ML19305C553
| ML19305C553 | |
| Person / Time | |
|---|---|
| Site: | 07100244 |
| Issue date: | 02/14/1980 |
| From: | Dixon G NL CHEMICALS (USA), INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19305C554 | List: |
| References | |
| 15554, NUDOCS 8003310044 | |
| Download: ML19305C553 (4) | |
Text
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$Y.",. $$Do8 February 14, 1980 Mr. Charles E. MacDonald Chief, Transportation Certification Branch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Subj ect:
Quality Assurance Program 10 CFR 71 Appendix "E
Reference:
Your letter dated August 29, 1979 Gentlemen:
NL Industries herewith responds to the questions and/or comments posed in the above referenced letter as follows:
4 Comment 1.
The QA/QC Manager of NL's Nuclear Transportation Department is responsible for establishing QA policies, goals and objectives (See revised Section 1, Organization, Page 8).
Comment 2.
As a minimum, the QA/QC Manager shall have five years experience in the field of Quality Assurance / Control.
There will be no specific qualification program for this position.
Comment 3.
See revised Section 2, Quality Assurance Program, Page 9.
Comment 4.
See revised Section 1, Organization, Page 8.
Comment 5.
The QA Manager reports to the Manager of Nuclear Transportation, but has the freedom to go directly to the General Manager should the need arise.
Organization chart revised to show dotted line from QA/QC Manager to General Manager.
Nuclear Division /NL Industries, Inc.
Foot of Wes' Street, Wilmington, Del.19801 Tel. (302) 656-1661 l
15554 8003 31Q
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e-Nuclear Regulatory Commission February 14, 1980 Page Four J
I Comments 88 through 91.
NL considers Section 17, Quality i
l Assurance Records, as now written to meet your comments 88 through 91 and the requirements of Appendix E.
Comments 92 through 100. See Revised Section 18, Audits.
1 i
l Please direct all future correspondence to the utdersigned.
Very truly yours, i
Geo N. D xon, Jr.
QA/QC Manager
/ljh Enclosure 4
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Nuclear Regulatory Commission February 14, 1980 Page two Comment 6.
See revised Section 18, Audits, Page 25.
Comment 7.
See answer to Question 1.
Comment 8.
See revised Introduction on Page 7.
Comment 9.
Refer to Introduction and Sections 1 and 2 of the QA Program Plan.
Comment 10. Refer to Section 1, Organization.
Comment 11. Refer to Section 2, Quality Assurance Program.
NL has stated that the program vill include procedures for quali-fication and indoctrination of personnel.
Comments (a) through (d) are specifics of those procedures.
Comment 12. Refer to Sections 1, 2 and 3 of the QA Program.
Comment 13. Refer to Section 3, Design Control.
NL already states that " 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" etc.
Comments 14, 15, 16, 17, 18 and 19.
Refer to Section 3, Design Control.
Comment 20. NL feels that this question has been addressed ade-quately in the Introduction Section of the Quality Assurance Program.
Comments 21 through 30.
See revised Section 4, Procurement Document Control.
Comment 31. See revised Section 6, Document Control.
Comment 32. NL considers that this program as submitted in total addresses the 18 point criteria. -
Comment 33. See revised Section 5, Instructions, Procedures and Drawings.
Comment 34. NL does not consider this comment to be an accurate interpretation of the requirements of Section 5 of Appendix "E".
However, we feel that the Introduction Section of this QA plan does adequately address this question.
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o-Nuclear Regulatory Commission February 14, 1980 Page Three Comments 35, 36, 37, 38 and 40. See revised Section 6, Document Control.
Comment 39. The written procedure made reference to in Section 6, Document Control, specifically delineates the detailed controls 2
to be used to assure that only the current approved documents are used.
This procedure also provides a comp.lete history of the document beginning from original issue.
Comments 41 through 47.
See revised Section 7, Control of Pur-chased Material, Equipment and Services.
Comments 48 through 53.
See revised Section 8, Identification and Control of Materials Parts and Components.
Comments 54 through 57.
See revised Section 9, Control of Special Processes.
i Comments 58, 59, 60, 61 and 63.
See revised Section 10, Inspec-tion.
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Comment 62. Refer to Section 2 of this Program (Quality Assurance Program) and NL's response to Comment 11.
Comment 64. See revised Section 11, Test Control.
t comment 65. NL considers this comment to be appropriately address-ed in Section 11 as originally written.
Comments 66 through 73.
NL considers that Section 12 as now written is acceptable in that we have stated a Tool & Gage Cali-bration Procedure has been developed in accordance with MIL-STD-120 and MIL C-45662 both of which cover all of the attributes which are listed in your Comments 66 through 73.
Comments 74 and 75.
See revised Section 13, Handling, Storage and Shipping.
Comments 76, 77 and 78.
See revised Section 14, Inspection, Test and Operating Status.
Comments 79 through 84.
See Section 15, Nonconforming Material, Parts or Components.
Comment 85. See revised Section 15, Nonconforming Material, Parts or Components.
Comments 86 and 87.
It is NL's opinion that these comments are covered in Section 16, Corrective Action, as previously sub-mitted.
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