ML20149J188
| ML20149J188 | |
| Person / Time | |
|---|---|
| Site: | 07100102 |
| Issue date: | 07/18/1997 |
| From: | Dicharry R SOURCE PRODUCTION & EQUIPMENT CO., INC. |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20149J191 | List: |
| References | |
| CAL-97-7-06, CAL-97-7-6, NUDOCS 9707280105 | |
| Download: ML20149J188 (2) | |
Text
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July 18,1997 Carl J. Paperiello, Director Office of Nuclear Materials Safety an.1 Safeguards U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Reference:
ConGrmatory Action Letter No. 97-7-006, dated June 24,1997.
SPEC QA Procedure 97-01, Revision (0), dated July 14,1997.
NRC Letter from Carl J. Paperiello dated July 15,1997.
Docket Number 71-0102.
i
Dear Mr. Paperiello:
1 This is in response to your letter dated July 15,1997, which is in regard to ConSrmatory Action Letter No. 97-7-006, dated June 24,1997. I hereby certify that the activities and corrective actions specified in SPEC QA Procedure 97-01, Revision (0), dated July 14,1997, titled " Phase I of Corrective Action Implementation Plan,"
have been completed, with two exceptions (described below). Regarding fabrication, pursuant to the requirements of 10 CFR 71.111 " Instructions, procedures and drawings," I assure that all activities affecting quality are prescribed by documented instructions, procedures, and drawings, that the instruc tions, procedures, and drawings are followed, and that the results of the activities are documented. In accordance with the 'NRC letter dated July 15,1997, we request authorization to resume fabrication.
Phase I Actions Completed:
1.
The Implementation Team, with one exception, was established on July 14,1997 and has met daily with recorded agendas & minutes. The exception is that the Special Projects Manager was absent and g/
therefore unable to serve as a member of the Implementation Plan Oversight Team as specified.
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2.
All non-QA related activities have been relieved from the QA Dept as of July 15,1997.
We have employed Dr. Roy A. Parker as an independent consultant to provide Phase 11 ov 3.
fabrication related QA activities as specified in QA Procedure 97-01.
h 4.
All Phase I corrective actions identified in the audit reports attached to the Plan have been completed with one exception. as explained below. A matrix list of the completed corrective actions is attached.
The exception is an intentional revision to one of the correcti.a actions. Corrective action #23 A was devised to address an observation from the NRC inspection The observation states "There is no apparent process whereby " preliminary" status is removed from drawings." While working on the specified corrective action we discovered that it did not reso've the observation. The original corrective 9707280105 970718 '
e.* Source Production & Equipment Co., Inc.
FAX 504/467 7685 m
113 Teal Street St. Rose, LA 70087 9691 Phone 504/464-9471 Telex 460156
bob 0ov Carl J. Paperiello July 18,1997 action stated " Complete the in-progress revisions to the Engineering Change Request and Engineering Change Notice procedures." However, those procedures do not control the approval, revision and distribution of preliminary drawings. Preliminary drawings are controlled by QA Procedure 1.10,
" Drawing Control." Therefore, we changed the corrective action and revised QA Procedure 1.10 instead.
Procedure 1.10 now requires that preliminary drawings must be controlled in accordance with existing procedures that apply to all other drawings, including the approval process to change from " preliminary" drawing to production drawing status. The Engineering Change Request was revised in accordance with the corrective action, but this action was done to address matters other than preliminary drawings. The Engineering Change Notice procedure has not been revised. I believe that this corrective action change is appropriate to the spirit and intent of the Plan. In fact, the original corrective action would not have met the intent.
5.
Completed retraining and written examination, with documented results of all personnel involved with QA activities.
I am confident that the corrective actions completed in Phase I assures the continued quality of the packages that we will fabricate once the suspension is lifted. Ifit would be possible for you or a member of your staff to call me at (504) 464-9471 as soon as this request has been reviewed I would greatly appreciate it.
J Phase II of the Corrective Action Plan, QA Procedure 97-01, Rev (0), will commence immediately upon NRC authorization to resume fabrication. Phase II includes the QA audit, which is Action Item No. 5 in the CAL. We hereby submit Mr. Cassius L. Tillman, President, Quality Management Support, Inc., as the QA expert to audit the effectiveness of SPEC's QA Program in complying with the requirements of 10'CFR Part 71. The attached biographical data describes Mr. Tillman's qualifications. The audit and root cause analysis will be completed with 60 days. Upon completion we will submit the results of the audit and a plen for any follow up action regarding findings identified in the audit.
Sinc
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R. D. (Donny) Dicharry President Enclosed: Matrix of Assignments and Co'rrective Actions, Phase I, Rev (4), dated July 18,1997.
Cassias L. Tillman Biographical Data.
cc:
Dr. Susan Shankman, NRC/NMSS William H. Spell, State of Louisiana w/o enclosures 07-18 97 GCl
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