ML20044A685
| ML20044A685 | |
| Person / Time | |
|---|---|
| Site: | 07100102 |
| Issue date: | 06/26/1990 |
| From: | Dicharry R SOURCE PRODUCTION & EQUIPMENT CO., INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9007020057 | |
| Download: ML20044A685 (3) | |
Text
Y O
i June 26, 1990 i
Mr. Charles E. MacDonald, Chief Transportation Branch Division of Safeguards and Transportation, NMSS U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dear Mr. MacDonald RE: Docket 71-0102 Notice of Nonconformance The following items are in response to the April 27, 1990 alleged items of nonconformance.
- 1. 10 CPR 71.103 requires that authority and duties of persons and organizations performing activities affecting safety-related functions must be clearly established and delineated in writing.
The NRC alleges that contrary to the
- above, responsibility for reviewing changes / additions, to the Quality Assurance (QA) Manual to determine if they affect the QA Program commitment, was not designated and procedures for determining whether an amendment to the QA Program did not exist.
Response
Chapter 5.0 Instructions, Procedures and Drawings, specifies that the President shall review and evaluate all instructions, procedures and drawings and he will document his approval on the Engineering Change Evaluation Record (Form QA 5.1) or the Procedure, Instruction and Special Process Docament Change Evaluation Record (Form QA 5.2).
Form QA 5.,1 and Form QA 5.2 have been revised effective 1/12/90 adding a
statement to be signed by the President that the change is consistent with the approved QA program.
This verification is made af ter the President has reviewed the applicable sections of the QA Program.
- 2. 10 CPR 71.113 requires that measures. be established to control the issuance of documents such as instructions, procedures, and
- drawings, including
- changes, which prescribe all activities affecting quality.
Contrary to the above, the NRC alleges SPEC Procedure QAM 9007020057 900626 t)
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C PDC Source Production & Equipment Co., Inc.
. iis T i street st. none, LA roos 74e91 Phone 504/4%9471 Telex 400154 FAX S04/447 7646
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@~0 Mr. Charles E. MacDonald June 26, 1990 Page 2 i
10.0 and 13.0 are not adequate.
It is further alleged l
that there are no provisions to measure radiation, levels on incoming radioactive packages and record the results on checklist Form No. QA 10.3 and to record safety checks l
on Checklist Form No. QA 13.1.
1
Response
Chapter 10.0 of the Quality Assurance Manual covers fabrication and assembly inspection of radioactive materials packages.
This Chapter is not intended to l
serve as a
requirement for receipt inspection of radioactive material packages.
Form QA 10.3 is the final inspection checklist and survey for SPEC 2-T devices and is neither utilized as nor intended to be a receipt inspection checklist.
Radiation levels on incoming radioactive material packages are recorded on Form QA 13.2 as required by Chapter 13.0 Section C.4 of the QA Manual.
Form QA 13.2 also provides blanks and check areas for the incoming physical damage inspection i
required by the SAR Chapter 7.
The safety checks required by the SAR Chapter 7 and 49 CFR 173.475 are recorded in Section V of the Radioactive Material Package Shipping Preparation Checklist Form QA 13.1 in use at the time of the inspection.
Source Production and Equipment Company, Inc.
believes action is not required to be in compliance with 10 CPR i
71.113.
l
- 3. 10 CPR 71.121 requires that inspections must be performed by individuals other than those who performed the activity being inspected.
l Contrary to the above, the NRC alleges the QA/ Production Manager is performing and inspecting safety related activities.
l
Response
The QA/ Production Manager does survey the.
depleted uranium castings and performs the computatious to determine if the.
resulting.
dose rates are satisfactory.
Form QA 11.1 was designed for -
an i
individual' other than the person performing.the survey l
and calculations to review and check the. report.
Erroneously the QA/ Production Manager ~ had also been signing the approval.
This practice has been changed.
l and an independent party such as the President will-review and sign the report.
Recently the. f unctions of Source Production & Equipment Co., Inc.
113 Teal Street St. Rose, LA 70087 9691 Phone 504/464 9471 Teles 440156 FAX 804/447 7646
@~v0 Mr. Charles E. MacDonald June 26, 1990 Page 3 1
l the QA Manager and the Production Manager have been separated and they are now perform by two individuals.
i
- 4. 10 CFR 71.125 requires that testing devices used in activities affecting quality be properly controlled, calibrated and adjusted at speci'ted times, to maintain accuracy within limits.
Contrary to the above, the NRC alleges there was no documentation to identify the calibration frequency for the inside and outside calipers used to measure the seam thermal metrl joining process.
created by the a
Responset Source Produr, tion and Equipment Company, Inc.
has obtained me a s u r e'.n e n t standards to confirm the accuracy of calipers used for Quality Assurance measurements.
Chapter 12 of the Quality Assurance Manual Control of Measuring and Test Equipment, has been i
revised to include., a requirement for annual calibration of calipers used for Quality Assurance measurement of the undercut created by the thermal metal joining process.
Please contact me if additional information or clarification is required, i
Sin r.s ky,
/
/C 70v R.D.DonnyDicharry; President
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Source Production & Equipment Co., Inc.
113 Teal Street St. Rose, LA 70047 M91 Phone 504/464-9471 Telex 4M154 FAX SO4/467 7M6 '