ML19259B156
| ML19259B156 | |
| Person / Time | |
|---|---|
| Site: | 07100244 |
| Issue date: | 12/28/1978 |
| From: | NL CHEMICALS (USA), INC. |
| To: | |
| Shared Package | |
| ML19259B151 | List: |
| References | |
| NLQ-63, NUDOCS 7901160385 | |
| Download: ML19259B156 (26) | |
Text
3.
NLQ-63
.- 0 2 Y Y u)//W Iz/28/78 QUALITY ASSURANCE PROGRAM FOR COMPLIANCE WITH APPENDIX "E" 0F 10 CFR PART 71 NLQ-63 NUCLEAR DIVISION NL INDUSTRIES, INC. P.O. BOX 2046 WILMINGTON, DELAWARE ? 'J$ b. 7001160Sf [ 0 " 2" 11611
RE LG AA VN OA RM PPC AQ / AQ NO I S D I R V O E C R E 3R F 6 O e - N u QO N s LI O s NT I I N T E P l T I a E R i R C t S i E n D I ET 8 A 7 D / 1 2 V / E 2 R 1 LEVEL 0 V v E e R R
NLQ-63 REV. O TABLE OF CONTENTS Introduction Page 4 Quality Assurance Program 8 8 NLQ-63 REV. O INTRODUCTION The following NL Industries, Inc., quality assurance program has been structured to satisfy the requirements of 10 CFR Part 71, Appendix E. The quality assurance program (Hereafter referred as NLI's Commercial Nuclear Quality Manual) is provided by NL Industries, Inc., Nuclear Division, to assure effective application of the effort and resources necessary to meet the quality objectives for cask design, fabrication and operation. The overall quality objective is to provide a shipping package whose safety related systems, structures and components will perform their required functions in the predicted manner over their intended service life. NLI's Commercial Nuclear Quality Manual has been designed to that quality related elements are identified and controlled assure and that documented records are provided which will demonstrate attainment of quality objectives in accordance with the require-ments of Appendix E, 10 CFR Part 71. The program includes directly or by reference the written policies, procedures and instructions for the execution of all quality related activities applied to the design, purchasing, fabrication, assembly, testing, use, repair, handling, inspecting, modifying and maintenance of the shipping package. The quality assurance program will be applied to all component parts, subassemblics, assemblies and/or systems which are critical in meeting performance requirements NLQ-63 REV. O in the following systems. Reactivity Control Containment of Radioactive Material Radiation Shielding Decay Heat Dissipation Carriage on and attachment to vehicle Cask lifting gear The above requirements are not applicable to commercially available vehicle running gear (rail car truck and draft gear) and cther commercially available components required in auxiliary systems. NLI Nuclear Division, as licensee, has the responsibility for development, implementation and execution of the overall quality assurance program. Certain delegations of responsibility are made to support groups within the NL organization, approved subvendors or clients for implementation of individual elements in the overall quality assurance plan. However, responsibility for the adequacy of procedures by which these delegated responsi-bilities are implemented is retained by the Nuclear Division, NL Industries, Inc. Specific responsibilities are as follows : (a) The Engineering Manager and QA Manager shall be responsible for indentifying the specific levels of quality required for each safety related component in the cask system. (b) The QA Department is responsible for review and approval of design drawings, purchase specifications, fabrication procedures and other pertinent prepared design media. 9 0 NLQ-63 REV. O These reviews are for the purpose of determining if the media adequately assures conformance of the item to the design basis and safety criteria. All design changes require review and approval by the Engineering and QA Department. (c) The Purchasing Department is responsible for such procure-ment documentation with internal review and approval pro-cedures provided to assure adequacy of quality provisions. Final approval of QC provision is by the Manager, Quality Assurance or his delegate. (d) The quality assurance department is responsible for establish-ing and carrying out programs for qualification and control of all subvendors. (e) The QA Department is responsible for preparation and appli-cation of a documented quality control plan for safety related equipment and components in accordance with ULI's Commercial Nuclear Manual. Responsibility for pre-paration of this document is assigned to the Manager Quality Assurance. Internal review procedures are utilized to assure adequacy and consistency with project quality objectives. (f) In those instances where engineering development work is required in support of design to assure equipment safety, responsibility for direction is with the NTD Manager. _
NLQ-63 REV. O Included within this responsibility is the evaluation of results and the subsequent application to those areas where quality requirements standards and controls are affected. v.
NLQ-63 REV. 0 QUALITY ASSURANCE PROGRAM 1. Organization The Nuclear Transportation Department of NL Industries, Inc., Nuclear Division, has the responsibility and authority for the design of the shipping packages for radioactive materials and is responsible for all procurement, manufacturing, testing, use, repair, maintenance, modification and quality assurance aspects related to the shipping packages for radioactive materials. Lines of responsibility and authority are shown on the attached Organization Chart. (Refer to Attachment I). The Quality Assurance Manager of the Nuclear Transportation Department (NTD) has full responsibility and authority for assuring complete implementation and maintenance of the Quality Assurance program. The Quality Assurance Department has the organiza-tional freedom to identify quality problems, to initiate, recommend or provide solutions; and to verify implementation of solutions.
NLO-63 REV. 0 2. Quality Assurance Program Appendix E of 10 CFR 71 Quality Assurance Criteria for packaging of radioactive materials for transport and ASME Code Section III (NA-4000) has been selected as the governing standards to assure that the required Quality standards are attained during the design, engineering, procurement, manufacturing, and acceptance testing of the NLI shipping packages for radioactive materials. Comprehensive documentation of the overall quality assurance program to be carried out throughout the life of the shipping packages for radioactive materials have been initiated. Struc-tures, systems and components the quality of which will affect attainment of program safety objectives and criteria have been identified through analysis of operating and potential accident conditions. Documented program plans and procedures provide control, verification and maintenance of quality by means appro-priate to each of the successive program phases, including necessary qua..fications and indoctrinatian of personnel execu-ting the progrem. _
NLQ-63 REV. 0 3. Design Control Measures have been established for the design phase of the Spent Fuel Shipping Cask program to assure that regulatory requirements, design bases and safety criteria are correctly implemented in the final design drawings, specifications, instructions, etc. These measures include NTD reticu and approval of all design media pertaining to safety significant systems, corponents and structures as well as periodic design safetr revitvs by teams of qualified individuals not directly associated with the design program. The scope and timing of such reviews have been such as to permit assessment of basic program concepts, safety assurance procedures and implementation of safety ob-jectives and requirements in cask detail design. By establishing policies and procedures, reports of review findings are directed to line organization management for review and documented res-ponse. Design control measures also require that design changes be prepared, reviewed and approved by the organizations performing these functions on the original design. Procedures by which design media are issued for review and approval, for revision, for release to fabrication and for accumulation of reference files have been established among participating organizations. NLQ-63 REV. 0 4. Procurement Document Control _ Design quality control procedures include provisions for assuring that quality requirements are suitably defined in the documen-tation supporting procurement of equipment, materials and services and that suppliers arc required to provide appropriate quality control plans where necessary to demonstrate attainment of re-quisite quality. NLQ-63 REV. 0 5. Instru2tions, Procedures and Drawings As with the control of design and procurement, such instruc-tions, procedures and supplementary information as may be neces-sary for control of other activities affecting quality have been or will be documented to include appropriate means for determining that important operations have been satisfactorily accomplished. Examples are operating and testing instructions, equipment maintenance procedures, etc., as required to implement the overall quality assurance program and/or specific quality control plans. NLQ-63 REV. 0 6. Document Control As for control of documents involving design interfaces, pro-cedures have been or will be estabiished for issuance of neces-sary documented instructions and procedures for other activities affecting quality such as acceptance testing, equipment main-tenance and cask. modification to assure review and approval by authorized personnel (original issue and subsequent changes) as well as distribution to and use at locations where the activities covered are performed. 4 NLQ-63 REV. 0
- 7. Control of Purchase Material, Equioment and Services By means of documented quality control plans and supporting inspec-tion and audit procedures, provisions have been made to assure that items procured meet established quality requirements.
These include frequent and regular assessment of control measure effectiveness through review of the accumulated file of material certifications, auditings, specification compliance records, test results, inspection reports, and other documented evidence of quality attainment for each critical item. Deficient material identification, reporting and disposition proceduras also are provided. Such provisions will be extended, as appropriate, to cover cask operation, maintenance and modification activities..
NLQ-63 REV. 0 8. Identification and Control of critical Items Established quality control plans and implementing procedures include provisions for assuring identification of quality-sensitive materials, parts and components from acquisition through final application as required to prevent use of incorrect, defective or uncontrolled items where specific levels of quality are called for. These include measures for assuring that treatment during shipping, handling, storage, etc., does not impair the quality of such items and that special protective conditions as required in certain cases are documented and provided. _
NLQ-63 REV. 0 9. Control of Special Processes Where special procedures are called for to assure requisite quality (e.g. welding, radiographing, leak tes ting, etc.), requirements have been or will be established by appropriate documentation, including essential procedures and personnel qualifications. NLQ-63 REV. 0 10. Inspection Requirements for in-process and final inspection of activities affecting the quality of critical items, both purchased and fabricated, are delineated in design and procurement documenta-tion and/or in applicable quality control plans and procedures. Specification of the level and type of inspection is based on the particular conditions, e.g. material control and in-process monitoring where non-destructive testing of finished items cannot provide complete demonstration of quality. Use is made of mandatory hold points where required to assure compliance with designs and specifications. -
NLQ-63 REV. 0 11. Test Control Measures have been established for assuring that checkout and acceptance of those Spent Fuel Shipr ng Cask components and structures having safety significance are fully utilized to demon-strate attainment of requisite quality. Test requirements and acceptance limits will be defined in documented procedures which will contain provisions for assuring that tests are pro-perly performed (adequate and correctly calibrated instrumenta-tion and test devices, under suitable environmental conditions) and that test results are documented and evaluated to verify attainment of requisite quality. _
NLQ-63 REV. 0 12. Control of Measuring and Test Equipment An established tool and gage calibration which has been developed in accordance with MILSTD 120 and MIL-C-4566L assures that all test and measuring equipment has been calibrated and is accep-table for use during the inspection and testing phase of the program. NLQ-63 REV. 0 13. Handling Storage and Shipping In addition to the existing general QA procedure (General Procedure for Handling, Storage, Shipping and Preservation) specific procedures whan needed are developed and made a part of the total shipping package program. i NLQ-63 REV. 0 14. Inspection, Test and Operating Status As with procurement and fabrication quality control plans, Spent Fuel Shipping Cask pre-operational testing and equipment opera-ting procedures will establish specific measures for maintaining identification and records as to the quality status (e.g. com-pliance with inspection and test requirements) or individual components and of operating equipment. NLQ-63 REV. 0 15. Nonconforming Material, Parts or Components Established quality control plans and procedures include appro-priate measures to prevent inadvertent use of installation of material, parts or components which do not conform with approved drawings and specifications. Requirements are docuuented for identification, segregation and disposition of such items and for necessary notification and record documentation. Disposition requirements include specific procedures by which non-conforming items are to be reviewed for acceptance, rejection, rework or repair and by which ultimate disposition is to be documented. NLQ-63 REV. 0 16. Corrective Action In addition to control of defective items during procurement and fabrication, Spent Fuel Shipping Cask pre-operational testing and operating procedures will provide measures to assure that all conditions adverse to quality are promptly identified and reported to appropriate levels of management; also that the cause of the adverse condition is determined and corrected. NLQ-63 REV. 0 17. Quality Assurence Records A basic requirement of the Spent Fuel Shipping Cask Quality Assurance Program and its implementing quality control plans and procedures is to provide a documented record of quality related activities which will (a) demonstrate that the cask has been built in accordance with approved plans and specifica-tions, and (b) provide sufficient information on the quality status of the as-built cask to permit critical requirements and standards to be met or improved throughout operation, maintenance and modification (if required). This requires accumulation of quality record files for all components and structures identified as contributing to attainment of safety objectives and criteria covering each operation, tests and inspection previously identified (in established specifications, plans and procedures) as necessary for assurance of requisite quality. For effective use in program management, it is required that record documents identify the activity, the results obtained and the action taken (e.g. accepted, rejected or corrected) and provide evidence that the activity was performed and/or approved by authorized individuals. Also, provisions are included for pre-paration of reference files, for recording location of detailed data and supporting information and for retention of detailed information to meet applicable regulatory requirements. NLQ-63 REV. O 18. Audits To provide additional control of program effectiveness, procedure for independent audit and review of quality assurance activities are extensively utilized in the Quality Assurance program. Furthermore, audits will be performed to insure that activities are being performed in compliance with the appropriate regulations. Audit requirements are appropriately documented and include provisions for assuring management review of audit findings and recommendations and for implementing follow-up action where indicated. Audit indications of non-conformance with the approved QA plan form the basis for discontinuance of fabrication or operations pending resolution. -
NL INDUSTRIES, INC. NUCLEAR DIVISION Gencral Manager I N cn i Manager Nuclear Transportation Albany Plant QA/QC Engineering Procurement & Contracts Administration .? 00}}