E910-03-002, of Saxton Nuclear Experimental Corporation Facility Quality Assurance Plan

of Saxton Nuclear Experimental Corporation Facility Quality Assurance Plan

ML030350010
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	01/20/2003
From:	Kuehn G GPU Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
E910-03-002 1000-PLN-3000.05, Rev 4
Download: ML030350010 (21)

Text

GPU Nuclear, Inc.

2iPU NUCLEAR Three Mile Island Nuclear Station Route 441 South Post Office Box 480 Middletown, PA 17057-0480 Tel 717-948-8461 January 20, 2003 E910-03-002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject:

Revision 4 of the Saxton Nuclear Experimental Corporation Facility Quality Assurance Plan Gentlemen, In accordance with 10CFR 50.54(a)(3) and Section 3.0 of the Saxton Nuclear Experimental Corporation (SNEC) Facility Quality Assurance (QA) Plan, enclosed is Revision 4 of the SNEC Facility QA Plan. A review of changes concluded that the changes do not constitute a reduction in commitment.

Revision 4 reflects the organizational changes resulting from GPU's merger with FirstEnergy and the appointment of a Vice President for Oversight. The "Summary of Change" on pages 3 and 4 of the enclosed document provides a description of all changes made with revision 4.

Should you have any questions or require additional information, please contact James Byrne at (717) 948-8461.

Sincerely, George A Kuehn Enclosure Revision 4 of SNEC Facility QA Plan cc: NRC Project Manager NRC Project Scientist, Region 1

(NPU NUCLEAR GPU NUCLEAR CORPORATE Number PAT TCTV Ag PRO"CEDUIRE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation FacilityDecommissioning Revision No.

Quality Assurance Plan 4 Applicability/Scope Responsible Office GPU Nuclear and Saxton Nuclear Experimental Corporation Wide Nuclear Oversight This document is within QA plan scope U Yes 0 No Effective Date Safety Reviews Required [3 Yes K No 0102003 List of Effective Pages Page Revision 1 4 2 4 3 4 4 4 5 4 6 4 7 4 8 4 9 4 10 4 11 4 12 4 13 4 14 4 15 4 16 4 17 4 is 4 19 4 20 4

_ Signature [ Concurring Organization Element Date Originator 3 jZ r Document Owner - /

Concurred Zed:,& Progr Director, SNEC Facility I/,/V/* .

Approved CA I(1i'$Q Vice President GPU Nuclear Oversight .

1 2

3000-05R2 7v1k0

C -7 NLPU NUCLEAR GPU NUCLEAR CORPORATE Number POIJCY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

Quality Assurance Plan 4 DOCUMENT HISTORY REV

SUMMARY

OF CHANGE DATE 0 Original Revision 04/03/96 04/20/98 1 In responding to the questions raised by the NRC's review of this plan, GPU Nuclear agreed to make three changes to the document. The first change is to add a requirement to section 3.1 of the plan, which requires NRC review of changes to this plan. The second change consists of providing more detail of the minimum content of inspection records as defined in section 18.1 of the plan. The final change adds Appendix A to the plan to provide a detailed list of the Quality Assurance Regulatory Guides utilized to implement the plan. An additional change was made to Section 2.3.3 to reflect the reorganization of the Financial and Planning Division, and changes were made throughout Section 2.3 to reflect a reorganization of GPU Nuclear Divisions.

2 1. Remove the concurrence signature of the Director, TMI from the procedure cover page.

2. Revise step 2.3.3 (GPUN Nuclear Director, Engineering), to include the attributes listed in step 2.3.4 (GPU Nuclear Director, Three Mile Island).

3. Delete step 2.3.4 (GPU Nuclear Director, Three Mile Island).

4. Renumber subsequent procedural steps2.3.5 through 2.3.9 as required.

NOTE: the reference to TMI documents in section 4.3, is still valid as the documents in question have been incorporated into Saxton activities as is.

Subsequent revisions and/or deletions to or of the originals will not affect their application at Saxton 2 of 20

(Ž'PU NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

Quality Assurance Plan 4 3 This revision to the Saxton Nuclear Experimental Corporation Facility Decommissioning Quality Assurance Plan is necessary to reflect the reduced scope and size ofthe GPU Nuclear organization and the reciprocal services agreement with AmerGen.

1. Change "Director, Nuclear Safety Assessment" to "GPU Nuclear Cognizant Officer" throughout the entire document.

2. Change "Office of the President" to "GPU Nuclear Cognizant Officer" throughout the entire document.

3. Delete references to "Nuclear Safety Assessment Department" throughout the entire document.

4. Section 1.0--Delete the reference to the GPU Nuclear Operational Quality Assurance Plan and 10CFR71 for the packaging and transportation of radioactive waste.

5. Section 2.2-Add a description of The GPU Nuclear corporate structure and the reciprocal services agreement with AmerGen owned TMI-1 following the sale ofthe Oyster Creek Nuclear Generating Station to AmerGen.

6. Section 23--Delete specific QA Responsibilities from the QA Plan and reference the organizational elements to GPU Nuclear Organization Plan, the SNEC Technical Specifications, and the Updated Safety Analysis Report for SNEC.

7. Section 19.4--Delete "GPU Nuclear, Director, Engineering" and change "Radiation Safety Committee" to "TMI-2/SNEC Oversight Committee."

8. Section 20-Add Section 20.0, "CONTROL OF RADIOACTIVE WASTES OR MATERIALS" 4 This revision to the Saxton Nuclear Experimental Corporation Facility Decommissioning Quality Assurance Plan is necessary to reflect the organizational changes resulting from the merger with FirstEnergy and appointment of a Vice President for Oversight.

1. Section 2.2 - Modifies the description of the SNEC Organization and deletes reference to the recipocal services agreement with AmerGen

2. Section 2.3 - Change to reflect the new title of the revised Organization Plan

3. Section 3.1 - Change to reflect that the plan is issued under the authority of the Vice President GPU Nuclear Oversight rather than the Cognizant Officer 3 of 20

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4. Section 8.4 - Change GPU Nuclear to authorized by the Vice President GPU Nuclear Oversight

5. Section 19.4- Changed to reflect the new organization by deleting the SNEC President and inserting the Vice President GPU Nuclear Oversight.

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NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

Quality Assurance Plan 4 1.0 POLICY STATEMENT It is the policy of GPU Nuclear to conduct decommissioning activities in such a manner as to ensure protection of the health and safety of the public and the personnel on site. To implement this policy, GPU Nuclear will adhere to the Quality Assurance (QA) requirements established in this Decommissioning Quality Assurance Plan and shall comply with, and be responsive to, applicable federal, state and local requirements; I0CFRl9, 10CFR20, 10CFR21 and appropriate sections of 10CFR50; applicable industry codes and standards; and commitments made to the U.S. Nuclear Regulatory Commission. Appendix A of this document provides a detailed listing of the Quality Assurance Regulatory Guides, and associated ANSI Standards, which are required to implement this plan.

Project procedures shall provide for compliance with appropriate regulatory, statutory, license, and industry requirements. Specific quality assurance requirements and organizational responsibilities for implementation of these requirements shall be specified.

Compliance with this QA program and provisions of project procedures is mandatory for personnel with respect to decommissioning activities which may affect quality or the health and safety of project personnel or the general public. Personnel shall, therefore, be familiar with the requirements and responsibilities of the QA program that are applicable to their individual activities and interfaces.

2.0 ORGANIZATION AND FUNCTIONAL OA RESPONSIBILITIES 2.1 General The persons and organizations performing QA functions report to a management level that assures the required authority and organizational freedom are provided, including sufficient independence from cost and schedule. The individuals assigned the responsibility for assuring effective execution of any portion of the QA Plan have direct access to the levels of management necessary to perform QA functions.

2.2 Organization The Saxton Nuclear Experimental Corporation (SNEC) facility organization is structured on the basis that the attainment of the objectives of the QA Program relies on those who manage, perform, and support the activities within the scope of this plan; and assurance of this attainment relies on those who have no direct responsibility for managing or performing the activity.

Specific QA requirements and organizational responsibilities for implementation of these requirements shall be specified in various implementing procedures and other documents. The requirements stipulated in the QA Program shall be imposed on all personnel and organizations, including contractors, who perform the decommissioning activities referenced in Section 3.0.

The SNEC Organization is defined in the GPU Nuclear/Saxton Nuclear Experimental Corporation Organization Plan. The GPU Nuclear Cognizant Officer for SNEC will have overall responsibility for decommissioning the facility and will maintain final authority over facility decisions.

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(GPU NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

Quality Assurance Plan 4 2.3 Functional QA Responsibilities The organizational elements responsible for decommissioning activities at SNEC are outlined in the following controlled documents: The GPU Nuclear/Saxton Nuclear Experimental Corporation Organization Plan, the SNEC Technical Specifications, and the Updated Safety Analysis Report for SNEC.

3.0 DECOMMISSIONING QUALITY ASSURANCE PROGRAM 3.1 General This Decommissioning Quality Assurance Plan is the highest GPU Nuclear document which provides the generic and some specific requirements and methods to control activities. The term "Program" as used herein includes this Plan and the approved documents which are used to implement this Plan. This Plan is implemented through such approved documents.

The Saxton Nuclear Experimental Corporation Facility Decommissioning Quality Assurance Program has been established to control the activities performed by GPU Nuclear, and its contractors, within the scope of this Plan. This control is exerted primarily through the provision of, and compliance with, implementing documents and assurance that such documents are adequate and consistently used.

Adherence to the requirements of this Plan is mandatory for all GPU Nuclear organizations and for all external organizations providing items, parts, materials, or conducting activities which are within the scope of this Plan.

This Plan shall be issued under the authority of the Vice-President GPU Nuclear Oversight. All changes to the Plan shall be approved by the Vice-President GPU Nuclear Oversight. Revisions to this plan will be submitted to the NRC; prior to the implementation of changes which involve a reduction in commitments previously accepted by the NRC and after implementation of changes having no reduction in commitment.

3.2 Scope The scope of this Plan includes radiological safety and implementation of the regulations as committed to in Section 1.0 of this Plan. To ensure consistency in identifying those items, parts, materials and activities within the scope of this Plan, a classification process shall be developed and documented. This process relies on the use of the term "QA Plan Scope".

3.2.1 A Quality Classification process for items shall be developed. This classification process shall produce a Quality Classification List which identifies the permanent plant structures, systems, and components that are within the scope of this Plan. New items to which this Plan applies shall be added to the Quality Classification List subsequent to their installation.

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Quality Assurance Plan _ _4 3.2.2 Activities within the scope of this Plan are those directly related to radiological safety and implementation of the regulations as committed to in Section 1.0 of this Plan. These activities are delineated below.

Support activities within the scope of this Plan are system/component/part classification, design, procurement, fabrication, handling, shipping, storage, cleaning, erecting, installing, testing, repairing, training, welding, in-service inspection, heat treatment, document control and records management.

Decommissioning activities within the scope of this Plan are equipment control, surveillance testing, functional testing, maintenance (including lifting and handling which could jeopardize operability of QA Plan Scope equipment or whose potential drop could have adverse radiological impact), housekeeping, fire protection, radiological controls, radiological environmental monitoring, technical specification compliance and emergency preparedness.

Assurance activities within the scope of this Plan are audit, inspection, non-destructive examination, monitoring, surveillance, and safety review. Assurance activities are performed by individuals who are not directly responsible for managing or performing the work or activity. Assessment personnel, who are independent of the organization performing the work or activity, perform periodic assessments of the assurance activities to assure effectiveness and adequacy.

The above activities are controlled through the use of approved documents, which are, as a minimum, consistent with the requirements of this Plan. This Plan shall remain in effect throughout the decommissioning project Activities affecting quality shall be accomplished under suitable controlled conditions.

Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied.

3.3 Training The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. The program shall take into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification of satisfactory implementation.

3.3.1 Training programs shall be established for those personnel performing quality affecting activities such that they are knowledgeable in the quality assurance program and proficient in implementing these requirements. These training programs shall assure the following:

a. Personnel responsible for performing these activities are instructed as to the purpose, scope, and implementation of applicable procedures.

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b. Personnel performing such activities are trained and qualified, as appropriate, in the principles and techniques of the activity being conducted.

c. The scope, objective, and method of implementing the training are documented.

d. Methods are provided for documenting training sessions describing content, attendance, date of attendance, and the results of the training session, as appropriate.

4.0 PROCEDURES AND DRAWINGS 4.1 Procedures, and drawings of a type appropriate to the circumstances, shall be provided for the control and performance of activities which affect quality, health and safety of the public or project personnel, or regulatory requirements.

4.2 Procedures and drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

4.3 A procedure shall be implemented to control and delineate the requirements for the review and approval of documents implementing the requirements of this plan. These documents typically include, but are not limited to, those termed plans, procedures, instructions, drawings, and specifications. This procedure shall include the review and approval requirements for the implementation of documents not specifically written for the site decommissioning activities (eg. vendor documents, TMI documents, or Oyster Creek documents). This review must consider the appropriateness of the document for work at the site, and must ensure the document complies with higher tier site documents.

4.3.1 The following typical procedures shall be provided as appropriate:

Calibration procedures, Radiation protection procedures, Special process procedures, Maintenance procedures, Dismantlement procedures, Audit procedures, Administrative control procedures, Emergency procedures, Rigging, lifting and handling, Inspection procedures.

5.0 DESIGN CONTROL 5.1 When decommissioning activities require design, or modification of existing design, controls shall be applied commensurate with the potential impact on quality or health and safety of project personnel and the general public.

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Quality Assurance Plan 4 5.2 Appropriate provisions of design control shall include the specifying of design input, the correct translation of input in design documents, the verification of design by persons other than the originator, and the assurance that changes to the design beyond design tolerance are properly reviewed and controlled.

6.0 PROCUREMENT DOCUMENT CONTROL 6.1 Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by GPU Nuclear or by its contractors or subcontractors. To the extent necessary, procurement documents shall require contractors or subcontractors to provide a quality assurance program consistent with the contractor's potential impact on quality or the health and safety of project personnel and the general public.

6.2 Procurement documents shall contain specific technical and quality requirements, as appropriate.

6.3 Procurement documents shall contain provisions which establish the right of access to vendor facilities and records for source inspection and audits as appropriate.

6.4 Documents, and changes thereto, initiating procurement of equipment, components, or services shall be approved by appropriate management personnel and shall be subject to a quality review to ensure applicable regulatory requirements, design bases, quality assurance, and other requirements are adequately satisfied prior to release.

7.0 DOCUMENT CONTROL 7.1 Measures shall be established to control the issuance of documents, such as procedures and drawings, including changes thereto, which prescribe activities affecting quality.

7.2 These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel, and are distributed to and used at the location where the prescribed activity is performed.

7.3 Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval or another designated responsible organization.

7.4 Procedures within the scope of this Plan shall be controlled to assure that current copies are made available to personnel performing the prescribed activities. These procedures shall be reviewed by a technically competent person other than the preparer, and shall be approved by a management member of the organization responsible for the prescribed activity.

7.5 Significant changes to procedures within the scope of this Plan shall be reviewed and approved in the same manner as the original.

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Quality Assurance Plan 4 8.0 CONTROL OF PURCHASED MATERIAL. EQUIPMENT. AND SERVICES 8.1 Measures shall be established to assure that purchased material, equipment and services conform to the procurement documents. These measures shall include provisions, as appropriate, for vendor evaluation and selection, objective evidence of quality furnished by the vendor, inspection at the vendor source, and inspection of products upon delivery.

8.2 The effectiveness of the control of contractor services shall be assessed at intervals consistent with the importance of the service.

8.3 The adequacy of vendor's quality assurance program specified in procurement documentation shall be verified prior to use when appropriate. Vendors' adherence to their quality assurance program shall also be verified as appropriate.

8.4 Commensurate with potential adverse impacts on quality or health and safety, material and equipment shall be inspected upon receipt at the SNEC facility or other sites authorized by the Vice President GPU Nuclear Oversight prior to use or storage to determine that procurement requirements are satisfied.

8.5 Measures shall be established for identifying nonconforming material, parts and components.

9.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 9.1 Measures shall be established for the control of materials, parts, and components which are within the scope of this Plan.

9.2 These identification and control measures shall be designed to prevent the use of incorrect or defective material, parts and components.

10.0 CONTROL OF SPECIAL PROCESSES 10.1 Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive examination are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

10.2 Welding of equipment within the scope of this Plan shall be performed in accordance with qualified procedures. Such procedures shall be qualified in accordance with applicable codes and standards and shall be reviewed to assure their technical adequacy.

10.3 Measures shall be established that assure welding of equipment within the scope of this Plan is performed by qualified personnel.

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Quality Assurance Plan 4 10.4 Nondestructive examinations (NDE) of equipment within the scope of this Plan shall be performed in accordance with procedures formulated in accordance with applicable codes and standards and shall be reviewed to assure their technical adequacy.

10.5 Measures shall be established that assure NDE is performed by personnel qualified in accordance with applicable codes and standards.

11.0 INSPECTION 11.1 Measures shall be established for review of appropriate activities to verify conformance with the documented procedures and drawings for accomplishing the activity.

11.2 If mandatory inspection hold points, which require witnessing or inspection and beyond which work shall not proceed without prior consent are required, the specific hold points shall be indicated in appropriate documents. The document containing the inspection hold points shall be reviewed prior to implementation by the organization required to perform the inspection.

11.3 Measures shall be established which assure that activities associated with technical services (such as surveillance testing, instrument calibration, laboratory services, etc.) are reviewed, when determined appropriate, by qualified personnel.

11.4 Required inspections shall be performed in accordance with appropriate procedures. Such procedures shall contain a description of objectives, acceptance criteria and prerequisites for performing the inspections. These procedures shall also specify any special equipment or calibrations required to conduct the inspection.

11.5 Personnel performing required inspections shall be qualified based upon experience and training in inspection methods. Required inspections shall not be performed by individuals who performed the inspected activity or directly supervised the inspected activity.

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2GPU NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

Quality Assurance Plan 1_4 12.0 TEST CONTROL 12.1 A documented test program shall be established to assure that all required testing is performed to demonstrate that the structures, systems or components within the scope of this Plan will perform satisfactorily in service. The tests shall be performed in accordance with written, approved, and controlled test procedures or instructions which incorporate or reference the requirements and acceptance standards contained in the applicable design documents. The extent of the testing shall be based on the complexity of the modification, replacement, or repair. Testing shall include proof tests prior to installation, hydro testing, functional testing and preoperational tests.

13.0 CONTROL OF MEASURING AND TEST EQUIPMENT 13.1 Measures shall. be established to assure that tools, gauges, instruments and other measuring and testing devices used in activities affecting quality or important to the protection of health and safety are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within necessary limits.

14.0 HANDLING. STORAGE. AND SHIPPING 14.1 Measures shall be established and documented to control handling, storage, and shipping, including cleaning, packaging, and preservation of items within the scope of this Plan in accordance with established instructions, procedures, and drawings to prevent damage, deterioration, or loss.

15.0 INSPECTION. TEST, AND OPERATING STATUS 15.1 Inspection, test, and operating status of equipment and components within the scope of this Plan shall be established based upon the following criteria:

a. Inspection, test, and operating status for equipment within the scope of this Plan shall be indicated and controlled by established procedures.

b. Status of such equipment shall be indicated by tag, label, marking or log entry.

c. Status of nonconforming parts, components, or materials shall be positively maintained by established procedures.

16.0 NONCONFORMING MATERIALS. PARTS OR COMPONENTS 16.1 Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition and notification to affected organizations.

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Quality Assurance Plan 4 16.2 Nonconformance items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.

17.0 CORRECTIVE ACTION 17.1 Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, discrepancies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

17.2 The identification of the condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

18.0 OUALITY ASSURANCE RECORDS 18.1 Sufficient records shall be maintained to furnish evidence of activities affecting quality (eg. inspection reports, receipt inspection documents, engineering evaluations, monitoring reports etc.). These records shall document, when applicable, the identification of the individual generating the document or the data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.

18.2 Records shall be identifiable and retrievable.

18.3 Requirements shall be established concerning record retention, such as duration, location, and assigned responsibility. Such requirements shall be consistent with the potential impact on quality, health and safety of the public, safety of project personnel, and applicable regulations.

18.4 Measures shall be established which assure that qualification records of personnel performing special process activities, such as welding, NDE, inspection, etc., are retained.

18.5 Measures shall be established which assure that quality related procurement documents are retained.

18.6 Measures shall be established which assure that appropriate records pertaining to audits are retained.

18.7 Measures shall be established which assure that records associated with personnel exposure control are retained.

19.0 AUDITS 19.1 A program of assessment will be conducted The assessment program will combine elements of monitoring and auditing to assess the adequacy of performance for activities within the scope of this Plan.

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Quality Assurance Plan 4 19.2 Planned audits shall be conducted to verify compliance with appropriate requirements of the Program and to determine its effectiveness. The audits shall be performed in accordance with written procedures or checklists by appropriately qualified personnel not having direct responsibility in the areas being audited. Audit results shall be documented, and reviewed by management having responsibility in the area audited. Follow-up action, including re-audit of discrepant areas, shall be taken where indicated.

19.3 Reports of the results of each audit shall be prepared. These reports shall include a description of the area audited, identification of individuals responsible for implementation of the audited provisions and for performance of the audit, identification of discrepant areas, and recommended corrective action as appropriate.

19.4 Audit reports shall be distributed to the GPU Nuclear Chief Nuclear Officer, the GPU Nuclear Cognizant Officer for SNEC , the Vice-President GPU Nuclear Oversight, the TMI-2/SNEC Oversight Committee, and to those individuals responsible for implementation of audited provisions.

19.5 Measures shall be established which assure that discrepancies identified by audits or other means are resolved. These measures shall include notification of the manager responsible for the discrepancy, recommended corrective action, and verification of satisfactory resolution. Discrepancies shall be resolved by the management responsible for the discrepancy. Line management should resolve disputed discrepancies. If line management is not capable of resolving disputed discrepancies, the resolution shall be escalated to the next level of management until the disputed discrepancy is resolved.

19.6 Monitoring is used to establish adequate confidence levels that activities within the scope of this Plan are being performed in accordance with the QA Program requirements and plant administrative controls.

Monitoring will be performed and the degree of monitoring performed shall be based typically upon the status and safety significance of activities, extent of previous experience, thoroughness of overall coverage, uniqueness of the activity, and trending data.

19.7 Monitors shall be qualified in accordance with a documented procedure that ensures Monitors are knowledgeable in the activities they are monitoring to the extent that they can readily verify compl'ince of the activity performed.

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Quality Assurance Plan 4 20.0 CONTROL OF RADIOACTIVE WASTES OR MATERIALS 20.1 General 20.1.1 Measures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71, Title 10, Part 20, and Title 49, Parts 100 through 199 applicable to the packaging and transporting of radioactive wastes or materials are satisfied.

20.1.2 Subpart H to 10CFR71 identifies the quality assurance criteria applicable to the control of packaging to be utilized to ship radioactive wastes or materials. The portions of this Plan that relate to the criteria in Subpart H to 10CFR71 describe to a large extent the administrative controls and quality requirements to be applied in the control, packaging and transportation of radioactive waste or material.

20.1.3 It is the policy of GPU Nuclear to minimize the generation of radioactive waste consistent with the ALARA concept to minimize personnel exposures and environmental contamination.

20.1.4 Title 10, Part 20, requires that a quality control program be implemented to verify compliance with Title 10, Part 61.55 (Waste Classification) and Title 10, Part 61.56 (Waste Characteristics). This Plan will be implemented to the extent necessary to assure compliance with those Parts of Title 10 using a graded approach.

20.2 Requirements 20.2.1 Procedures and administrative controls shall be developedand implemented to cover the following:

a. Processing of radioactive wastes including the collection, handling and preparation for shipment of radioactive liquids and solids. These procedures shall be consistent with the ALARA program and shall clearly identify the administrative controls and organizational responsibilities.

b. Training and qualification of personnel operating radioactive waste processing equipment, health physics monitoring, packaging and shipping (which includes Waste Classification and establishment of Waste Characteristics) and other operations deemed appropriate by management.

c. The activities associated with the packaging of radioactive wastes or materials to include the proper selection of the receptacles to be used for containing the waste materials, the selection of the shipping containers (structures used to contain and support the receptacle and its contents), establishment of Waste Characteristics, Radiological control inspections of the packaging prior to release, proper markings on the outside of the package and the preparation of shipping papers and certificates.

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Quality Assurance Plan 4 The activities shall be in accordance with 10CFR20, 10CFR61, 10CFR71, and 49CFR.

d. Movement of radioactive wastes or materials to assure personnel protection at all times.

e. The shipment of radioactive wastes or materials from the Station to be in accordance with the regulations of the U.S. Department of Transportation for the transportation of hazardous materials (49CFR) and of the NRC (10CFR71 and IOCFR20).

f. Design, fabrication, assembly, testing and modification of packaging used for transportation of radioactive waste or material which exceed the limits specified by 10CFR71.10 shall not be performed by GPU Nuclear. Such packaging shall be purchased from an outside supplier and shall comply with IOCFR71 and 49CFR.

GPU Nuclear shall review and accept designs of packaging purchased from an outside supplier.

g. The packaging used for transporting of radioactive waste or material, which does not exceed the limits specified in 10CFR71.10, whether purchased from an outside supplier or designed by GPU Nuclear, shall meet 49CFIL

h. Minimization of the generation of radioactive wastes through training programs, prudent scheduling and use of equipment and personnel and good housekeeping practices.

20.2.2 The carriers to be used for transporting of radioactive waste or material shall be selected on the basis of their experience, knowledge of DOT regulations, control and maintenance of their equipment and the selection and control of their drivers. The carrier is required to have or shall be supplied documented procedures covering acceptance of radioactive waste or material from a shipper, certification requirements, placarding, storage control, reporting of incidents and security. GPU Nuclear shall review and accept carrier procedures specified by procurement documents covering the acceptance of radioactive waste or material for shipment.

20.2.3 Operations involving radioactive waste processing or radioactive material shall be controlled to minimize personnel exposures or environmental contamination consistent with ALARA.

20.2.4 Operations procedures relating to radioactive waste or material shipping and packaging shall be reviewed by Quality Verification to establish any necessary inspection points.

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Quality Assurance Plan 4 APPENDIX A COMMITMENT TO OUALITY ASSURANCE REGULATORY GUIDES FOR SNEC FACILITY DECOMMISSIONING DEGREE OF REG. GUIDE ANSI STD. COMPLIANCE REMARKS 1.58 9/80, Rev. I Qualifications of Nuclear N45.2.6 1978 Modified See attached Power Plant Inspection, comments Examination and Testing Personnel 1.88 10/76, Rev. 2 Collection, Storage and N45.2.9 1974 Modified See attached Maintenance of Nuclear comments Power Plant Quality Assurance Records 1.123 7/77, Rev. 1 QA Requirements for N45.2.13 1976 Modified See attached Installation, Inspection comments and Testing of Mechanical Equipment and Systems.

1.144 1/79 Requirements for N45.2.12 1977 Modified See attached Auditing of Quality comments Assurance Programs for Nuclear Power Plants 1.146 8/80 Qualification of Quality N45.2.23 1978 Full Comply with Assurance Program Regulatory Position Auditors for Nuclear Power Plants 17 of 20

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Quality Assurance Plan 4 APPENDIX A (Cont.)

NRC Regulatory Guide 1.58, Rev. 1. September 1980 Qualifications of Nuclear Power Plant Inspection, Examination, and Testing Personnel The SNEC Facility Decommissioning Quality Assurance Program complies with this guide with the following clarification:

I1. The guidance of Regulatory Guide 1.58 shall be followed as it pertains to the qualifications of inspection personnel who verify conformance of work activities to quality requirements. The qualification of other GPU Nuclear personnel shall be in accordance with GPU Nuclear established requirements.

No operational requirements of Regulatory Guide 1.58 will be implemented due to the cessation of operation and defueled status of the SNEC Facility.

The qualification of nondestructive testing personnel shall be in accordance with the requirements and recommendations of ASNT Recommended Practice No. SNT-TC-IA, 1980, Edition. In addition, SNT-TC-IA shall be used in conjunction with the additional provisions of the applicable ASME Boiler and Pressure Vessel Code. Later editions of SNT-TC-lA may be utilized as referenced in Section XI of the Code provided that the edition of the Code has been incorporated by reference into Title 10 of the Code of Federal Regulations, Part 50.55a.

Recertification of NDE Level El personnel shall be at an interval of every 5 years as noted by ASME Code Case N-341 and N-356 rather than the 3 year interval recommended by SNT-TC-lA, 1980.

Qualification and subsequent requalification of personnel conducting visual examination activities within the scope of the applicable ASME Section XI edition shall be performed consistent with that applicable ASME Section XI edition as further permitted and accepted by ASME Section XI Code Cases associated with qualification in visual examination endorsed by the current revision of Regulatory Guide 1.147.

2. Not all personnel who:

a. Reviewed and approved inspection and testing procedures,

b. Evaluate the adequacy of activities to accomplish the inspection and test objectives, C. Evaluate the adequacy of specific programs used to train and test inspection and test personnel,

d. Certify Level Ill individuals in specific categories or classes, will be certified as meeting the Level MI capability requirements of ANSI N45.2.6-1978.

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NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

Quality Assurance Plan 4 APPENDIX A (Cont.)

Rather these personnel will be determined by management through evaluation of their education, experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented.

NRC Regulatory Guide 1.88, Rev. 2. October, 1976 Collection, Storage and Maintenance of Nuclear Power Plant Availability Assurance Records GPU Nuclear will comply with the intent of this regulatory guide by compliance with the requirements of ANSI/ASME NQA-1-1979, Supplement 17S and Appendix 17A-1 including Appendix 17-1, NQA-IA-1981.

NRC Regulatory Guide 1.123, Rev. 1. July 1977 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants The SNEC Facility Decommissioning Quality Assurance Program complies with this guide with the following clarification:

1. Section C.3. A corrective action system may, depending upon complexity and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action is imposed on a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.

2. Section C.4. Applicable information concerning the method(s) of acceptance of an item or service will be made available to receiving inspection personnel.

3. Section 4.2a of ANSI N45.2.13-1976. When evaluation of a supplier is based solely on historical supplier data, these data will primarily include records that have been accumulated in connection with previous procurement actions. Data that includes experience of users of identical or similar products of the prospective supplier and product operating experience will be used if available.

4. Section 4.2 of ANSI N45.2.13-1976. In the special case of "commercial grade items" the supplier does not have to be evaluated by one of the methods identified; however, the procurement documents shall contain requirements specific to the item being procured.

5. Section 7.5. As a point of clarification, personnel who perform the audit(s) as described in Section 19.0 of this Plan will not be qualified in accordance with ANSI N45.2.6. Such personnel are qualified in accordance with Regulatory guide 1.146, dated 8/80.

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(GPU NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.

QuRlity Assurance Plan 4 APPENDIX A (Cont.)

6. Section 10.2d of ANSI N45.2.13-1976. The requirements of this section are interpreted as follows:

The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.

7. Section 10.2.1, Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows: The verification of the validity of supplier certificates and the effectiveness of the certification are accomplished as an integral part of the total supplier control and product acceptance program, and no separate GPU Nuclear system exists that addresses itself solely to such verification. The degree of verification required will depend upon the type of item or service and their safety importance. The means of verification may include source witness/hold points, source audits, and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such as concrete components; and tests after installation on selected components and systems. All of these means verify whether or not a supplier has fulfilled procurement document requirements and whether or not a certification system is effective.

NRC Regulatory Guide 1.144, January 1979 Auditing of Quality Assurance Programs for Nuclear Power Plants GPU Nuclear is in basic agreement with the position set forth in the Regulatory Guide subject to the following comments:

1. Section C.3a(l) and C.3a(2)

The frequency of performance and minimal topical coverage of internal audits will be consistent with the plant technical specifications.

2. Section C.3.b(1)

Source surveillance will be utilized in lieu of or in addition to receipt inspection. As permitted, external audits of such procurement actions will typically not be scheduled.

3. Section C3.b(2)

External audits of selected suppliers of services which are within the scope of this Plan will be scheduled and conducted at least once within the life of the activity or every three years.

An annual evaluation of suppliers of items and services will be conducted. These evaluations will be conducted utilizing the results of source surveillance, source inspection, receipt inspection and/or audits; and, other factors. These evaluations will determine the need to conduct audits of suppliers of items, parts or materials; or, increase the frequency of conducting audits of suppliers of services.

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