ML19323G525
| ML19323G525 | |
| Person / Time | |
|---|---|
| Site: | 07100135 |
| Issue date: | 05/16/1980 |
| From: | Austin M BABCOCK & WILCOX CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19323G526 | List: |
| References | |
| 16373, NUDOCS 8006040054 | |
| Download: ML19323G525 (5) | |
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Transportation Branch
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Dear !*r. f'acDonald:
This refers to your March 14,19?0 lette and its enclose'i request for additional information to satisfy the applicable requirements of Appendix E to 10 CFR Part 71.
In response to this request, seven copies of Revisicn f;o. 9 of the Pennsylvania Operations' Quality Assurance Policy and Procedures f:anual cre provided as enclosures to this letter.
To facilitate your reviea of this manual, a table referencing each of your ccmments to the applicable paragraphs of the manual is provided as an attachment to this letter.
If you have any questions regarding this ' submittal, please contact either myself or i:r. Robert M. Jackman, Manager of Quality Assurance.
Sincerely, 1thMen'u Michael A. Austin Manager, Technical Control MAA/mhb Attachments 8006040 0 7 y
ATTACn:C7 Infornaticn P.eccuestad Acolicable Para. 0A-72-1 1.
Describ2 the QA rnpans cilities of each organizational 1.3.1 element ';hich falls undar the CA departr.ient (?igure 1-3).
2.
Identify the mana:ement level responsible for establishing 1.1, 1.2, 1.3.1 CL'i's Qi policies, goals, and objectives.
3.
Describe the qualification requirements for the position
- 1. 3.1. l ( d )
of.'4anagar, Quali ty fcsurance.
4.
Provide a staterent that managrent (i.e., abnve or 2.10 outside the QA organization) regularly assesses the scopa, status, imple. mentation, and effectiveness of the QA progran to assure that the program is adaquate and co~ plies with 10 C:P. Part 71, Appendix E criteria.
5.
Ocscrite the mechanism for ccm:mnicating to all Intr: duction, QA Policies, rencasible org3qization and individuals tn t quality Ite r 11 nolicies, QA manuals, and procedures are mandatory requirements.
6.
Provide a matrix of the QA procedures cross-raferenced 2.9.1, Appendix I to each criterion of Appendix E to 10 CFP Part 71.
7.
Identify the safety-related structures, systems, and 2.9.2, Appendix II components controlled by the QA program.
C.
Provide a statement that B&W reviews and documents 4.2.5.3, 7.1 agreement with the QA prograa provisions of his con-tractors to the extent that he can be assured that Appendix E will be implemented.
~9.
Describe hos disputes involving quality, arising fr'em 2.2 a difference of opinion between QA/QC perscnnel and other department (engineering, procurement, manu-facturing, etc.) personnel are resolved.
10.
Clarify that the indoctrination and training program is established such that:
a.
Personnel responsible for performing quality-2.6.2 affecting activities are instructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures.
b.
Persone.cl performing quality-affecting activities 2.6.-
are trained and qualified in the princicl2s and techniques of the activity being performed.
1
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ATTACH.'E T (Cont'd)
Information Rcquested Apolicable Para._0A-72-1 c.
The scope, the cSjective, and the mothed of implemanting 2.6.3 the indoctrination and training program are dacu rented.
d.
Proficiency of persennel performing quality-affecting 2.6.4 activities is maintained by retraining, reexamining, and/cr recerti fying, 11.
Provide a stateent that procure.mnt documnts identify tha 4.2.5.3, 4.2.5.9 00plicable 10 CFR Part 71, ApMndix E requicenents which rust be cceplied with and described in the supplier's QA program.
This QA progrn or portions thereof sh.Il be reviewed and concurred with by qualified personnel in QA orior to initiation cf activities affected by the program.
12.
P. ovide a statement tnat procurement documents identify the 4.2.5.7, 4.2.5.9, documentation (e.g., drawings, specifications, procedures, 10.2.2.1 inspaction and fabricatian plans, inspectica and test records, personnel andpectedure qualifications, and chem.ical and physical test results of material) to be prepared, maintaincd, c.d submitted to 33'.' for review and approval.
13.
Provide a statement that procurement documents identify those 4.2.5.7 records to b2 retained, controlled, and maintained by the supplier, and those delivered to BSW prior to use or installation of the hardware.
la.
Provide a statement that procurement documents contain the 4.2.5.10 B'W right of access to supplier's facilities and records for source inspection and audit.
1.5.
Provide a statement that methads for complying with,each of 5.2.6 the 18 criteria of 10 CFR Part 71, Appendix E are specified in instructions, procedures, and drawings.
16.
Provide a statement that instructions, procedures, and 5.2.2, 5.2.6 draaings include quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workmanship samples) acceatance criteria to verify that important activities have been satisfactorily accocplished.
17.
Provide a statement that documents are available at the 5.3 location where the activity will be performed prior to coc.rencing the work.
13.
Provide a statement that the results of supplier evacuaticns 7.1, 7.5.8 cec documented and filed.
19.
Drnvide a statemant that the sucalier furnishes the follouing records as a minirum to B&W:..
ATTACHIG T (Cent'd)
Taformaticn Requested Acolicable Para. 0A-72-1 c.
Docu.r.entation that identifies the purchased naterial 4.2.5.7, 7.6.1 or equipreent and the specific procurement require-ments (e.g., codes, standards, and specifications) mot by the items.
b.
Documentation that identifies any procurement require-7.6.2 r:ents uhich have not been net together with a des-cription of those nonconfccmances dispositioned " accept as is" or " repair."
ihe revies and acceptance of these dccuments shall be des-7.6.3 cribed in B2.l's QA program and as a minimum shcIl be ur.dertaken by a responsible QA individual.
20.
Provide a statement that sup. lier's certificates of con-7.5.3.5, 10.2.2 n
formance are periodically evaluated cy audits, independent inspections, or tests to assure they are valid.
21.
Provide a statement that identification requirements are S.2.1.1 detarmined during generation of specifications and design drawings.
22.
Provide a statement that the identification and control 8.2.1.2 procedures assure that identification is maintained either on the item or on records traceable to the item to preclude use of incorrect or defective items.
23.
Provide a statement that identification of materials cad 8.2.1.3 parts icportant to the function of safety-related structures, systems and cceponents can be traced to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing and inspection dccuments, deviation i
reports, and physical and chemical mill test reports.
24.
Provide a statement that the location and the method of 8.2.1.2 ider.tification do not affect the fit, function, or quality of the item being identified.
25.
Provide a statement that special processes such as welding 9.2.1, 9.2.2 and heat treating are precedurally controlled.
26.
Provide a statement that procedures, equipment, and 9.1 personnel connected with special processes are qualified in accordance with applicable codes, standards, and specifications.
27.
Provide a statement that special processes are pe d W ed
/
9.2.4 cualified :erscnnel and accomplished in accordano
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..ritten process sheets or equipment with recorded aidena cf verification.
20.
revide a statement that inspection procedtres or 10.2.1.4
'nstruc*,ians are us2d ::ith necessary drawings and 3;en #ic0:iccs e. hen cerforming inspectian operatians.
3
_ ~. _...
ATTACl!ME;T (Cont'd)
Infor.?stion Pequested Acolicable Para. QA-72-1 2D.
re:ide a statement that inspectors are qualified in cccordance 2.6, 10.2.1.5 t.i tn applicable codcs, standards, and ccmpany trainiag programs, cnd their qualifications and certifications are kept current.
30 I c"ide a statement th;t odifications, rcpairs, and replace-10.2.1.6 r.:s are inspected in cecordance with the original design and in;nction requirements or acceptsbie alternatives.
31.
I"avida a statorent that indirect control by nenitoring 7.5.1, 10.2.6 crocessing metaods, equipment, and parsconel is undertaken when direct inspac; ion is not possible.
32.
F ~avide a s tatement that special hand 1ir.g preservation, storage, 13.1 cleaning, packaging, and shipoing requirements are established ir.d acccmplished by qualified individuals in accordance with t redetermined work and inspection instructi:ns.
33.
Provide a statement that procedures ara prepared which conte:1 13.1 tha cleaning, handling, storage, packaging, shipping, and preservation of materials, components, and systems in accordance uith design and specification requirements to preclude damage, 1:ss, or deterioration by environmental conditions such as ten.perature or humidity.
3".
Provide a statement that bypassing of required inspections, 14.2.1.2 tests, and other critical operations is procedurally controlled under the cognizance of the QA organization.
35.
Provide a statement that acceptability of rework or repair of 8.2.4.7, 15.2.1.3 titerials, parts, components, systems, and structures is verified by reinspecting and retesting the item as originally t
inspected and tested or by a method which is at least equal to the original inspection and testing method.
Inspection, testing, rework, and repair procedures are documented.
36.
provide a statement that ncnconformance reports dispositioned 8.2.4.9, 15.2.2 "cccept es is" or " repair" are made part of the inspecticn records and forwarded with the hardware to S&W for review and assessment.
37.
Provide a statement that record storage facilities are con-17.2.4
- ructed, located, and secured to prevent destruction of the ret ards by fire, ficoding, thef t, and deterioration by environ. mental conditicns such as temperature or humidity.
33.
Provide a statament that deficient areas are reaudited en a 13.3 - 16(a) timely basis to verify implementatica of corrective actions which minimi:e recu-rsace of deficiencies.
33.
'rovida a state:ent tnat audits include an objective evaluation 13.3 - 7 of qualitj elated T a;; ices, ;rocedures, and instructions and tr.e eff2ctiven s; M W erantati:n.
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