ML19259A897
| ML19259A897 | |
| Person / Time | |
|---|---|
| Site: | 07100227 |
| Issue date: | 12/21/1978 |
| From: | Gilleland J TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901110146 | |
| Download: ML19259A897 (10) | |
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PD A-s TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 500;C,hestnut Street Towers II DE: 21Jgy y' gs 25
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. 2CIlOli Director of Nuclear Material and Safcguards Nuclear Regulatory Commission Washington, DC 20555
Dear Sir:
In accordance with the requirements of 10 CFR 71.51, enclosed is TVA's " Quality Assurance Program Description for Radioactive Material Shipping Packages Licensed Under 10 CFR Part 71."
This program description references TVA-TR75-1A, " Quality Assurance Prcgram Description," which has been accepted by the Nuclear Regulatory Commission (September 1,1977, letter from C. J. Heltemes, Jr. to J. E. Gilleland).
Copies were submitted previously by my September 16, 1977, letter to C. J. Heltemes, Jr.
Very truly yours,
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1 Ju M J. E. Gilleland Assistant Manager of Power Enclosure
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QUALITY ASSURANCE PROGRAM DESCRIPTION i
FOR RADIOACTIVT.
MATERIAL SilIPPING PACKAGES LICENSED UNDER 10 CFR PART 71 e
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. s Table of Contents Topic Page No.
Introduction 1
1.0 Organization.
1 2.0 Quality Assurance Program 4
3.0 Document Control 5
4.0 Handling, Storage, and Shipping 5
5.0 Inspection, Test, and Operating Status.
5 6
6.0 Quality Assurance Records 6
7.0 Audits.
INTRODUCTION The Division of Pouer Production is the licensee within TVA for radioactive material shipping packages licensed under 10 CPR Part 71.
The purpose of this document is to establish a quality assurance program that satisfies the requirements of Appendix E to 10 CFR Part 71.
This program primarily addresses a quality assurance program for use, maintenance, modification, and repair of radioactive material shipping packages (hcreinafter referred to as " packages"). Design, fabrication, assembly, and testing of new packages are performed for TVA under contract.
liowever, TVA retains full responsibility for the procured services and performs review and evaluation of the vendor's quality assurance program to verify that it meets the requirements of Appendix E to 10 CFR Part 71.
The TVA quality assurance program for nuclear plant operations is contained in Topical Report TVA-TR75-1A which has been approved by the Nuclear Regulatory Commission. Certain aspects of TVA-TR75-1A are applicable to this program and are identified by reference.
1.0 ORGANIZATION The organization chart in Figure 1 shows the Division of Power Production which has responsibility for the quality assurance progran (hereinafter referred to as the Package Quality Assurance Program or PQAP) for radioactive material shipping cackages and its implementation for the design, fabrication, assembly, testing, use. maintenance, modification, and repair of packages.
1.1 Director of Power Production The Director of Power Production is responsible for maintaining the PQAP description and Radioactive Material Shipment Manual (RMSM). Ile ensures that responsibilities for quality assurance are clearly defined and understood and that each organization is adequate to accomplish its task.
Significant problems or occurrences relating to safety or quality assurance are brought to his attention and he participates directly in their resolution as required.
1.2 Ou_a_lity Assurance Staff The Supervisor, Quality Assurance Staff, reports to the Director of Power Production or his designated alternate and acts as his representative on all quality assurance matters. Functions and responsibilities of the Quality Assurance Staff are as follows:
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1.7, Reactor Engineering Staff The Reactor Engineering Staff has the following responsibilities:
a.
Prepares and coordinates review of specifications for design, fabrication, and testing of packages, b.
Prepares and coordinates review of package license applications and amendments.
c.
Maintains the PQAP description and the RMSM in order to ensure that the most current NRC and DOT regulations are incorporated into the shipping procedures.
d.
Analyzes reports of abnormal equipment operation or personnel errors to identify and correct problems.
1.S puclear Plant _ Superintendent Primary responsibility and authority for implementing the use, maintenance, modification, and repair requirements of the PQAP are vested in the plant superintendent. Through assignments to his section supervisor, he ensures that instructions are prepared in accordance with established quality assurance policies and requirements; that work is performed in accordance with approved documents; and that results are documented and proper records maintained. The plant superintendent is responsible for the necessary training and qualification of plant personnel. He is also responsible for the training and qualification of contractor personnel as required by the RMSM.
1.9 Plant Quality Assurance 1taff The Plant Quality Assurance Staff assists the plant superir.uetdetat in developing and implementing a comprehensive plant quality assurance program which meets the RMSM requirements for the use, maintenance, modification, and repair of packages. The Quality Assurance Staff performs periodic surveys of quality assurance functions to evaluate the effectiveness of the program and makes recommendations to the plant superintendent regarding implementation.
When quality assurance problems occur, the Plant Quality Assurance Staff supervisor has the responsibility and authority to take the necessary corrective action including termination of an activity through the plant superintendent when use, maintenance, modification, or repair work fails to comply with approved specifications and plans.
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1.
Coordinates quality assurance activities between the Division of Power Production and the Office of Power Quality Assurance and Audit Staff (QA&AS).
2.
Provides guidance on quality assurance natters relative to NRC regulatory requirenents and coordinates replies to liRC-NRR questions or concerns. Reviews and concurs in proposed PQAP revisions.
3.
Monitors regulatory compliance actions and conmitments, QA&AS audit findings, and keeps Director of Power Production informed regarding the status and adequacy of the PQAP.
1.3 _ Office of Power Quality Assurance and Au_d_it Staff _ (QA&AS)
Provides support to the Division of Power Production in implementation of the PQAP. Specifically, it provides the independent audit function and evaluates the adequacy of vendor quality assurance prograns.
1.4 Power Plant liaintenance Branch The Pouer Plant Maintenance Branch provides assistance and guidance to plant superintendents on difficult or unusual package maintenance problems. The Power Service Shops manufacture and test package liners in accordance with approved drawings, specifications, and procedures as appropriate.
1.5 Plant _ EngineerinJ; Branch The Plant Engineering Eranch provides technical and engineering support for radiochenical analyses and resolution of difficult or unusual nroblems associated utrh the use, maintenance, modification, or repair of packages.
1.6 Nuclear Generation Branch The Chief, Nuclear Generation Eranch, is responsible for PQAP development and implementation to ensure the proper design, fabrication, assembly, testing, use, maintenance, modification, and repair of packages. Uc is responsible for coordinating the activities of the radioactive vaste management program with other branches and divisions as required.
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Should the plant superintendent fail to follow the reco==endations of the Plant Quality Assurance Staff supervisor, the supervisor has the authority to report directly to the Nuclear Generation Dranch chief.
2.0
_UALITY ASSURA?!CE PROCPRf Q
The PQAP is directed at providing the appropriate control or quality in relation to the importance of the acti11ty or iten to radiological safety.
It includes procedural controls for ensuring that the use of packages does not result in undue risk to the health and safety of the public or employees. These procedural controls are established in the R fSM and imple=enting plant instructions. The requirements of the certificate of compliance for each package shall be included in these procedural controls. Revisions to PQAP documents shall be made in accordance with established procedures and instructions.
All work affecting the characteristics of the package which are critical to safety shall be controlled by properly approved procedures. Maintenance and repair work on packages shall be performed in accordance with the provisions of Topical Report TVA-TR75-1A as specified for critical (safety related) structures, systens, and components.
TVA personnel who handle radioactive caterials shall be trained in accordance uith established procedures. They shall also be indoctrinated in the aspects of the PQAP. Non-TVA personnel who transport or handle radioactive materials at TVA sites shall receive radiological and energency preparedness training fron TVA as specified in the R: ISM.
Proposed package codifications shall be submitted to the Reactor Engineering Staf f in accordance with approved procedures for review and evaluation. Modifications involving unreviewed safety questions shall be submitted to NRC for revicu and approval before inple=entation.
POAP revisions shall be reviewed and concurred in by the Power Production Quality Assurance Staff. The Office of Power QASA Staff shall provide independent audits of the effectiveness of implementation of the PQAP.
Contractor services are procured for design, fabrication, asse=bly, and testing of new packages. The contractor will be required to have a quality assurance program that =eets the requirenents of Appendix E to 10 CFR Part 71.
The adequacy of his program will be evaluated by the Office of Power Quality Assurance and Audit Staff.
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3.0 _DOCbitnNT CONTROL Requirements for preparation, revision, and approval of implementing procedures for the use, maintenance, codification, and repair of packages shall be established in the RMSM.
POAP implenenting procedures and associated revisions shall be prepared, reviewed by qualified individuals, and approved for issuance by authorized personnel prior to release or issuance in decordance with written procedures. Preparation, review, approval, and issue of controlled documents shall be accomplished in accordance with written approved procedures. These procedures shall identify the organization responsible for the actions and ensure that changes to these documents will be reviewed and approved by the originating group.
4.0 IIA'!DLINC, STORACE, AND SHIPPING _
The RMSM requires approved procedures for handling, storing, and shipping optrations; establishes safety restrictions concerning handling, storage, and shipping of packages; and ensures that all tests, certifications, acceptances, and final inspections have been completed before shipnent. Packages shall be handled, stored, cleaned, and shipped in a manner to minimize deterioration, contamination, or damage.
Package-handling equipment such as cranes, forklifts, and cables uhich are important to safety shall be checked or tested in accordance with established procedures before use.
The plant superintendent shall designate those persons responsible for the critical (important to safety) handling, storage, and shipping operations.
5.0 INSPECTION, TEST, AND OPERATING STATUS The RMSM shall establish procedures for determining inspection, test, and operating status of the packages. A log of inspection, test, and operating status shall be raintained for each package.
Receipt, preshipnent, and certificate of compliance test and inspection results shall be logged. A " hold" on package use shall be established in the log uhen inspection or test criteria are not satisfied. Only authorized personnel shall be allowed to remove a " hold."
The plant superintendent shall designate those persons responsible for implementing this part.
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, UALITY ASSUPJU!CE RECORDS 6.0 Q
The RMSM shall establish the requirements for preparation and storag.e of quality assurance records. Isotopic analyses, cask liner leak test certifications, checklists, audit reports, package logs, Radioactive Material Shipment Records, and other records shall be maintained as specified in the RMSM. Records shall be identifiabic and retrievable and maintained in designated storage locations in accordance with established procedures. Records shall be naintained for a minimum of two years.
7.0 AUDITS Periodic audits of the PQAP shall be conducted by the Office of Power Quality Assurance and Audit -Staf f in accordance with the provisions of section 17.2.18 of TVA Quality Assurance Topical Report TVA-TR75-1A.
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DIVISION OF PO'ER PRODUCTION QUALITY OFFICE OF PO'ER ASSURANCE QA&A STAFF STAFF POWER PLANT NTCLEAR CENERATION PLANT ENdINEERING MAINTENANCE BRANCH BRANCH BRANCH REACTOR ENGINEERING STAFF offsite onsite NUCLEAR PLANT PLANT QA STAFF PLANT STAFF LEGEh3 Independent audit function Figure 1 Division of Power Production Organization
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