ML20138A780
| ML20138A780 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1985 |
| From: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Woodhall C NAC INTERNATIONAL INC. (FORMERLY NUCLEAR ASSURANCE |
| References | |
| REF-PROJ-M-40 NUDOCS 8510110081 | |
| Download: ML20138A780 (3) | |
Text
_ _ _
y w-DISTRIBUTION:
FC Central Files NMSS r/f MT01E FCAF r/f
/ M-40_ File M-40
- rurown PDR JRoberts FSturz Nuclear Assurance Corporation n der ATTH: Colman B. Woodhall Vice President 5720 Peechtree Parkway Norcross, Georgia 30092 Gentleren:
While we have not cor:pleted our initial safety review of the
" Topical Safety Analysis Report for the HAC Storage / Transport Cask for Use at an Independent Spent Fuel Storage Installation" sub-i mitted by Nuclear Assurance Corporation by letter dated Decenher 12, 1984, we have completed our initial review with respect to your quality assurance program. Accordingly, we are enclosing a reauest for additional infomation on it to afford you the opportunity of j
preparing your response and expediting this pa~rt of the review.
Sincerely, Origim)
_ e5 W l
Johnt F. Robertn
(
Leland C. Rouse, Chief Advanced Fuel and Spent
)
Fuel Licensing Branch Division of Fuel Cycle and Material Safety
Enclosure:
Request for Additional Infomation, 8510110001 8510d1 PDR PROJ PDR N
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REQUEST FOR ADDITIONAL INFORMATION NAC QA 1.
The NAC QA Manual, referenced in chapter 11 of the TSAR for the NAC Storage / Transport Cask for use at an ISFSI, uses the term
" safety-related." 10 CFR 72 (S72.80) requires a QA program based on the criteria of Appendix B to Part 50 be established and implemented for structures, systems, and components of an ISFSI that are "important to safety." 10 CFR 72 includes a definition of the term "important to safety" unique to ISFSIs.
It appears that the term " safety related" in the NAC QA Manual meets the definition of "important to safety" in 10 CFR 72, i.e., the terms are used interchangeably.
If you agree with this assump-tion, please so document in the TSAR or the NAC QA Manual.
2.
Identify the items of the NAC storage / transport cask which are important to safety (per 10 CFR 72) and are therefore controlled per the NAC QA Manual.
(Note that table I in QAM 19.2 of the QA Manual does not agree with section 1.2.8 of the TSAR.)
3.
Section 1.6 of QAM 03.1 indicates that drawings and specifications are reviewed by " personnel independent of the designer...."
Provide a state-ment that verification of conformance (i.e., design checks, design verifi-cations, inspections, and tests) is accomplished by individuals or groups who do not have direct responsibility for performing the work being verified.
4.
QAM 00.1 and elsewhere in the QA Manual indicate that QA requirements are l
applied with a graded approach.
Provide a statement that the extent of QA l
centrols is determined by the QA staff in combination with the line staff and is dependent upon the specific activity, item complexity, and its importance to safety.
5.
Describe how management (above and outside the QA organization) will regularly assess the scope, status, adequacy, and compliance of the QA program to 10 CFR 72.
These measures should include:
a.
Frequent contact with program status through reports, meetings, and/or audits.
b.
Performance of a periodic assessment which is preplanned and docu-mented with corrective action identified and tracked.
6.
Provide a statement, or justify not doing so, that the review and approval of procurement documents are documented prior to release and available for verification.
2 7.
Provide a statement, or justify not doing so, that the QA organization reviews and concurs with drawings and specifications and changes thereto.
8.
Discuss NAC's supplier surveillance.
Surveillance of suppliers during tabrication, inspection, testing, and shipment of materials, equipment, and components should be planned and performed in accordance with written -
Y 2-procedures to assure conformance to the purchase order requirements.
These procedures should provide for:
Instructions that specify the characteristics or processes'to be a.
witnessed, inspected or verified, and accepted; the method of sur-veillance and the extent of documentation required; and those respon-sible for implementing these instructions.
~ b.
Surveillances which assure that the supplier complies with the quality requirements.
Surveillance is performed on those items where verification of procurement requirements cannot be determined upon receipt.
9.
Provide a statement, or justify not doing so, that NAC suppliers furnish the following records as a minimum:
Documentation that identifies the purchased items and the specific a.
procurement requirements (e.g., codes, standards, and specifications) met by the items.
b.
Documentation that identifies any procurement requirements which have not been met together with a description of those nonconformances dispositioned " accept as is" or " repair."
The review and acceptance of these documents should be by a responsible QA individual.
19 D--"id: 3 statement, or justify not doing so, that certificates of conformance from NAC suppliers are periodically evaluated by audits, independent inspections, or tests to assure they are valid.
11.
Provide a statement, or justify not doing so, that the effectiveness of the control of guality by NAC suppliers is assessed at intervals consistent with the importance, complexity, and quantity of the items supplied.
12.
Provide a statement, or justify not doing so, that nonconformance reports identify the nonconforming item; describe the nonconformance, the disposition of the nonconformance, and the inspection requirements; and include signa-ture approval of the disposition.
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