ML19263E620
| ML19263E620 | |
| Person / Time | |
|---|---|
| Site: | 07100230 |
| Issue date: | 05/10/1979 |
| From: | BABCOCK & WILCOX CO. |
| To: | |
| Shared Package | |
| ML19263E619 | List: |
| References | |
| NUDOCS 7906200515 | |
| Download: ML19263E620 (34) | |
Text
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3 I
QUALITY ASSURANCE OF SHIPPING CONTAINERS 1
2
.f 2287 002 Babcock & WJIcox Naval Nucl. ear Fuel Division Lynchburg, Va.
Revision 1
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,$'/'*7,dhN 4f~S' Signature p/
DP3826 N !
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TABLE OF CONTENTS Scetion Title i
Table of Contents 11 Introduction 1
Organization 2
Quality Assurance Program 3
Design Control 4
Procurement Document Control 5
Instructions, Procedures, and Drawings 6
Document Control 7
Control of Purchased Materials, Equipment, and Services 8
Identification and Control of Nbterials, Parts, and Components 9
Control of Special Processes 10 Inspection 11 Test Control 12 Control of Measuring and Test Equipment 13 Ilandling, Storage, and Shipping 14 Inspection, Test, and Operating Status 15 Non-Conforming bbterials, Parts, or Components 16 Corrective Action 17 Quality Assurance Records 18 Audits
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Appendix A Organization Charts A?bSO DP3827
11.
INTRODUCTION PURPOSE:
This plan defines the quality assurance program to be applied by the Naval Nuclear Fuel Division to the design, fabrication, testing, inspection, use, and repair of radioactivematerialsshippingcontainerwhicharesubjEct to the QA requirements of 10 CFR 71.
This document excludes those shipping containers constructed, maintained and used solely by/for Naval Reactors under the Department of Energy.
SCOPE:
Management policy incorporates high standards of quality not only relative to product, but also where employee and public safety is concerned.
The Quality Assurance program is established to assure that shipping containers are designed, built, and used in an orderly manner and in accordance with established criteria and regulations.
Shipments of radioactive material from NNFD are of a relatively narrow scope, and consist chiefly of:
(1) Unirradiated, high enriched fuel, samples and clad elements (2) Unirradiated scrap and waste materials or contaminated material for burial (3) Unirradiated recovered scrap (UNH crystals).
(4) Sealed B/Y emitting sources used for activations analysis, calibration, and other analytical purposes.
Consequently, radioactive material shipping containers anticipated to be used by NNED are relatively uncomplicated and the QA program has been limited to those areas where manufacturing and us~e specifications impact nuclear or radiological safety.
Due to the variability between container designa and types, no attempt is made in this plan to define applicability of specific requirements to individual 2287 004 DP3828
containers, (i.e., which components are safety related).
Such decisions will be made on a case-by-case basis by management.
DISTRIBUTION AND APPROVALS:
The following limitations will be applied to tie distribution and use of this plan:
i (1)
The plan and revisions thereto will, at a minimum, be approved by the Manager, Materials Managecent, and Manager Nuclear Materials Control.
(2) Distribution of this manual will be controlled by NMC to provide assurance that there is adequate dissemination of information and maintenance of the current version in the distribution chain.
Subsequent sections of this manual describe the implementation of the criteria specified in Appendix E of 10 CFR 71.
As noted above, individual consideration of these criteria is predicated on the importance of safety and proper use of a container and considers the level or risk involved.
Delegation of individual functions specified within this plan may be undertaken by management in accord with established policy.
2287 005 DP3329
1.0 Organization 1.1 Scope NNFD may fabricate contnir.crs internally or employ a vendar for either design or fabrication. Additional 1j, nuclear safety evaluations or other specialized functions may be delegated io consulting organizations.
This section provides, in general, the QA controls necessary to assure that final responsibility remains with NNFD as the licensee, and that individual approval and associated QA functions within NNFD maintain independence from the design, fabrication, and use functions.
~~
1.2 Personnel Qualifications Personnel reponsible for shipping container QA functions are appropriately trained and educated so as to understand and implement QA functions.
1.3 organization Implementation and maintenance of the QA program for manufacture (if appropriate), use, and repair of radioactive material shipping containers utilized shall be the responsibility of NNFD management.
NNFD organization (Appendix A)
's sur.h that the plant organizations responsible for the QA program are functionally independent and have authority to approve procedures, implement changes or corrective actions, and to terminate container use, if necessary, until improper conditions have been completed and approved.
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4 The principal responsibilities and authorities for the Quality Control Program are vested in the following positions.
1.3.1 Manager, Nuclear Materials Control The direct organizational responsibility for implementing the Quality Assurance Program lies'5:ith the Manager, Nuclear Materials Control.
He reports directly to the Fbterials Management Manager and is wholly independent of other plant operations, thus assur1.ng independence in carrying out the functions of checking, inspecting, auditing, and otherwise verifying that work has been performed satisfactorily such '
that the containers conform to applicable specifications.
Specifically, the Manager of Nuclear Materials Control is responsible for assuring the impletantation of all quality related factors.
In the Procurement of shipping containers he is responsible for assuring the Quality Control Program relating to the purchase order specifications, vendor quality assurance requirements, vendor system audits, and inspections. He is responsible for asssuring plant audits to assess the overall effectiveness of the quality program.
He is responsible for the review and approval of all vendor quality assurance programs. He has the authority to withhold from further processing or use any components, which do not meet applicable specifications.
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1.3.2 Nuclear and Radiological Safety Nuclear and Radiation Safety personnel report directly to the Manager, Nuclear Materials Control and Manager, Radiation Control and are responsible for preparing and executing procedures that control nuclear and radiological safety,
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respectively.
Typical nuclear and radiological safety respon-sibilities include: appropriate inspections, radiation surveys, proper labeling of shipping containers and vehicles, proper generation and retention of safety documentation, and the overall enforcement of health physics and nuclear safety standards.
These sections have the freedom and authority, if necessary, to terminate the use of a shipping container if the nuclear or radiological standards are not satisfied.
The Manager, Nuclear Materials Control is responsible to assure that container design and use is in compliance with
.r regulatory criteria.
In the case of new container design and fabrication, the Manager, Nuclear Materials Control will be responsible for coordinating and approving nuclear and radiological safety evaluations necessary to assure safety.
1.4 Interrelationships Interfaces within the QA program are assured through assigned responsibility and the division's policy to adhere to all requirements. Nuclear Material Control has responsibility to coordinate all such activities.
Other sections within NNFD may be assigned responsibility to design, fabricate and esercheck Quality Assurance requirements pertaining to radioactive 2L287 008 12 w DP3832
1.4 (Cont'd) shipping containers such as:
Industrial Engineering - (design), Materials and Structurals Quality Control - (vendor audits), Q.C. Inspection -
(overchecks), Radiation Control - (radiation safety), Nuclear Materials Control Accountability - (use), and NMC Nuclear Safety and Licensing, i~
(auclear safety and licensing compliance criteria).
Other sections /de-partments interface as needs dictate.
2.0 Quality Assurance Program 2.1 Scope The QA program, as described in this plan applies to nuclear and radiological safety consideration involved with packaging and trans-port of radioactive material. This program is established and approved by management with future revisions requiring equivalent approval.
Implementing procedures and subsequent revisions are also approved in writing by division management.
The fact thatallrequire[ents of this program are mandatory is communicated to all responsible organizations and individuals.
Functional organizations with primary responsibility for implementing and accomplishing this QA program are as follows:
Nuclear Materials Control is responsible in areas generally involving nuclear or radiological safety evaluations, licensing new or modified containers, (including design coordination and approval in safety related areas), preparation of oper-tional procedures 'and checklists for container inspection to assure compliance with certificates, and other regulatory criteria as well as overall coordination and resolution of disputes involving quality.
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2.1 (Cont'd)
Quality Control / Materials Management Section is responsible in areas involving initial and "in-use" container inspections.
verification that containers are tubricated in accordance with approved specifications, appli,qation of appropriate QC procedures relative to material control / traceability, and vendor QA programs and audits.
As shown in Section 1, both Quality Control and Material Management organizations report independently to the Division Vice President.
In addition to the above, shipping containers "in use" may, on occasion, be inspected by other NNFD organizations for routine "in use" inspection (such as Manufacturing).
In these cases, the inspection shall be conducted only in accorance with written procedures or checklists approved by Nuclear Materials Control or QC management and the resulting inspection data will be for-warded to NMC for review and retention.
2.2 Requirements The Quality Assurance program will contain the following elements:
2.2.1 Personnel training, retraining and familiarization with QA, QC and regulatory requirements as defined by management to assure effective control and compliance.
2.2.2 Audits of the QA program to assure continuing compliance with its provisions and intent.
~
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2.2.3 Designation, through procedures, or equally c fective means, of the responsibilities for operating the QA program.
2.2.4 Requirements for the approval of procedures, manuals, design specifications, and other documents affecting safety or regulatory compliance.
2.2.5 Identification, based on the specific container involved, of safety relative criteria.
Typically, these may include but are not limited to:
- Structural requirements for maintenance of geometric controls or container integrity.
- Neutron absorbants.
- Radiation shielding.
2.2.6 Procedures and controls shall be maintained, as appropriate, by vendor or consulting organizations and are applied as intended.
2.2.7 Quality related activities are performed with specified equipment under suitable environmental conditions and prerequisites identified prior to inspection or testing.
3.0 Design Control 3.1 Scope This section describes the system by means of which effective control is exercised throughout the design of new or modified containers.
2287 0ii ine DP3835
3.2 Responsibility Responsibility for design control as related to interpretation of regulatory criteria and nuclear / radiological safety is the responsibility of the Manager, Nuclear Materials Control.
The Manager, NMC will coordincte all nuclear, radiological, and licensing aspects.
In case of disagraerant in these areca, the position of the Manager, ::MC will prevail.
3.3 Procedure The design control program will include provision for the following:
3.3.1 Independent verification of nuclear or radiological safety calculations.
3.3.2 Design review and written approval of drawings and specifications prior to release for fabrication, by individuals independent of designs.
3.3.3 The review shall consider the following as appropriate:
3.3.3.1 Adequacy of calculations.
3.3.3.2 Compliance with applicable provisions of the Code of Federal Regulations.
3.3.3.3 Accident evaluations.
3.3.3.4 Inspection, maintenance, and repair criteria.
3.3.3.5 Structural design, construction materials, and purchased parts as related to the maintenance of safety.
3.3.4 Proposed modifications or revisiods affecting safety will be reviewed and approved by the Manager, NMC.
3.3.5 A prototype will be tested under design conditions when a new container is proposed for construction.
This is not required if a proven design exists.
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3.3 (Cont'd) 3.3.5.1 When proposed design changes may affect safety limitations or controls, design review criteria equivalent to that described above will be implemented.
3.4 The following activities will be docunanted in writing:
3./.1 Detailed nuclear and radiological evaluations and acceptance thereof.
3.4.2 Specific safety criteria upon which container design is based.
3.4.3 Results of final design evaluations, identification of "probler.s", or quaationable areas and their resolution,-
4.0 Procurement Document Control 4.1 Scope This section describes the method for controling all requirements relative to nuclear / radiological safety and container stractural integrity are suitably included or referenced in documeats used to procure materials, components, and services.
Proceduces shall be established to assure that procurement documents art approved by NMC prior to issuance and incorporate applicabic 10 CF A part 71 requirements.
4.2 Requirements 4.2.1 Technical and quality requirements arc. normally contained in the applicable drawings and specifications.
- However, technical requirements can be supple:nented or defined complete-ly by supplementary documents.
Supplementary documents shall not modify design or functional requirementa as specified by the applicable drawing or specification.
2287 013 As ~ ~,. u a,.
9 r DP3837
4.3 Purchasing Procedure 4.3.1 NMC shall prepare a Technical Package for transmittal to the Materials Engineering section far inclusion of appropriate Procurement Control documents and their disposition. The requisition shall denote all of the technical and quality requirements.
4.3.2 The Purchasing Section shall prepare a purchase order for transmittal to an approved vendor from the information contained in the purchase requirition.
The purchase order will be checked to verify that the technical and quality requirements in this procurement document are sat 3sfactory. Any chaages are subject to the saae review and approval as the original documents.
4.3.3 In general, the major purchased materials, components, and services will ae procured only from vendors who have been evaluated fo; acceptability with respect to manufacturing and/or
.r technical capability.
Vendor quality assurance programs may or may not be applicable since the shipping containers used by NNFD consist of standard off-shelf items.
Procurement documeats will contain the right for NNFD to have access to venders records etc. for inspection and audit purposes.
5.0 Instructions, Proc 2dures, & Drawings 5.1 Scope Effective :ontrol of fabrication and use of radioactive material shipping containers necessitates the use of approved written procedures and equivalent documentation such as drawings, and specifications.
This sectic.n provides general criteria for the content and proper use of such procedures anu auings.
22187 0l4 Dr3838
5.2 Requirements 5.2.1 Procedures or drawings, as applicable, will be used by the followin,t QA related activities and be approved by QC and other organizations performina QA Junctioao; 5.2.1.1 In-house fabrication of sl ipping containers or compon-ents (if applicable).
5.2.1.2 Qualification testing of containers or components.
5.2.1.3' Inspection and audit of fabrication activities.
5.2.1.4 Audit of shipping container QA program.
5.2.1.5 Routine in-use inspection of shipping containers.
5.2.2 Procedures, instructions, and drawings will contain sufficient information relating to regulatory requirements, specifications, and acceptance criteria to allow complete and effective applica-tion by user personnel.
Existing systems provide detailed re-quirements for the content and organization of procedures such that format standardization assures comprehensive coverage, logical sequencing, and appropriate approvals.
6.0 Document Control 6.1 Scope The control of instructions, procedures, or drawings is the responsibility of the originating unit.
This section describes the system whereby such documents which relate to QA, are maintained in a current status (by use of a plan list) and are properly approved and distributed (including available documentation at the work location prior to work commencing).
6.2 Requirements 6.2.1 Prior to issue, design specifications, construction drawings, procurement documents, and design change requests will be 2287 015 r< ~m DP3839
6.2.1 (Cont'd) approved by the Manager o f N:tC.
Prior t'o approval, responsible managers will take necessary steps to assure themselves that the docunent is correct end, if applicable, that proposed revisions do not alter safety criteria.
6.2.2 The shipping container QA plan and revisions thereto will be aparoved by the Manager Materials Management, Manager NMC and Manager M&SQC.
6.~.3 Operating instructions and procedures will be approved by the Manager of the originating section.
6.2.4 Non-conforming findings are reported to NMC for review. Any non-conforming findings will be dispositioned by consultations with appropriate design or operating personnel. Non-conformance reports and subsequent actions shall be documented.
Containers in a non-conformance status will be identified and withheld from use or further fabrication until resolution is obtained. '
6.2.5 The section assigned responsibility for preparing a document is also responsible for obtaining the required approvals, controlling the distribution, initiating modifications as required. Assuring that superseded pages are removed from the revised document, is the responsibility of the recipient.
6.2.5.1 The originating section shall be responsible for transmitting to individuals / sections those documents for which they have sole responsibility of maintaining.
22187 016 DP3840
6.2.5.2 The section responsible for originating the document is also responsible for assuring that changes to documents have the same reviewing and approval authority as the original issue.
6.2.5.3 vace received, it then becomes the responsibility of the document recipient to distribute the new or revised document and to remove and destroy obsolete documents.
(Files wherein outdated documents, spe-m cifications, and drawings are retained for historical purposes are exempt from thie requirement.)
7.0 Control of Purchased Material, Equipment, and Services 7.1 Scope To assure that purchased material, equipment and services conform to purchase specifications, specific evaluations of vendor capabilities consistent with the importance, complexity, and quantity of the product or services,are made by qualified personnel.
This is accomplished through vendor evaluations (ability to comply with request and past performance) and inspection of the product received.
The results of these reviews is documented and filed.
7.2 Requirements 7.2.1 Prior to procurement of items considered as critical to safety, an evaluation may be made of the vendor's facilities.
7.2.2 Vendors supplying material, components, or services may be audited during periods of procurement or fabrication activities in accordance with procedures for the purpose of ensuring that quality requirement 5 are being met and maintained.
The audits will be conducted in accordance with a planned agenda covering vendor operations such as inspection activities, etc., as specified by the applicable Quality Control Requirement.
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7.2.3 As deemed necessary, NNFD n:ty elect to perfonn inspection at supplier's plant wherever:
7.2.3.1 Inspection of the vandor's facility before fabrication is commenced is desired.
7.2.3.2 First-piece inspection at the supplier's facility is desired.
7.2.3.3 At the discretion of the Manager, NMC, Materials Engineering and Materials & Structural Quality Control.
7.2.4 Incoming materials and components will undergo a receiving in-spection prior to release of such items for use.
These in-spections shall be in accordance with procedures and instructions appropriate to the type of test or inspection applicable to the item.
The test results are available prior to release and judgements made to acceptability and proper identification.
7.2.4.1 Concurrent with the receipt inspections, all docu-mentation which the vendor is required to submit (reguirements met or not met) shall be reviewed for completeness and for compliance with applicable drawings and specifications.
7.2.4.2 Items which have been determined to comply with the receiving inspection and documentation requirements shall be released for use.
7.2.5 Results of audits and any follow-up activities shall be retained on file.
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t~s a DP3842
8.0 Identification and Control of Materials, Parts, and Components 8.1 Scope This section describes the techniques used to identify the control radioactive material shipping containers, materials, parte, or components where fabrication in at the NNFD, to provide traceability and to ausure that only acceptable parts are utilized in the fabrication of radioactive material shipping containers for the case where sp_cification of these parts or materials is based on safety or licensing requirements.
8.2 Requirements 8.2.1 Incoming Material, Parts, and Components 8.2.1.1 The NMC Section is responsible for the receipt inspection of all incoming radioactive material shipping containers and material, parts, and components.
8.2.1.2 The results of inspection shall be reviewed along with the vendor certification of physical, chemical, non-destructive testing, and dimensional inspection as specified in the purchase order for compliance with the applicable specifications and drawings.
- 8. 2.1. 3 Upon completion of all required inspections and certifiations, NMC shall be advised as to the acceptability of the material or components in question.
Non-conforming parts, materials, and components will be handled as described in Section 15 of this plan.
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8.3 Traceability 8.3.1 The program used to control and identify material and components is based on unit traceability.
8.3.1.1 All sub-conponents which are identi' led with a serial number or other specific identifier shall be subject to unit traceability.
8.4 Inspection Completed components are withheld from use until the following actions have been completed:
8.4.1 All inspections have been completed'and the results of these,
inspections have been reviewed for compliance with applicable specifications and drawings.
8.4.2 All documentation has been verified for completeness and accuracy.
R.4.3 Prior to a shipping container's first use, all necessary' safety, nuclear and radiological inspections must be completed and documented by the responsible group before being released for use.
8.5 Non-Conforming Conditions 8.5.1 The non-conforming containers shall not be used until:
8.5.1.1 The nonconforming condition or item has been repaired, replaced, or reworked in accordance with approved procedures to restore it to the design specification and/or drawing requirements 8.5.1.2 The non-conforming condition has been approved by NMC.
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9.0 Control of ' Special Processes 9.1 Scope This section is not applicable since CFD uses of f-the-shelf c ate rial to fabricate shipping containers and no special processes are used.
10.0 jaspection 10.1 Scope The inspection program is conducted in accordance with standards and doct1ented procedures which incorporate the quality requirements defined in applicable specifications and drawings.
The procedures encompass necessary inspections which establish minimum requirements for acceptance on both original and replacement parts, etc.
Inspection personnel are independent from individuals performing the activity being interpreted and are kept current as to training and qualification.
10.2 Requirements 10.2.1 Source or Receiving Inspection All purchased items which effect safety of the final shipping container shall be either source or receipt inspected under an approved E6W procedure.
Such inspection shall consist of the following:
10.2.1.1 Review of vendor certification and test reports to ascertain conformance with requirements.
10.2.1.2 Receipt inspection sampling, when needed, shall be in accordance with MIL-STD-105D or an approval alternate plan consistent with the requirements.
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10.2.1.3 Any non-conforming componen".s shall be processed per Section 15 of this tanua.., "Non-conforcing Materials, Parts, or Components." Non-conforming components shall not be released until the defective condition is either corrected or the deviation is accepted in 'the reanner outlined in Section 15.
10.2.1.4 Parts shall also be inspected for proper identification, and other applicable requirements.
10.2.1.5 Following the receipt inspection and satisfactory review of all necessary reports and subsequent verification that the material or parts are acceptable, formal acceptance shall be made as defined in Section 8 of this plan.
10.2.1.6 The NMC Section shall be responsible for decisions affecting B&W acceptance of parts, except in th6se instances where Section 15 of this plan applies.
10.2.2 Final Inspection Final inspection shall be performed on completed components prior to use in the following manner:
10.2.2.1 Components shall be inspected in accordance with inspection procedures which assure verification of all specified quality requirements.
10.2.2.2 All as-built dimensions shall be compiled and forwarded to the cbgnizant design group as required by specifica-tions.
10.2.2.3 All acceptable components shall be released for further processing upon completion of final inspection.
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10.2.2.4 All deviated components shall be treated in accordance wLth Section 15 of this manual.
10.2.2.5 All final inspection data shall be nalntained and stored as defined in Section 17 of this manual.
10.3 Overinspection If witness or mandatory hold points are listed in the documents as a condition of release for further fabrication, such points shall be included in the inspection process outline.
The cognizant designer or procurement group shall be notified as required to allow the cognizant agency to perform the specified surveillance.
11.0 Test Control 11.1 Scope Components manufactured at or for NNFD are inspected for compliance with design specifications and drawings by one or a combination of the following techniques:
11.1.1 Various methods of metrology to verify dimensional requirements.
11.1.2 Verification of mechanical properties and/or chemical requirements to meet material requirements.
11.1.3 Additionally, a program shall be maintained to assure that all testing activities affecting quality and serviceability of nuclear material shipping containers are identified and performed in accordance with approved procedures.
These testing activities include but are not necessarily limited to tests which are performed on new shipping container designs which evaluate their specified durability and integrity.
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( - J v._
DP3847
11.2 Requirements 11.2.1 Testing 11.2.1.1 Any prerequisites that are essential for the proper execution of a given test will be outlined in the appropriate procedures.
Acceptance criteria shal.
be incorporated in test procedures for both original and replacement parts, etc.
11.2.1.2 Adequate test instrumentation will be available and used as required in procedure.
11.2.le3 Tests will be performed under conditions which yield representative test results as stated in procedures and as required by applicable regulations.
11.3 Documentation Essential testing performed by the designer, fabrication vendor and/or NNFD will be documented and a final evaluation shall be performed by. NMC to assure that all test requirements have been satisfied.
12.0 Control of Measuring and Test Equipment 12.1 Scope This section sets forth measures in effect to assure that all measuring and test equipment used in activities affecting quality and safety are properly controlled, calibrated and adjusted to maintain accuracy within required limits.
It is the responsibility of responsible sections and Ni4C to assure that proper procedures are followed for active gages, meas-uring devices, and inspection, fixtures under their respective control.
2287 024 DP3848
12.2 Requirements - Ouality Control Equipment 12.2.1 New or Reworked Equipment 12.2.1.1 When applicable, inspectio, equipment used for quality verification shall be initially calibrated against available knowa standards traceable to the National Bureau of Standards.
12.2.1.2 Inspection equipment for which standards traceable to the National Bureau of Standards are not available will utilize manufacturer's certificate of accuracy.
12.3 Storage of Equipment 12.3.1 When equipment must remain permanently in work area, adequate means for its protection and cleanliness will be provided within the limits of work requirements.
12.3.2 Any gage to be repaired will be removed from service and controlled until repair and recalibration has been complete.
12.4 Periodic Inspection of Equipment 12.4.1 All inspection gages shall be examined, calibrated, and/or serviced at scheduled intervals specified in applicable procedures by personnel who are specifically charged with the responsibility of maintaining accurate gage and related records.
12.4.2 Additional gage inspection shall be made when there is evidence of excessive wear, suspected, or actual instrument damage.
12.4.3 The inspector, when'using relatively simple gages such as micrometers, which can be readily checked for accuracy, shall check them with known standards during the usage of such gages.
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12.4.4 Any gage or equipment utilized in the inspection process which exceeds the established calibration accuracy limits shall be subject to the following action:
(a)
Removal from service and stored in an appropriate detention area.
c-(b)
Deternine disposition of the gage, i.e.,
- rework, recalibrate or scrap and replace.
(c) Reuorked gages shall be recalibrated prior to return to service.
12.4.4.1 All components measured with a gage or equipment that had exceeded the established calibration accuracy limits shall be reinspected with correctly calibrated equipment.
12.5 Requirements - Radiation Monitoring Equipment 12.5.1 Radiation Survey and Analysis Equipnent Equipment falling into this category shall be calibrated and maintained as specified by SMN-42.
13.0 Handling, Storage, and Shipping 13.1 Scope This section sets forth measures for preventing damage or deterioration during packagirg, s lpping, and storage of shipping containers.
It is the responsibility of all operating sections to follow procedures which will establish the methods and techniques which are to be followed to prevent damage.
Specifically, NMC shall verify that the shipping containers and associated parts are adequately protected in accordance with procedures listed below.
221B7 026 DP3850
13.2 Requirements General 13.2.1 All assembly operations shall be carried out in an area adequate which permits the attainment of the appropriate cleanliness standards.
13.2.2 Prior to each use, shipping containers are inspected for compliance with applicable regulatory controls includi ng certificates of compliance and the Code of Federal Regulations.
13.2.3 Movement of a package / con:ainer will be accounted for to a degree consistent with the safe transportation of the package /
container. All applicuble shipping papers will be completed as required.
14.0 Inspection, Tett, and Operating Status 14.1 Scope This section sets forth measures for ascertaining the status of inspections and tests performed on shipping container.
14.2 Requirements The status of inspection operations for components which are to be supplied to or used shall be documented in the following manner:
14.2.1 New Container Inspection 14.2.1.1 Receiving inspection on incoming containers shall be performed in accordance with appreved procedures.
If these items are found to be acceptable, appropriate documentation shall be generated to indicate acceptability.
14.2.1.2 Any items determined to be non-conforming shall have a " Hold" tag attached to the item.
If the assessment of the non-conforming condition establishes that rework is permissible, a " Rework Required" tag shall 2287 027 be attached to the item.
DP3851
14.2.1.3 Any item deeted to be unacceptable and not subject to rework or repair shall have a " Reject" tag attached to 4.t and shall be segregated f rom conforming units to await final disposition.
14.2.2 Final Inspection 14.2.2.1 Containerswhichhavecomp5etedthefinalinspection operation shall have an " Inspection Complete" tag attached by the Inspection Group.
This tag will indicate that all inspection operations are complete.
The tag may be removed when container is placed in service.
If rework is necessary, a " Rework Requireb" tag shall be attached.
14.2.2.2 Under no circumstances shall a non-conforming part or container which has been processed through final inspection be used until the discrepant conditipn has
~~
been corrected.
14.2.3 In-Use Inspection 14.2.3.1 In-use inspection shall be performed under the auspices of NMC in accordance with approved procedures.
14.2.3.2 Any item or component found to be non-conforming during in-use inspection shall have a " Hold" tag attached t_
it indicating a deviation which may require a repair, rework, rej ect, or use as is dispositioned.
14.2.3.2.1 If rework is required, a " Rework Required" tag shall be attached.
14.2.3.2.2 Any component classified as reject shall have a " Reject" tag attached to it and shall be processed per paragraph 14.2.1.3.
,,-c.,
DP3852
15.0 Non-Conforming Materials, Parts, or Components 15.1 Scope This section sets forth the measuro t.M a to centrol shipping cantainers s
or parts which do not c.;uform to requirements to prevent subs-quent use until the non-cenforming condition is corrected.
It is tho responsibility of NMC to assure that the following requirements are fulfilled on non-con-forming units.
15.2 Requirements General 15.2.1 All non-conforming parts / containers shall be documented.
15.2.2 All non-conforming components shall be separated from conforming components and identified (tagged, marked) as being non-conforming.
15.2.3 Sufficient data shall accompany the non-conforming part/ container to identify the non-conforming condition.
(Such data is not required for any part or container which will be scrapped []
15.2.4 NMC shall recommend the disposition of the non-conforming parts /
containers.
15.3 Disposition of Non-Conforming parts 15.3.1 Items which are identified to be non-conforming at receiving or "in use" shall be properly documented as such.
15.3.2 NMC shall review the completed documentation and recommend disposition.
15.4 Repair of Non-Conforming Components 15.4.1 Af ter the repair has been completed, the component shall be inspected for conformance to the original applicable design criteria.
2287 029 DP3853
15.5 Keject or Non-Conforming Cornonentg 15.5.1 Material and components which have been rej ected shall be tagged and placed on hold.
16.0 Corrective Action 16.1 Scope This section sets forth neasures for assuring conditions adverse to quality in safety related areas such as defective material, non-conformances to design specifications and drawings, deficiencies, and non-compliance with approved procedures are promptly identified and corrected.
It shall be the responsibility of the NMC Section to brin'g to the attention of management any condition adverse to quality and to verify that appropriate corrective actions have been taken to preclude its repetition.
16.2 Requirements Review of Non-Conforming Conditions 16.2.1 A review of non-conforming conditions shall be conducted' period-ically.
16.2.2 The purpose of this review shall be to analyze the deviated conditions for chronic recurrence, determination of cause, and to recommend the corrective action to be implemented. Also.
previously identified corrective actions will be followed up to ascertain the status and effectiveness of the measures taken.
16.2.3 NMC shall be responsible for documenting the resulks along with the corrective action taken on each identified item.
- Also, included shall be the follow-up performed on previously identified corrective actions.
16.2.4 The Manager, NMC shall review the results.
2287 030 DP3854
16.3 Operational Reviews 16.3.1 Findings shall be brought to the immediate attention of management to:
16.3.2.1 Determine if use of the container should be t e rmina t ed.
16.3.2.2 Assess the risk involved with continued use.
16.3.2.3 Establish appropriate corrective actions and means for implementation.
17.0 Quality Assurance Records 17.1 Scope This section sets forth measures for the preparfmg and maintaining Quality Assurance records.
It is the responsibility of the NMC Section to assure that adequate tests and inspection records are maintained for verifying compliance with the provisions of this QA program.
17.2 Requirements 17.2.1 Inspection forms, test report, and other pertinent reco'r'ds shall be completed by personnel assigned the responsibility to perform such inspections and tests.
17.2.2 Inspection forms, test reports, and records shall indicate any deviation from requirements of Section 15 of this manual.
17.2.3 NNFD shall retain Quality Assurance records from a container's first use shipment to its removal from use as a minimum.
After this period, the necessity for longer storage of these records shall be reviewed.
Final disposition of these records shall be contingent on management ccacurrence that they are no longer required.
2287 031 DP3855
18.0 Audits 18.1 Scope This section sett, f o rt h audit p ror, ram 4, both Internal and supplier.
Internal audits will be perf or ed to veri f y coupliance with the Quality As:,ucance Program and to de t e mine the overall +ffectiveness of the p ro r, ra n'.
Supplier audits raay be perforc.2d to monitor qualit y programs in ef f ect at vendor facility while thny are supplying material or components to current porchase orders (depending upon need.) The audits will be conducted by personnel who have experience or training in auditing and will use a checklist and/or other appropriate audit forms.
NMC has responsibility to assure proper administration of the audit program as outlined below.
18.2 Requirements 18.2.1 Audits are performed in accordance with pre-established written procedures or check lists and conducted by personnel not having direct responsibilities in the area being audited.
8.2.2 Audit results are documented and then reviewed with management having responsibility in the area audited.
Necessary action is then taken to correct the deficiencies.
18.2.3 Re-audits are routinely scheduled to verify implementation of corrective actions which minimize recurrence of deficiencies.
18.2.4 Audits are performed at least annually on safety significance of the activity being audited.
2287 032 DP3856
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