Energy Facility Contractors Group (EFCOG) Safety

Transcript:Energy Facility Contractors Group (EFCOG) Safety:
Energy Facility Contractors Group (EFCOG) Safety Working Group Regulatory & Reporting Technical Subgroup Enforcement Letter: Suspect Documentation October 21, 2015 Alan Duncan Enforcement Coordination Consolidated Nuclear Security, LLC Alan.Duncan@cns.doe.gov Event Reporting ORPS NA- -PS-BWP-PANTEX-2014-0036, Discovery of Suspect Supplier Documentation On May 14, 2014 in support of evaluation of a specific container for off-site shipment of components, the Packaging Engineer determined that reports received from the manufacturer were inconsistent and suspect. Subsequent investigation by the Supplier Quality organization determined that inadequate quality controls were in place with regard to the quality assurance documentation system and in particular that the questioned record included a signature from an individual no longer in the employ of the manufacturer. One of several issues raised with the manufacturer was lack of date associated with the signature and inadequate change control practices with regard to the certifications. 4C(2) – Discovery of any other suspect or counterfeit item or material (i.e., not found in a Safety Class or Safety Significant Structure, System, or Component) that is found in any application whose failure could result in a loss of safety function, or present a hazard to public or worker health and safety. NTS-NPO—CNS-Pantex-2014-0009 submitted October 2, 2014 2 Event Reporting ORPS NA- -NPO-CNS-PANTEX-2014-0027, Discovery of Noncompliant Containers As a part of an extent of condition review for the May 2014 noncompliance, certification documentation was reviewed and the review determined that documentation described differing testing conditions between lots. When the requirements were investigated it was determined that some testing results were not in conformance to DOT requirements. 4C(3) – Discovery of any defective item or material, other than a suspect/counterfeit item or material, in any application whose failure could result in a loss of safety function, or present a hazard to public, or worker health and safety. Additional information added to NTS-NPO- -CNS-Pantex-2014-0009. 3 Significance of Conditions The Office of Enforcement guidelines considered the false record created by the vendor a willful act and were reluctant to believe it was isolated. The Office of Enforcement assigns greater significance to the actions of managers and supervisors. The occurrence report identifies the Quality Manager as the individual responsible for the false record. The vendor provides numerous containers in support of the NNSA mission. Customers include Pantex, Los Alamos, Sandia, Y-12, Brookhaven, and Oak Ridge National Lab. Joint investigation of record-keeping revealed that the wrong calculation had been used in support of United