ML070430201

Yankee Decommissioning Quality Assurance Program Periodic Update

ML070430201
Person / Time
Site:	Yankee Rowe
Issue date:	06/22/2001
From:	Kay J Yankee Atomic Electric Co
To:	Document Control Desk, NRC/FSME
References
BYR 2001-051
Download: ML070430201 (72)

Text

YANKEE A TOMIC ELECTRIC COMPANY Telephone (508) 721-7736 Facsimile (508) 721-7743 J.

FSuite 200, 19 Midstate Drive, Auburn, Massachusetts 01501 TYAN KIE1E June 22, 2001 BYR 2001-05 1 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

References:

(a) Letter, M. Atkins (YAEC) to USNRC, BYR 1999-057, "Proposed Revision 29 to the Decommissioning Quality Assurance Program in Accordance with IOCFR50.54(a)(3)," dated August 31, 1999 (b) Letter, P. Ray (USNRC) to M. Atkins (YAEC), NYR 2000-045, "Yankee Nuclear Power Station - Quality Assurance Program Changes," dated June 20, 2000

Subject:

Yankee Decommissioning Quality Assurance Program Periodic Update Submittal In accordance with 10CFR50.54(a)(3) and 10CFR50.7 1(e), this letter transmits Revision 30 of the Yankee Decommissioning Quality Assurance Program (YDQAP) to the NRC for the periodic update. Revision 29 to the YDQAP was transmitted to the NRC on August 31, 1999 (Reference a) and was approved by the NRC on June 20, 2000 (Reference b).

Additional organizational, responsibility, program applicability and administrative changes were implemented during 1999 and 2000. These changes have been included in Revision 30 of the YDQAP and are described in Attachment A to this letter. The changes are arranged in a format, which coincides with the sections of the YDQAP.

These changes do not reduce the commitments within the YDQAP and continue to meet the requirements of 10CFR50, Appendix B. Attachment A provides reasons for the changes, but may not discuss re-formatting, typographical changes, in accordance with 10CFR50.54(a)(3).

Please note that Revision 30 of the YDQAP has been issued for use. A copy of Revision 30 showing the changes and the description of the change from Revision 29 is also provided in Attachment A for your information.

Page 2 of 2 If you have any questions, please contact Mr. James A. Kay, Manager of Regulatory Affairs, at 978 568-2302.

Sincerely, YANKEE ATOMIC ELECTRIC COMPANY James A. Kay Manager of Regulatory Affairs cc:

H. Miller, Regional Administrator, NRC Region I J. Hickman, Project Manager, NRC NRR M. Virgilio, Director, Office of Nuclear Material Safety and Safeguards

ATTACHMENT A YDQAP Summary of Changes - Revision 30 YDQAP Item No.

Section Change Description Reason for Change

1.

All Changed title of "Oversight Manager" To reflect organization As to "Nuclear Safety Manager" as change.

Applicable applicable.

2.

Policy Removed "Chairman" from title. Now To reflect Statement reads Chief Executive Officer and organizational change.

and Section 1 President.

3.

Section 1 Added "Vice President" as applicable To reflect throughout the document.

organizational change.

4.

Cover Sheet Changed personnel titles and names.

To reflect organizational changes.

5.

Table of Revised Table of Contents Appendix C To reflect title change.

Contents title.

6.

Amendment/

Added Revision 30 to the To provide a summary Revision Amendment/Revision Sheet and of the Revision 30 Sheet provides reason for change.

changes.

7.

All Revised headers and footers and text of Editorial changes As individual pages to Revision 30 and necessary to identify Applicable revised the issuance date of the Revision 30 as a document when applicable, controlled document.

8.

All Removed reference to Duke Engineering Editorial change.

As

& Services throughout the document.

Applicable

9.

All Revised DQAP to read YDQAP Editorial change.

As throughout the document.

Applicable

10.

Cover Sheet Changed reviewed by signature from To reflect Decommissioning Manager to Site organizational change.

Manager's.

11.

All Deleted Decommissioning Manager To reflect As when referenced next to Site Manager.

organizational change.

Applicable

12.

Policy Added the commitment to Regulatory To allow a graded QA Statement, Guide 7.10, Rev. 1.

approach for ISFSI.

Section I,Section II

13.

Section I Added responsibilities assigned to To reflect Decommissioning Manager.

organizational changes.

14.

Section I Changed IRC to read Independent To reflect Technical Review and Audit Committee Specification I Amendment 154

Attachment A Page 2 of 4 T YDQAP Item No.

Section Change Description Reason for Change

15.

Section I Removed Fuel Storage Oversight To reflect Manager paragraph.

organizational change.

16.

Section I Revised Organization Chart To reflect current organizational changes.

17.

Section I Added titles and responsibilities for Vice To reflect current President and ISFSI Oversight Manager.

organizational changes

18.

Section I Revised title of Oversight Manager to To reflect current Nuclear Safety Manager and revised organizational changes reporting chain from Chairman, CEO and President to Vice President.

19.

Section I Combined responsibilities of Quality To reflect current Assurance Manager under Nuclear -

organizational changes.

Safety Manager and removed reference to Quality Assurance Manager.

20.

Section II Added Item 15.

To reflect commitment to Regulatory Guide 7.10, Rev. 1.

21.

Section II Removed Note 2 and renumbered Note No longer applicable 3 to Note 2 for Decommissioning activities (covered by administrative procedures).

22.

Section II Item, E.4., Added "Periodic" and deleted To clarify training "re-examining, and/or recertifying" from requirements.

the sentence.

23.

Section II Moved statement *Exceptions and Format correction.

alternatives...... from under Item C.3 to directly under item C. 14.

24.

Section III Page 1, B. I and B.2, Specified To reflect responsibility of Site Manager organizational changes.

(Decommissioning Manager) and Independent Review and Audit Committee (IRAC).

25.

Section III B.2., Added "design activities" to the To clarify IRAC sentence.

responsibilities.

26.

Section IV B. 1., Specified responsibilities of the To reflect Site Manager (Decommissioning organizational changes.

Manager)

27.

Section IV C.2, Added 10CFR71, Subpart H and To reflect ISFSI license 1 OCFR72, Subpart G to sentence.

and design requirements.

Attachment A Page 3 of 4 YDQAP Item No.

Section Change Description Reason for Change

28.

Section IV C.3, Added sentence to end to provide a To reflect ISFSI records tie to Section XVII of the YDQAP.

needs.

29.

Section V Renumbered.

Format correction.

30.

Section V B.2.b., Added "instructions, procedures, To reflect Technical and drawings" to the sentence.

Specification Amendment 154.

31.

Section VI Corrected typos.

Editorial

32.

Section VII B. 1 and B.2 - reversed order.

Format correction.

33.

Section VII C.2 - combined a with b to form one Format correction.

sentence.

34.

Section VIII B.1 and B.2 - reversed order.

Format correction.

35.

Section VIII Combined responsibilities under B.2 and Provide more specific B.3 and assigned to Decommissioning assignment of Manager under B. 1. Renumbered responsibilities and paragraphs. Change Decommissioning addresses Manager to Site Manager.

organizational changes.

36.

Section IX B. 1.e, Revised entire sentence.

Editorial for readability.

37.

Section X B. 1 and B.2 - reversed order. L.a Format change.

deleted, other items renumbered.

38.

Section XI B. 1 and B.2 - reversed order. B. I Format change.

broken down into items a through d.

39.

Section XV B. 1, Separated the performance of Correct an error in audits/surveillances from the Site assignment Manager (Decommissioning Manager) responsibilities.

responsibilities and relocate to B.2 under Quality Assurance. Renumbered.

40.

Section XV C. 1.d - added sentence and renumbered Clarification.

41.

Section XVI C. 1 through C.4 Editorial changes.

42.

Section XVII B. 1 and B.2 - reversed order.

Format change

43.

Section XVII Added A.3 to address commitment to To address ISFSI record keeping requirements specified in requirements.

10CFR71.135 and 10CFR72.174.

44.

Section B. 1.d, Replaced NSARC with IRAC.

To reflect Technical XVIII Specification Amendment 154.

45.

Section B. 1.e Replaced the term "oversight" Editorial.

XVIII with Audits and surveillances

46.

Appendix A Changed title to read Qualification Reflect organizational Requirements for the Nuclear Safety changes.

Manager.

47.

Appendix B Revised first sentence.

Editorial.

48.

Appendix B Added Yankee to beginning of title.

Editorial.

Attachment A Page 4 of 4 YDQAP Item No.

Section Change Description Reason for Change

49.

Appendix B V.A, removed reference to Vermont Inadvertently left in Yankee.

after Revision 28 of YDQAP which removed Vermont Yankee from the Quality Assurance Program.

50.

Appendix B VII, Removed requirement to review Section VI of YDQAP routine plant procedures not used for addresses procedure two years.

maintenance.

51.

Appendix C Revised Appendix C to provide a listing To reflect ISFSI needs.

of SSCs Important to Safety.

52.

Appendix D Added Appendix D, "Administrative Replicated Sections 6.5, Controls.

6.7 and 6.9 of the Technical Specification Amendment 154.

53.

Throughout Minor editorial and format changes To standardize format and improve readability.

YANKEE ATOMIC ELECTRIC COMPANY DECOMMISSIONING QUALITY ASSURANCE PROGRAM YDQAP PREPARED BY:

REVIEWED BY:

APPROVED BY:

JOseph Fý. Bourassa Nuclear Safety Manager Brian C. Wood Site nagerDecommissioning Manager)

Ke6 nth.'Hider Vice President Russell Mellor Chief Execu ificer and President

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YDQAP 1

30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY

)

YDQAP TABLE OF CONTENTS/INDEX Section No.

Title Revision AMENDMENT/REVISION 30 POLICY STATEMENT 30 I

ORGANIZATION 30 II QUALITY ASSURANCE PROGRAM 30 III DESIGN CONTROL 30 IV PROCUREMENT DOCUMENT CONTROL 30 V

INSTRUCTIONS, PROCEDURES, AND DRAWINGS 30 VI DOCUMENT CONTROL' 30 VII CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND 30 SERVICES VIII IDENTIFICATION AND CONTROL OF MATERIAL, PARTS, AND 30 COMPONENTS IX CONTROL OF SPECIAL PROCESSES 30 X

INSPECTION 30 XI TEST CONTROL 30 XII CONTROL OF MEASURING AND TEST EQUIPMENT 30 XIII HANDLING, STORAGE, AND SHIPPING 30 XIV INSPECTION, TEST, AND OPERATING STATUS 30 XV NONCONFORMING MATERIALS, PARTS, AND COMPONENTS 30 XVI CORRECTIVE ACTION 30

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YANKEE ATOMIC ELECTRIC COMPANY YDQAP TABLE OF CONTENTS/INDEX (Continued)

Section No.

XVII XVIII APPENDIX A APPENDIX B APPENDIX C APPENDIX D Title QUALITY ASSURANCE RECORDS AUDITS QUALIFICATION REQUIREMENTS FOR THE NUCLEAR SAFETY MANAGER YANKEE DECOMMISSIONING QUALITY ASSURANCE PROGRAM EXCEPTIONS CLASSIFICATION OF SYSTEMS, STRUCTURES AND COMPONENTS ADMINISTRATIVE CONTROLS Revision 30 30 30 30 30 30

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YDQAP III 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY YDQAP AMENDMENT/REVISION SHEET Revision No.

0 (Amendment 1) 0 (Amendment 2) 1 2

3 4

5 6

6 (Amendment 1) 7 8

9 10 11 Date Reason 12/10/76 To address questions submitted by letter from NRC (K. R.

Goller) to L. H. Heider (11/1/76).

1/13/77 To address questions submitted by letter from NRC (K. R.

Goller) to L. H. Heider (12/28/76).

9/15/77 To address organizational, programmatic, and editorial changes.

11/01/77 To address organizational changes.

11/25/77 To address organizational changes at Vermont Yankee.

1/13/78 To address combined inspection numbers 50-29/77-20; 50-271/77-15; and 50-309/77-16 unresolved item 4.a.

1/30/78 To address change in exception for ANSI N45.2.3-1973.

10/19/78 To address exceptions to ANSI N45.2.2-1972.

3/29/79 To resolve items submitted by letter from NRC (W. P. Haass) to L. H. Heider (3/6/79).

9/11/79 To address changes to Yankee Rowe (Appendix D) and Vermont Yankee (Appendix E) Safety Classifications.

4/04/80 To address organizational changes.

3/09/81 To address organizational changes.

4/03/81 To add "Packaging of Radioactive Materials" and "Fire Protection of Safety-Related Areas"' to "Other Items Requiring Quality Assurance".

3/01/82 To resolve items submitted by letter from NRC(W. P. Haass) to W. P. Johnson (6/10/81).

12 13 14 15 16 3/11/83 10/12/83

.2/15/84 10/31/85 To address organizational changes.

To address organizational and programmatic changes.

To address organizational changes.

To address programmatic changes.

To address organizational and programmatic changes.

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YDQAP IV 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY YDQAP AMENDMENT/REVISION SHEET (Continued)

Revision No.

Date Reason 17 12/05/86 To address organizational and programmatic changes.

17A 8/14/87 To clarify surveillance activities and change VP-MOO responsibilities for the level of deficiencies requiring evaluation.

18 4/29/88 To address organizational and programmatic changes.

19 10/02/89 To address organizational and responsibility changes and deletion of Appendix C.

19A 6/01/90 To update organizational chart (for VY) to be consistent with Proposed Change No. 157 and to address organizational changes at Vermont Yankee.

20 12/21/90 To update organizational changes at Yankee and change QAD's responsibility from reviewing design documents to auditing those documents for inclusion of quality requirements.

21 11/15/91 To update organizational changes at Yankee and Vermont Yankee and change QAD responsibility from revising recommendations to prevent recurrences of significant condition adverse to quality to providing the option to review and/or audit recommendations.

22 4/15/92 To delete Appendix D listing and reference Yankee Safety Classification of Systems Manual.

23 9/30/92 To address organizational and responsibility changes.

24 12/15/93 To address organizational changes, and DQA/NSARC reporting clarifications for Vermont Yankee.

25 12/15/94 To address organizational changes made at the Yankee Nuclear Power Station addressing the decommissioning organization. Clarifications in the revised corrective action process at Vermont Yankee, and to address an exception to Regulatory Guide 1.64, and to clarify responsibilities between the Yankee and Vermont Yankee Plants.

26 12/21/95 To address organizational changes at the Yankee Nuclear Power Station and the Vermont Yankee Nuclear Power Station.

To address exceptions to ANSI 18.7 and Regulatory Guide 1.33.

27 12/20/96 To address organizational changes.

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YANKEE ATOMIC ELECTRIC COMPANY YDQAP AMENDMENT/REVISION SHEET (Continued)

Revision No.

Date Reason 28 28 29 30 5/30/97 To update organizational changes. Changed exception to Regulatory Guide 1.26 for VY only. (This was withdrawn in BYR 98-025, dated 4/14/98.)

10/16/98 Resubmit Rev. 28 to update organizational changes, delineate decommissioning organization and eliminate all references to Vermont Yankee Nuclear Power Corporation.

8/31/99 To update the Program to include 10CFR72 and to redefine responsibilities and requirements based on the current status of the plant.

8/17/00 Revised Appendix C to include listing of SSCs "Important to Safety." Added Appendix D, Administrative Controls. Updated the program to include a commitment to Regulatory Guide 7.10; 1 OCFR71.135; 1 OCFR72.174 and recent organizational changes. Made editorial comments throughout.

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YDQAP VI 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY POLICY STATEMENT DECOMMISSIONING QUALITY ASSURANCE PROGRAM It is the policy of the organizations operating under the Yankee Decommissioning Quality Assurance Program (YDQAP) to strive for excellence in all aspects of nuclear power plant decommissioning and spent fuel storage. This goal can only be attained if each individual recognizes that Quality is everyone's responsibility. Each worker, supervisor, and manager has a role to play in achieving the goal of "doing it right the first time." Only if we recognize that Quality is of paramount importance, can we continue to provide for safe decommissioning and fuel storage.

The YDQAP applies to activities associated with systems, structures and components which have been identified as important to safety and subject to the regulatory requirements of 10CFR71 and 10CFR72. This program complies with the requirements of 10CFR50, Appendix B, and satisfies the quality assurance program requirements of 10CFR71, Subpart H; and 10CFR72, Subpart G. Appendix C defines the systems, structures and components (SSCs) under the purview of this program.

Implementation of this program is achieved through the controls established in administrative procedures based on the requirements of this program and Regulatory Guide 7.10, Revision 1, dated 6/86. These controls are executed in a graded approach to an extent that is commensurate with the importance to safety.

The function of the Quality Oversight Program is to assess and communicate to management the adequacy, content, and appropriateness of the work being performed and to facilitate continuous improvements. However, supervision and management does not rely solely upon the efforts of the Quality Assurance Organization for quality oversight; they also take an active role in self-assessment of those activities under their control to identify problems. As previously noted, the ultimate responsibility for quality lies with each individual.

Under this program, The Yankee Atomic Electric Company (YAEC) Chief Executive Officer (CEO) and President is the final management authority responsible for assuring that the YDQAP is effectively implemented by the YAEC organization.

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1.

ORGANIZATION A.

SCOPE This section of the YDQAP describes the duties and responsibilities of the personnel involved in establishing and executing the YDQAP.

B.

RESPONSIBILITY The responsibility for decommissioning and safe spent fuel storage at the Yankee Nuclear Power Station (YNPS) rests with YAEC. The responsibility for developing and implementing the Quality Assurance Program for YNPS is vested in the CEO and President of YAEC. The CEO and President has delegated certain areas of authority for the development and implementation of this Program as set forth in the following paragraphs of this section.

The Quality Assurance Organization, reporting to the Vice President of YAEC, through the Nuclear Safety Manager, has the organizational responsibility for the continuing review and audit of the implementation of the YDQAP.

C.

ORGANIZATIONAL RELATIONSHIPS The lines of authority for personnel and functional positions involved in the implementation of the YDQAP are shown in Figure 1.

D.

QUALITY ASSURANCE PROGRAM RESPONSIBILITIES

1.

Chief Executive Officer and President The Chief Executive Officer (CEO) and President reports to the YAEC Board of Directors. This individual has overall responsibility for the development and implementation of the YDQAP, and for establishing an organization to ensure the effective implementation of the program. The CEO and President delegated the authority and responsibility for implementation of the YDQAP for the Yankee Atomic Electric Company to the Vice President. The Vice President is responsible for the development and implementation of the YDQAP.

)

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2.

Vice President The Vice President reports to the CEO and President. The Vice President is responsible for providing direction for development of the YDQAP and for ensuring the effective implementation of supporting policies and programs. The Vice President is responsible for maintaining an organization that is capable of ensuring the proper implementation of the YDQAP, resolving quality concerns, and ensuring the safe storage of spent nuclear fuel.

3.

Site Manager (Decommissioning Manager)

The Site Manager reports to the Vice President. The Site Manager is responsible for implementing the YDQAP and providing support services to the operating staff to store the spent nuclear fuel safely. The Site Manager is responsible for the safe operation of the site systems, structures, and components and for providing support activities required for safe operation, maintenance, and decommissioning of the facility. The Site Manager is also responsible for the administration of Engineering, Licensing, Health and Safety, Construction, Site Services, Radiation Protection, Training, Chemistry, Independent Spent Fuel Storage Installation (ISFSI), Radioactive Waste, and the Independent Safety Review (ISR) process.

The title Site Manager as discussed in the YDQAP is synonymous with the title Decommissioning Manager as discussed in the Defueled Technical Specifications and Appendix D.

4.

Nuclear Safety Manager The Nuclear Safety Manager reports to the Vice President and is responsible for the Quality Assurance function. This individual is also responsible for providing oversight of the implementation and maintenance of the YDQAP and associated implementing procedures. The Nuclear Safety Manager provides reviews and evaluations for compliance with state and federal regulatory requirements applicable to the YNPS. This individual ensures that the Quality Assurance Organization has sufficient organizational freedom and authority to: identify problems; to initiate, recommend or provide solutions through designated channels; verify implementation of solutions and stop unsatisfactory work. The Quality Assurance Organization performs audits, surveillances and inspection activities to verify compliance with the YDQAP; Licensing Requirements; 10CFR50, Appendix B; 10CFR71, Subpart H; 10CFR72, Subpart G; and other regulatory requirements.

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5.

Independent Review and Audit Committee (IRAC)

The IRAC is responsible for those activities defined in the approved Defueled Technical Specifications and Appendix D to this program. The Defueled Technical Specifications and Appendix D to this program also define the functional reporting requirements for this committee.

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Section I, Organization 3 of 4 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY ORGANIZATION CHART YAEC Board of Directors CEO and President Independent Review and Audit Committee (IRAC)

Vice President Site Manager Nuclear Safety Manager Quality Assurance Engineering Dry Cask/Spent Fuel Storage Licensing Radiation Protection/Radiological Waste Training Independent Safety Review (ISR)

Administrative Services Spent Fuel Pool Island Operation/Maintenance Lines of Communication

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Section I, Figure 1, Yankee Organization 4 of 4 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY I II.

QUALITY ASSURANCE PROGRAM A.

SCOPE This section of the YDQAP establishes the criteria to be applied to the systems, structures and components considered important to safety. These systems, structures and components are listed in Appendix C.

B.

RESPONSIBILITIES

1.

Compliance with the requirements of the YDQAP is the responsibility of personnel involved in quality effecting activities. The performance of quality affecting activities shall be accomplished in accordance with suitable instructions, procedures and drawings utilizing appropriate equipment under suitable environmental conditions.

Note:

Each section of the YDQAP identifies specific organizational responsibilities.

2.

Individuals having overall responsibility for the establishment/distribution control and implementation of the YDQAP are delineated in Section I "Organization" of the Program.

3.

The Quality Assurance Organization performs audits and/or surveillances and inspections of the implementation of this YDQAP criterion.

C.

IMPLEMENTATION Administrative procedures are developed to implement the YDQAP and control all activities in a graded approach to the extent necessary that is commensurate with the importance to safety. This graded approach is based in part on Regulatory Guide 7.10, Revision 1, dated 6/86 guidance. The following Regulatory Guides and ANSI Standards are also utilized, when applicable, to meet the requirements of the YDQAP. The Quality Assurance Organization shall review, by the use of audits, surveillances and inspections, admrinistrative procedures developed to implement the YDQAP.

1.

10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants

2.

ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of NucleE-r Power Plants (Endorsed by Regulatory Guide 1.33, Revision 2)

3.

ANSI N45.2.2-1972, Packaging, Shipping. Receiving, Storage and Handling of Items for Nuclear Power Plants (Endorsed by Regulatory Guide 1.38, Revision 2)

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Section II, Quality Assurance Program

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4.

ANSI N45.2.3-1973, Housekeeping During the Construction Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.39, Revision 2)

5.

ANSI N45.2.5-1974, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.94, Revision 1)

6.

ANSI N45.2.6-1978, Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.58, Revision 1)

7.

ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants (Endorsed by Regulatory Guide 1.88, Revision 2)

8.

ANSI N45.2.10-1973, Quality Assurance Terms and Definitions

9.

ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (Endorsed by Regulatory Guide 1.64, Revision 2)

10.

ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Program for Nuclear Power Plants (Endorsed by Regulatory Guide 1.144, Revision 1)

11.

ANSI N45.2.13-1976, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorsed by Regulatory Guide 1.123, Revision 1)

12.

ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Endorsed by Regulatory Guide 1.146, August 1980)

13.

ANSI N18.1-1971, Selection and Training of Nuclear Power'Plant Personnel (Endorsed by Regulatory Guide 1.8, Revision 1-R)

14.

Regulatory Guide 1.26, Revision 3, Quality Group Classifications and Standards for Water-, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants

15.

Regulatory Guide 7.10, Revision 1 (6/86). Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material

• Exceptions and alternatives to the provisions contained in this Standard/Guide are detailed in Appendix B.

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YANKEE ATOMIC ELECTRIC COMPANY Notes: 1) If conflicts are identified between the approved Technical Specifications, Appendix D, and any of the above listed documents, then the Technical Specifications take precedence.

2)

Only those documents listed above are considered applicable to the YDQAP.

Documents further referenced by the above listed documents shall not be considered applicable.

D.

MANAGEMENT EVALUATION The Vice President ensures the performance of periodic evaluations of the YDQAP. These reviews are performed to evaluate compliance with and the effectiveness of the YDQAP.

E.

TRAINING The Site Manager is responsible for indoctrination and training of staff personnel involved with YDQAP activities.

This indoctrination and training shall include the following:

1.

Instruction as to the purpose, scope, and implementation of applicable quality-related manuals, instructions, and procedures.

2.

Training and qualification in the principles and techniques of the activity being performed.

3.

Documentation of the training.

4.

Maintenance of personnel proficiency by periodic retraining.

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Section II, Quality Assurance Program 3 of 3 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY III.

DESIGN CONTROL A.

SCOPE This section of the YDQAP establishes measures to assure the control over the design of, and changes to, SSCs under the purview of the YDQAP.

B.

RESPONSIBILITIES

1.

The Site Manager shall ensure the following:

a.

The control of design activities for applicable SSCs, including the requirement for an independent review. This review shall be performed by an uninvolved, technically knowledgeable person from the applicable engineering discipline.

b.

Identification, documentation, and control of deviations from specified design requirements and/or quality standards.

c.

The appropriate review and approval of proposed plant changes.

d.

Design analysis and delineation of acceptance criteria for inspections and tests when required.

e.

Verification of the adequacy of a specific design feature by implementation of a prototype test when required.

f.

Review of inspection and test data for compliance with established engineering criteria when required.

2.

IRAC shall review design activities as required by the approved Technical Specifications and Appendix D.

3.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Correct translation of applicable regulatory requirements and design basis into specifications, drawings and written documents.

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2.

Application of suitable design controls to such activities as seismic, stress, thermal, hydraulic, radiation, and accident analyses; compatibility of materials; and accessibility for inservice inspection, maintenance and repair.

3.

Design reviews to assure that design characteristics can be controlled, inspected and tested.

4.

Identification of appropriate methods for and accomplishment of design verification such as design reviews, alternate calculations, qualification testing or test programs. If a test program is used to verify the adequacy of a design, then a qualification test of a prototype unit under the most adverse design conditions shall be used. The responsibilities and qualifications of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation are identified in procedures.

The criteria that specifies when the verification should be performed by test will be provided in procedures. If the verification method is by test only, the the prototype, component, or feature testing will be performed in accordance with written procedures prior to relying upon the SSC to perform its intended safety function.

5.

Changes to design and specifications will be subject to the same design controls and approvals that were applicable to the original design unless delegated in writing to another responsible organization.

6.

Documenting errors and deficiencies in the design process that adversely affect SSCs important to safety and the performance of corrective action to preclude repetition.

7.

Review of standard "off-the-shelf" commercial or previously approved materials, parts, and equipment that are essential to the quality functions of systems, structures and components, for suitability of application prior to selection.

8.

Selection of suitable materials, parts, equipment, and processes for important to safety SSCs.

9.

Establishment of procedures to assure that computer programs are verified and validated for a particular application.

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YANKEE ATOMIC ELECTRIC COMPANY IV.

PROCUREMENT DOCUMENT CONTROL A.

SCOPE This section of the YDQAP establishes the measures necessary to assure that applicable regulatory requirements, design basis 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.

B.

RESPONSIBILITIES

1.

The Site Manager shall ensure the following:

a.

The preparation of detailed procedures as to how purchase documents are prepared, reviewed, approved, issued, and controlled.

b.

The preparation of engineering specifications which detail the technical and quality requirements for material, equipment and services.

c.

The integration of appropriate quality assurance requirements into procurement requisitions

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

The review and approval of procurement documents will be documented prior to release. This documentation will be maintained for verifidation.

2.

Identification of applicable quality assurance requirements of 10CFR50, Appendix B; 10CFR71, Subpart H; and 10CFR72, Subpart G, and/or ANSI N 18.7, and/or other applicable codes, standards or regulatory documents referenced in procurement documents which are to be reviewed by the qualified personnel.

Title:

Section IV, Procurement Document Control Page:

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3.

Identification in the procurement documents of applicable quality assurance records requirements to be: prepared; maintained; and/or submitted to the purchaser. These requirements are identified in Section XVII of this manual and include the following examples:

a.

Drawings, specifications, procedures

b.

Inspection and fabrication plans

c.

Inspection and test records

d.

Personnel and procedure qualifications

e.

Chemical and physical test results of material

4.

Ensuring that procurement documents include requirements for the right of access to the vendor's facilities and records for the purposes of audit, surveillance or inspection.

5.

Review and approval of changes and revisions to procurement documents at least equivalent to those for the original document.

6.

Control of procurement documents for spare and replacement parts at least equivalent to that used for the original equipment.

Section IV, Procurement Document Control 2 of 2 30 August 2000

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YANKEE ATOMIC ELECTRIC COMPANY V.

INSTRUCTIONS, PROCEDURES, AND DRAWINGS A.

SCOPE This section of the YDQAP establishes the measures for prescribing and accomplishing activities requiring quality assurance in accordance with approved instructions, procedures, and drawings.

B.

RESPONSIBILITIES

1.

The Site Manager is responsible for ensuring appropriate administrative procedures to control activities affecting quality are established and followed.

2.

Persons preparing and approving documents are responsible for assuring that specifications, instructions, procedures, and drawings include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished; assuring that the applicable criteria of 10CFR50, Appendix B which satisfies the requirements of 10CFR71, Subpart H and 10CFR72, Subpart G and/or ANSI N18.7 are specified; and assuring that the documents are kept current. In addition, the following organizational positions have the specific responsibilities identified below:

a.

The Site Manager shall be responsible for ensuring the preparation, approval, maintenance, and implementation of all instructions, drawings, and procedures associated with plant and contracted service and activities.

b.

Independent Safety Reviewers (ISRs) shall be responsible for reviewing those instructions, procedures and drawings defined in the approved Technical Specifications and Appendix D.

3.

The Quality Assurance Organization performs audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Establishment of provisions which clearly delineate the sequence of actions to be accomplished in the preparation, review, approval, and control of instructions, procedures, and drawings.

Title:

Section V, Instructions, Procedures, and Drawings Page:

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2.

Review of quality affecting procedures, drawings and specifications and changes thereto by knowledgeable personnel.

Section V, Instructions, Procedures, and Drawings 2 of 2 30 August 2000

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YANKEE ATOMIC ELECTRIC COMPANY VI.

DOCUMENT CONTROL A.

SCOPE This section of the YDQAP establishes the measures for controlling the issuance of documents, including revisions thereto, which affect quality activities.

B.

RESPONSIBILITIES

1.

The Site Manager shall ensure document control measures are established which provide for the following:

a.

Identification of controlled documents utilized for performing quality activities.

b.

Identification of organizations responsible for preparation, review, approval, and control of documents used in performing the activity.

c.

Coordination and control of interface documents.

d.

Establishment of distribution lists.

e.

Action to be taken for obsolete or superseded documents.

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Review and approval of document changes by the same organizations that performed the original review and approval or by other responsible organizations delegated by the controlling authority.

2.

Inclusion of approved changes in instructions, drawings, and other applicable documents prior to placing the system in operating status.

3.

Provision to allow availability of documents, as needed, at the location where the activity is to be performed prior to commencing the work.

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Section VI, Document Control 1 of 2 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY

4.

Establishment, revision, and distribution of a master list or equivalent to identify the current revision number of instructions, specifications, drawings, procurement documents, or other quality assuring documents. (Cancelled procedures are not required for inclusion within the list.)

5.

Control of documents as identified in administrative procedures.

6.

Appendices to the YDQAP are considered to be part of the Program and are reviewed and approved in accordance with the Program.

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Section VI, Document Control 2 of 2 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY VII.

CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES A.

SCOPE This section of the YDQAP establishes measures to assure that purchased material, equipment and services, whether purchased directly or through contractors and subcontractors, conforms to the requirements of the procurement documents.

B.

RESPONSIBILITIES

1.

The Site Manager shall ensure that provisions have been established for the:

a.

Receipt inspection and control of material and equipment.

b.

Evaluation of purchased services during and/or after completion of the service.

c.

Control of purchased material, parts and components until issued for installation or use.

2.

The Quality Assurance Organization shall be responsible for:

a.

Audits and Commercial Surveys of vendor quality assurance programs.

b.

Surveillances of vendor activities.

c.

Maintenance of an approved vendors list.

d..

Audits and/or surveillance of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Audits and Commercial Surveys of vendors based on one or more of the following, as appropriate for the scope of procurement activities:

Title:

Section VII, Control of Purchased Material, Equipment, and Services Page:

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a.

When required to verify a vendor's ability to comply with the applicable criteria of 10CFR50, Appendix B, 10CFR71, Subpart H; 10CFR72, Subpart G; ANSI N18.7, or other quality program baselines.

b.

When required, based on the results of a review and evaluation of vendor performance history.

c.

When required in order to observe vendor activities to assure conformance to purchase specifications.

2.

Surveillances of vendors which provide for:

b.

Verification that the vendor complies with the quality requirements specified in procurement documents by observation or inspection of in-process work or by indirect monitoring of processing methods, equipment and personnel.

3.

Transfer of the following records from the vendor to the plant:

a.

Documentation that identifies the purchased material/services and demonstrate compliance with procurement document requirements.

b.

Documentation that identifies any deviation(s) from procurement requirements, including a description of those deviations dispositioned "accept as is" or "repair".

4.

Review and acceptance of vendor documentation by a responsible qualified individual.

5.

Receipt inspections of vendor furnished material/services, in accordance with predetermined instructions.

6.

Evaluations of vendor effectiveness to control quality is performed at intervals consistent with the importance, complexity and quality of the item/services.

Title:

Section VII, Control of Purchased Material, Equipment, and Services Page:

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YANKEE ATOMIC ELECTRIC COMPANY VIII.

IDENTIFICATION AND CONTROL OF MATERIAL, PARTS, AND COMPONENTS A.

SCOPE This section of the YDQAP establishes the measures for identification and control necessary to prevent the use of incorrect or defective material, parts, and components.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for:

a.

Assuring that specifications, procedures and procurement documents contain appropriate requirements for the identification and control of materials, parts, and components.

b.

Providing review and approval of documentation for the purchase of materials, parts, and components.

c.

c.

Ensuring that traceability of materials, parts, and components which are received, stored, installed, and used at the YNPS are maintained when required by codes, standards, and/or regulatory requirements.

2.

The Quality Assurance Organization shall be responsible for:

a.

The review, evaluation, or verification (audit, commercial survey or surveillance) of vendor quality controls and work processes to assure that traceability of materials is maintained through the use of heat number, part number, or serial number, either on the item or on records traceable to the items when required by codes, standards, and/or regulatory requirements.

b.

Performing audits and/or surveillances and inspections of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the applicable actions listed below:

1.

Traceability of the identification of materials and parts to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing

Title:

Section VIII, Identification and Control of Materials, Parts, and Components Page:

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YANKEE ATOMIC ELECTRIC COMPANY and inspection documents, deviation reports, and Physical and Chemical Material Test Reports when required.

2.

Identification of the item in a location and with a method which does not affect its fit, function or quality when required.

3.

Documented verification of correct identification of materials, parts, and components prior to release for use.

Section VIII, Identification and Control of Materials, Parts, and Components 2 of 2 30 August 2000

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YANKEE ATOMIC ELECTRIC COMPANY IX.

CONTROL OF SPECIAL PROCESSES A.

SCOPE This section of the YDQAP establishes the measures necessary to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria and other special requirements.

B.

RESPONSIBILITIES

1.

The Site Manager shall ensure the following:

a.

Preparation and implementation of documents for welding, heat treating, filler metal control, and nondestructive examinations.

b.

Review and approval of special process documents provided by the vendor for use on-site or when otherwise specified by procurement documents.

c.

Assurance that maintenance and modification work involving special processes are performed by qualified personnel in accordance with qualified and approved procedures.

d.

Control and traceability of material used in special processes by plant personnel when required.

e.

Training, qualification, requalification and maintenance proficiency for personnel performing special processes.

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Completion of qualification records of documents, equipment, and personnel connected with special processes in accordance with applicable codes, standards, and specifications.

Title:

Section IX, Control of Special Processes Page:

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2.

Performance of special processes in accordance with written process sheets or equivalent with recorded evidence of verification.

3.

Maintenance and updating of qualification records of special process documents, equipment, and personnel.

Section IX, Control of Special Processes 2 of 2 30 August 2000

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YANKEE ATOMIC ELECTRIC COMPANY X.

INSPECTION A.

SCOPE This section of the YDQAP establishes measures for inspection of activities requiring quality assurance to verify conformance with approved procedures, drawings, specifications and instructions.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for:

a.

Assuring that activities requiring quality assurance meet predetermined requirements through the use of approved inspection instructions and/or checklists.

b.

Providing qualified personnel and necessary equipment for inspections performed to assure work met predetermined requirements.

c.

Performing plant inspection activities to assure that predetermined requirements have been met.

d.

Incorporating hold points into instructions or procedures where applicable.

2.

The Quality Assurance Organization shall be responsible for:

a.

Surveillance of vendor inspection activities and personnel.

b.

Incorporation of mandatory inspection notification/hold points for plant or vendor activities into the QA surveillances.

c.

Writing, reviewing and approving quality control inspection checklists.

d.

Performing independent QC inspection, when necessary, to assure that predetermined quality requirements have been met.

e.

Performing reviews, surveillances and audits of inspections performed by plant or contractor personnel at the plant.

f.

Reviewing plant developed inspection procedures.

Title:

Section X, Inspection Page:

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YANKEE ATOMIC ELECTRIC COMPANY C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Personnel performing the inspection are independent of the activity being inspected.

2.

Use of instructions and/or checklists.

3.

Use of necessary drawings and specifications when performing inspections.

4.

Inspection of repairs and replacements in accordance with the approved design and inspection requirements or acceptable alternatives.

5.

Surveillance of processing methods, equipment, and personnel when direct inspection is not possible.

6.

Qualification of inspectors in accordance with applicable codes, standards, and company training programs; and maintenance of qualifications and certifications.

7.

Review of maintenance documents by knowledgeable personnel to determine the need for inspection, identification of inspection personnel, and documentation of inspection results.

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Section X, Inspection 2 of 2 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY XI.

TEST CONTROL A.

SCOPE This section of the YDQAP establishes the measures for a test program to demonstrate that SSCs will perform satisfactorily in service.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for ensuring a testing process is developed and implemented for applicable plant changes. The testing process shall include the following:

a.

Evaluation of the results

b.

Approval of the results

c.

Qualifiying personnel involved in the testing

d.

Calibration requirements for equipment used in the testing

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

1.

Assurance that changes, repairs, and replacements are tested in accordance with the approved design and testing requirements or acceptable alternatives.

2.

Review and acceptance of written test documents and test results. Consideration shall be given to the following items:

a.

Requirements and acceptance limits contained in-applicable design and procurement documents

b.

Instructions for performing the test

c.

Test prerequisites

d.

Mandatory inspection hold points requiring witnessing by the owner, contractor or inspector, when applicable

e.

Acceptance and rejection criteria

f.

Method of documenting test data and results

Title:

Section XI, Test Control Page:

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YANKEE ATOMIC ELECTRIC COMPANY Xll.

CONTROL OF MEASURING AND TEST EQUIPMENT A.

SCOPE This section of the YDQAP establishes the measures for the control, calibration and periodic adjustments of tools, gages, instruments, and other measuring and test devices used to verify conformance to established requirements.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for ensuring the development and implementation of documents for control of measuring and test equipment, including identification, calibration, traceability and records.

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the actions listed below:

1.

Identifying, controlling, and calibrating measuring and test equipment with traceability to the calibration and test data.

2.

Calibration of measuring and test equipment at specified intervals and the maintenance of the associated documentation. Calibration intervals are based on required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.

3.

Documentation of measures taken to determine the validity of previous inspections performed when measuring and test equipment is found to be out of calibration.

4.

Use of calibration standards have an uncertainty (error) requirement of no more than /4 of the tolerance of the equipment being calibrated. Calibration standards limited by the "state-of-the-art" may have a greater acceptable uncertainty.

5.

Documentation and maintenance of the status of all items under the calibration system.

Title:

Section X1I, Control of Measuring and Test Equipment Page:

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6.

Traceability of reference and transfer standards to nationally recognized standards; or, documentation of the basis for calibration where national standards are nonexistent.

Section X1I, Control of Measuring and Test Equipment 2 of 2 30 August 2000

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YANKEE ATOMIC ELECTRIC COMPANY XIII.

HANDLING, STORAGE AND SHIPPING A.

SCOPE This section of the YDQAP establishes measures to control the handling, storage, shipping, cleaning and preservation of material and equipment to prevent damage or deterioration.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for ensuring:

a.

The development and implementation of documents for the handling, storage and shipping of materials and equipment.

b.

Suitable facilities and equipment for handling, storage, and shipping of materials are provided.

c.

Inspections and tests of special handling tools and equipment.

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the development and implementation of documents for special handling, preservation, storage, cleaning, packaging, and shipping, by qualified individuals, in accordance with predetermined work and inspection instructions.

Title:

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Section XIII, Handling, Storage, and Shipping 1 of 1 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY XIV.

INSPECTION, TEST AND OPERATING STATUS A.

SCOPE This section of the YDQAP establishes the measures for indicating the status of items undergoing inspections and tests (tags, labels, logs, data sheets, etc.), to prevent the unintentional bypass of required inspections and tests. In addition, this section establishes measures for indicating the operating status of components and systems to prevent their inadvertent operation.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for ensuring the control of operating equipment or systems, including the use of qualified personnel.

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of procedural controls for inspecting, testing, and operating status of systems, structures and components, utilizing status indicators, such as tags, markings, labels, and stamps.

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Section XIV, Inspection, Test, and Operating Status 1 of 1 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY XV.

NONCONFORMING MATERIALS, PARTS, AND COMPONENTS A.

SCOPE This section of the YDQAP establishes the measures to control materials, parts, components, or any other activities which do not conform to requirements, in order to prevent their inadvertent use.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for:

a.

Written instructions or procedures are established for the identification, control and resolution of nonconforming conditions.

b.

Initiating nonconformance reports when conditions are found which may adversely affect the quality of plant systems, structures, components, or activities.

c.

Review and approval of nonconforming services or items which cannot be corrected by vendor action.

d.

Preparation or approval of implementing documents for repair and/or rework of nonconfirming items.

2.

The Quality Assurance Organization will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION

1.

Satisfaction of the requirements of this section shall be assured through the development and implementation of the actions listed below:

a.

Identification, disposition, inspection and segregation of nonconforming items, services, or activities, including associated documentation.

b.

Identification of those individuals or groups delegated the responsibility and authority for the disposition and written approval of nonconforming items or activities.

c.

Subsequent inspections and tests of reworked or repaired items which require reinspection and retest to original or equivalent methods.

d.

Review and approval prior to implementation of any vendor identified nonconformance dispostioned as "accept-as-is" or "repair".

Title:

Section XV, Nonconforming Materials, Parts, and Components Page:

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e.

Inclusion of nonconformance reports dispositioned "accept as is" or "repair" and associated records as part of the quality assurance records furnished by a vendor.

f.

Periodic analysis of nonconformance reports to show quality trends with the results reported to management for review and assessment.

2.

The identification, description, disposition, inspection and signature approval of the final disposition of nonconformances shall be documented.

Section XV, Nonconforming Materials, Parts, and Components 2 of 2 30 August 2000

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YANKEE ATOMIC ELECTRIC COMPANY XVI.

CORRECTIVE ACTION A.

SCOPE This section of the YDQAP establishes measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment are promptly identified and corrected.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for the development and implementation of a process for identifying, documenting, and correcting conditions adverse to quality, including the identification of causes for significant conditions adverse to quality.

2.

The Quality Assurance Organization, will perform audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through implementation of the actions listed below:

1.

Documentation of conditions and significant conditions adverse to quality.

2.

Initiation and documentation of corrective actions taken for conditions adverse to quality, including, the identification of the cause of significant conditions adverse to quality, and any actions taken to preclude recurrence.

3.

Reporting of significant conditions adverse to quality, the cause of the conditions, and the corrective action implemented to the appropriate levels of management for review and assessment.

4.

Periodic reviews to verify proper implementation of corrective actions and identification of repetitive conditions.

Title:

Section XVI, Corrective Action Page:

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YANKEE ATOMIC ELECTRIC COMPANY XVII.

QUALITY ASSURANCE RECORDS A.

SCOPE

1.

This section of the YDQAP establishes the measures for maintenance of records which provide documentary evidence of the quality of items and the activities affecting quality. Requirements shall be established for identification, transmittal, retrievability and retention of quality assurance records including duration, location, protection and assigned responsibility.

2.

The quality assurance records shall include, but not be limited to: applicable plant history; operating logs; principal maintenance; design change activities; reportable occurrences; nonconformance reports; results of reviews, inspections, tests, audits and material analyses; monitoring of work performance; qualification of personnel; documents and equipment; drawings; specifications; procurement documents; calibration documents and reports; corrective action reports, and other applicable decommissioning and spent fuel storage records.

3.

Quality assurance records shall also include those records required by 10CFR71.135 and 10CFR72.174 if not provided for in Item 2 above.

B.

RESPONSIBILITIES

1.

The Site Manager shall be responsible for assuring that a process for the identification, review, approval and retention of quality assurance records as defined above and the approved Defueled Technical Specifications and Appendix D is established and effectively implemented.

2.

The Quality Assurance Organization will perform of audits and/or surveillances of the implementation of this YDQAP section.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of an established process which provides for administration, receipt, storage, preservation, safe keeping, retrieval, and final inspection of records.

Title:

Section XVII, Quality Assurance Records Page:

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YANKEE ATOMIC ELECTRIC COMPANY The construction location and security of record storage facilities shall prevent destruction of the records by fire, flooding, theft, and deterioration by environmental conditions such as temperature or humidity. Duplicate records shall be stored in a separate remote location when the type of document is not permanently maintained in the record storage facility.

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Section XVII, Quality Assurance Records 2 of 2 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY XVIII.

AUDITS A.

SCOPE This section of the YDQAP establishes the measures for a comprehensive system of planned and documented audits and in-plant surveillances to verify compliance and assess effectiveness with all aspects of the YDQAP.

B.

RESPONSIBILITIES

1.

The Quality Assurance Organization shall be responsible for:

a.

Providing objective evidence for audit/surveillance activities encompassed by the 18 criteria of 1 OCFR50 Appendix B; 1 OCFR71, Subpart H; 10CFR72, Subpart G; and the YDQAP, as applicable, and ANSI N18.7.

b.

Training and qualification of audit and surveillance personnel.

c.

Scheduling, coordinating, and implementing the Audit/ Surveillance Programs.

d.

Preparing information regarding the Audit/Surveillance Program for review by IRAC.

e.

Performing vendor audits and surveillances.

f.

Following up of findings discovered during audits or surveillances.

g.

Providing recommendations to preclude recurrence of audit/surveillance findings.

h.

Performing periodic audits of functional areas, activities, and procedures under the YDQAP.

2.

The Site Manager shall be responsible for correcting findings identified during audits and surveillances.

C.

IMPLEMENTATION Satisfaction of the requirements of this section shall be assured through the implementation of the following actions:

Title:

Section XVIII, Audits Page:

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1.

Documentation of the results of audit/surveillance activities and the review of these results with management having responsibility in the area assessed.

2.

Management action to correct findings identified by audit/surveillance activities.

3.

Review of corrective action effectiveness during audits.

4.

Evaluation of quality-related practices, procedures, instructions and the effectiveness of their implementation.

5.

Performance of audits.

6.

Scheduling of audits and surveillances based on the status and importance to safety of the activities being performed.

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Section XVIII, Audits 2 of 2 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY APPENDIX A Qualification Requirements for the Nuclear Safety Manager The Nuclear Safety Manager shall, at a minimum, meet the following qualification requirements:

A.

EDUCATION:

Bachelor's degree in Science or Engineering, or the equivalent in practical experience.

B.

EXPERIENCE:

1.

Four years experience in the field of Quality Assurance, or

2.

Equivalent number of years of nuclear plant experience in a supervisory position preferably at an operating or decommissioning nuclear power plant or a combination of the two.

a.

At least one year of this four years experience shall be nuclear power plant experience associated with the implementation of the Quality Assurance Program, and

b.

Six months of the one year experience shall be obtained within a Quality Assurance organization.

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Appendix A, Qualifications Requirements 1 of 1 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B Yankee Decommissioning Quality Assurance Program Exceptions This Appendix details the exceptions to committed codes and standards noted in Section I of the YDQAP.

Appendix B Sub-Category Standard/Guide Title

1.

ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants I1.

ANSI N45.2.10-1973 Quality Assurance Terms and Definitions II1.

R.G. 1.64, Rev. 2 Quality Assurance Requirements for the Design of Nuclear Power Plants IV.

ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants V.

ANSI N45.2.6-1978 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants VI.

R.G. 1.26, Rev. 3 Quality Group Classifications and Standards for Water-,

Steam-and Radioactive-Waste-Containing Components of Nuclear Power Plants VII.

ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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Appendix B, YDQAP Exceptions 1 of 13 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

ANSI N45.2.9 - 1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants A.

EXCEPTION:

Subsection 5.6(3) Facility The Yankee plant takes exception to "structures, doors, frames, and hardware should be Class A fire rated with a recommended four hour minimum rating."

ALTERNATIVE:

"Doors, structures, frames, and hardware shall be designed to comply with the requirements of a minimum two (2) hour fire rating, meeting NFPA No. 232 guidelines."

JUSTIFICATION:

The two (2) hour rating has been endorsed by the NRC Standard Review Plan NUREG-0800, Revision 2, dated July 1981.

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Appendix B, YDQAP Exceptions 2 of 13 30 August 2000

YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

I1.

ANSI N45.2.10 - 1973, Quality Assurance Terms and Definitions A.

EXCEPTION:

Subsection 2 - Terms and Definitions The Yankee plant takes exception to the definitions of "Certificate of Conformance" and "Certificate of Compliance".

ALTERNATIVE:

The Yankee plant shall reverse the definitions of the above terms so our Program will be in compliance with the implied definitions in the ASME B&PV Code and Yankee specifications.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

Ill.

Regulatory Guide 1.64, Revision 2, "Quality Assurance Requirements for the Design of Nuclear Power Plants" A.

EXCEPTION:

Subsection c.2 The Yankee plant takes exception to the regulatory guide position on the exclusion of supervisors performing design verification.

ALTERNATIVE:

The Yankee plant will continue the accepted practices for independent design verification in accordance with the provisions of ANSI N45.2.11-1974, Section 6.1.

JUSTIFICATION:

The exclusion of line supervision to perform design verification has proven to be an unnecessary burden on the resources within the engineering organizations of the company, and counterproductive during heightened periods of engineering activities.

ANSI N45.2.11 contains specific limitations on the situations in which a supervisor is permitted to perform design verification. The standard states, "This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, or rule out certain design considerations and did not establish the design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification." This control was developed through realistic evaluation of the practicable limits that restrictions impose on engineering organizations by the working group that developed ANSI N45.2.1-1.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

IV.

ANSI N45.2.2 - 1972, Packaging, Shipping, Receiving, Storage & Handling of Items for Nuclear Power Plants A.

EXCEPTION:

Subsection 3.7.1 & A3.7.1 - Containers The Yankee plant takes exception to the specific requirements for containers.

ALTERNATIVE:

Containers shall be of suitable construction to assure material is received undamaged.

JUSTIFICATION:

Containers shipped by closed carrier, stored inside and not subjected to a wet environment do not require weather resistant fiberboard, therefore, this is an unnecessary expense. Additionally, numerous vendors utilize shipping containers that do not comply with the specific requirements of this section, i.e., flaps overlap. The acceptance criteria for a shipping container should be established based on the capability of the container to maintain the component material in a safe condition. Technology has advanced beyond the standard.

B.

EXCEPTION:

Subsection 3.7.2 - Crates and Skids The Yankee plant takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.

ALTERNATIVE:

Skids or runners shall be used on boxes with a gross weight of 100 pounds or more if practical.

JUSTIFICATION:

Storage methods and container design frequently are such that runners or skids are not feasible.

C.

EXCEPTION:

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

Subsection 5.2.1 - Shipping Damage Inspection The Yankee plant takes exception to the requirement that a preliminary visual inspection or examination be performed prior to unloading.

ALTERNATIVE:

The Yankee plant shall perform those required inspections after unloading. In special instances, preunloading inspections shall be performed.

JUSTIFICATION:

Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling.

D.

EXCEPTION:

Subsection 5.2.2 - Item Inspection The Yankee plant takes exception to the requirement, that "The inspections shall be performed in an area equivalent to the level of storage requirements for the item."

ALTERNATIVE:

The Yankee plant shall perform receiving inspection in a manner and in an environment which do not endanger the requisite quality of the item; however, receiving area environmental controls may be less stringent than storage environmental controls for that item. When inspections are performed in receiving areas with environmental controls less stringent than storage area environmental controls, a time limit shall be established on a case basis for retention of items in the receiving area. Retention time shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed.

JUSTIFICATION:

Receipt inspection activities are for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for storage.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

E.

EXCEPTION:

Subsection 5.2.3 - Special Inspection The Yankee plant takes exception to attaching special inspection procedures to the item or container.

ALTERNATIVE:

Special inspection procedures shall be readily available to personnel performing inspections.

JUSTIFICATION:

Procedures are subject to less abuse and more stringent controls when maintained on file and not attached to the item. Inspection status is maintained by tagging and procedure control.

F.

EXCEPTION:

Subsection 6.1.2 - Levels of Storaqe The Yankee plant takes exception to two specific requirements associated with fuel storage (classified Level A).

ALTERNATIVE:

The Yankee plant shall meet the requirements of Level A storage for new fuel with the exception of special air filtering; and temperature and humidity controls.

JUSTIFICATION:

The existing storage conditions at the Yankee plant is consistent with the protection provided to the fuel while in storage at the manufacturer (vendor) and/or while in transit to the plant site and are judged to provide adequate protection to the fuel assembly structure which is of highly corrosion resistant materials. We believe that the above listed requirements are intended for application at the manufacturing facility (vendor) where the uranium pellets may be exposed to the atmosphere and not in its fully encapsulated, and therefore, fully protected form in a completed fuel assembly.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

G.

EXCEPTION:

Appendix A-3 Subsection A3.5.1(1') - Caps & Plugs The Yankee plant takes exception to the requirement that nonmetallic plugs and caps shall be brightly colored.

ALTERNATIVE:

Nonmetallic plugs and caps shall be of a contrasting color.

JUSTIFICATION:

The purpose of utilizing brightly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating components or systems. By using plugs and caps of a contrasting color this objective can be achieved.

H.

EXCEPTION:

Appendix A-3 Subsection A3.910) - Second Group. Markinas The Yankee plant takes exception to the requirement that container markings shall appear on a minimum of two sides.

ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievability.

JUSTIFICATION:

Containers are tagged to provide identification and inspection status. Employment of two tags on small containers adds bulk and confusion and does not provide for better identification or traceability.

EXCEPTION:

Appendix A-3, Subsection A.3.9(4) - Second Group, Marking The Yankee plant takes exception to the requirement that container markings shall be no less than 3/4" high, container permitting.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

ALTERNATIVE:

Container markings shall be of a size which permits easy recognition.

JUSTIFICATION:

Markings were intended to provide identification and instructions. The criteria should be that the markings clearly provide the same.

J.

EXCEPTION:

Appendix A-3 Subsection A.3.9(6) - Second Group, Marking The Yankee plant takes exception to the information required for container marking.

ALTERNATIVE:

Marking shall be adequate in each case to provide identification, traceability and instructions for special handling, as applicable.

JUSTIFICATION:

The information required is excessive. Cluttering a container with excessive markings only reduces the main objectives, maintaining identification and establishing special controls.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

V.

ANSI N45.2.6 - 1978, Qualification of Inspection, Examination and Testinq Personnel for Nuclear Power Plants A.

EXCEPTION:

The Yankee plant takes exception to the application of the Standard to all Yankee personnel performing inspection, examination and testing.

ALTERNATIVE:

Yankee personnel identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N18.1-1971.

Yankee personnel not identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N45.2.6-1978.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

VI.

Regulatory Guide 1.26, Rev. 3, (2/76), Quality Group Classifications and Standards for Water-,

Steam-and Radioactive-Waste-Containinc Components of Nuclear Power Plants A.

EXCEPTION:

The Yankee plant takes exception to the Regulatory Guide in its entirety.

ALTERNATIVES:

The Yankee plant shall continue to classify structures, components and systems in accordance with ANSI Standard N18.2, January 1973, "Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants", as in the past.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

VII.

ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants EXCEPTION:

Subsection 5.2.15 - Review, Approval and Control of Procedures The Yankee Plant takes exception to the following paragraph; "Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable".

ALTERNATIVES:

Plant procedures will be periodically reviewed in accordance with administrative controls. These controls will establish a schedule for these periodic reviews. All applicable plant procedures will be reviewed following an unusual incident,, unexpected transient, operator error, or equipment failure (malfunction), and following a modification to a system.

Nonroutine procedures such as Emergency Plan Implementing Procedures, or other procedures whose use may be event driven, will be reviewed every two years.

However, if a nonroutine procedure is fully exercised and there is a detailed scrutiny of the entire procedure as part of a documented training program, this may serve as the biennial review of the procedure used.

At least every two years, the Quality Assurance (or other independent) organization shall audit a representative sample of routine plant procedures that are used more freiluently than every two years. The audit is to ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies is to be determined and corrected.

JUSTIFICATION:

The current requirement to review each safety-related procedure on a biennial cycle results in the expenditure of significant technical and administrative resources. Programmatic controls and practices are in place to provide adequate reviews, including the following:

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The plant modification processes require that procedures affected by the modification be identified during the design change preparation, and revised prior to closure of the modification package.

Administrative controls currently exist requiring that if a procedure cannot be performed as written, a procedure change must be completed prior to continuation of the procedure.

Temporary changes are occasionally generated during, or prior to procedure use. Current administrative controls require that those changes that are permanent shall be incorporated into the procedure via the procedure revision process.

As part of the audit and surveillance process, procedures are evaluated as to adequacy, ease of use, proper technical content, and compliance with applicable plans and programs.

The corrective action process requires that a root cause analysis be performed for events, violations and nonconforming conditions. Where identified as contributing factors, procedure changes are initiated.

Changes to Technical Specifications and the FSAR are reviewed for potential impact on, and initiation of changes to plant procedures.

Plant procedures are approved by appropriate personnel prior to initial use. Current administrative controls also require pre-job briefings for procedures identified as infrequent.

This modification meets the intent of published regulatory requirements involving activities important to safety.

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX C Classification of Systems, Structures and Components Safety-Related None.

Important to Safety as Defined by 10CFR71 and 10CFR72 A.

Storage of Spent Fuel (10CFR72)

The ISFSI. Systems, Structures and Components (SSCs) that are "Important to Safety" and the associated quality category in accordance with 10CFR72 Regulatory Guide 7.10 and NUREG/CR-6407 are as follows:

SSC Quality Category Transportable Storage Canister and A

Fuel Basket Assembly Vertical Concrete Cask B

Transfer Cask and Adapter Plate B

Reconfigured Fuel Assembly A

ISFSI Pad B

)

Lifting Yoke B

B.

Transport of Spent Fuel and GTCC Waste (IOCFR71)

The ISFSI SSCs that are "Important to Safety" and the associated quality category in accordance with 10CFR71 and NUREC/CR-6407 are as follows:

SSC Quality Category Transportable Storage Canisters A

and Fuel Basket Assembly Reconfigured Fuel Assembly A

Storage Transport Cask A

Transportable Storage Canister and A

Basket Assembly for GTCC Waste Containers

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YANKEE ATOMIC ELECTRIC COMPANY Notes:

1. See NAC-MPC Final Safety Analysis Report (FSAR), Revision 0, dated April 2000 (NRC Docket No.

72-1025) and associated NAC specifications for additional classification.

2.

See NAC Storage Transport Cask (STC) Safety Analysis Report, Revision 12, dated April 1999 (NRC Docket No. 71-9235) and associated NAC specifications for additional detail.

3.

NUREG/CR-6407 states that the ISFSI concrete pad is Category C. For YNPS, the pad is considered the same category as the Vertical Cask since the cask tip analysis defines limits for the pad.

4.

For the definition of Quality Categories A, B, and C, refer to NUREG/CR-6407.

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YANKEE ATOMIC ELECTRIC COMPANY Appendix D Administrative Controls Administrative controls are the written rules, orders, instructions, procedures, policies, practices, and the designation of authorities and responsibilities by the management to obtain assurance of safety and quality of maintenance of a nuclear facility. These controls shall be adhered to.

A.

REVIEW AND AUDIT

1. Independent Safety Review An Independent Safety Review shall be a thorough review conducted by one or more qualified Independent Safety Reviewers. Persons performing these reviews shall be knowledgeable in the subject area being reviewed. Independent Safety Reviews must be completed prior to implementation of proposed activities.

a.

Independent Safety Reviewers shall be individuals without direct responsibility for the performance of the activities under review;, these reviewers may be from the same functionally cognizant organization as the individual or group performing the original work.

b.

Independent Safety Reviewers shall have at least 5 years of professional experience and either a Bachelor's Degree in Engineering or the Physical Sciences or shall have equivalent qualifications in accordance with ANSI 18.1-1971. The Decommissioning Manager (or a designee) shall document the appointment of Independent Safety Reviewers.

c. The following subjects shall be independently reviewed by a qualified Independent Safety Reviewer:

Safety evaluations for changes in the facility as described in the Final Safety Analysis Report (FSAR), changes in procedures as described in the FSAR., and tests or experiments not described in the FSAR to verify that such actions do not involve a change to the Technical Specifications or will not involve an unreviewed safety question as defined in 10CFR50.59; Proposed changes to the programs required in Section B to verify that such changes do not involve a change to the Technical Specifications and will not involve an unreviewed safety question as defined in 10CFR50.59; and Proposed changes to the Technical Specification Bases.

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YANKEE ATOMIC ELECTRIC COMPANY Appendix D (Continued)

2.

IIndependent Review and Audit Committee (IRAC)

The IRAC is responsible for reviewing, auditing, and advising the President of Yankee Atomic Electric Company (or a designee) on matters related to the safe storage of irradiated fuel. This review and audit function is independent of line organization responsibilities.

a.

The IRAC shall include a minimum of five members. Alternates may be substituted for regular members. The licensee shall designate in writing the chairman, the members, and alternates for the IRAC. The chairman shall not have management responsibilities for, or report to, the line organizations responsible for operation or maintenance of the fuel storage facility.

b.

The IRAC shall collectively have experience and knowledge in the following functional areas:

Fuel handling and storage (including the potential for criticality),

Chemistry and Radiochemistry, Engineering, Radiation Protection, and Quality Assurance.

If necessary, individuals with knowledge and experience in other functional areas may be utilized to provide advice to the IRAC.

c.

The IRAC shall hold at least one meeting per quarter.

d.

A quorum shall consist of three regular members or their duly appointed alternates. Those members representing the line organizations responsible for the operation and maintenance of the facility shall not constitute a majority of the quorum. At least one member of the quorum shall be the chairman or the chairman's designated alternate.

e.

As a minimum, the IRAC shall perform the following functions:

Advise the Decommissioning Manager (or a designee) on all matters related to safe storage of irradiated fuel; Advise the management of the audited organization and the Decommissioning Manager (or a designee) of audit results as they relate to safe storage of irradiated fuel; Recommend to the management of the audited organization, and its management, any corrective action to improve the safe storage of irradiated fuel; and

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Notify the President of Yankee Atomic Electric Company of any safety significant disagreement between the IRAC and the Decommissioning Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f.

The IRAC shall be responsible for reviewing:

The safety evaluations for procedures, and changes thereto, completed under the provisions of 10 CFR 50.59 to verify that such actions do not involve an unreviewed safety question as defined in 10 CFR 50.59. This review may be completed after implementation of the affected procedure; Changes to systems, structures or components important to the safe storage of irradiated fuel to verify that such changes do not involve an unreviewed safety question as defined in 10 CFR 50.59. This review may be completed after implementation of the change; Tests or experiments involving the safe storage of irradiated fuel to verify that such tests or experiments do not involve an unreviewed safety question as defined in 10 CFR 50.59.

This review may be completed after performance of the test or experiment; Proposed changes to the YNPS Technical Specifications or the license; Violations of codes, regulations, orders, license requirements, or internal procedures/instructions having nuclear safety significance; Indications of unanticipated deficiencies in any aspect of design or operation of systems, structures or components that could affect safe storage of irradiated fuel; Significant accidental, unplanned, or uncontrolled radioactive releases, including corrective action(s) to prevent recurrence; Significant operating abnormalities or deviations from normal and expected performance of equipment that affect safe storage of irradiated fuel; The performance of the corrective action system; and Internal and external experience information related to the safe storage of irradiated fuel that may indicate areas for improving facility safety.

Reports or records of these reviews shall be forwarded to the Decommissioning Manager within 30 days after completion of the review.

g.

The IRAC's audit responsibilities shall encompass:

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Conformance of irradiated fuel storage to provisions contained within the YNPS Technical Specifications and applicable license conditions at least once per 12 months; The training and qualifications of facility staff at least once per 12 months; Implementation of all programs required by Section B at least once per 24 months; Actions taken to correct deficiencies occurring in systems, structures components, or methods of operation that affect safe storage of irradiated fuel at least once per 6 months; Facility operations, modifications, maintenance, and Surveillance related to the safe storage of irradiated fuel to verify independently that these activities are performed safely and correctly at least once per 24 months; and Other activities and documents as requested by the Decommissioning Manager (or a designee).

Reports of records of these audits, including any recommendations for improving the safe storage of irradiated fuel, shall be forwarded to the Decommissioning Manager (or a designee) within 30 days after completion of the audit.

3. Records Written records of reviews and audits shall be maintained. As a minimum, these records shall include:

a. Results of the activities conducted under the provisions of Sections A.1 and A.2;

b.

Recommendations to the management of the audited organization;

c. An assessment of the safety significance of review or audit findings;

d.

Documentation of reviews conducted under Section A.1.c; and

e.

Determination of whether each item considered under Section A.2.f (first three items) involves an unreviewed safety question as defined in 1 OCFR50.59.

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YANKEE ATOMIC ELECTRIC COMPANY Appendix D (Continued)

B.

PROCEDURES AND PROGRAMS

1.

Written procedures shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of Sections 5.2 through 5.2.9 and 5.3 of ANSI N18.7-1972 and Appendix "A" of Regulatory Guide 1.33, Revision 2, except as provided in B.2 below. The written procedures shall also cover the activities relating to:

a.

Fire Protection Program implementation.

b.

PROCESS CONTROL PROGRAM implementation.

c.

OFF-SITE DOSE CALCULATION MANUAL implementation.

d.

Quality Assurance Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975.

2.

Each procedure and administrative policy of B.1 above, and changes thereto, shall be reviewed by an Independent Safety Reviewer and approved by the Decommissioning Manager prior to implementation and reviewed periodically as set forth in administrative procedures.

3.

Temporary changes to procedures of B.1 above may be made provided:

a. The intent of the original procedure is not altered.

b.

The change is approved by two members of the plant management staff, at least one of whom is a Certified Fuel Handler.

c.

The change is documented and approved by the Decommissioning Manager within 14 days of implementation.

4.

The following programs shall be established, implemented, and maintained:

a.

Radioactive Effluent Controls Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The prograrm shall include the following elements:

Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation, including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;

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Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 CFR, Part 20, Appendix B, Table II, Column 2;

Monitoring, sampling, and analysis of radioactive liquid, and gaseous effluents in accordance with 10 CFR 20.106 and with the methodology and parameters in the ODCM; Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR, Part 50; Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days; Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2%

of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR, Part 50.

Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the SITE BOUNDARY conforming to the doses associated with 10 CFR, Part 20, Appendix B, Table II, Column 1; Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR, Part 50; Limitations on the annual and quarterly doses to a MEMBER OFJTHE PUBLIC from lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than eight days in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR, Part 50; Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR, Part 190.

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b.

Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the Effluent Monitoring Program and modeling of environmental exposure pathways. The program shall (1) be contained in the ODCM; (2) conform to the guidance of Appendix I to 10 CFR, Part 50; and (3) include the following:

Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM, A Land Use Census to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the monitoring program are made if required by the results of this census, and Participation in an Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the Quality Assurance Program for environmental monitoring.

C.

RECORD RETENTION

1. The following records shall be retained for at least 5 years:

a.

Records and logs of facility operation covering time interval at each power level.

b.

Records and logs of principal maintenance activities, inspection, repair and replacement of principal items of equipment related to nuclear safety.

c.

All REPORTABLE EVENT reports submitted to the Commission.

d.

Records of surveillance activities, inspections and calibrations required by Technical Specifications.

e.

Records of reactor tests and experiments.

f.

Records of changes made to Operating Procedures.

g.

Records of radioactive shipments.

h.

Records of sealed source leak tests and results.

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i.

Records of annual physical inventory of all sealed source material of record.

2.

The following records shall be retained for the duration of the Possession Only License:

a, Records and drawing changes reflecting facility design modifications made to systems and equipment described in the FSAR.

b, Records of new and irradiated fuel inventory, fuel transfers and assembly bumup histories.

c. Records of facility radiation and contamination surveys.

d, Records of radiation exposure for all individuals entering radiation control areas.

e, Records of gaseous and liquid radioactive material released to the environs.

f.

Records of transient or operational cycles for the Reactor Pressure Vessel.

g, Records of training and qualification for current members of the plant staff.

h, Records of inservice inspections performed pursuant to Technical Specifications.

i.

Records of Quality Assurance activities required by the YDQAP.

j.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k.

Records of Independent Safety Reviews and the IRAC meetings, and records of the Plant Operational Review Committee (PORC) and the Nuclear Safety Audit and Review Committee (NSARC), the review and audit functions which preceded the Independent Safety Review function and IRAC.

I.

Records for Environmental Qualification.

m. Records of analysis required by the Radiological Environmental Monitoring Program.

n.

Records of the service lives of all snubbers, including the date at which the service life commences and associated installation and maintenance records.

o.

Records of reviews performed for changes made to the OFF-SITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

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