ML20125E350
| ML20125E350 | |
| Person / Time | |
|---|---|
| Site: | 07100122 |
| Issue date: | 12/03/1992 |
| From: | James Shepherd J.L. SHEPHERD & ASSOCIATES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212170001 | |
| Download: ML20125E350 (38) | |
Text
-
SHE34ERC b ASSOCIATES 1010 ARROYO A\\T, BAN FERNANDO. CALIFORNIA 91MO-1822 818 @ 8-2361 FAX 818-361-80W December 3,1992 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Reference:
A Reply to a Notice of Nonconformance, Docket No. 71-0122 Per the above referenced Notice of Nonconformance, the two notice of nonconformances are addressed below.
A. 10CI'R71.113, " Document Control."
J.L Shepherd and Associates denies the alleged nonconformance, that four changes to the QA Program Plan were revised without the document revision level changing.
Response: See the enclosed QAM Revision Sheets, for all four changes.
The name change from QA Manual to QA Program Plan was at the sug-gestion of the NRC Auditors during the NRC Audit of 1/91.
T he Matrix subsection change, again was at the suggestion of the Auditors mentioned above, with revision numbers and approvals.
Ihe remaining two changes redected personnel changes in the Organiza-tion Chart, with revision numbers and approvals All changes also were documented and approvell on the QAM Revision Sheet,Iay,1.113 states that the issuance of change to documents be con e ii.
Section <
trolled by review for adequacy, approved for release and distributed to the proper location. The changes to the QA Program Plan encompass all this -
criteria. Because the changes to the QA Program Plan did not substantively change the Quality Assurance procedure content to the Plan itself, a total revision of the plan was not required. Section 71.113 does not specifically require that if a subsection change of a document is required that the entire document, instruction, etc. be revised, only that the revision is reviewed, approved and distributed, which has been done.
B. 10Cl R71.137 " Audits."
J.L She9 herd and Associates admits incompletion of alleged nonconformance, keply: As we went on.line with a new computer system, we were trying to work out " bugs" and incorporate each applicable area into the QA Pro. gram Plan, with specinc audits. We started this process, with documentation (see the enclosed Audit) but did not camp ete the process formally in accordance with our Program Plan.
Corrective Steps: we have had a Preaudit Conference (results enclosed),-
and are in the process of completing our internal audit. We will be pleased
,07o0rh, to forward reports as the Audit is completed.
A.
gjfShepherd,Fresideng ~
flh ns/mfs CC: Granch Chief, Transportation Branch, Office of Nuclear Material Safety & Safeguards (NMSS) 9212170001 921203
\\\\
\\
C p pg _ -
}
_q s'
., fs Page li
.QAM REVISION SHEET QA RM 001-A, Revision #3, Revised in Entirety 10/10/90, 3er NRC Regulatory Guide 7.10,
- Establishing Quality Assurance Programs for
)ackaging Used in the Transport of Radioactive Material", Revision 1, June 1986.
Revision #
Date Summary Page #
Approval initials
MFS #f' 8
Pageli QAM REVISION SHEET l
QA RM 001-A, Revision #3, Revised in Entirety 10/10/90, aer NRC Re 3ulatory Guide 7.10,Establishine Quality Assurance Programs for'ackaging L sed in the Transport of Radioa;f e Material", Revision 1, June 1986.
Revision #
Date Summary Page #
Approval initials
MFS
- 2, pages 2/15/91 Matrix subsections 6.0 - G.6 deleted & recombined pages5 9 into 1 section,6.0, per verbal recommendation of NRC during 1/28/91 Audit MfS
- 3, 3/5/92 Organization Chart revised l
page 2 MFS page 3.7 O. Carandang deleted, D.Tran replaced page 3.9 D. Haynes deleted MF She acting QA Program, Admin, pherd replaced as page 4.11 A. Con, van deleted, K. Thoune replaced
- 3, 8/1/92 Organization Chart revised page 3.19 J. Veilleux deleted, C. Krieger replaced MFSg 1
?
-e
l
'l.
Page 3.19 ANNEX 1,1.1 and ANNEX 2,2.1 COMBINED 4,19 loh. Description - 1. Veilleur q
Responsibilities:
i Shipping:but not limited to Operatiresponsible for all shippin arrange including installation Manuals, Ship cations and Overpack Log, ping Documents, Lea Test and External Radiation level Cer working with QA/QC and Radiological.
1 I
QA/QC Audits: participation in areas other than shipping.
3 Records Maintenance: responsibility for all shipping records and documentation, with general responsibility for all Qa/QC records.
Authority and responsibility to stop at any time, the further process on nonconfo material, work, shipment, delivery or installation until disposition thereof has been ascer-tained, and to supervise further processing of corrections.
Qualifications:
Hartford High School i
Q 1962-1980 - Hewlitt Packard office manager l
1982-1984 - Cal Prop, genera,l office 1985-1987 - IMI, general office 1987-Present -JLS&A, Shipping e
O 5
n
_