inc. (Hittman) Quality Assurance (QA) program at the Columbia, Maryland facility was reviewed with respect to transportation packages (casks). Hittman is a subsidiary of the Westinghouse Electric Corporation. Hittman's QA Manual encompasses two QA programs. C-100, Revision 2, dated March 1, 1985, is the QA program for the engineering, design, procure-ment, fabrication and initial testing of radwaste shipping packages. C-200, Revision 3, dated March 1,1985, is the QA program which governs the use of shipping packages. Both programs have been reviewed and approved by the NRC and incorporate the criteria of 10 CFR Part 71, Subpart H. Cask designs are authorized for use through the Certificate of Compliance (C of C) issued by the NRC. Hittman is the C of C holder for several cask designs. .As a result of the inspection and in accordance with.Section 206 of the Energy Reorganization Act of 1974, 10 CFR Part 21 and 10 CFR Part 71, the following violations were identified and categorized in accordance with the NRC Enforcement Policy, -

10 CFR Part 2, Appendix C.

1. Section 21.31 of 10 CFR Part 21 requires, in part, that each corporation assure that each procurement document for a basic component issued by that corporation specifies, when applicable, that the provisions of 10 CFR Part 21 apply.

Contrary to the above, Hittman issued Purchase Orders for basic components, N43369, dated April 21, 1986, and N43888, dated July 22, 1986, to-the George P. Thomas Rubber Company for replacement gaskets and N43492, dated May 12, 1986, to the Alleghany-York Corporation for replacement 0-rings, without specifying that the provisions of.10 CFR Part 21 were applicable.

This is a Severity Level V violation (Supplement VII).

2. Paragraph 71.133 of Subpart H to 10 CFR Part 71 requires, in part, that i the licensee establish measures to assure that conditions adverse to l

quality are promptly identified and corrected.

Section 16.1.3 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1,-1985, req ires, in part, that the QA Manager be responsible for the control of conditions l

i adverse to quality including performance of follow-up reviews to verify proper implementation of corrective actions.

8611040333 861030 PDR GA999 EMVWHIT 99900768 PDR

Section 16.2.15 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1, 1985, requires, in part, that the QA Manager maintain a file of all Corrective Action Memos (CAM) and regularly review the log of CAMS to ensure that follow-up acticn is being taken in a timely manner.

Contrary to the above, the Corrective Action Log indicated that several responses to CAMS from the Action Designees had not been received for items identified in 1985, several CAMS from 1984 and 1985 remain open and the last documented review of the CAM system by the QA Marager was performed on April 19, 1985.

This is a Severity Level V violation (Supplement V).

3. Paragraph 71.137 of Subpart H to 10 CFR Part 71 requires, in part, that the licensee carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the Quality Assurance program to determine the effectiveness of the program and that follow-up action, including re-audit of deficient areas, must be taken where indicated.

Section 18.1.7 of C-200, " Quality Assurance Program for the Use of _

Radwaste Shipping Packages," Revision 3, dated March 1, 1985, requires, in part, that deficient areas be re-audited on a timely basis to verify implementation of corrective actions.

Section 18.2.4 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1, 1985, requires, in part, that the audit schedule be periodically reviewed and revised by the CA Manager as necessary to assure that coverage and schedule reflect current activities.

Contrary to the above, audits scheduled to be performed in July and August,1986, have not been conducted and the correc*.ive actions for several deficient areas identified in the 1985 Internal Audit have not been re-audited to verify implementation.

This is a Severity Level V violation (Supplement V).

4. Paragraph 71.137 of Subpart H to 10 CFR Part 71 requires, in part, that follow-up action, including re-audit of deficient areas, must be taken where indicated.

- Section 18.2.12 of C-200, " Quality Assurance Program for the Use of Radwaste Shipping Packages," Revision 3, dated March 1, 1985, requires, in part, that deficiencies determined by the audit team leader to represent conditions adverse to quality must be documented on a CAM in accordance with the requirements of Section 16 of the QA program.

3-Contrary to the above, three deficiencies' identified in audit number 86-09 were not documented on a CAM as required, i This'is a Severity Level V violation (Supplement V).

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