ML19211C268

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QA Program for Packaging Licensed Radioactive Matl for Shipment,Revision a
ML19211C268
Person / Time
Site: 07100035
Issue date: 12/05/1979
From: Jaseph R
ROCKWELL INTERNATIONAL CORP.
To:
Shared Package
ML19211C266 List:
References
14965, NUDOCS 8001110135
Download: ML19211C268 (33)


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DOCUMENT TYPE PROGRAM TITLE QA Criteria for Shipping Packages for Quality Assurance Functional Plan Radioactive Material KEY NOUNSWualltv A S S u rance, Packagine, Licensed Radioactive DOCUMENT TITLE ORIGIN AL ISSUE DATE QA Prograra for Packaging Licensed Radioactive Material for Shipment GO NO.

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Title 10, Code of Federal Regulations, Part 71,

% M. T. A. Gentry KA06,

D. N. Glas s KB45 (10 CFR 71) requires entities licensed to hande special nuclear mate"lal by the Nuclear Regula-C.

I. Adams KB45 tory Commission (NRC) to establish and maintain A. P. Lichtman KE4D a quality assurance program for the design, fab-C. F. Hof KB06 rication, assembly, testing, use, and mainten-R. L. Jaseph KB44 ance of each packaging of quantities of licensed W. R. McCurnin T020 material in excess of type A quantities for ship-ment.

This document describes that program for R. J. McDe rmott KB44 Energy Systems Group of Rockwell International.

K. D. Mille r JB02 M. E. Remley NB08 V. J. Schaube rt NB 10 J. H. Shive rdecke r JB02 R. J. Tuttle NB 13 B. F. Ureda NB02 J. H. Walter T009

[ c Rockwell Intemat.ional

& M. S. Wright T030 Energy SySterns Group 8900 se scio Aseque N' Cancga Park, Caucmia 9004 RESERVF l740 l9b NOTICE In providing this.nformation, Rockwell International Cort: oration makes no repre-sentation, either expressed or implied, as to its adequacy, sufficiency, or freedom from fault and incurs no responsibility or 754-B.17/sjd obligation whatsoever by reason thereof; and the furnishing of such information shall not Convey any rignts or license With re T Y 6 5

>W COMPLETE DOCUMENT thereto.

NO ASTERISK. TITLE PAGE/

SUMMARY

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5. Atom.ics International NO.

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SUMMARY

OF CH ANGE APPROVALS AND DATE n

A f 5/I1/18 Change No. 1 (L % W 1

Add d SOF K-14 to paragraphs 4.6 and 4.13, corrected 19 c ) b.. r ' /e /ir pp'L.DA~[

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,'anged corporate name from Atomics International (AI) to Energy Systems Group throughout. Updated 1 3 and upgraded Section 4, implementing procedures, I

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A and added Sections 5 and 6.

Section 5 provides

.., ij y an annotated bibliography of the implementing pro-4/ h"'A y., n

-~*'l cedures, and Section 6 imposes additional require-ments on the programs encompassed by this plan.

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' A no N011QFP810001 Rockwelllnternational Erwegy Setems Group PAGE.

2 CONTENTS Page

1.0 INTRODUCTION

4 2.0 SC0PE.......................................................

4 3.0 APPLICATION.................................................

4 4.0 QUALITY ASSURANCE PR0 GRAM...................................

6 4.1 O rg a n i z a t i o n.......................................... 6 4.2 QA Program............................................

6 4.3 Design Control........................................

6 4.4 Procurement Document Control..........................

7 4.5 Ins tructions, Procedures, and Drawings................

7 4.6 Document Control......................................

7 4.7 Control of Porcnased Material, E Services........................quipment, and 8

4.8 Identification and Control of Materials, Parts, and Components...........................,............

8 4.9 Control of Special Processes..........................

8 4.10 Inspection............................................

9 4.11 Te s t C o n t ro l.......................................... 9 4.12 Control of Measuring and Test Equipment...............

9 4.13 Handling, Storage, and Shipping.......................

9 4.14 Inspection, Tes t, and Operating Status...............

10 4.15 Nonconforming Materials, Parts, or Components........

10 4.16 Corrective Action....................................

10 4.17 QA Records...........................................

10 4.18 A u d i t s ;..............................................

10 1740 198

tAN NO N011QFP810001

(/ y Rockwellinternational Energy Systems Group PAGE 3

CONTENTS (Continued)

Page 5.0 PROCEDURE DESCRIPTIONS.....................................

10 6.0 ADDIT IONAL REQ U IREMEllTS.................................... 3 0 QA FUNCTIONAL PLAN PROCEDURE DESCRIPTIONS STAtiDARD OPERATItiG PCLICIES (50P's)........................

11 ENGINEERING MANAGEMEllT PROCEDURES (EMP's)...................

18 QUALITY ASSURA!;CE OPERATII;G PROCEDURES (QA0P's)............

22 MAN U FA CTU R I N G MANUA L ( l'14 )...................................

2 9 HEALTH Att0 SAFETY PRCCEDURES (HSP).........................

30 CORPORATE PATERIAL PROCEDURES (CMP 's)......................

30

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NO N011QFP810001 Rockwelllnternational i

Energy Systems oroup PAGE 4

1.0 INTRODUCTION

Effective October 18, 1977, the Nuclear Regulatory Commission (NRC) amended its regulations for packaging and transport of radioactive material. These amendments, published as changes to CFR Part 71, upgrade requirements for quality assurance in the design, fabrication, assembly, testing, use, and mainte-nance of packagings for shipping and transporting licensed radioactive material.

In general, the upgrading consists of applying the eighteen criteria of 10 CFR 50 Appendix B to the packaging of radioactive material; the criteria are published as 10 CFR 71 Appendix E.

2.0 SCOPE This QA program applies to all organizations and personnel who perform activities affecting the safety-related functions associated with designing, fabricating, maintaining, and using packages fc'r licensed radioactive material.

It does not apply tc packages used only for onsite shipments (i.e., where the vehicle rever leaves ESG or government-owned land), to license-exempt activities (e.g., where ESG has a G0C0 (Government owned-contractor operated) contract with Department of Energy (DOE), or to shipments in government-owned, government-escorted vehicles.

3.0 APPLICATION In determining hcw to apply the requirements of this program to a particular activity, responsible management shall consider:

1)

The importance of malfunction or failure of the item to safety; 2)

The design or fabrication complexity or uniqueness of the item; 1740 200

NO N011QFP810001 Rockwelllnternational Energy Systems Group PAGE 5

3)

The need for special controls or surveillance over pro-cesses and equipment; 4)

The degree to which functional compliance can be demon-strated by inspection or test; and 5)

The quality history and degree of standardization of the item.

Any change to design documents that changes conditions specified in the NRC approval of a package or container must also be approved by NRC.

When ESG purchases materials or services, measures to assure adequate quality shall be included in the procurement documents. Subtier con-tractors shall be required to provide quality assurance programs to the extent necessary to assure adequate quality. The degree to which QA requirements are passed down to subtier suppliers shall specifi-cally be considered by Engineering and QA personnel during P.O.

initiation and review.

The documents listed in Section 4, following, as implementing pro-cedures for this QA program are the procedures cf the following ESG or departmental manuals.

In every case, the latest revision of any procedure referenced must be used.

S0P Standard Operating Policies EMP Engineering Management Procedures Manual QA0P Quality Assurance Operating Procedures, Quality Assurance Manual MM Manufacturing Manual HSP Health and Safety Manual CMP Corporate Material Procedures 1740 201

NO N011QFP810001 Rockwellinternational Energy Systems Group PAGE 6

This matrix, numbered similarly to the criteria in 10 CFR 71 Appendix E, demonstrates how ESG conformance to each criterion is implemented.

Section 5, following, provides an annotated bibliography of all listed documents.

4.0 QUALITY ASSURANCE PROGRAM ESG Imolementina Document ni E

Requirement Number Title 4.1 Organization S0P Organization Section S0P Q-10 ESG Quality Assurance Program SOP E-15 Manager Selection 4.2 QA Program S0P K-17 Audits of Special Nuclear Material Control and Radioactive Material Shipping Systems S0P A-01 ESG Policies and Procedures S0P Q-10 ESG Quality Assurance Program S0P Q-12 Quality Assurance Program Audits EMP 3-42 Engineering Management System for Specifications QA0P N1.01 QA Department Functions QA0P N1.20 QA Program Administrator QA0P N7.00 Product Acceptance Tests 4.3 Design Control SOP M-10 Program Management S0P Q-14 Corrective Action System EMP 1-1 Engineering Systems Management EMP 3-1 Engineering Documentation Process EMP 2-8 Engineering Studies EMP 2-9 Design and Acceptance Criteria EMP 3-42 Engineering Management System for Specifications EMP 3-22 Interface Requirements Control EMP 4-1 Test Engineering Process EMP 5-3 Design Reviews EMP 5-17 Engineering Drawing Checking EMP 5-24 Application of Standards 1740 202

NO N0110FP810001 Rockwellinternational Energy Systems Group PAGE 7

p ix E ESG Implementing Document Requirement Number Title 4.4 Procurement 50P J-12 Preparation and Processing of the Document Control Purchase Requisition S0P K-78 Procurement and Control of Supplier Data QA0P f14.00 Procurement Documents QAOP N4.01 Supplier Evaluation and Approval QA0P N4.02 Procurement Quality Verification Instructions 4.5 Instructions, EMP 2-9 Design and Acceptance Criteria d es, and EMP 3-1 Engineering Documentation Process EMP 3-42 Engineering Management System for Specifications QAOPfl5.01 Shop Travellers QA0P N7.00 Product Acceptance Tests 4.6 Document Control EMP 3-1 Engineering Documentation Process EMP 3-5 Drawing Preparation - Standard Release System EMP 3-42 Engineering Management System for Specifications EMP 3-21 Engineering Change Control EMP 3-46 Document Release and Control Systems EMP 3-52 Engineering Release Plan of Action EMP 5-17 Engineering Drawing Cilecking SOP K-14 Shipping Radioactive Materials 50P M-18 Configuration Management QAOP N2.02 Document Review QA0P N5.01 Shop Travellers MM M-2-22 Revision Instructions, MP0/MOR MM fi-3-3 Document Distribution MM M-3-21 Change Letter / Engineering Order -

Documentation on Manufacturing Work Orders 1740 203

NO N011QFP810001 RockwellInternational Enern snt.m. croup PAGE 8

10 CFR 7'^

ESG Implementing Document Appendix E Requirement Number Title 4.7 Control of Pur-S0P J-58 Receiving and Inspection of Incoming chased Material, Material and Equipment Equ e t, and S0P Q-12 QA Program Audits QA0P N1.04 QA Audits QA0P N1.22 QA Acceptance Procedures QA0P N4.01 Supplier Evaluation and Approval QAOP N4.02 Procurement Quality Verification Instructions QA0P N4.03 Source Inspection / Surveillance QA0P N4.04 Receiving Inspection QA0P N9.00 Stamp Control QAOP N13.02 QA Data Packages 4.8 Identification 50P J -58 Receiving and Inspection of Incoming and Control of Material and Equipment Materials, Parts, SOP K-84 Warehousing of Direct-Charged Pur-and Components chased Materials by Traffic and Warehousing QA0P N4.02 Procurement Quality Verification Instructions QA0P N5.01 Shop Travellers QA0P N6.04 Weld Material Control QAOP N9.02 Serialization of Hardware QAOP N10.00 Nonconforming Material and Items MM M-3-6 Productive Material Control EMP 3-28 Component Traceability EMP 3-29 Engineering Requirements for Serialization 4.9 Control of Special QAOP N6.01 Qualification of Welding Procedures Processes and Personnel QAOP N6.02 Qualification and Certification of NDE Personnel QAOP N6.03 Nandestructive Examination Procedures QA0P N6.04 Weld Material Control QAOP N6.05 Qualification of Special Processes 1740 204

NO N011QFP810001 Rockwelllnternational Eriergy Systems Group PAGE 9

CFR 71 ESG Implementing Document E

Requirement Number Title 4.10 Inspection QA0P N1.21 QA Plans QA0P N1.22 QA Acceptance Procedures (This section QAOP N5.01 Shop Travellers d"

P QA0P N6.03 fon structive Examination t on fp u

tion, not of procurements.

QA0P N6.05 Qualification of Special Processes d

QAOP N7.00 Product Acceptance Tests n Sect on QA0P N7.01 Pressure Testing QA0P N7.02 Qualification and Certification of Visual and Dimensional Inspection Personnel QA0P N9.00 Stamp Control 4.11 Test Control EMP 4-1 Engineering Test Process EMP 4-3 Test Plans EMP 4-4 Test Procedures EMP 4-5 Test Reports QA0P N1.22 QA Acceptance Procedures QA0P N7.00 Product Acceptance Tests 4.12 Control of Mea-S0P K-68 Calibration of Measuring Instru-suring and Test ments and Equipment Equipment QA0P 43.00 Control of Measuring and Test Equipment (M&TE)

QAOP N3.02 ESG Special Tooling 4.13 Handling, Storage, S0P J-60 Handling and Storage of Project and Shipping Critical Hardware 50P K-44 Shipping SOP K-50 Material Handling Equipment EMP 3-43 Packaging Engineering QA0P N6.05 Qualification of Special Processes QA0P N12.00 Packaging and Shipping Inspection MM M-3-6 Productive Material Control MM M-3-10 Packaging and Shipping 50P K-14 Shipping Radioactive Materials F740 205

NO N011QFP810001 Rockwellinternational PAGE 10 Energy Systems Group 7l ESG Imolementing Document pn1 E

Requirement Number Title 4.14 Inspection, Test, HSP 29 Health and Safety " Red Tag" -

and Operating Form N44-1 Status QA0P N5.01 Shop Travellers QA0P N9.00 Stamp Control QA0P N10.00 Nonconforming Material and Items 4.15 Nonconforming QA0P N10.00 Nonconforming Material and Items Materials, Parts, S0P J-58 Receiving and Inspection of or Components Incoming Material and Equipment 50P Q-14 Corrective Action System 4.16 Corrective Action S0P Q-14 Corrective Action System QA0P N10.00 Nonconforming fiaterial and Items CA0P N14.00 Corrective Action 4.17 QA Records 50P Q-18 Quality Records EMP 3-1 Engineering Docu entation Process CMP 2-126 Case File Documentation QA0P N2.03 Document Control QA0P N13.02 QA Data Packages QA0P N13.03 Use of QA Laboratory Test Report -

Form 711-V QA0P N13.04 Preparation and Use of Inspection Test Report - Form 732Q 4.18 Audits 50P K-17 Audits of Special Nuclear Material Control and Radioactive Material Shipping Systems S0P Q-12 Quality Assurance Program Audits QA0P N1.04 Quality Assurance Audits 5.0 PROCEDURE DESCRIPTIONS This section briefly describes the directives listed in the Section 4 matrix of implementing procedures for the criteria of 10 CFR 71 Appendix E.

1740 206

m 0001 Rockwelllntemational Energy Systems Group PAGE QA FUNCT10tlAL PLAtt PROCEDURE DESCRIPTIONS STANDARD OPERATIfiG POLICIES (SOP's) S0P Organization Section This section of the S0P contains organization charts depicting all levels of management within ESG and demonstrates independence of QA Department from other line functions. S0P A ESG Policies and Procedures This 50P defines the types of ESG administrative policies and procedures authorized and establishes minimum format and distribution requirements for such policies and procedures. It identifies the highest level of management, corporate or otherwise, responsible for establishing quality policies, goals, and objectives. A clear path of communication between Quality Assurance organization and corporate management is defined. Positions and groups responsible for defining both content and changes to th? Quality Assurance Program and manuals are identified, in addition to the management level responsible for the approval of the Quality Assurance Program and manuals. Provisions are established for controlling and dis-tribution of Quality Assurance manuals and revisions. SOP E Manager Selection This 50P defines basic policy and assigns specific responsibilities rela-tive to selection and assignment of individuals to fill new or vacant management positions. 1740 207

NO N011QFP810001 RockwellInternational PAGE 12 Energy Systems Group S0P J Preparation and Processing of the Purchase Requisition This SOP establishes methods and policies applicable to the preparation and processing of the Purchase Requisitions (Form N25-R-2). The requi-sition is used for authorizing procurement, through Purchasing, of materials, equipment, and services from suppliers. Procedures are established that delineate the sequence of actions to be accomplished in preparation, review, approval, and control of the Purchase Requisition. 50P J Receiving and Inspection of Incoming Material and Equipment Receiving inspection of supplier-furnished material and equipment is per-formed in accordance with the following. The material is properly iden-tified and corresponds with receiving documentation. Inspection is per-formed and judged acceptable, in accordance with predetermined instructions, prior to use. Items accepted and released are identified as to their inspection status, prior to release. Nonconforming items are segregated, controlled, and identified until proper disposition is made. S0P J Handling and Storage of Project Critical Hardware Special handling, preservation, storage, packaging, and shipping require-ments are specified and performed by qualified personnel under predeter-mined instructions. S0P K Shipping Radioactive Materials This procedure establishes the methods and responsibilities for the ship-ment of radioactive material from ESG sites, whether to customers, asso-ciate contractors, suppliers, or other ESG sites. 1740 208

NO N011QFP810001 Rockwelllntemational PAGE 13 Energy Systems Group S0P K Audits of Special Nuclear Material Control and Radioactive Material Shipping Systems This procedure requires that QA perform annual audits of SNM Control (Accountability) systems, SNM Physical Protection systems, and Radioactive Material Shipping systems, and to perform additional quarterly audits of selected operations significant to the safety of shipments and receipts. SOP K Shipping Special packaging and shipping requirements are specified and accomplished by qualified individuals, in accordance with predetermined instructions. Procedures are prepared in accordance with design and specification requirements which control the packaging and s..ipping of materials, com-ponents, and systems to preclude damage, loss, and deterioration. SOP K Material Handling Equipment Special handling requirements are specified and accomplished by qualified individuals, in accordance with predetermined instructions. Procedures are prepared in accordance with design and specification requirements which control the handling of materials, components, and systems, to prevent damage. 50P K Calibration of Measuring Instruments and Equipment Procedures describe the calibration technique and frequency, maintenance, and control for all measuring instruments and test equipment which are used for obtaining data, where traceable calibrations are required. Mea-suring and test equipment is identified, and the calibration test data is identified with the associated equipment. Measurement and test equipment are calibrated at specified intervals, based on the conditions affecting the measurement. When measuring and test equipment is found to be out of 1740 209

NO N011QFP810001 RockwellInternational Energy Systems Group PAGE 14 calibration, any items measured with this equipment are withheld until the accuracy of the results is evaluated. The complete status of all items under the calibration is recorded and maintained. Reference and transfer standards are traceable to national standards. If national standards do not exist, the basis for calibration is documented. S0P K Procurement and Control of Supplier Data Procedures are established for preparation, review, and control of instructions, procedures, drawings, and changes thereto. These documents and changes thereto are procedurally controlled to assure adequacy. Pro-visions are established, identifying the personnel responsible for these activities. Changes are reviewed by the same organizations that performed the original review, unless delegated by the applicant to qualified responsible organizations. Approved changes are promptly included in the appropriate documents. S0P K Warehousing of Direct-Charged Purchased Materials by Traffic and Warehousing Methods are specified to identify and control materials. Verification of correct identification of material, prior to release, is required. Material shall be protected against loss, damage, or deterioration from environmental conditions. 50P M Program Management This S0P sets forth principles and guidelines for the managements of Energy Sys+. ems Group Business Programs. The guidelines include organi - zational framework, program management processes, performance monitoring, and reporting systems. 1740 210

NO N011QFP810001 Rockwelllnternational PAGE 15 Energy Systems Group S0P M Configuration Management This procedure establishes general policy for the application and implementation of configuration management, to assure that the physical and functional characteristics of the end product are adequately identified, controlled, and accounted for. 50P Q ESG Quality Assurance Program This procedure defines the Quality Assurance Program to be applied to all ESG products and services, in compliance with applicable contract, federal, or state requirements. Management regularly assesses the Quality Assurance Program effectiveness, and coor-dinates quality assurance activities of ESG with those of customers or subcontractors. QA Program functions are described, as are the QA Director's responsibilities for assuring ESG's conformance. Responsibilities include stopping or controlling nonconforming work. The establishment of indoctrination and training programs appropriate to the various functions is required. S0P Q Quality Assurance Program Audit Procedures and responsibilities for assuring the adequacy and effectiveness of the ESG Quality Assurance Program through audits of procedures, standards, methods, and practices used in producing ESG hardware or software products are established by this 50P. Audits are. performed in accordance with pre-established written procedures or checklists and are conducted by trained personnel not having direct responsibilities in the areas being audited. The audits include an objective evaluation of quality-related practices, procedures, and instructions, and the effectiveness of implementa-tion and conformance with policy directives. 1740 211

No N011QFP810001 Rockwellinternational Energy Systems Group PAGE 16 Audit data are analyzed and reports indicating quality trends and the effectiveness of the Quality Assurance Program are provided to management. The audit results are documented and then reviewed with management having responsibility in the area audited. Sub-sequently, responsible management takes the necessary action to correct the deficiencies revealed by audit. 50P Q Corrective Action System Evaluation of nonconformances and determination of the need for corrective action follow established procedures. Prompt corrective action is initiated, following the determination of nonconformance to procedural or technical requirements. Adverse conditions sig-nificant to quality, their causes, and corrective actions are reported to the appropriate levels of management. 50P Q ESG Quality Records ESG Quality Records are defined, and responsibilities for their retention are established by this 50P. Its purpose is to establish standards for meeting ESG and customer requirements for filing, storing, and retrieving of quality history information on ESG products and services. Quality Assurance records include: (1) operating logs, (2) results of reviews, inspections, tests, audits, and material analyses, (3) monitoring of work performance, (4) qualification of personnel, procedures, and equipment, and (5) other. documentation, such as drawings, specification, procurement documents, calibration pro-cedures and reports, and nonconforming and corrective action reports. The records are to be readily identifiable and retrievable. 1740 212

NO N011QFP810001 Rockwelllntemational Energy Systems Group PAGE 17 Requirements and responsibilities for record transmittals, retention and maintenance subsequent to work completion must be consistent with applicable codes, standards, and procurement documents. Record storage facilities are to be constructed, located, and secured to prevent loss or destruction of the records or their deterioration by environmental conditions. 1740 213 9 I FO R M 714.7 R F V

7. M

NO N011QFP810001 Rockwell!nternational Ewgy syuems Group PAGE yg ENGINEERING MANAGEMENT PROCEDURES (EMP's) EMP 1 Engineering Systems Management This procedure presents a summary of the salient features of a formalized system for implementation of the Integrated Engineering Process and defines how this process will be managed, particularly so as to assure accurate translation of requirements into design and fabrication documents. EMP 2 Engineering Studies This procedure establishes the requirement for conducting studies to establish that the design meets the design criteria, is based upon proven practices or analysis, and is adequate for the intended service. It describes the method for preparing, releasing, and controlling Engineering Studies. EMP 2 Design and Acceptance Criteria This procedure delineates the need for design and acceptance criteria to be defined and published in the appropriate design basis documents. EMP 3 Engineering Documentation Process This procedure describes the scope of the procedures which control the preparation, release, and control of specifications, drawings, and reports by Engineering, including control of changes. For convenience, Manufacturing and QA procedures (but not shop travellers) are released through the Engineering document control system. EMP 3 Standard Release System This procedure provides instructions for the preparation, numbering, release, and control of drawings for the Standard Release System and provides guidelines for application of the standard release. 1740 214 P O R M 719 P A E V. 7 78

NO N011QFP810001 Rockwelllnternational Energy Systems Group PAGE gg EMP 3 Engineering Change Control This procedure defines the method for requesting, evaluating, approving, and executing engineering changes. EMP 3 Interface Control This procedure establishes the criteria for interface definition and the methods for describing and controlling the interface in appropriate documentation drawings and specifications. EMP 3 Component Traceability This procedure defines the basic elements for the traceability system at ESG, including identification of items by part number and/or individual item batch, heat, or lot serial number. EMP 3 Engineering Requirements for Serialization This procedure provides conditions under which Engineering may require serialization and the methods by which unique numbers, on an individual or lot basis, are affixed to parts or assemblies. EMP 3 Engineering Management System for Specifications This procedure defines the method for the preparation and control of Engineering specifications. EMP 3 Packaging Engineering This procedure defines the steps required to assure that ESG products as well as incoming shipments from suppliers are adequately preserved against corrosion and packaged and packed to prevent physical damage during storage and shipment. Implementation of this procedure will also assure compliance with all regulations applicable to special materials and special containers. 1740 215 F OR M 719 P A EV. 7.78

NO N0110FP810001 Rockwell!nternational 20 Energy Systems Group PAGE EMP 3 Document Release and Control Systems This procedure describes the Engineering Order Release System, the Supporting Document Release System, and the Technical Data Transmittal System. EMP 3 Engineering Release Plan of Action This procedure gives the format and requirements for a plan describing the means of preparation and release and approval of program documents. EMP 4 Engineering Test Process This procedure defines the manner and sequence in which engineering test functions are perfomed. Tests are performed when a need is identified for experimentally derived design information, demonstration of design characteristics, or performance verification. EMP 4 Test Plans This procedure establishes the requirement for the preparation, approval, distribution, and revision of Test Plans. Test Plans are prepared to describe how test requirements will be met, in response to a Request for Test or other requirements documents. EMP 4 Test Procedures This procedure establishes the requirement for the preparation, approval, distribution, and revision of Test Procedures. Test Procedures are detailed instructions containing sufficient information to allow those performing the test to proceed independently in accordance with the provisions of the Test Plan. 1740 216

NO N011QFP810001 j Rockwellinternational Energy Systems Group PAGE. 21 EMP 4 Test Reports This procedure establishes the requirements for Test Reports, which will contain all significant data, reference other pertinent data, and include an evaluation of test results and observations. EMP 5 Design Reviews This procedure establishes the requirements for independent design reviews, and the means of their scheduling, conduct, and reporting. EMP 5 Checking of Engineering Drawings This procedure establishes the responsibilities for checking of all engineering drawings. EMP 5 Application of Standards This procedure provides guidance and direction for the application of codes and standards. It categorizes various types of standards, establishes responsibilities for their collection, application, and change control, and applies to parts and materials as well as to documents. 1740 217

NO N011QFP810001 Rockwell!nternational Erergy Systems Group PAGE 22 QUALITY ASSURANCE OPERATING PROCEDURES (QA0P's) QAOP N1.01 - Quality Assurance Department Functions This document outlines the functions of the individual groupi., within the QA department. QA0P N1.04 - Quality Assurance Audits This procedura outlines the Quality Assurance responsibilities for implementing and maintaining an audit program to determine the overall effectiveness of the ESG and supplier quality programs and to identify areas where corrective prevention action is required. QA0P N1.20 - Quality Assurance Program Administrator This procedure defines the activities of a QA Program Administrator, which include resolution of disputes between QA and other functions. QA0P N1.21 - Quality Assurance Plans ~ This procedure defines Quality Assurance Department responsibilities for parti ipating in the preparation of Quality Assurance Program Plans.or Quality Assurance Program Indexes and for preparing Quality Assurance Functional Plans. QA0P N1.22 - Quality Assurance Acceptance Procedures This procedure defines requirements and responsibilities of the Quality Assurance Department for the preparation, release, and control of Quality Assurance Acceptance Procedures (QAP's). 1740 218 'ORM 719 P R E V. 7 78

NO N011QFP810001 Rockwelilnternational Energy Systems Group PAGE 23 QA0P N2.02 - Document Review This procedure identifies requirements, assigns responsibility, and defines procedure for review by QA prior to release of drawings, specifications, and technical procedure / instruction documents. QA0P N2.03 - Document Control This procedure provides direction for the control of engineering and shop drawings, including customer drawings applicable to prod-ucts to be fabricated in the ESG Manufacturing Shops. The purpose of such control is to assure the fabrication, processing, inspec-tion, and testing of products to the proper drawings. CA0P N3.00 - Calibration of Measuring and Test Equipment This procedure defines requirements for calibration control of tools, gauges, instruments, and test equipment used by Manufactur-ing and Quality Assurance to measure products (materials, parts, components, and appurtenances) or to control processes related to the product. QAOP N3.02 - Control of ESG Tooling This procedure defines the requirements ar.d responsibilities for control of tooling used by Mr.ufacturing and Quality Assurance Departments in product fabrication. QA0P N4.00 - Procurement Documents This procedure defines requirements and responsibilities for prepara-tion, review, and approi al of procurement documents associated with the purchase of materials, parts, and services. 1740 219

( Rockwelllnternational PAGE 24 Energy Systems Group QA0P N4.01 - Approved Procurement Sources This procedure defines Quality Assurance Department requirements for evaluation and approval of procurement sources (suppliers) of material, parts, and services used in ESG products. Suppliers are evaluated to applicable standards by survey or evaluation of pre-vious performance. QA0P N4.02 - Procurement Inspection Instructions This procedure defines Quality Assurance Department requirements and responsibilities for preparing inspection instructions appli-cable to procured items and services. QA0P il4.03 - Source Inspection / Surveillance This procedure defines Quality Assurance Department requirements and responsibilities for inspection of procured items and services at a supplier's facility. QAOP N4.04 - Receiving Inspection This procedure defines Quality Assurance Department requirements and responsibilities for inspecting and testing incoming procured items and services. QA0P N5.01 - Shop Travellers This procedure defines the requirements and responsibilities for the preparation and utilization of the Manufacturing Production Order (MPO) and Manufacturing Operationg P.ecords (MOR), which are ESG's shop travellers. 1740 220

NO N011QFP810001 Rockwell!nternational Energy Systems Group PAGE 25 QA0P i;6.01 - Qualification of Welding Procedures and Personnel This procedure establishes requirements and responsibilities for qualifying welding procedure specifications and welding personnel. QA0P ti6.02 - Qualification and Certification of tiondestructive Examination Personnel This procedure establishes requirements and responsibilities for the training, examination, qualification, and certification of Energy Systems Group personnel engaged in the following nonde-structive examination processes: Radiographic Liquid Penetrant Magnetic Particle Eddy Current Ultrasonic Leak Detection QA0P !!6.03 - tiondestructive Examination Procedures This procedure establishes requirements and assigns responsibilities for preparing and controlling nondestructive examination (NDE) procedures used for determining compliance of products to require-rents of applicable codes and standards. QA0P N6.04 - Weld Material Control This procedure defines requirements and responsibilities for issuance and control of welding materials (electrodes, rods, spools, and flux). QA0P ti6.05 - Qualification of Special Processes This procedure defines requirements and responsibilities for quali-fication of special processes used during fabrication or inspection of products at Energy Systems Group. 1740 221

NO N011QFP810001 Rockwell!nternational Eugy Systems Group PAGE 26 QA0P N7.00 - Product Acceptance Tests This procedure defines requirements and responsit Mites of Quality Assurance Department personnel in performing acceptance tests, or witnessing acceptance tests performed by others on parts, material, subassemblies, assemblies, subsystems, and systems (items) that require acceptance by Quality Assurance, and requires provisions for satisfaction of test prerequisites, suitable environments, and appropriate equipment. QA0P N7.01 - Proof Pressure Testing of Pressure Vessels This procedure defines the requirements and responsibilities for performing hydrostatic or pneumatic tests of ESG-fabricated ASME Code or other products. QA0P N7.02 - Qualification and Certificaticn of Dimensional Inspection Personnel This procedure defines requirements and responsibilities to provide a mandatory program of training, examination, and certification for personnel performing dimensional inspection. The program will provide periodic updating to accommodate changes in requirements and maintain the level of knowledge necessary to perform dimen-sional inspection assignments. QA0P N9.00 - Stamp Control This procedure defines the requirements and responsibilities for the issuance, application, and control of stamps used for markings that identify personnel performing examination, inspection, test, welding, and brazing operations. 1740 222 ._,m....

NO N011QFP810001 Rockwelllnternational PAGE 27 Energy Systems Group QAOP N9.02 - Serialization of Hardware This procedure defines Manufacturing and Quality Assurance Depart-ment requirements associated with the serialization of parts and assemblies that are fabricated or procured by Manufacturing. QAOP N10.00 - Nonconforming Materials, Parts, and Components This procedure defines reuqirements and responsibilities for con-trol and disposition of nonconforming materials and items in the product manufacturing / procurement processes. QA0P N12.00 - Packaging and Shipping Inspection This procedure defines Quality Assurance Department responsibilities for inspecting the packaging and the preparation for shipment of ESG products. It applies to products requiring Quality Assurance acceptance that are shipped from ESG, to an ESG construction site, to an ESG customer, or to an ESG supplier. QA0P N13.02 - Quality Assurance Data Packages This procedure provides format and content requirements for QA data packages, which include, inter alia, configuration summaries, shop travellers and supporting documentation, procurement data, personnel qualifications and certifications, and engineering documents. QA0P N13.03 - Use of QA Lab Test Report - Form 711-V This procedure provides for the use of the QA Lab Test Report to report results of chemical, physical, mechanical property, MDE, and other tests performed by the QA Lab. 1740 223

NO N011QFP810001 h Rockwelllnternational Energy Systems Group PAGE 28 QA0P N13.04 - Preparation and Use of Inspection and Test Report, Form 732Q The purpose of this procedure is to establish requirements for use of the Inspection Test Report to report results of tests performed by QA when other report forms are not specified. QAOP N14.00 - Corrective Action This procedure establishes requirements for taking action to correct conditions causing nonconforming material, parts, and components. Its purpose is to provide increased assurance that ESG products will meet design, configuration, and performance requirements. 1740 224 OO6ge eeS e ee e M

A NO N011QFP810001 y Rockwelllnternational PAGE 29 Energy Systems Group mat 1UFACTURING MAflUAL (MM) M-2 Revision Instructions, MP0/MOR This procedure provides instructions and responsibilities when revisions to an MP0/MOR (shop travellers) are required due to Engineering document changes or are requested by Manufacturing or QA. M-3 Cocument Di;tribution This procedure provides the direction and responsibilities for the dis-tribution and control of Engineering, Manufacturing, and QA documents used for fabrication, processing, inspection, and testing in ESG shops, including document changes. M-3 Material Centrol This procedure provides direction for tne control of material whose fabrication or initiation of procurement action is under the jurisdic-tion of Manufacturing. M-3 P3ckaging and Shipping This procedure delineates the responsibilities for, and the methods of assuring, proper packaging of components, materials, assemblies, and tooling when special in-plant handling containers are required, or when the items are prepared for storage or shipment to the custcmer. M-3 Change Letter / Engineering Order - Documentation on Manufacturing Work Orders This procedure establishes instructions for statusing Engineering and shop-floor document changes to shop travellers. 1740 2~25

NO N011QFP810001 Rockwe:llnternational PAGE 30 Energy Systems Group HEALTH AND SAFETY PROCEDURES (HSP) HSP Health and Safety " Red Tag" Form N44-1 This procedure describes the function of the Red Tag, which is placed by Health, Safety, and Radiation Services personnel to prohibit use of equipment or areas that could produce imminent hazards to personnel or property, or that are not in compliance with existing codes. CORPORATE MATERIAL PROCEDURES (CMP'<,) CMP 2.126 - Case File Documentation This procedure establishes the docurrentation required to be accumulated in procurement case files. 6.0 ADDITI0t!AL REQUIREME!!TS This section applies certain additional requirements on programs that package licensed radioactive material fo, shipment that are not specifically addressed in existing ESG or departmental procedures. These requirements are listed below and numbered similarly to the criteria in Section 4, preceding. 4.2: QA Program Reouirement: Management (i.e., above or outside the QA organization) regularly assesses the scope, status, implementation, and effectiveness of the QA program to assure that the program is adequate and complies with 10 CFR 71 Appendix E criteria. 1740 226

4 NO N011QFP810001 RockwellInternational PAGE 31 Energy Systems Group Discussion: Fortuitously, ESG is required by the Clinch River Breeder Reactor Program PSAR to undergo sesquicenually an audit of our compliance with the requirements of the ASME Code Section III and 10 CFR 50 Appendix B by a Rockwell Inter-national audit team independent of ESG. These audits satisfy the requirement stated above, because of the similarity between 50 Appendix B and 71 Appendix E. However, should ESG's involve-ment with CRBRP end, so will the requirement for those audits. In that event, it is ESG's position that the audits required by S0P K-17 still satisfy the requirement because the audit team is selected from a group within QA (QA Audits and Con-trols) which is independent from those who perform the work being audited (Manufacturing, Purchasing, or Research and Engineering), from those who perfonn inspection activities (Inspection & Test), and frcm those responsible for estab-lishing the QA programs (QA Engineering). 4.4: Procurement Document Control Recui rement: Procurement documents for spare or replacement parts of safety-related structures, systems, and components are subject to controls at least equivalent to those used for the original equipment. Discussion: No ESG procedure specifically adresses spares and replacements. However, since those are deliverable end items, they will be handled the same as any other deliverable end item, including the imposition of the same controls as would be to end items identified as plant units. 4.6: Document Control Requirement: The documents that are controlled under this subsection are identified in the PSAR. (Minimum list provided.) 1740 227

k NO MMMM Rockwell!nternational PAGE 32 Energy Systems Group Discussion: Reference to a PSAR is not appropriate for this program. However, each of the items listed (except for the PSAR) is addressed elsewhere in this QFP. 4.7: Control of Purchased Material, Equipment, and Services Requirement: Suppliers' certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid. Discussion: ESG does not routinely require overchecks of certificates of conformance. However, items purchased for packaging of licensed radioactive material for shipping shall have their certificates overchecked at intervals consistent with their contribution to safety. 4.8: Identification and Control of Materials, Parts, and Components Requirement: The location and method of identification do not affect the fit, function, or quality of the item being identified. Discussion: Other than for small parts, this requirement is not addressed in ESG directives. Shop travellers shall specify the method and location of identification markings so that the fit, function, or quality of the item is not impaired. 1740 228 14065 ............. -}}