ML20203C935
| ML20203C935 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 01/26/1999 |
| From: | Schoone T MISSOURI, UNIV. OF, COLUMBIA, MO |
| To: | Eng P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20203C927 | List: |
| References | |
| NUDOCS 9902120306 | |
| Download: ML20203C935 (16) | |
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5 Res arch Reactor Center i
Research Park
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Columbia, Missouri 65211 Telephone (573) 882-4211 FAX [573] 882=3443 UNIVERSITY OF MISSOURI-COLUMBIA January 26,1999 r
Patricia Eng Office of Nuclear Material Safety j
and Safeguards Mail Stops 06F18 i
U.S. Nuclear Regulatory Commission J
Washington, DC 20555
Reference:
Docket No. 50-186 University of Missouri Research Reactor Facility i
Reactor License R-103 i
Subject:
Request Changes to Quality Assurance Program The requested changes to our Quality Assurance Program are to update the MURR organization charts and the QA personnel Responsibilities Description on page 3,4,7, appendix A-1, and B-1. The changes are indicated in bold. The specific changes requested are as follows:
- 1) On page 3 and page 7, the position of Service Engineer has been changed to Shipping Section Supervisor.
- 2) In page 4, a paragraph is added to allow changes to the QA program that do not reduce the effectiveness of the program. These changes will be authorized by the Reactor Manager and subsequen'j the changes will be reviewed by the Reactor Advisory Committee. The changes will be i
submitted to the NRC as a follow-up. This would allow the same latitude in this plan as is allowed in Security and Emergency plans approved by the NRC under 10 CFR 54(p) and 10 CFR 54(qh
- 3) On Appendix page A-1, the position of Assistant Director of Service Application is changed to Assistant Director ofincome Generating Operation. The position of Service Application Engineer is removed and the Service Application Supervisor is changed to Shipping Section Supervisor.
- 4) On Appendix page B-1, the title of Reactor Service Engineer is replaced with Shipping Section Supervisor, if you have additional questions or require additional clarification please call me at 573-882-5296.
Sincerely, ENDORSEMENT:
Reviewed and Appr: ved D
Tony choone J. Charles McKibben Reactor Manager Associate Director
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- Attachment Notary PuMir.
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204 h STATE OF MD Y.CRI Doone County My Commission Ex;;res: April 14,1999 990212O306 990ADOCK 05000106 a mene mum PDR
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I. INTRODUCTION By this document the University of Missouri Research Reactor (MURR) establishes a Quality Assurance (QA) Program in accordance with 10CFR-71, Subpart H. The program covers the use, testing, maintenance and repair of shipping containers covered by i
10CFR-71. The' QA Program applies to those activities affecting the casks and their components, which are significant to safety. QA comprises those planned and systematic i
actions necessary to provide adequate confidence that a system or component will perform.
satisfactorily in service. ' Shipping casks covered by 10CFR-71 will be released for shipping i
only after they have satisfactorily met the requirements of the QA Program.
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II.. QUALITY ASSURANCE i
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' Organization r
The Reactor Manager is responsible for the QA Program and shall assure the c
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- program complies with 10CFR, Part 71, Subpart H criteria. The Reactor Manager l
will have the following minimum qualifications: Bachelors degree in Engineering or.
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. related field; Senior Reactor Operators license; five' years experience with reactors; and' 1
general knowledge of all aspects of research reactor operation.
l The Reactor Manager shall designate individuals in writing as QA Supervisors who =
l have the responsibility to insure that work in their assigned area meets the requirements t
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. of the QA Program and that the program complies with 10CFR-71, Subpart H criteria.
Additionally, the Reactor Manager shall designate individuals as QA Inspectors who have r
the responsibility and authority, delineated in writing, to stop unsatisfactory work and f
control further processing, delivery, or installation of non-conforming material. Due to e MURR's small staff, the QA Supervisor and Inspector positions will be collateral
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jesponsibilities of designated staff members. Responsibility for execution of parts of this j
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- n may be delegated to individuals either within or outside of the Reactor Operations j
section.'
j If a difference in' opinion between a QA Inspector and other MURR personnel concerning the QA Program requirements occurs, the evolution involved shall be stopped
-and put in a safe condition. The QA Inspector shall show the individual (s) the basis for the
, requirement."If the' difference of opinion still exists, the difference shall be resolved by the
' Reactor Manager _
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The Shipping Section Supervisor is responsible for all shipping casks except for
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the casks used to ship spent fuel and fissile material or radioactive waste. The Reactor Physicist is responsible for casks used for spent fuel shipping, and the Manager, Health Physics is responsible for casks used for radioactive waste shipments.
The Reactor Operations Engineer, Shipping Section Supervisor, Reactor
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Physicist, and Manager, Health Physics are responsible for insuring any work under their direction performed on shipping casks is in compliance with the requirements of the QA Program.
2.
Quality Assurance Prostram The QA Program covers the activities which are significant to safety involving the use, testing, maintenance, and repair of shipping casks that are required to be in complinnee with 10CFR-71. Any activity which could significantly aff ct the ability of such e
a structure, system, or component to perform safely and se :,pecified falls within the scope of this Quality Assurance Program. These activities may involve purchasing, testing, handling, shipping, storing, cleaning, inspecting, maintaining, repairing, loading, and modifying. Where appropriate, these quality-related activities are performed with specified equipment under suitable environmental conditions carried out in accordance with written procedures, instructions, and drawings; as described in the following subsections. The QA Program will be applied in a graded approach, i.e. applied to an extent consistent with the importance to safety. The training and experience requirements will be accomplished in accordance with established procedures for appropriate QA l
functions. QA manuals containing the QA Program, procedures, instructions, and i
appropriate reference material will be distributed to individuals on the QA manual distribution list. Revisions to items contained in the QA manual will be distributed to the 3
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same individuals requiring the revisions to be entered in a timely fashion.
Changes may be made to the QA program that do not reduce the
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effectiveness of the program. These changes will be authorized by the Reactor
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Manager, submitted to the NRC to update records, and subsequently reviewed
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by the Reactor Advisory Committee.
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3.
Procurement Document Control In documents for procurement of materials, equipment, and service; assurance that 1
applicable regulatory requirements, design bases and other requirements which are necessary to assure adequate quality are suitably included or referenced in such documents, shall be accomplished by requiring that the appropriate person as listed in
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the last paragraph of Section 1 and the Reactor Manager (or his designee) must both
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review and approve the specifications, drawings, procedure or other documents which are parts of purchase orders and contracts subject to the QA Program. The review and approval of procurement documents shall be documented prior to release and will be available for verification. The Reactor Manager shall specify for which materials, I
equipment, and services the procurement documents will be reviewed.
The procurement documents shallidentify the applir.able 10CFR, Part 71, Subpart H requirements which must be complied with and descibed in the suppliers QA Program. The procurement documents shall further identify the documentation to be prepared, maintained and submitted to the University of Missouri for review and approval.
I The procurement documents shallidentify those records to be retained, controlled and maintained by the supplier, and those delivered to the University of Missouri prior to use j '
or installation of the hardware. All procurement documents shall contain the statement that the University of Missouri has the right of access to the supplier's facilities and l
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, records for source inspection and audit.
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4.
' Instructions. Procedures. and Drawings l
Activities affecting quality shall be prescribed where appropriate by documents l
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'which shall be prepared, approved, and retained on file.
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5.
Document Control :
' Documents relating to a particular type of activity are, in general, prepared under :
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. the direction of the Supervisor who is delegated the responsibility for maintaining a file of -
such documents, revising them to reflect NRC approved changes to a shipping l
' container license or Certificate of Compliance and as-built conditions, clearly identifying the documents as originally approved, and all revisions. Distribution of j
documents is subject to the approval of the bactor Manager or other designated
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- individual.
' Changes to documents shall be reviewed and approved by the same bactor Operations person or group, or the same organization that performed the original review and approval, unless the bactor Manager specifically designates another responsible -
group or organization.
' Prior to implementation, the bactor Manager shall verify that approved changes are included in instruction, procedures, drawings, and other documents.
The Supervisor in charge of a particular activity shall assure that approved
. documents are available at the location where the activity will be performed prior to commencing the work.
A master list or equivalent is established to identify the current revision number of instructions, procedures,' specifications, drawings, and procurement documents. This list is 5
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, updated and distributed to predetermined, responsible personnel to preclude use of superseded documents.
6.
Control of Purchased Material. Eauioment. and Service In general, all materials, equipment, and services are subject to inspection and approval of both the quality and quantity prior to acceptance. Responsibility for these f
functions rests with the group Supervisor initiating the procurement, or his designee, i
unless responsibility is otherwise assigned by the Reactor Manager. Inspection generally -
~ is performed after receipt of the material, equipment or service at the reactor site.
- When considered necessary to assure quality, and particularly for non-standard items, i
only bids submitted by vendors deemed qualified and acceptable to the Reactor Manager (or his designated representative) will be considered. Contractors and suppliers are
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selected on the basis of references, past performance to MURR, reputation and other investigation. Appropriate credentials, and licenses if required by law, code or regulation, -
will be furnished and retained on file. No deviations from proeirement documents are allowed without written request by the vendor and approval by the Reactor
- Manager or his designated representative.
7.
Identification and Control of Materials. Parts. and Components Identification and control is required for materials, parts or components where it is necessary to identify items through stages of fabrication, delivery, utilization, repair and/or modification.
8.
. Control of Special Processes The Shipping Section Supervisor, or the Reactor Physicist, or such other
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, individuals or organizations as designated by the Reactor Manager, is assigned the responsibility for incorporating into instructions, procedures, and drawings (used either for procurement or for control ofinternal activities within the scope of the Quality Assurance Program) the applicable portions of codes and standards in order to assure that special processes (including welding, heat treating, and non-destructive testing) are accomplished J
l by qualified personnel using qualified procedures.'
Vendors will be required to furnish documented evidence of qualification, when 1
applicable, including individual as well as company licenses or other proof of competence.
The QA Supervisors and Inspectors are responsible for surveillance of both vendor and in-house special processes when needed, and for certifying to the Reactor Manager in
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written form that the work has been accomplished as specified.
The Reactor Manager may at times involve expert counsel on special problems. The written recommendation of the consultant shall be obtained and shall be part of the QA file, but responsibility for acceptance of the work shall remain with the Reactor Manager or his designated alternate.
9.
Insoection and Test Control The inspection program includes examinations, measurements, and tests to assure that materials, equipment, and services conform to the requirements of applicable instructions, procedures, and drawings. The inspection program shall verify conformance of quality-affecting activities with requirements that are accomplished in accordance with written controlled procedures. When a QA procedure requires an independent inspection, l
',it will be conducted by a QA Inspector who is not performing the activity being inspected.
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. Quality in structures, systems and components, affectad by the above activities is assured l
. through inspection and/or testing on completion of a job or prior to use. General 7
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, requirements for the inspection of purchased material, equipmert and services were stated in Section 6.
Casks which fail to meet the requirements ofinspections or tests will be handled in
. accordance with Section 13.
10.
- Control of Measuring and Test Eauioment Measuring and test instruments shall be calibrated at specified intervals based on the required accuracy, purpose, degree of usage, stability characteristics, and other L conditions affecting the measurements. Calibration shall be traceable to nationally recognized standards; or, where nationally recognized standards do not exist, provisions.
i shall be established to document the basis for calibration.
~ When measuring and test equipment is found to be out of calibration, any
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I measurements or tests performed since the previous calibration shall not be used to meet i
QA requirements for subsequent use of the casks or equipment tested.
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' Handline. Storare and Shinoine 11.-
The handling, storage, and ' moving of casks and all parts of casks will be controlled so as to assure safety; minimize degradation, damage and/or loss. The safety significant i
tasks shall be performed by qualified individuals in accordance with established work procedures and instructions. Shipments will not be made unless all tests, certifications, i
l acceptances, and final inspections have been completed. Prior to shipment, the departure,.
l arrival time, and destination of the shipment shall be established and monitored to a l.
dhgree consistent with the safe transportation of the package.
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1 12.
Insoection. Test. and Operating Status The status of shipping containers will be indicated by a tag, label, marking, a log entry, or l
other documentation. The records will indicate when periodic surveillance tests have been
- performed. No deviation from required inspection, test, or other critical operations are authorized without the approval of the Reactor Manager.
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Non-Conformine Materials. Parts. and Comoonents j
Items found to be'non-conforming in operation or in surveillance tests are recorded i
'l by identification number, if any, in the appropriate document and removed from service until repaired. The repair, transfer to other use, disposal, or other ultimate disposition will be recorded. The repaired items must still comply with the original specifications or approved modifications.
The control, documentation, and notification to affected organizations of non-l conforming casks, parts, components, or services shall be procedurally controlled.
14.
Corrective Action Because of the relatively small number of casks, most conditions adverse to safe operation are easily and quickly communicated. Depending upon the importance of the deficiency, the information and corrective action may be transmitted to Supervisors or
. to the Reactor Manager for a decision on appropriate corrective action.
Decisions as to corrective action 'are made on a case-by-case basis depending upon the nature, severity, and frequency of the deficiency.
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Quality Assurance Records u
The Reactor Manager shall maintain a master list showing the person i.
' (by title) respoNible for the storage location of all documents within the scope of QA 1.
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, activities. These records shall include operating logs, results of reviews, inspections, tests, j
audits, and material analysis; qualifications of personnel, procedures, and equipment; f
- and other documentation such as drawings, specifications, procurement documents, c'alibration procedures, and reports; non-conformance reports; and corrective action j
i reports.
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16.
Audits An audit of the QA Program shall be conducted, by knowledgeable personnel not.
i having direct responsibilities in the areas being audited, at least annually and shall be performed in accordance with pre-established written procedures or check lists. The audit will be performed by the Manager, Reactor Health Physics, or other persons delegated by l
1 the Director.
l The audit will cover all aspects of the Quality Assurance Program. Documentation i
of the audit willinclude, as a minimum, a report of any changes in the program made since the previous audit, a report of random or complete reviews of the records and an evaluation of the effectiveness of the program,
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The results of the audit shall be documented and then reviewed with management 1
having responsibility in the area audited.
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Any deficiencies revealed by the audit shall be investigated by management and corrective action taken. Deficient areas shall be re-audited on a timely basis to verify 1
implementation of corrective actions.
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,13.
Non Conformina Materials. Parts. and Components Items found to be non-conforming in operation or in surveillance tests are recorded by identification number, if any, in the appropriate document and removed from service until repaired. The repair, transfer to other use, disposal, or other ultimate disposition j
will be recorded. The repaired items must still comply with the original specifications or approved modifications.
l The control, documentation, and notification to affected organizations of non-conforming casks, parts, components, or services shall be procedurally controlled.
i 14.
Corrective Action i
Because of the relatively small number of casks, most conditions adverse to l
safe operation are easily and quickly communicated. Depending upon the importance of the deficiency, the information and corrective action may be transmitted to Supervisors or to the Reactor Manager for a decision on appropriate corrective action.
Decisions as to corrective action are made on a case-by-case basis depending upon I
the nature, severity, and frequency of the deficiency.
1 15.
Quality Assurance Records The Reactor Manager shall maintain a master list showing the person l
(by title) responsible for the storage location of all documents within the scope of QA l
j activities. These records shall include operating logs, results of reviews, inspections, tests, audits, and material analysis; qualifications of personnel, procedures, and equipment; 11
and other documentation such as drawings, specifications, procurement documents, calibration procedures, and reports; non-conformance reports; and corrective action reports.
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16.
Audits An audit of the QA Program shall be conducted, by knowledgeable personnel not having direct responsibilities in the areas being audited, at least annually and shall be performed in accordance with pre-established written procedures or check lists. The audit will be performed by the Manager, Reactor Health Physics, or other persons delegated by the Director.
l The audit will cover all aspects of the Quality Assurance Program. Documentation j
- of the audit will include, as a minimum, a report of any changes in the program made since i
the previous audit, a report of random or complete reviews of the records and an evaluation 1
of the effectiveness of the program.
The results of the audit shall be documented and then reviewed with management having responsibility in the area audited.
' Any deficiencies revealed by the audit shall be investigated by management and corrective action taken. Deficient areas shall be re-audited on a timely basis to verify.
implementation of corrective actions.
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updated and distributed to predetermined, responsible personnel to preclude use of superseded documents.
6.
Control of Purchased Material. Eauinment. and Service In general, all materials, equipment, and services are subject to inspection and approval of both the quality and quantity prior to acceptance. Responsibility for these functions rests with the group Supervisor initiating the procurement, or his designee, unless responsibility is otherwise assigned by the Reactor Manager. Inspection generally is performed after receipt of the material, equipment or service at the reactor site.
When considered necessary to assure quality, and particularly for non-standard items, only bids submitted by vendors deemed qualified and acceptable to the Reactor Manager (or his designated representative) will be considered. Contractors and suppliers are selected on the basis of references, past performance to MURR, reputation and other investigation. Appropriate credentials, and licenses if required by law, code or regulation, will be furnished and retained on file. No deviations from procurement documents are allowed without written request by the vendor and approval by the Reactor Man'ager or his designated representative.
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Identification and Control of Materials. Parts. and Comnonents i
Identification and control is required for materials, parts or components where it is necessary to identify items through stages of fabrication, delivery, utilization, repair and/or modification.
8.
Control of Special Processes The Shipping Section Supervisor, or the Reactor Physicist, or such other
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QA PERSONNEL RESPONSIBILITIES Reactor Manager The Reactor Manager will be responsible for the development and implementation of the Quality Assurance Program.
bactor Physicist The bactor Physicist will provide for the shipping of all spent fuel and fissile material.
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Shioning Section Supervisor J
The Shipping Section Supervisor will provide for the shipping of all by-product
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- material, Manager-bactor Health Physics The Manager-Reactor Health Physics will be responsible for the shipping of radioactive waste and will be the auditor for the QA Program, except for radioactive waste shipments.
Reactor Ooerations Engineer The bactor Operations Engineer will be the' auditor for radioactive waste shipments.
QA Supervisors The QA Supervisors are responsible for insuring that work in their assigned area meets the requirements of the QA Program.
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OA Inspectors l
The QA Inspector shall perform the required QA inspection and have the authority l
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' to stop work not meeting the requirements of the QA Program.
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REFERENCES 1.
- 10CFR-71.
2.
Regulatory Guide 7.10 (Rev.1). June 1986. " Establishing Quality i
i Assurance Programs for Packaging Used in the Transport of l
Radioactive Material."
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. ANS '- 15.8(N402) - 1976. ' Quality Assurance Program Requirements
' for Research Reactors." (ReafHrmed December 15,1986).
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