ML23102A041
ML23102A041 | |
Person / Time | |
---|---|
Site: | 07109187 |
Issue date: | 04/10/2023 |
From: | Podolak L QSA Global |
To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
References | |
Download: ML23102A041 (1) | |
Text
QSAGLOBALo 1OApril 2023 Branch Chief Storage and Transportation Licensing Branch Division of Fuel Management U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards 11555 Rockville Pike One White Flint Rockville, MD 20852 RE: Renewal Request for CoC number USA/9187/B(U)-96 Revision 12 (Model 865)
Dear Sir or Madam:
QSA Global, Inc. requests renewal of the certificate referenced above for the Model 865 Type B(U) container. The current certificate expires on March 31, 2024. There are no major changes to the approval at this time, however, enclosed is Revision 14 of the Safety Analysis Report
{SAR). This revision makes minor updates/corrections to the document. These changes are minor formatting, editorial or clarification revisions with no significant impact on the package performance or continued compliance for Type B transport. Also enclosed are SAR and.
drawing change tables that identify specific changes and their impact on package compliance.
Please see the attached CD for copies of all application enclosures. A hard copy of the full application is being submitted separately to the Document Control Desk.
In addition to the attached documents, we request clarification of the wording in Section 5(a)(2)
- of the Certificate of Conformance. The current wording contains dimensional specifications that are more restrictive than specified on the approved package drawing R86590 Revision L.
Specifically:
- Handle is 0.88" OD x 9.25" long (these values are not specified on R86590) *
- Triangular shaped legs, two 1.38" x 5.5" (these values are not specified on R86590)
This level of detail is not critical to the package compliance under 10 CFR 71 and should be removed from the certificate description in Section 5(a)(2). Also, this Section states the package weight is "approximately 59 pounds", however, the approved drawing R86590 Revision Lon sheet 1 note 1 states the maximum package weight as "60 pounds". To avoid confusion, the wording on the certificate in Section 5(a)(2) should also reference the package weight as "maximum 60 pounds" to be consistent with the approved drawings and as supported under the SAR.
QSA Global Inc.
- 40 North Avenue Burlington, MA 01803
- 800.815.1383
- 781.272.2000 ext. 241
- qsa-global.com
Page2 Should you have any additional questions, or wish to discuss our renewal request, please.feel free to contact me.
Sincerely, E-SIGNED by Lori Podolak on 2023-03-08
'*__,/
15:01 :58 GMT E-Sl,GN~p by Mary Flanigan on 2023-03-09
.,....,_ ~" 18 :42:45 GMT Lori Podolak Regulatory Affairs Senior RA/QA Specialist Approval Ph: (781) 505-8241 Email: lori.podolak@qsa-global.com
Enclosures:
- List of Affected Pages
- Summary Table of SAR Changes Rev 13 to Rev 14
- SAR Revision 14
- Summary Drawing Change Table R86590 Rev L to M and R865-USER Rev A to B cc: ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint Rockville, MD 20852 Mr. Bernard White Senior Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory_ Commission 11555 Rockville Pike One White Flint Rockville, MD 20852 QSA Global Inc.* 40 North Avenue Burlington, MA 01803
- 800.815.1383
- 781.272.2000 ext. 241
- qsa-global.com
Safety Analysis Report for the Model 865 Transport Package List of Affected Pages Revision 1, Revision in entirety. This revision supercedes previously November, 2001 submitted SAR's for the 865.
Revision 2, Revision of Descriptive Drawings and minor modifications January, 2003 including Section 3.5 on device assessment regarding thermal testinQ and Sections 2.6 and 2.7 reQardinQ actuator sleeves.
Revision 3, July Revision of Descriptive Drawings, Chapters 5 and 7 and minor 2003 modifications throuQhout to address heat output calculations.
Revision 4, July 24, Revised Section 7 to reference device drawing for package 2003 surveys.
Revision 5, August Revision of Descriptive Drawings and reference to drawing 27,2003 revision level under Section 1.2.2.
Revision 6, Revision to Section 8 clarifying NOT as NOE (Non-destructive September 10, 2003 examination).
Revision 7, October Revision to Section 8 providing additional clarification to 10,2003 maintenance requirements Revision 8, March 6, Revision in entirety. This revision supercedes previously 2006 submitted SAR's for the 865. Change detail is contained in "Revision Description for the Model 865 SAR from Revision 7 to Revision March 2006" Revision 9, 24 Revisions to Table of contents pagination, pages 2-1, 2-19, 2-20, August2006 2-27, 2-28, 2-31, 2-32, 2-37, 7-2, 7-3, 7-4, 8-1 and 8-2. Letter dated March 16, 1999 removed from Section 2.12.1. Change detail is contained in "Revision Description for the Model 865 SAR from Revision 8 to Revision 9" Revision 1O, 20 Revisions to pages 1-1, 7-1 through 7-6 and Section 1.4.
September 2006 Includes identification of IAEA TS-R-1 reference, clarification in inspection/loading steps for device and update to drawings to reflect "-96" in the label depiction.
Revision 11, 03 Revision to address NRC RAI questions. Changes affect pages February 2009 3-2, 7-1 throuQh 7-6 and 8-2 through 8-4.
Revision 12, 13 Revision to detail actions taken should the package fail the March 2009 maintenance inspections. ChanQes affect paQes 8-3 and 8-4.
Revision 13, 25 Revision to reflect changes in descriptive drawings, formatting January 2017 changes for compliance to NUREG-1886 and other minor corrections.
Revision 14, April Revision for formatting changes and other miscellaneous 2023 updates/corrections (see SAR change table with submission)
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 1 of 8 Revision 14 to the 865 SAR updates reference revision information based on document changes and makes other minor editorial or clarification revision with no significant impact on the package performance or continued compliance for Type B transport. These changes are listed under the SAR Section in Revision 14 where the change occurs.
Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units Various Revised Section headers to reflect new branding None. Administrative change only. None. Not applicable.
colors. (For simplification due to volume of formatting changes, these changes are not denoted by color and change bars in text of SAR.)
Throughout References to dose rates in the document revised to Change made to reflect both SI and standard units in all cases None. Not applicable.
SAR list SI units followed in parentheses with the and follow a standard format in the document.
standard unit equivalent values.
Throughout References to measurements revised as applicable Change made to reflect both SI and standard units in all cases None. Not applicable.
SAR to reflect both standard and metric equivalents. and follow a standard format in the document.
Throughout Minor grammatical corrections made in text. None. Changes made for accuracy and formatting. None. Not applicable.
SAR Cover Updated revision level and revision date. None. Administrative change only. None. Not applicable.
page &
- Throughout
- Revised figure references from the general format None.* Administrative change only. None. Not applicable.
SAR "1.1a" to "1.1.A". Similarly revised Table references from the format "1.1a" to "1.1.A".
1.1 Noted submission formatting in accordance with None. Administrative change only. None. Not applicable.
NUREG-1886 (2009).
1.2 Minor formatting revisions and added detail. Figure None. Changes made for clarity and/or completeness. None. Not applicable.
1.2.a from SAR Rev 13 replaced with an external photograph of the Model 865 package identified as Figure 1.2.A. New Figure 1.2.B added to provide key components of the Model 865 package.
1.2.1 Revised major component description in list to None. Changes made for clarity and/or completeness. None. Not applicable.
match identification from Figure 1.2.B.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 2 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units 1.2.1.3 Added "assembly" after "source rod in the first Change made for clarity. None. Not applicable.
sentence.
1.2.1.4 Added description of role played by the actuator None. Changes made for clarity and/or completeness. None. Not applicable.
piston and actuator spring related to source rod assembly retention during transport.
1.2.1.5 Added description of role played by the cover as a None. Changes made for clarity and/or completeness. None. Not applicable.
secondary securing mechanism to source rod retention in the shielded position during transport.
1.2.4 Added description of the containment system for None. Changes made for clarity and/or completeness. None. Not applicable.
the 865 package related to the special form source capsules, including additional detail on mechanisms involved.
1.3 Changed figure reference from 1.3 to 1.3.A. Added None. Changes made for accuracy and formatting. None. Not applicable.
sub-sections 1.3.1 and 1.3.2 to identify the drawing provided for NRC review of the Model 865 design and for use by shippers of the package in routine transport.
- 2, 4.1 and Added reference toTS,,:R-,1.andSSR~6;.?,\ :*,,~ None. Changes madefor compl4=ter:iess. None. Not appik:abfe ...
4.4 .. ... ,
2.1.1 Added section title to Section 1.2 reference. None. Clarity. None. Not applicable.
2.1.2 and Added reference to SSR-6 .. None. Changes made for accuracy. None. Not applicable.
Table 7.1.A 2.1.2 Second paragraph clarified that the 865 meets the None. Changes made for accuracy. None. Not applicable.
requirements of ISO 3999:2004(E).
2.1.3 Added identification of depleted uranium content of None. Clarity. None. Not applicable.
shield in the Model 865 package.
2.1.4 Section simplified and removed sub-section None. Simplicity. None. Not applicable.
breakdown for information.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 3 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units 2.2.1 Added note indicating material property references None. Clarity. None. Not applicable.
listed after Table in section.
2.2.2
- 1st sentence, 1st paragraph added "safety None. Accuracy and/or completeness. None. Not applicable.
related" to materials described.
- 2nd paragraph replaced "Chapter 8" with "Section 8".
- Added detail in 3rd paragraph relative HAG testing and relative impacts.
2.2.3 Added historical impact of irradiation on package None. Completeness.
- None. Not applicable.
components to this section.
2.3.1 Added reference to NUREG/CR-6407 related to the None. Accuracy and/or completeness. None. Not applicable.
QA program application for this package design.
2.4.3 Section wording revised and expanded slightly. None. Accuracy and/or completeness. None. Not applicable.
2.5.1 & Calculations updated to include unit details in None. Clarity. None. Not applicable.
2.5.2 Sub- equations shown.
sections 2.5.1.1.3*, Calculated value of lxx corrected from 712 mm4 to None. Resulting calculation for modulus of weld 1;mchanged. None. Not applicable.
2,130 mm4 .
2.5.1.1.4 Calculated value of F2 corrected from 487 N to 488 None. Accuracy and clarity. None. Not applicable.
N and F1 corrected from 308 N to 307 N. Resulting calculations also corrected accordingly with end result of section conclusions remaining unchanged.
Also added ref. to 2.5.1.1.1 for additional equation values.
2.5.1.1.5 Corrected maximum applied moment assessment None. Accuracy. None. Not applicable.
from 28,766 Nmm < 98,440 Nmm to"< 97,440 Nmm". Added section reference for calculation of Aw used in the tension capacity of weld calculation.
No change in end result of section conclusions.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 4 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units 2.5.1.1.6 Corrected value used in calculation of applied None. Accuracy. None. Not applicable.
bending stress and resulting calculations. No change in end result of section conclusions.
2.5.2.3.1 Corrected description of yz to reflect as None. Accuracy. None. Not applicable.
"Acceleration factor in z-direction" instead of "y-direction".
2.5.2.4 None. Accuracy. None. Not applicable.
Corrected value used in calculation of CTsw and resulting calculations. No change in end result of ; :
section conclusions.
2.6.1 Added detail related to the heat source in package None. Accuracy and/or completeness. None. Not applicable.
including resource reference for isotope information.
Tables Maximum package temperature under insolation None. Accuracy. .. None. Not applicable.
2.6.8, conditions revised from 99.5°C (211 °F) to 62.9°C 3;1.A& (145.2°F). Value changed based on correction to
. 3.1.B,. 01c value used in Section 3.4.1.1. No change in Sections package compliance. ..
3.4.1.1 and ..
3.4.3 ,. . .
2.6.1.1* Added reference to NTC thermal assessment None. Completeness: . None. Not applicable .
results on package containment.
2.6.1.4 Added reference to Section 2.6.1 to support None. Completeness. None. Not applicable.
compliance.
2.6.2 Added details of cold limits on general pae::kage None. Accuracy and/or completeness. None. Not applicable.
construction materials.
- 2.6.3 & Added information related to the special form None. Accuracy and/or completeness. None. Not applicable. *
- * *2.6.4 capsule ANSI/ISO performance test pressure classification to support containment under pressure conditions.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 5 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units 2.6.4 Corrected conversion of 25 kPa to 3.6 psi instead None. Correction of error in text. None. Not applicable.
of 360 psi.
2.6.5 Changed operational service history reference of None. Change more accurate than prior reference for None. Not applicable.
"over 33 years" to "since 1984". timeframe.
2.6.9, 2.8, Updated/Added section title as applicable. Consistency with formatting in accordance with NUREG-1886: None. Not applicable.
3.1.2, Joint Canada - United States Guide for Approval of Type B(U) 3.5.4, 3.5.5 and Fissile Material Transportation Packages (2009).
& 4.1.1 2.7 1st paragraph, revised to reflect locations of None. Accuracy. None. Not applicable.
evaluation/testing summaries. Expanded reference to test orientations and conditions justification under Test Plan & Test Plan Report 84.
2.7.3 Added information related to test justification and None. Accuracy and completeness. None. Not applicable.
conditions.
2.7.3.1 Section headers for 2.7.3.1 & 2.7.3.2 revised to None. Clarity and completeness. None. Not applicable.
through reflect consistency with orientation formatting used 2.7.3.3 for drop testing in 2. 7 .1. instead of based on test -.' '. -*
~ '
- . specimen identification references. Added detail to section 2. 7.3.2 for the test specimen after testing. '
Added new Section 2.7.3.3 to address why an End Puncture Drop orientation was determined to not be needed based on prior specimen test damage.
2.7.4 Text of section revised for clarity and None. Clarity and completeness. None. Not applicable.
completeness.
2.7.4.1 Added section reference for references 1 and 2 in None. Aid to reference location for ease of use. None. Not applicable.
this section.
2.7.4.3 Added "Summary" to section title. None. Clarity. None. Not applicable.
2.7.4.4 Removed tables in this section and added None. Simplification and removal of duplication in document. None. Not applicable.
reference to tables in Section 3 where the thermal analyses were performed.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 6 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units 2.7.4.6 Replaced section 2.12.3 with general reference to None. Completeness. None. Not applicable.
the finite element analysis to support thermal stress calculations.
2.7.6 Included reference to ANSI N43.6 in addition to ISO None. Completeness. None. Not applicable.
2919 regarding source capsule pressure test criteria.
2.8 Section description expanded to address exclusion Compliance to NUREG-1886 format criteria. None. Not applicable.
of normal form radioactive material and special form material exceeding 3,000 A1 values.
2.10 Included reference to ANSI N43.6 and ISO 2919 None. Completeness. None. Not applicable.
source capsule pressure test criteria for the special form capsule containment.
2.12.4 Updated title to reflect revision changes in Special Change made for accuracy. None. Not applicable.
Form Certificate.
3.1.4 . Added argument related to impact of pressure None. Completeness:
- None. Not applicable .
.generation within the special form source capsule during the HAC testing. '
3.3.2 Added that evaluations may be described in the None. Accuracy. None. Not applicable.
SAR section in which they apply.
3.4.1.1 Added reference tables for insolation information None. Accuracy and improved ease of use. None. Not applicable.
for IAEA TS-R-1 (2009) and SSR-6 (2018).
3.4.1.1 Corrected calculation of the insolation heat None, result remains compliant to requirements. Accuracy. None. Not applicable.
generated on the curved package surfaces 01c from 76 m2 to 49.6 m2 . This change produces a change in 01N from 86 W to 28.8 Wand the resulting maximum wall temperature of 62.9°C (145.2°F) instead of 99.5°C (211 °F).
3.4.1.2 Revised concluding paragraph to address None. Completeness. None. Not applicable.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 7 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units compliance to applicable requirements.
3.4.1.3 Added material assessment for cold temperature None. Completeness. None. Not applicable.
range and compliance based on testing performed.
3.4.1.4 Added section to address thermal analysis of the None. Not specifically addressed previously. Added for None. Not applicable.
source capsule to the HAG thermal test conditions. completeness.
3.4.2 & Sections reversed and title updated to match None. Formatting consistency. None. Not applicable.
3.4.3 formatting from NUREG-1886.
3.4.3 Added reference to applicable NCT maximum None. Completeness. None. Not applicable.
temperature for package and added detail on expected pressure differential under the maximum normal operating pressure conditions.
3.5.1 Added details/information related to the initial None. Completeness .. None. Not applicable.
conditions for the HAG thermal evaluation.
- 3.5.3 and Section descriptions revised for simplicity and None. Completeness .. None. Not applicable.
3.5.4 added detail.
- 4.2 & 4.3 Added summary of compliance for package to None. Completeness:* *. ', .. .::;_,,, '.1*.* None . Not applicable.
requirements.
4.4 & 8.1.4 Updated revision date for ISO 9978 reference. None. Accuracy. None. Not applicable.
5.1.1 Added reference to tungsten shielding which is part None. Completeness. None. Not applicable.
of the source rod assembly.
Tables in Added paragraph references for TS-R-1 and SSR-6 None. Completeness. None. Not applicable.
Section 5 to tables.
Table 5.1.A Corrected mSv/h converted radiation levels at 1 None. Accuracy. None. Not applicable.
& 5.1.B meter from the package surface in the last three table columns.
5.4.2 Changed Figure 5.4.2.a reference to 5.4.A. None. Formatting consistency. None. Not applicable.
Revision Description for the Model 865 SAR from Revision 13 to Revision 14 April 2023 Page 8 of 8 Section Summary Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location under the Certificate Regarding Affected Units 7.1.2 Added Note regarding loading/unloading None. Completeness. None. Not applicable.
requirements for Model 865 package within a shield cell/enclosure.
7.1.3 & Reformatted section to match similar formatting None. Formatting consistency. None. Not applicable.
8.1.1 used in this SAR.
7.1.3.1.d Replaced "procedure" with "requirements" and None. Accuracy based on intent of section. None. Not applicable.
added reference to 10 CFR 71.5.
7.2.1.2.a Added reference to non-NRG based regulation None. Accuracy based on regulatory jurisdiction. None. Not applicable.
references.
7.4.1.3 Added step to properly block and brace package in None. Completeness. None. Not applicable vehicle prior to transport.
7.4.2 Updated revision year and document name for None. Accuracy. None. Not applicable.
Emergency Response Guidebook.
8.1.1.1 Added references when appropriate to information None. Completeness. None. Not applicable.
on the Type B transport certificate.
_;,8,,1:6 Revised to clearly indicate that any shielding test None. Clarity. . ,,.*.
.. \;:*"':. ; : 1-~. . None. Not applicable. *
._ ..... _' failure will prevent use of the package for Type .
I B(U) shipments.
8.2.3 Revised to include reference to pre-shipment None. Completeness. None. Not applicable.
surveys for compliance to regulatory radiation limits.
8.2.5.3 Corrected section references to exclude 8.2.5.3. None. Section 8.2,5.3 is not a check but an evaluation step. None. Not applicable.
Summary Table of Changes to Drawing R86590 Revision L to M & R865-USER Revision A to B Change Location Summary Change Impact of Change on Units Previously or Currently in Use under Action Taken by QSA Regarding the Certificate Affected Units R86590 Sheet 1 Added "REF" to the overall package The actual dimensions for this package are based on a stack up None. Not applicable.
& R865-USER dimensions on this sheet. of tolerances for the finished package assembly and is more Sheet 1 appropriately stated as "reference" dimensions.
R86590 Sheet 1 Removed Note 6 and incorporated None. Information consolidated in the drawing areas typically None. Not applicable.
applicable fractional and non- used to specify drawing tolerances to avoid confusion when fractional tolerances for this sheet reading/interpretating the drawing.
into the "UNLESS OTHERWISE SPECIFIED" block on the drawing.
R865-USER Removed Note 4 to reflect fractional None. Information consolidated in the drawing areas typically None. Not applicable.
Sheets 1 & 2 tolerances for this sheet into the used to specify drawing tolerances to avoid confusion when "UNLESS OTHERWISE reading/interpretating the drawing.
SPECIFIED" block on the drawing.
R865-USER 2nd Bullet of Note 3, removed "304" None. The material specification on the current drawing R86590 None. Not applicable.
Sheet 1 from the stainless steel specification Revision L is the accurate representation for the material used to match the material specification on the shipping cover and actuator guard bolts before 1-Jan-listed for the equivalent note on 2017. Change to R865-USER made for consistency across the drawing R86590 sheet 1. drawings.
R86590 Sheets Incorporated applicable fractional None. Information consolidated in the drawing areas typically None. Not applicable.
2, 4 &5 and non-fractional tolerances for this used to specify drawing tolerances to avoid confusion when sheet into the "UNLESS reading/interpretating the drawing.
OTHERWISE SPECIFIED" block on the drawing.
R86590 Sheet 3 Removed Note 4 and incorporated None. Information consolidated in the drawing areas typically None. Not applicable.
applicable fractional, non-fractional used to specify drawing tolerances to avoid confusion when and angular tolerances for the reading/interpretating the drawing.
- drawing into the "UNLESS OTHERWISE SPECIFIED" block on the drawing. Renumbered Note 5 as Note 4 and updated the Note reference for the ". 75" dimension on the drawing.
Page 1 of 2 QSA Global, Inc. "40 North Avenue Burlington, MA 01803
- 800.815.1383
- 781.272.2000
- qsa-global.com
Summary Table of Changes to Drawing R88590 Revision L to M & R885-USER Revision A to B Change Location Summary Change Impact of Change on Units Previously or Currently in Use under Action Taken by QSA Regarding the Certificate Affected Units R86590 Sheet 5 Removed Note 8 and incorporated None. Information consolidated in the drawing areas typically None. Not applicable.
applicable fractional, and non- used to specify drawing tolerances to avoid confusion when fractional tolerances for the drawing reading/interpretating the drawing.
into the "UNLESS OTHERWISE
- SPECIFIED" block on the drawing.
R86590 Sheet 6 Increased the tolerance between the None. Existing Model 865 packages comply with the+/- 1/16". None. Not applicable.
handle mounts from+/- 1/16" to+/-1/4" Change would only impact future manufacture or repairs to for the 5 3/4" dimension. existing 865 packages. The spacing of the gap between the handle mounts is not critical for package qompliance. A +/- 1/4"
' tolerance is sufficient to ensure package transport performance.
R865-USER Revised last bullet of Note 3 to None. Change is consistent with material authorizations listed None. Not applicable.
Sheet 1 include ASTM F738M, ISO 4017 on drawing R86590 Sheet 1 in the last bullet of Note 3.
and/or ISO 3506-1.
R865-USER On the material reference for the There is no sheet 3 of this drawing. The material specification None. Not applicable.
Sheet 2 source rod & holder assembly, for the source rod and holder assembly as reeded by users of replaced "See Sheet 3" with this package is appropriately detailed as "tungsten and stainless "Tungsten and stainless steel". steel".
Page 2 of2 QSA Global, Inc. a 40 North Avenue Burlington, MA 01803
- 800.815.1383
- 7_81.272.2000 a qsa-global.com