ML20151D472
| ML20151D472 | |
| Person / Time | |
|---|---|
| Site: | 07100651 |
| Issue date: | 03/22/1988 |
| From: | Cost R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20151D476 | List: |
| References | |
| 29163, QA-88-169, NUDOCS 8804140262 | |
| Download: ML20151D472 (4) | |
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PD /L Mr. Charles E. MacDonald Chief of Transportation Branch office of Nuclear Material Safety and Safeguards Division of Safeguards and Transportation U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Approval of Revised Quall'ty Assdrance Program Plan for Westinghouse Nuclear Waste Department (Docket No. 71-0651)
Reference:
Facsimile Transmittal from U.S. Nuclear Regulatory Commission, from Len Gordon to Lou Huber, dated March 17, 1988.
Dear Mr. MacDonald,
In accordance with 10CFR71.101(c), I am, by this letter, requesting that the Quality Assurance Program Plan for the Nuclear Waste Department of Westinghouse Electric Corporation's Nuclear Fuel Business Unit as described in Revision 1 of NWD-TR-005 be approved for use.
The attachment describes the changes which have been made to this document to resolve the NRC's comments provided by the above reference.
Seven (7) copies of Revision 1 of NWD-TR-005, dated March 1988, are enclosed.
Should you have any questions concerning this submittal or the Nuclear Waste Department's quality assurance program, please contact the undersigned.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION p g [.g i n L '!, r et.iU
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l R. R. Cost, Manager
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Quality Assurance Attachment - Changes to Resolve NRC Comments Enclosure - Revision 1 to NWD-TR-005 8804140262 080322 PDR ADOCK 07100651 C
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fi Attcchment QA-88-169 1
Changes to NWD-TR-005 to Resolve NRC's Comments
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Comment A.1:
Throughout your quality assurance program description reference is made to compliance with requirements specified in Appendix B of 10 CFR Part 50 and ANSI /ASME NQA-1, "Quality Assurance Program Requirements for Nuclear Facilities."
NQA-1 has been endorsed by 1
NRC for implementation of NRC requirements.
Since this quality assurance program is to address transportation activities, your commitment should address Subpart H of 10 CFR Part 71, "Quality Assurance Requirements for Packaging and Transportation of Radioactive Material."
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Response
}
Section 1.1 has been revised to specifically indicate compliance with Subpart H of 10 CFR Part 71.
In-text references to 10 CFR, Part 50, Appendix B have been deleted.
l Comment A.2:
Throughout your quality assurance program description reference is made to its applicability to "Quality related-activities."
The requirements of Subpart H of 10 CFR Part 71 specifies applicability to activities and components "important-to-safety."
Your quality assurance program should be revised to identify those items important to safety that are to be controlled under this program.
Response
Throughout the document, as appropriate, the words "quality-related activities" have been replaced with "activities important to safety and other activities affecting quality."
In addition, Section 1.1 has been expanded to indicate that, as far as the quality assurance program is concerned, all items are treated as if they were important to safety unless they have been specifically excluded from this consideration.
For the cask program to date there have been no such exclusions.
Comment A.3 Include a policy statement endorsed by top management i.e.
(general manager, vice president) that work on items important to safety will be in accordance with the requirements of Subpart H of 10 CFR Part 71 and as described in the QA Program Plan and implemcnted in QA manuals.
Response
Such a directive has been endorsed and included following the title page.
?C'
' Page 2 Comment B.1: Organization (paragraph 1.2)
Include the qualification requirements for the position of Quality Assurance Manager.
Response
Section 1.2 has been expanded to include the qualification requirements for the Quality Assurance Manager.
Comment B.2: Design Control (paragraph 3.2)
Expand the design process description to include that design input requirements are specified in design documents.
Response
The first paragraph of Section 3.2 has been expanded to highlight how design requirements etc. are to be documented.
Comment B.3: Control of Purchased Items and Services (paragraph 7.1)
Expand the description to state that the QA organization reviews and concurs in inspection reviews, in inspection plans, calibration and special process procedures.
Response
Section 7.1 has been expanded to indicate that the QA Department provides review / overview of procurememt planning and control.
Comment B.4: Audits (paragraph 18.2)
Expand the description to reflect the following:
a.)
Internal audits - applicable elements of the Westinghouse -
NWD quality assurance program are audited at least annually or once within the life of the activity, whichever is
- shorter, b.)
External audits - major suppliers or contractors will be audited when sufficient work is in progress to demonstrate implementation of the QA program, c.)
Management audits - management audits to assess the status, scope and effectiveness of the QA program should be conducted at least every 12 months.
Response
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Section 18.2 has been expanded to hit
.ght commitment to perform 1
internal audits on an annual basis o-during the life of the activity and to audit suppliers during work in progress.
4 The commitment for the performance of management assessments of
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the QA program is found in Section 2.6.
Section 2.6 has been revised to indicate that "periodically" should be interpreted to mean usually on an annual basis.