ML20245A703
| ML20245A703 | |
| Person / Time | |
|---|---|
| Site: | 07100632 |
| Issue date: | 04/30/1987 |
| From: | Potter R QUALITY ENERGY SERVICES & TESTS (QEST) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20236B880 | List: |
| References | |
| 28208, NUDOCS 8705110257 | |
| Download: ML20245A703 (2) | |
Text
7/-C681 3 RETUIOR TF3975 gg9 w
Quality Energy Services & Tests S
233 N. Quentin F
,__ ichita, KS 67208 Sk S
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April 30,.1987 MAIL ITICM b
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Director, Office of Nuclear Material Safety & Safeguards l:
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Washington, DC 20555
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SUBJECT:
Licenses Requirements -10 CFR Part 71
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REFERENCES:
- 1) USNRC Region IV Safety Inspection (dated 4/)
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- 2) Docket Number 030-20348/ License Number 35-2 5 Fee Ca v:n R k-- - -,--
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Gentlemen:
Octc C'arh :
On ' April 9,1987, Mr. R. L ' Keaton of the -USNRC-Region IV eq%ucted_a M:d Date Ccr@t safety -inspection of the QEST Corporation - Tulsa, Oklahomn _ %dng the
' inspection, Mr. Keaton identified and issued'a Notice of Violation to 10 CFR Part 71 requirements. The violation identified was stated as follows :
" Contrary-to 10 CFR 71.12 (b),- the licensee did not have a doctamented '
L NRC-Approved Q/A program satisfying the provisions of Subpart H of 10 CFR 71."
- Upon completion of the inspection, the QA management of QEST performed an cvaluation to establish and schedule both corrective and preventative
, action. The process of performing corrective action is defined in the QEST Quality Assurance Program Manual of which is' en integral part of the Radiation Safety Program.
We are somewhat confused about the true intent of the violation and 10 CFR 71.12.
The Purpose and Scope of Part 71 (71.0 (d)) states in part "The
. general license in 71.12 requires that an NRC certificate of compliance or other' package approval be issued for' the package to be used under the general'11 cense."
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71.12-(b) states "This ' general license applies only to a licensee who has i
a quality assurance proram approved by the Commission as satisfying the provisions of Subpart H of this part."
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Apr11'30, 1987~
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QEST applied for a source material license in accordance with the require-l ments of 10 CFR Part.40. Within the scope of Part 40,.a Quality Assurance I
Program Manual and a Radiation Safety Procedures Manual was developed and l
implemented to control the receipt, use, transfer and delivery of
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byproduct materials. These documents were reviewed and approved by the i
Region IV NRC office and a license was issued.
QEST has' operated in accordance with the QA Program Mar 4ual and RSP Manual since issuance of the NRC License.
Both of these documents address the requirements mandated by 10CFR71.
It appears the intent of the require-ments of Subpart H (as discussed in the preceding paragraphs) applies to source material manufacturers. The basis of this assumption is that QEST is only authorized to procure source material from manufacturers licensed l
by the NRC.
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QEST has prepared a QA Program Plan based on the requirements of the i
existing QA. Program Manual and RSP Manual to address the violation.
The l
plan is hereby submitted for your review and approval.
OEST Corporation i
feels that the applicable requirements of 10CFR 71 were factored into the RSP Manual and application for license in accordance with Part 40.
Please consider providing more detailed guidance in how the two regulations interface, i
l Sincerely, Er'T' \\{'q;sk;
Robert J. Potter cc: R Keaton J Wilson i
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_ ___ ___ - __________-__-_-__ _ ____________________- - - __ - __ _ _ _ _ _ _ _ _ _ _