Information Notice No.80-26 – Evaluation of Contractor QA Programs

                                                             SSINS No.: 6835 
                                                             Accession No.:  
                                                             8005050064      

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555 
                                     
                               June 10, 1980  

                                           Information Notice No. 80-26 
                                           To All Part 50 Licensees        

EVALUATION OF CONTRACTOR QA PROGRAMS 

Description of Circumstances: 

Appendix B to 10 CFR 50 requires that each applicant and licensee establish 
and execute a Quality Assurance Program, and that each licensee "shall 
require contractors or subcontractors to provide a quality assurance 
program".  Further Appendix B requires each applicant and licensee to 
regularly review the status and adequacy of subcontractor programs. 

The NRC is becoming increasingly concerned by continuing evidence that many 
holders of construction permits and operating licenses are not properly 
implementing these facets of their quality assurance programs. Examples of 
this lack of effectiveness of contractor QA program implementation, and 
inadequacy of licensee overview of contractor QA program implementation are 
appearing in every facet of project activity. Instances have been observed 
where architect-engineers have released documents for procurement with 
inappropriate material specifications. Nuclear steam system suppliers have 
overlooked erroneous assumptions in analysis of instrument system response 
to design basis transients. Other cases have been observed where both AE's 
and NSSS have not followed through on commitments to review vendor detailed 
designs. Vendors' quality assurance programs have been found to contain 
errors of both omission and commission. 

A containment tendon installation contract was awarded to a specialty 
contractor. During a licensee audit some three months after work started it 
appeared that a contractor inspector was falsifying records by initialing 
inspection points not actually observed. A subsequent investigation by the 
licensee revealed that the contractor had required that QC inspections be 
performed only on a random basis even though all records had QC signatures. 
The signatures could mean that the activity was inspected or that record 
signoffs by others were reviewed; or that the data were recorded by the QC 
inspector. It is apparent that the licensee had not appropriately reviewed 
the contractor's inspection program prior to the start of work. 

In another instance, after completion and acceptance of a major structural 
steel installation, the licensee found that significant rework would be 
required to correct construction quality problems. NRC inspection at the 
contractors fabrication facility disclosed that in addition to work for that
license, the contractor had contracts for "high density" fuel storage racks 
from several operating licensees. None of the NRC licensees had inspected 
the contractor's shop or examined his quality assurance programs. 

Response to Information Notice No. 80-26 is not required. The NRC expects 
appropriate action from all licensees and organizations engaged in nuclear 
activities and actions will be examined in the ongoing NRC inspection 
program.