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
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. y w-DISTRIBUTION:
FC Central Files NMSS r/f MT01E FCAF r/f M-40 / M-40_ File
- 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 PROJ 8510d1 N PDR PDR l
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Enclosure 1 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:
- a. Instructions that specify the characteristics or processes'to be 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:
- a. Documentation that identifies the purchased items and the specific 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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