ML20217Q378
| ML20217Q378 | |
| Person / Time | |
|---|---|
| Site: | 07100231 |
| Issue date: | 04/29/1998 |
| From: | Campbell R CHEM-NUCLEAR SYSTEMS, INC. |
| To: | Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 71-0231-98-201, 71-231-98-201, NUDOCS 9805080088 | |
| Download: ML20217Q378 (3) | |
Text
'~ '
dHEM-NUCLEAR SYSTEMS
'71-O U '
1 740 Osborn Road
- Barnwell, South Carolina 29812 t
April 29,1998 RA-0020-98 Ms. Susan F. Shankman, Acting Deputy Director U.S. Nuclear Regulatory Commission Transportation Safety and Inspection Branch Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Washington, DC 20555
SUBJECT:
NRC INSPECTION REPORT NO. 71-0231/98-201 AND NOTICE OF NONCONFORMANCE
Dear Ms. Shankman:
This letter is in response to your request, dated April 3,1998, for additional information regarding Nonconformance C.3 of the subject inspection. Your request asked for clarification of the process of how an NCR identified as "10 CFR applicable" is transferred to the individual who first completes the NCR form. The following is CNS' response:
The process, in effect at the time of your inspection, required the QA Supervisor to forward any NCRs identified as "10 CFR 21 Applicable" to the General Manager, QA for submittal to the SRB. In the case of the subject NCR the QA Supervisor failed to submit it to the General Manager, QA due to inattention to procedural requirements. The QA Supervisor was counseled on the importance of procedure compliance.
Since your inspection we have taken the following actions to ensure this situation will not be repeated:
/
//
CNS Procedure CN-AD-015, " Nonconforming item and Corrective 7j)
Action", has been revised to clarify the responsibilities for reporting potential Part 21 issues to the General Manager, QA. Further, the term "10 CFR 21 Applicable" has been replaced with "10 CFR 21 Potentially Reportable" to eliminate any confusion.
/'I 'y,-
3 Procedure CN-AD-015 now requires QA to " perform a review of the nonconformance for potential reportability under 10 CFR 21 in 9805080088 980429accordance with CNS Procedure CN-AD-004, " Defect Reporting".
{DR ADOCK 07100231 1
PDR (803) 259-1781 ep e -.
_. 7 a
e Procedure CN-AD-004 has been revised to require the following:
"CNS Quality Assurance is responsible for notifying the General Manager, QA of any nonconformances associated with basic components."
"Any nonconformance or failure to comply with technical requirements associated with a basic component shall be identified on the Condition Report as 10 CFR 21 potentially reportable and forwarded to the General Manager, QA for Evaluation." [The Condition Report replaces the Nonconformance Report in the revised procedurel "The General Manager, QA shall present the results of any reportability evaluation to the SRB for their review in accordance with the SRB Procedure."
Attachment A,10 CFR 21 Applicablity List, has been added to CN-AD-004 to clearly identify the basic components associated with CNS business lines.
These proceduralimprovements along with training of the appropriate personnel will correct this nonconformance and prevent its recurrence.
I apologize for not including a more detailed explanation in the original response to this nonconformance. If you have any additional questions on this matter you may contact me at (803) 758-1808.
Sincerely, fE w/
Richard E. Campbell General Manager, Quality Assurance cc:
Regan Voit Bill House Len Toner Mike Mohundro l
m m.----u-,
- $h
- 2 nI'
=O I pd
_b s"
,t&
l1 l
,a 1 NG U
r s
m o
d t
r
\\'
c a
e h
u
,.1 r
c g
i n
D e
li a
f y
a l.
rB S
tu 1
p n
d l.
e no
'r oi t Dic a
l, s
gs e y
1, t
nip e
1,
)
ms 8
it f
I.
a a
cml S
R Aodel l
s l
nCnca I,
U' afiir 1,
ay e5 f
mr yOt 5 ot 1
Gkt e
a5 naf sM0 at a luSe r2 c
h g
Se
,jaC n oe D
. RoPc rl F
i un rt naaleNo aet t
r uf g s lc oFon u up i
S.Nst eh n cs n
ei a
f a sSr pf MUTSOW 2
1 892 S
an M
lo i
E a
r T
C h
S tu Y
o S
S l,
R le wn A
ra E
B L
C da U
o R
N n
r o
M bs E
O H
04 C
7 O
.