ML20038A659
| ML20038A659 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/09/1981 |
| From: | CHEM-NUCLEAR SYSTEMS, INC. |
| To: | |
| Shared Package | |
| ML19262F767 | List: |
| References | |
| 4313-01354-01-N, 4313-01354-01-NP, 4313-1354-1-N, 4313-1354-1-NP, TAC-57811, TAC-57812, NUDOCS 8111160122 | |
| Download: ML20038A659 (89) | |
Text
{ R E v. DESCRIPTION REVISIONS DATE APPRO IE D l
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O Doc. # 0021b, Disk 0001B
! R EVISION ST A TUS SHEET 1 2 3 4 5 6 7 8 I 9 10 11 12 13 14 15 16 17 I REV. - - - - - - - - - - - - - - - - -
SHEET 18 19 20 21 22 23 24 25 26 27 28 29 30 l REV.
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PREPARED DAT l ,
f/ggf // y/gj CHEM - NUCLEAR SYSTEMS, INC.
( C KED TITLE I I TOPICAL REPOP.T
_EIIG191EER 4 ll CNSI CEMENT SOLIDIFICATION SYSTEf1 C( 8111160122 811109 OUAL Ty PDR
^ ADOCK 05000395
- h. E 't.l I' $ tij PDR APPROVE D .
CONTR ACT NO. DOCUMENT NO. REV. SHEET ghg )[j Q $l 4313-01354-01-NP -
1 l CNSO 1001/8-78
r 3 ABSTRACT O
i Chem-Nuclear Systems, Inc. (CNSI) CEMENT SOLIDIFICATION SYSTEM is' designed to process low-level, liquid radioactive w;.ste. The waste is solidified within a shielded container and then sealed for transport.
CNSI's CEMENT SOLIDIFICATION concept uses Portland Type I Cement and various pretreatment additives for solidification control in a Process Unit. Two types of Process Units are in opei ation: an all-weather mobile trailer model and a portable skid-mounted unit.
Waste solidification is accomplished in accordance with an approved Process Control Program. The program is designed to ensure each batch of radioactive waste received by the process unit is capable of being solidified into a monolithic solid having essentially no free water.
All processes are remotely operated from a low radiation area. Industrial O serets e#e ree4 14e# Pretectien Pei4c4es er casi ere eer4#ee e#e e#rercee.
The CNSI Quality Assurance Department ensures that CEMENT SOLIDIFICATION SYSTEM operations are monitored and controlled for safety and efficiency.
CNSI's CEMENT SOLIDIFICATION SYSTEM is designed and operated in accordance with the current applicable industrial and nuclear regulatory requirements.
the present system represents CNSI's eight years of operating experience and I an on going research and development program to provide state-of-the-art technol ogy.
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TABLE OF CONTENTS
't Abstract 2 Table of Contents 3 List of Figures 5 1.0 SCOPE 6 l.1 Purpose 6 1.2 Applicability 6 2.0 SYSTEM DESCRIPTION 7 2.1 Radwaste Transfer 7 2.2 Dewatering System 7 2.3 Chemical Cretreatment 8 2.4 Cement Transfer System 8 2.5 In-Container Mixing 8 2.6 Piping and Instrumentation 8 3.0 PROCESS CONTROL PROGRAM 12 3.1 Program Design 12 O 3.2 weste SemPlies erd Anal > sis ,2 3.3 tample Acceptance Criteria 13 3.4 Records 13 4.0 EQUIPMENT DESCRIPTION 14 4.1 Plant Connection Stand /Dewater .wp Assembly 14 4.2 Fillhead 14 4.3 Hydraulic System 14 4.4 Cement Transfer Equipment 14 4.5 Bulk Transport Trailer or Storage Silo 15 4.6 Cement Transfer Compressor 15 4.7 Containers 15 4.8 In-Container Mixing Equipment 15 4.9 Vent Filters 15 4.10 Installed Crane 15 5.0 SAFETY CONSIDERATION 16 5.1 Radiation Protection 16 5.2 Industrial Safety & Fire Protection Program 17 DOCUMENT REV. bHEET 4313-01354-01-NP -
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r 3 TABLE OF CONTENTS (continued)
T 6.0 EQUIPMENT ARRANGEMENT 19 6.1 Utility Interface Requirements 19 7.0 OPERATING EXPERIENCE (HISTORY) 20 8.0 QUALITY ASSURANCE PROGRAM 21
! 8.1 Program Design 21 8.2 Quality Assurance Responsibilities 21 9.0 RESEARCH AND DEVELOPMENT PROGRAM 24 9.1 Objectives 24 9.2 Primary Development Plan 24 9.3 Laboratory Test Results 25 9.4 Pilot Plant Experience 25 10.0 POSTULATED ACCIDENT ANALYSIS 27
! 11.0 APPLICABLE CODES AND STANDARDS 29 11.1 Operating Equipment 29 11.2 Operating Procedures 29 O 11.3 Si stem Precesses 30 Appendix A Chen-Nuclear Systems, Inc., Process Control Program Using CNSI Portable Solidification System (Typical)
Appendix B Chem-Nuclear Systems, Inc., Operating Procedures for the Portable Solidification Units (Typical)
Appendix C Chem-Nuclear Systems, Inc. , Quality Assurance Program Appendix D Solidification Testing Program O
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LIST OF FIGURES a
_F_IGURE PAGE
- 1. Mobile Tra1!er Cenent Solidification Unit 9
! 2. Portable Skid-Mounted Cenent Solidification Unit 10
- 3. Typical P & ID for Cenent Solidification Unit 11 l
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DOCUMENT REV. SHEET 4313-01354-01 -NP - 5 t J CNSO 1002/8 78
r 3 1.0 SCOPE e
1.1 Purpose i This topical report describes the design and operation of Chen-Nuclear Systens, Inc. (CNSI) CEMENT SOLIDIFICATION SYSTEM (CSS). A discussion of individual issues which relate to the safe operation of a nobile unit at a customer site is also included. The report is intended to provide the Nuclear Regulatory Cornission with sufficient information to evaluate CNSI's CEMENT SOLIDIFICATION SYSTEM.
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- 1.2 Applicabiiity The information presented in this document applies only to CNSI's CEMENT SOLIDIFICATION SYSTEM.
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DOCUMENT REV. SHEET 4313-01354-01-NP - 6 t J CNSO 1002,8 78
- r 3 2.0 SYSTEM DESCRIPTION CNSI'sCEMENTSOLIDIFICATIONSYSTEMprovidesallcomponents)andcontrols necessary to process liquid radwaste into a water free c2 ment monolith.
Subsystem assemblies provide for the transfer of radwaste to 'the disposable liner, the dewatering of ion-exchange slurries or filter sludges, the transfer of cement and additives to the liner, and proper agitation to ensure a liquid free, homogeneous end product.
A combination of electric and pneumatic controls are provided to allow l precise monitoring and control of all system functions by the mobile ur.;t operator.
l The unit provides a pneumatic conveyor system for transfer of the cement from a silo or trailer-mounted storage container to the disposable liner. A specially designed filter assembly removes dust and excess water vapor from the air and ensures that cement dust is not released during the transfer operation.
The CNSI CSS system functions include:
2.1 Radwaste Transfer Radwaste is transferred to the CSS from the plant through 1-1/2 inch waste hose to the waste container. An automatic shut-of f valve and l sample / flush connections are included in the plant connection stand. Standard waste batches up to 75% of the rated container
! volume are common. This quantity May vary and will be determined by the Process Control Program.
l 2.2 Dewatering System
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A pneumatic diaphragm pump assembly with sample and flush connections removes excess sluice water from the waste container before solidification. Mechanical filtration through a disposable filter removes waste solids from the sluice water and allows excess water to be returned to the plant.
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i r 3 2.3 Chemical Pretreatment I
O Various chemicals are ac'Jed to the waste stream to obt)in optimum solidificatito of the waste / cement mixture. This chemical pretreatment includes pH and setting time adjustment.
! 2.4 Cement Transfer System Portland Type I Cement is delivered to the site in bulk pneumatic discharge trailers. A pneumatic conveying system transfers the cement while an electronic load cell accurately totals the weight of cement delivered to the waste container. The transfer system is designed to eliminate any cement dusting.
4 2.5 In-Container Mixing The cement and radwaste are mixed inside the disposable waste container using a disposable shaf t/ blade mixing assembly mounted in the container. The mixer is driven by a hydraulic motor mounted on j
I O the fiiiheed esseme>>.
2.6 Piping and Instrumentation i
1 The Piping and Instrumentation Diagram (Figure 3) suamarizes the principal system components, indicators, and controls.
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l A general arrangement of the system components and the mobile f transporter are illustrated in Figures 1 and 2.
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DOCUMENT REV. SHEET 4313-01354-01-NP 11 CNSO 1002/8 78
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3.0 PROCESS CONTROL PROGRA!!
3.1 Program Design The process control program for CNS ' 2;mnt Solidification Units is designed to establish a set of procc:; parameters which provide reasonable assurance of complete solidification of low-level i radioactive waste.
The program consists of instructions for sample collection and analysis for the determination of specific solidification process parameters. Acceptance criteria ard program variations are also included.
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3.2 Waste Sampling and Analysis A 100 or 200 al. sample is taken from the waste to be soliditied prior to full scale solidification. This sample is solidified j according to the sample verification procedure given in the process control program (PCP). From this is calculated the amount of waste, cement, and any additives (discussed in section 2.3) required for complete solidification of the weste.
If there is no change in the chemical composition of the waste as verified by the utility, test results and full scale solidifications will be considered reproducible. Thereafter a sample will be taken and analyzed prior to the tenth batch solidified from the same waste j source. A " Batch" is defined as the amount of radwaste required to fill one disposable liner to its maximum waste level setting.
1 Typical waste types processed by the Cement Solidification Units are evaporator bottoms, ion exchance resin slurries, boric acid solutions, sodium sulfate solutions, and filter sludges.
O DOCUME N T REV. SHEET 4313-01354-01-NP -
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3.3 Sample Acceptance Criteria Acceptance criteria for sample test-solidification are't
) (1) Visual inspection of the mixture after cement addition confim I
that the mixture is homogeneous wi+h no free water on the i surface.
(2) Visual inspection of the end product after hardening verifies that it is a unifom, liquid free, free standing monolith.
(3) The end product resists penetration when probed with a pencil sized probe.
When the sample tested meets these criteria the appropriate volumes and amounts of materials required for full scale solidification are calculated using work sheets supplied in the PCP for that specific waste material.
3.4 Records
, O A solidification worksheet is filled out for each sample test solidification. The following data are recorded on the worksheet 4 for future reference: '
(1 ) Waste Type j
1 (2) Waste Concentration (3) Resin Type
! (4) Density l (5) Volumes of additive chemicals if applicable.
.l (6) Volume cement added (7) Sample evaluation: time, description, acceptable The following data are recorded for all batch solidifications:
- (1) Waste Volume (5) High Level Height (2) Additive Volumes (6) Cement Alam Height (3) Cement Volume (4) Waste Alam Height l DOCUME N T REV. SHEET 4313-01354-01 -NP -
13 i t J CNSO 1002.8 78
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r 3 4.0 EQUIPMENT DESCRIPTION The equipment for the CSS is designed to be modular and pedeit maximun l flexibility of operation at individual clants. Major components of the syste.a include:
4.1 Plant Connection Stand /Dewater Pump Assembly Includes waste control valve with radiation monitor, a stainless steel dewater pump with sample and flush connections, service water and service air connections.
4.2 Fillhead Includes level, pressure and proximity instrumentation; process connections for waste, cement, additives, vent and dewater; mixing systen notor; nechanical clanping system; closed circuit TV camera.
4.3 Hydraulic System (1) The purpose of the hydraulic system is to supply motive power to operate the liner mixer blade at the correct speed.
(2) The major components of the hydraulic system include:
e hydraulic power plant (mot.,ted in the mobile unit trailer) e hydraulic mixer motor nountec on the fillhead for direct drive of container mixing shaf'., capable of 0-300 rpn.
e flow neter providing mixer speed indication e necessary high pressure hoses and fittings 4.4 Cenent Transfer Equipment A cement conveyor system, suitable for transferring 4 - 5 tons / hour of cenent from a bulk transport trailer to the waste container, is located near the bulk trailer. A built-in electronic load cell which precisely weighs the cenent transferred to the liner is DOCUMENT REV. SHEET 4313-01354-01 -NP -
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r 3 incorporated in this system.
4.5 Bulk Transport Trailer or Storage Silo i A trailer or silo provides for cement storage at the plant. A specially desigr.ed coupling connect! to the cement conveyor suction hose.
4.6 Cement Transfer Compressor Electrically powered, skid mounted compressor to supply air to cement conveyor for cement transfer, air to the bulk transport tank for aeration, ard line cleanout.
4.7 Containers Standard shipping containers with disposable mixing shaft assemblies must be provided by CNSI.
4.8 In-Container Mixing Equipment Shaft-mounted, paddle wheel mixers driven by the mixing motor. A bushing mounted in the bottom of the container and the hydraulic rixing motor shaft provide the end supports for the mixing shaft.
l 4.9 Vent Filters i
A filter system is installed to trap any cement dust that escapes the container.
4 j 4.10 Installed Crane
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A 2-1/2 ton crane is supplied with each transport trailer that is capable of ha.1dling the fillhead and other systems components. This crane is not suitable for handling cask lids or liners. (Portable f systems designed for installation in plant do not have this feature.)
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r 3 5.0 SAFETY CONSIDERATIONS O 5.1 Radiation Production g
- (1 ) System Design Radiation protection measures for CNSI's Cement Solidification System begin with the basic design of the individual unit. The l design has been developed to maintain radiation levels as low as reasonably achievable. Design features which illustrate this are as follows:
o remote operation of waste transfer process from a low radiation area. _
e remote operation of flushing sequences for the waste and solidification agent lines to prevent radiation buildap.
e remote monitoring of automatic processes.
e strategic placement of flow control valves for isolation O e of '#8ivie#ei sist e co Po#emts-use of stainless steel components wnich come into contact with radioactive naterial during sc.lidification.
i (2) On-site Radiation Protection l On-site radiation protection measures are closely interfaced f with the facilities radiation protection program. The Cenent Solidification System operating procedures are reviewed by the facility prior to operation to determine that the sytem meets the requirements of the custoner's Final Safety Analysis Report.
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Specific CNSI required radiation monitoring procedures for each unit utilize both portable radiation instrumentation and facility radiation detection instrumentation. The following l
surveys are performed to meet CNSI requirenents: .
e continual in-line monitoring of the radwaste transfer i
O iine s radiat4en leveis e#rine waste tremsfer e#8 fieshi 9 operation DOCUMENT REV. SHEET 4313-01354-Ul NP -
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r 3 e radiation surveys of the exterior of the transport cask or i liner before and after filling with processed waste e radiation surveys of the fillhead following nach container ,
filling e radiation survey of the unit and imediate area following l unit operation CNSI operating procecures raquire the following radiation protection measures to be ft,limzad at all time::
e Appropriate protective clothing must be worn when perfoming any work activity which has a potential for contamination.
e The Unit's operators must remain at a " safe" distance or in a shielded area as auch as possible during all routine operations 5.2 Industrial Safety & Fire Protection Program (1) Program Design CNSI's safety and fire protection requirements satisfy the current industrial standards for operatirg equipment and operating procedures.
The Solidification Units are designed to meet the applicable I requirements of the Occupation Safety and Health Act (OSHA).
The Unit's design and operation must meet or exceed the customer's standards.
1 The Solidificaiton Units are built in compliance with the current National Electrical Code (NEC). Loads, wiring, circuit breakers, motor starters and overload heaters, fuses, and grounding are installed in accordance with applicable NEC subsections.
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The mobile units with trailers are equiped with a 600 volt,100
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! amp AC-grounded input power connector and a fused disconnect switch. The main power disconnect feeds a 480 VA(/240-120 VAC 25KVA transformer.
The transformer secondary feeds a 100 amp main circuit breaker panel which supplies power via a 20 circuit panel for
- instrumentation, control and heating.
No fle- e materials are use in the solidification process.
(2) Unit safety Equipment
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Each Unit is equipped with a 9 lb. Halon type fire extinguisher i specified for use on Class A, B and C fires. Each Unit is also equipped with first aid kits which include eye. flushing equipment, face shields and protective clothing. While on a customer site, the customer's fire fighting unit will provide
() equipment for any Solidification Unit emergency.
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r 3 6.0 EQUIPMENT ARRANGEMENT O 6.1 Utility Interface Requirements g (1) General Requirements:
Electrical: 120A, 480/3 Phase /60 Hz.
Service Water: 25 gpm at 80 psi minimum Service Air: 75 SCFM at 80 psi minimum Waste: 1-1/2 inch 150 pound ANSI flange connection Dewater: 1-1/2 inch 150 pound ANSI flange connection Vent: 2-1/2 inch vent hose discharge to plant off-gas system,150 SCFM at 10 inches (H20) approximately (2) Telephone comunication between the plant operator and the CNSI mobile unit operator must be provided by the utility.
l (3) The utility shall make prior arrangements for shipping of the solidified material.
l (4) The utility must be prepared to accept cement shipments prior to the arrival of the unit on site.
(5) The utility shall issue, according to its radiation protection procedures, a Radiation Work Permit (RWP) to the CNSI operator before operations begin.
(6) The utility shall provide the CNSI ooerator with any clothing or equipment for necessary radiation protection.
(7) A controlled area must be established around the processing area including cement storage trailer.
(8) Utility personnel shall designate an area to be used for test solidifications.
(9) The utility will provide crane services, torque wrenches, and other material necessary for loading the disposible liners and preparing the solidified waste for shipment. (Portable units also require crane service for placing fillhead on liner during operation).
(10) The utility will provide a forklift capable of 4000 pounds at 6 O foot moment am to unload the removable skids and place them in position for full-scale solidification.
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r 3 7.0 OPERATING EXPERIENCE (HISTORY)
O Chem-Nuclear Systems, Inc. has been actively involved in thq safe transport and dispesal of radioactive waste using solidificetion methods for the past eight years.
On-site processing of radioactive waste has been efficiently and effectively performed using various media. Over the past eight years CNSI has processed radwaste at 19 nuclear facilities using these processes.
Cement is the newest process added to the CNSI line of services. The prototype mobile solidification using cement was released early in 1981 and has been in service processing liquid radwaste at a nuclear facility since that time. This unit is housed in a 24 foot trailer which serves as an operator station as well as the transport vehicle. As experience has been gained using this new process, the first unit has been updated and modernized.
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Production cement mobile solidification units have incorporated design changes based on the operating experience of the first unit. Portable, skid-mounted units have also been developed for use within a facilities radwaste building. The solidification function and basic operational l design of both trailer and skid units are identical. One each of the l production portable and mobile units are currently in operation servicing I
nuclear facilities. The prototype un.L is also currently in service at a f nuclear facility.
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r 3 8.0 QUALITY ASSURANCE PROGRAM 8.1 Program Design CNSI's Quality Assurance (Q. A.) Program is designed to ensure that ,
the systems or components developed by CNSI will perfom satisfactorily in service. The Q. A. responsibilities outlined below are specific to Q. A.'s involvement in the CEMENT SOLIDIFICATION SYSTEM. However, they may be extrapolated to other safety related I issues. CNSI's Q. A. program meets the requirements of 10 CRF 50 Appendix B and 10 CFR 71 Appendix E.
8.2 Quality Assurance Responsibilities (1) Inspection Control Q.A.'s inspection program for the CEMENT SOLIDIFICATION SYSTEM is designed to verify that quality related activities i
within the system confom to design or process requirements.
O Scheduied e#d unenno#<.ced 4nsPections or eudits of field units are routinely perfomed by CNSI's Q.A. inspectors.
Refer to CNSI Document QA-AD-001, Quality Assurance Program.
(2) Drawing and Document Control Q. A. confims the adequacy and completeness of all Solidification Unit drawings, procedure.s and instructions. .
All changes to drawings or documents are subject to the same confimation. These controls are detailed in CNSI documents I EN-AD-001, Drawing Control Procedure and CN-AD-002, Document Storage and Control l
(3) Purchased Material, Equipment or Service Control Q. A. perfoms preliminary evaluations of potential vendors and makes procurement source recorraendations to CNSI's l Purchasing Solidification Design Groups. Q. A. also confims that the supplied items or services conform to the f procurement requirements.
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i r- 3 (4) Component & Material Identification and Controi Q. A. confims that the identification and control of purchased components, naterials, parts or assemblies used within the CEMENT SOLIDIFICATION SYSTEM meet the established requirements. This applies to all phases of fabrication and installation.
(5) Special Process Control Q. A. confims that special fabrication, installation and inspection processes associated with the CEMENT SOLIDIFICATION SYSTEM are performed in accordance with the applicable CNSI requirements.
i (6) Test Control
. Q. A. 's test control progran confims that tests associated with Solidification Unit's fabrication, checkout, operation and maintenance are perforned in accordance with written procedures.
(7) Measuring and Test Equipment Control Equipment used for testing of Mobile Unit equipnent is calibrated to NBS Standards.
(8) Handling, Storage and Shipping Control i Q. A. confims that handling, storage and shipping requirements of any iten related to the Solidification Unit,
, including the Unit itself, are satisfied.
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l (9) Nonconformance Control l Q. A. identifies and documents nonconforming materials, parts or processes dealing with Solidification Unit operation.
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- (10) Corrective Action l Q. A. continually monitors materials, processes or workaanship to ensure nonconf omances are corrected and the corrective I
action is documented.
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r 3 (11) Audits Q. A. conducts systen and procedure audits of quality-related issues to verify the effectiveness of CNSI's Q.1. program in relation to the CEMENT SOLIDIFICATION SYSTEM.
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r 3 9.0 RESEARCH AND DEVELOPMENT PROGRAM 9.1 Objectives 't The technical objectives of CNSI's Cement Waste Solidification Program recognized the need for investigation of the chemistry and mechanical systems best suited to accommodate safe and thorough irziobilization of a variety of waste materials. Chemically, it was necessary to detemine a reliable and practical cement composition along with the appropriate additives providing controllable setting reactions. Of particular importance was the fomation of a dry solidification product with superior mec1anical strength and integrity. Agitator design and selection of an adequate power supply were primary equipment considerations, which also included means for remote bulk transfer of principal fomula components.
9.2 P_rimary Development Plan O in4tiei review of eortieed eed nesonry Cements indiceted 18et Portland Type I provided the most practical combination of unifomity, formula versatility, and general availability.
Necessary neutralization cf acidic wastes and conditioning of ion-exchange type materials required evaluation of alkaline hydroxides including those of sodium, potassium, magnesium, and calcium. The exothemic nature of cement hydration, particularly in large containers, was a significant concern as controlled by ~such factors as cement concentration, pH, and specific accelerators and retarding agents. The influence of these variables on reabsorbing l bleed liquid and monolith properties was also of importance. The range of test compositions was selected to represent typical waste streams from boilirg water reactors (BWP,'s) and pressurized water reactors (PWR's). These then included simulated concentrates of l boric acid and sodium sulfate, partial'y depleted ion-exchange resin beads and powdex, also filter sludges containing diatomaceous earth.
! O DOCUMENT REV. SHEET 4313-01354-01-NP -
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r 3 9.3 Laboratory Test Results l Ir.vestigation of cement solidifications using bench-scile quantities
! revealed that calcium hydroxide (line hyorate) wa , the most effective means of moderating setting characteristics over a broad range of waste acidities, and provided advantageous control of bleed liquid even at reduced cement levels. PrJ-treatment of ion-exchange l mcterials with lime produced firm, water-resistant matrices, consistent with the known hartening chemistry of cement and the order of ion replacement according to valence. For certain waste streams the addition of limited amounts of sodiura hydroxide solution in combination with lime proved beneficial. Solidification by addition of soluble silicates was found to involve critical setting times, and provided solids lacking stability after water immersion.
Continued silica studies were rejected.
A later positive development linking laboratory results with field experience was t' use of conditioning ovens to sinultte, on a small scale, the thermal effects of cement t :tions in large containers.
In this way, meaningful process control program (PCP) results were obtained within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The variable nature of waste streams and j
waste temperatures necessitatec empirical determination of
! conditioning procedure it individual operating sites. The oven l
technique was also applief to leachability studies so that sealed l test samples containing radioactive nuclides muld re esent as at.arly as practicable the actual structure of cenent waste solidifications.
9.4 Pilot Plant Experience Cement hydration reactions in 55-gallon drums demonstrate time-temperature profiles in much closer agreement to those in 200 l cubic foot masses than obtainable from beaker tests. Thermocouple probes in combination with recorder charts showed distinct exotherm patterns differentiating the effect of even small quantities of DOCUMENT REV. SHEET 4313-01354-01-NP -
25 t J CNSO 1002,8 78
. _ - - _ _ .-. - _-__ - _ - _ - _ _ - . . _ . _ - ~ . _ - _ _ _ . - _ - - - - _ _ - _ _ _ _ _ - .
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F 3
J reaction accelerators and inhibitors. The desired concentrations of l such additives were then determined as to safety, free liquid, and setting time considerations. It is probable that the ligher l
sustained solidification temperatures in large containers converts some waste chemicals to insoluble zeolitic conpounds thereby improving both mechanical strength and leach resistance. Sample ;
I cubes cut from full scale test billets representing all major waste streams demonstrated compressive strengths of 1000 psi or more. i Minimizing cement usage while yet maintaining final billet dryness and integrity reduces mixing requirements as well as operating costs. Disposable mixer blades proved usable in full-scale
! pilot-plant tests, and heavy duty hydraulic units provided the
! reserve power to assure uninterrupted agitation during addition of 4
dry components. Semi-automated air fluidizers were found effective in delivering both cement and line from portable carrier compartments.
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O DOCUMENT REV. SHEET 4313-01354-01-r4P - 26 w J CNSQ 1002/8 78
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10.0 POSTULATED ACCIDENT ANALYSIS O
The CNSI CEMENT SOLIDIFICATION $1' STEM is designed, fabric 6t3d and operated in accordance with the applicable NRC and National Electric Code Standards. The operating and maintenance proceduies are designed to insure that the risk of an accident is as low as possible. There is no risk of explosion, and the only source of fire is the electrical power
, and control system. Even in the event of an electrical fire, the fail-safe control system is designed to prevent leakage of radioactive materials or spread of the fire to non-electrical components.
4 i The possibility of a release o) liquid radioactive material exists during waste transfers to the waste container and while waste is being stored in the container prior to solidification. A lina rupture during a waste transfer is considered to be the less serious of the potential accidents. The total curie content of the spilled material in a line rupture depends on the specific activity and the quantity of the waste material being transferred. In turn, the quantity of the waste material O sniiied eene#es e# the rie rete e#8 resne#se time er the enereter- ri e" rates depend on the capacity of the facility transfer pumps, but flow rates of 50 gpm are typical, while maximum rates of 100 gpm can be realistically anticipated. The response time of the operator depends on how quickly the operator observes the failure and actuates the waste control valve. Once actuated, the waste control valve closes within 3 -
4 4 seconds. During a waste transfer, the operator is positioned at the control station, visually monitoring the transfer p,ocess. It is estimated that no nore than two r.:inutes would transpire prior to closing the waste control valve. A spill considering maximum flow rate and maximum response time, then, would generate about 200 gallons of liquid ,
or resin slurry waste.
The estimated volume of waste spilled considering the rupture of a liner after both waste and solidification agent transfer to the liner is 2,100 '
- gallons. Therefore, CNSI considers the maximum credible accident to be O
DOCUMENT REV. SHEET 4313-01354-01-NP - 27 e J CNSQ 1002/8 78
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(' 3 l the rupture of a filled liner prior to solidificatioru A postulated accident O anelisis was performee usine the feiiewies essumntions: >
't e The liner contains approximately 2,100 gallons of waste and f solidification agent in liquid state at atmospheric pressure. !
e The iodine partition factor is 10,000 between the liquid and npre
- j phases once the liquid escapes from the liner, j s There is total escape of all noble gases upon ruptore of the liner.
The worst case chi /Q is 7.6 x 10-4 s/m3 .
2 e
- The accident considered was the rupture of approximately 1/3 of the circumference of the liner's botton weld ( Approximately 90 inches x 0.5 inches or 45 Square inches). The lict:r was considered outside the facility's radwaste building. The results of the analysis were:
- e escape rate of approximately 57 gallons per second e time for liner to empty approximately 40 seconds d
e maximum instantaneous radgas concentration at the site boundary
) (dorst case or.ly):
1-131 = 17% MPC O 1-ia - o.i: "ec I-135 = 0.04% MPC Xe-133 = 0.1% MPC K r-88 = 11% MPC J
i O
DOCUMENT REV. hHEET 4313-01354-01-NP -
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CN501002,8-78
- r 3 11.0 APPLICABLE CODES AND STANDARDS i 11.1 Operating Equipment s~
.i (1) 10 CFR 20 Stendards for protection against radiation.
e 10 CFR 20.1 Purpose e 10 CFR 20.101 Exposure of ir.dividuals to radiation in restricted areas. !
i e 10 CFR 20.103 Exp N e of individuals to concentration of j radioactive materials in air in restricted areas.
t (2) Regulatory Guides e R.G. 1.143 Design guides for radioactive waste management systems, structures, and components installed in light-water cooled nuclear power plants.
e R.G. 8.8 Information relevant to ensuring that occupational radiation exposures at nuclear O Power stetiens wiii de es iew as reesene8,1 achievable.
l [ (3) ANSI Standards e ANSI B31.1 Power piping (4) ASTM Standards e E84 Test for surface burning characteristics of building materials.
11.2 Operating Procedures (1) 10 CFR 20 Standards for protection against radiation e 10 CFR 20.1 Purpose e 10 CFR 20.101 Exposure of individuals to radiation in restricted areas.
e 10 CFR 20.103 Exposure of individuals to concentrations of radioactive materials in air in restricted areas.
DOCUMENT R E V. SHEET 4313-01354-01-N P -
29 L J CNSO 1002/S 78
1 r 3 e 10 CFR 20.201 Surveys (precautionary procedures) e 10 CFR 20.203 Caution signs, labels, signals and controls, e 10 CFP 50 Quality Assurance criteria fo't nuclear
, Appendix B power plants and fuel reprocessing plants.
e 10 CFR 71 Quality Assurance criteria for shipping i
packages for radioactive materials.
l (2) CNSI Standards e (lA-AD-001 Quality Assurance Program.
e CN-AD-002 Document Storage and Control.
o EN-AD-001 Drawing Control Procedure.
j e EN-AD-002 Design Control Procedure.
! e CN-AD-003 Procedure for Document Preparation.
e SD-0P-003 Process Control Program For CNSI Cement Solidification Units.
11.3 System Processes (1) 10 CFR 20 Standards for protection against radiation.
e 10 CFR 20.1 Purpose.
e 10 CFR 20.201 Surveys (precautionary procedures).
(2) Regulatory Guides e RG. 8.8 Information relevant to ensuring that occupational radiation exposures at nuclear power stations will be as low as reasonablv achievable.
O DOCUMENT REV. SHEET 4313-01354-01-NP -
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r 3 APPENDIX A Chem-Nuclear Systems, Inc., Process Control Program Using CNSI Portable Solidificatior. System (Typical)
-PROPRIETARY-O I
DOCUBAENT "'* "'"
4313-01354-01 _
t J C8eSO 1002/8 78
r APPENDIX B
(
Chem-Nuclear oystems, Inc. , ONrating Procedures for the Portable Solidification Units (Typical)
-PROPRIETARY-I I
O DOCutAENT R E V- SMEET 4313-01354-01 -
L J cNso toons 7e
F 3 APPENDIX C Chem-Nuclear Systems, Inc. Quality Assurance Program l
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. O DOCUMENT "'V- MEET 4313-01354-01 .
CNSO 1002/3 73
CHEM-NUCLEAR SYSTEMS INC.
9 P.O. Box 1866 e Bellevue,Wav ston 98009 e (206) 8274711 QMLITY ASSUPATE F90GRM O
Prepared by: #
Manalfr, Quality Assurance Approved by:
Di~ -tor of Regulatorb A a a Approved by:
Pre. Tees, asi rim
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Copy No.
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- ' 'e, UNITED STATES
! , e.< -*% NUCLEAR REGULATORY COMMISSION 77 ,i mAsmNGTON. D C. 20555 O {c%.....# i OCT 2 51979 FCTR: RHO 71-0231 Chem-Nuclear Systems, Inc.
ATTt!: Mr. Louis E. Reynolds P.O. Box 1866 Bellevue, WA 93009 Gentlenen:
Enclosed is Quality Jssurance Program Approval for Radioactive Material Packages No. 0231. Revision No. O.
Sincerely.
O Cha les E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosure:
As stated I
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's NRC FORM 311 U3. NUCLE AR REGULATORY COMMISSION i APPROV A L NuueEm 0231 "2- OUALITY ASSURANCE PROGRAM APPROVAL s "'V *"U"*E" FOR RADIOACTIVE MATERIAL PACKAGES 0 Pursuant to the Aton. einergy Act of 1954, as amended,the Energy Reorganization Act of 1974, as amended, and Title 10, Code of Federal Regulations, Chacter 1, Part 71, and in reliance on statements and representations heretofore made in item 5 by the pe son named in item 2,the Quality Assurance Program identified in item 5 is herecy approved. This approvat is issued to satisfy the recuirements of Section 71.51 of 10 CF R Part 71. This approvst is subject to all applicable rules, regulations, and orders of the Nuclear Regulatorv Commasion now or hereafter in effect and to any conditions specified below.
- 3. E E P A R ATION o AT E 2 Newt Chem-Nuclear Systems, Inc.
sTattT Aeoness January 31, 1985 a coc=ETaventa P.O. Box 1866 en- g rip coot l STATE 71-0231 Bellevue WA 98009 5 QU ALIT Y AssW R ANc1 P RoGR AM APPLIC ATION OAT Et&#
Serte-ber 6. 1979 s coNoiTioNs Activities conducted under applicable criteria of Appendix E of 10 CFR Part 71 to be executed with regard to transportation packages by January 1, 1980.
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O %)HE US fft[LE AF, REGUL ATORY CO*AM;SSION
,/f n ,,
sicN ATua s gg OAT Charles E. MacDo a d Chief, Transportation Certification Branch 5 1979 nivie<-- n< rno, cyc 7 e w v3 g < g m y , y--3
PAGE REVISION ETATUS Page Rev. Page Rev.
I A 11-1 A II A 11-2 A III A 12-1 A IV A 12-2 A V A 13-1 --
VI A 14-1 A VII --
14-2 A 1-1 A 14-3 --
1-2 A 15-1 A 1-3 --
15-2 A 1-4 A 16-1 A 2-1 A 17-1 A 2-2 A 17-2 A 2a3 A 18-1 a 2-4 A 18-2 --
2-5 A s-) 3-1 A 3-2 A 4-1 A 4-2 A 5-1 --
5-2 -- I 6-1 A 6-2 A 6-3 A 6-4 A 7-1 A 7-2 A 7-3 A 4-1 A 8-2 A 9-1 A 9-2 A 10-1 A 10-2 A pocume=T REV. SMEET QA-AD-001 A I J
CNso too2/s 7s
r REVISIONS
Description of Revision Rev. A Revised per Change Request QA-AD-001-01 (Approved by CNSI Safety Review Board 8/30/79)
O l
Revised by:
' ' ^ S- . T M /f Date
~
Approved b f W.Q a o u R E V. SMEET g yy QA-AD-001 J CNs01002/3 73
I r 3 TABLE OF CONTENTS i
Page TITLE PAGE PAGE REVISION ETATUS I REVISIONS II TABLE OF CONTENTS III PORIV0RD VII 1.0 ORGANIZATION 1-1 2.0 QUALITY ASSURANCE PPDCRAM 2-1 2.1 Hana gement 2-1 2.2 Personnel Qualifications 2-1 2.3 Quality Assurance Policies, Goals and Objectives 2-2 2.4 Quality Assurance Manual Distribution 2-2 2.5 CNSI Procedure List 2-2 3.0 DESIGN CONTROL 3-1 4.0 PROCUREMENT DOCUMENT CONTROL 4-1 5.0 INSTRUCTIONS, PROCEDURES AND DRAWINGS 5-1 6.0 DOCUMENT CONTROL 6-1 6.1 Document Types controlled 6-1 6.2 Document Review 6-1 6.3 Document Control 6-1
= 6.4 Document Change Control (Excluding Drawings) 6-2 6.5 Drawing Control 6-3 6.6 Document Control for Suppliers 6-3 6.7 Document Availability 6-4 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7-1 O 7.1 Supplier Evaluation 7-1
=
DOCUedENT REV. SHEET QA-AD-001 A III CNSQ 100U5 78
- r 3 TABLE OF CONTENTS, cont. ,
O P,,ag_e 7.2 Procurement Requirements 7-1 7.3 Supplier Surveillance 7-2 7.4 Receiving Inspection 7-3 7.5 Supplier Audit 7-3 8.0 IDENTITICATION Ah"O CONTROL OF COMPONENTS AND MATERIALS 8-1 8.1 Components and Materials 8-1 8.2 Bulk Raw Material 8-1 9.0 CONTROL OF SPECIAL PROCTSSES 9-1 9.1 Personnel Certification 9-1 9.2 Subcontractor Control 9-1 q
9.3 Procedures 9-2 10.0 INSPECTION 10-1 10.1 Inspection Procedures 10-1 10.2 Supplier Inspection 10-2 10.3 Indirect Control 10-2 11.0 TEST CONTROL 11-1 11.1 Test Procedures 11-1 11.2 Test Records 11-1 11.3 Test Control for Procured Items 11-2 11.4 Modifications, Repairs and Replacements 11-2 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12-1 12.1 CNSI's Equipment Calibration and Control 12-1 12.2 Measuring and Test Equipment at Subcontractors 12-1 12.3 Inspection Validity 12-2
()
l DOCUMENT R E V. '8HEET QA-AD-001 A IV w J CNs01002/8 78 t
r 3 TABLE OF CONTENTS, cont.
O m 13.0 HANDLING, STORACE AND SHIPPING 13-1 13.1 Procured Items 13-1 13.2 Transport Casks 13-1 14.0 INSFECTION, TEST AND OPEP.ATING STATUS 14-1 14.1 Equipment Status 14-1 14.2 Establishment of Exa=inations and Tests 14-1 14.3 Hold Point s 14-1 14.4 Check Lists of Examinations, Tests and Inspections 14-2 14.5 Examination or Process Status 14-2 14.6 Inspection Status 14-2 14.7 Control of Inspection Stamps 14-2
() 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS 15-1 15-1 15.1 Internal Nonconformances 15.2 Subcontra: tor Control 15-1 15.3 Verification of Rework or Rep?ir Acceptability 15-2 15.4 Nonconformance Disposition 15-2 15.5 Assessment of Nonconformances 15-2 16.0 CORRICTIVE ACTION 16-1 17.0 QUALITY ASSURANCE RECORDS 17-1 17.1 Maintenance and Access to Records 17-1 17.2 Contents of Record Files 17-3 17.3 Permanent Records 17-2 t
17.4 Non-Permanent Records 17-2 17.5 Record Storage Facilities 17-2 O
DoCUeAENT REv- SHEET A V QA-AD-001 e '
eNso iocus 7e
F- 3 TABLE OF CONTENTS, cont. i P,,agg l
18.0 AUDITS 18-1 l
18.1 Audit Schedule 18-1 18.2 Audit Personnel 18-1 18.3 Audit Reports 18-1 18.4 Audit Follow-Up 18-2 1
O 1
O R E V. 3 MEET DocuutNT A VI QA-AD-001 L J cmso toove.7e
. . __ ._ , . - =- - .
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This program defines and describes the basic policies nd procedures used .
by Chem-Nuclear Systems, Inc. (CNSI) to establish quMir y assuranse e-quirements for all activities af fecting safety-related functions of systems and components, including transport casks, of CNSI. The activities include designing, purchasing, fabricating, handling, shipping, storing, inspecting, testing, operating 7nd using, maintaining, repairing and modifying. Chem-Nuclear Systems, Inc. top management has approved and fully supports ad-herence to the policies and procedures contained in this progra=.
It is intended that policies and procedures described in this prugram meet or exceed the appropriate requirements of ASME Boiler and Pressurt Vessel Code Section VIII, ANSI N!.5.2-1977, IOCTR50 Appendix B, 10CTR71 Appendix E and MIL-Q-9858A. This program, in full or in part, is sub?cet to review and comment by customer representatives.
Revisions or additions to the program will be made as necessary to con-for= to the current needs of the company. All revisions will be dated and referenced on the revision page in front of the program.
i Copies of the Quality Assurance Progra= will be issued to the customer and government representatives, as required. Assigned copies of this pro-gram will be serialized and a record maintained showing the transmittal I of each revision. Information copies of the progran may be distributed without serialization and they will not be updated with revisions.
t l
This program is reviewad in total by CNSI's management at least once a year to assure conformance to current practices and requirements.
l The Quality Assurance (QA) Progra= for CNSI was established and imple-mented by the President of CNSI. The Q.A. Program has the full support of CNSI's management and all CNSI's employees shall adhere to its provisions.
O DocumstNT REV. SMEET
- VII QA-AD-001 j c=so inovaas i - _ _ . . , _ , , , _ , , _ - _ . _ _ . _ _ _ - . _ _, . _ , _ _ _. _ _ _ _ _ . _. -
r 3 1.0 ORGANIZATION The Quality Assurance organization within Chem-Nuclear Systems, Inc. , con-sists of a Quality Assurance Manager with the overall responsibility for pro-viding quality assurance of design, fabrication and operation. He has a staff of quality assurance personnel reporting to him, who are assigned to the following areas:
A. Vendor inspection B. Engineering / Fabrication C. Field Operations D. Barnwell operations The individual assigned to vendor inspection is responsible for quality assurance activities to assure CNS1 that all vendor and/or subcontractor s I
activities are conducted in accordance with a written program that addresses the applicable criterla of CNSI's Quality Assurance Program.
Quality assurance for engineering / fabrication is responsible for
() verifying that all equipment has been designed, f abricated and tested in accordance with established CNS1 procedures.
Quality assurance for field operations has the responsibility for audit performance of all CNSI field operations. Audits include verification of field unit operation in accordance with prescribed procedures and inst ructions .
The individual assigned to the Barnwell site is responsible for monitoring all quality-related activities. Special emphesis is placed on assuring that the operation (use), maintenance and performance of applicable quality control checks on casks licensed per 10CFR71 are conducted in accordance with written procedures. He also has the responsibility for monitoring the rolling stock maintenance and health physics activities performed at Ba rnwell .
All quality assurance personnel report directly to the Quality Assurance Manager. The Quality Assurance Manager reports to the Director of Regulatory Af f airs of Chem-Nuclear Systems, Inc. (see Figure 1-1).
f)
V arv, sNEET 00Cuusgy A 1-1 QA-AD-002 J C88sQ 10024 7s
r 3 This reporting route has been selected specifically to allow the Quality Assurance Manager suf ficient authority and autonomy to implement and
(
direct CNSl's Quality Ascarance program, to assure conformante to quality requirements, and to f anction independent of undue influences and responsibilities for schedules and costs (eee Figure 1-2).
Quality Assurance personnel shall have the responsibility and authority, specified in written proceducts, to perform the following functions effectively and without hindrance or reservation:
- a. Identify quality problems, stop unsatisfactory work, and control further processing, delivery or installation of nonconforming material:
- b. Recommend and/or approve solutions through proper channela;
- c. Verify Lsplementation of solutions. ,
Position descriptions of the Quality Assurance Manager and al] Quality Assurance personnel shall include prerequisite experience and/or required training, which assures that they are competent to perform the assir,ned
() duties. Qualifications for the position of Quality Assurance Manager are as follow:
- a. A bachelor's degree in a technical field;
- b. At least ten gears of experience in esgineering or manufacturing;
- c. A working knowledge of applicable quality-related codes, standards, regulatory and statutory requirements;
- d. The ability to prescribe, apply and assess compliance with applicable requirements.
While other organizations may be delegated the tasks of establishment and executica of a quality assurance program, it must be recognized that the responsibility for equipment m.ned and operated by CNSI is retained by CNSI The Quality Assurance Kanager, upon notification of need for forther direction or resolution of Q. A. problems, has the authority to communicate or direct communications with any contractor doing business with CNSI.
Ordinarily, such communications vlil be through the branch of CNSI having responsibility for the function provided by the contractor involved.
O DocumswT REV. EMEET QA-AD-001 A 1-2 CNs0100LW71
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2.0 QUALITY ASSURANCE PROGRAM r The Quality Assurance Program is comprised of those planned and systsmatic actions necessary to assure adequate confidence that all Chem-Nuclear activi-ties will be conducted in a satisfactory manner and that all equipment and material vill perform satisfactorily in service. It is the intent of this progra= to insure that all activities are conducted in a manner that has the degree of reliability on which safety and performance of these activities were evaluated. The CNSI Quality Assurance Program applies to the design, l manufacture and operation of casks, liners, mobile solidification units, dendneralization units and decontamination units and.the operation of trans-portation trailers.
2.1 Management in order to assure effective implementation, assess the scope and status, and determine the effectiveness of the Q. A. Program, the President of Chem-Nuclear has appointed a member of Senior Management, with broad authority, to execute these functions. Programastically, these functions are executed through the use of internal audits, field investigations, customer / user service reports and internal reporting procedure.
2.2 Personnel Qualifications The personnel assigned to perform quality assurance functions are trained and qualified to perform those functions in accordance with ANSI N45.2.6, NRC Regulatory Guide 1.58, ANSI N45.2.12 and other applicable documents. Further, an indoctrination and training pro-gra= is established such that;
- a. Personnel responsible for performing quality-related activities are instructed as to the purpose, scope and implementation of quality-related manuals, instructions and procedures;
- b. Personnel perfo ming quality-affecting activities are trained and qualified in the principles and techniques of the activity being performed;
- c. The scope, objective and the method of implementing the indoc-trination and training program are documented;
- d. Proficiency of personnel performing quality-affecting activities is maintained by retraining, re-*vamining and/or recertifying.
ft E V. SHEET DOCUaNNT A 2-1 QA-AD-OOl J L csso toors 7s
r 2.3 Quality Assurance Policies, Goals and Objectives It is the policy of Chem-Nuclear that all activities which are governed by the Code of Federal Regulation, license, Certification of Complince, Letter of Approval or other regulatory requiremente, be conducted in accordance with written, approved procedures which incorporate the regulatory requirements in a manner which is easily understood by the user / operator. Quality-related activities shall be performed with specified equipment and under suitable environmental conditions, and prerequisites shall be satisfied prior to inspection and test.
Adherence to the procedute requirements is mandatory for all Chem-Nuclear saployees. All procedures which are required to assure ,
health and safety are required to be submitted to the Safety Review Board for approval prior to implementation.
It is the stated goal and objective of the Chem-Nuclear Quality Assurance Progra= to provide those mechanisms and environ =ents necessary to achieve a reliable Quality Assurance Program for all activities which affect health and safety or are specified by a regulatory re-quirement. This goal and objective is promulgated throughout the company through the use of written procedures, management memoranda and management / staff meetings.
Differences of opinion between QA personnel and other CNSI depart-ments shall be resolved in a meeting of the Safety Review Board.
2.4 Quality Assurance Manual Distribution Measures to control the distribution of the Quality Assurance Manual
~
at.d revisions thereto are described in Section 6 of this docu=ent.
2.5 CNSI Procedure List Table 2-1 provides a suncary listing of written CNSI procedures cross-referenced to the 18 criteria of 10CFR 71, Appendix E and 10CFR50, Appendix B.
m U .
DOcutaENT REV. SHEET A 2-2 QA-AD-001 CNs01002/8 7s
r 3 TABLE 2-1 CNSI PROCEDURES CROSS-REFERENCED TO THE 18 CRITERIA OF 10CFR 71, APPENDIX E di 10CFR 50, APPENDIX B Key: I. Organization II. Quality Assurance Progra:
III. Design Control IV. Procurement Document Control V. Instructions, Procedures and Drawings VI. Docaent Control VII. Control of Purchased Material, Equipment, and Services VIII. Ide-tification and Control of Materials IX. Cantrol of Special Processes I. Inspection II. Test Control XII. Control of Measuring and Test Equipment XIII. Handling, Storage and Shipping XIV. Inspection, Test, and Operating Status XV. Nonconfor=ing Materials, Parts, or Components XVI. Corrective Action XVII. Quality Assurance Records XVIII. Audits CNSI Procedure Title Criteria Number Addressed CN-AD-001 Safety Review Board II CN-AD-002 Document Storage and Control VI, XVII CN-AD-003 Procedure for Document Preparation IV CN-AD-004 Defect Reporting Procedure IV CN-AD-005 Incident Reporting Procedure IV, XVI CN-AD-006 Radioactive Material License State of South n.a.
Carolina CN-AD-007 Purchasing Procedures and Guidelines VII, IV CN-AD-008 Quality Assurance Records XVII CN-AD-009 Packaging, Shipping, Receiving, Storage XIII and Handling Procedure DOCutAENT REV. SMEET QA-AD-001 A 2-3 L i C'eso 1002/s-7s
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TABLE 2-1 (CONT'D)
O Criteria Pr dure Title Number Addressed CN-AD-010 Control of Special Processes IX CN-AD-Oll Control of Measuring and Test Equipeent XII CN-AD-012 Training and Indcctrination Program II CN-AD-013 Test Control XI CN-AD-014 Internel Audit Procedure XVIII, I CN-AD-015 Procedure for Control of honconforming Ite=s XV CN-AD-016 Corrective Action Procedure XVI CN-AD-017 Approved Vendor List IV, VII CN-AD-018 Inspection Progra: X CN-EM-001 Emergency Notification Procedure n.a.
CN-QI-001 Instructions for Nonconformance Report XV, XVI CN-QI-002 Instructions for Inspection / Rejection Report VII, XV, XVI DC-OP-001 Operating Procedure Electro-Con Decontamination V, Syste=s EN-AD-001 Drawing Control Procedure III, VI EN-AD-002 Design Control Progra= III, EN-AD-003 Engineering Drafting Standards III, V EN-OP-001 Crimp-A-Cap Lid Crimper Installation V Operation, and Maintenance Manual HC-MF-001 Glass Inspection Procedure V HC-MF-002 Grounding Procedure V HC-MF-003 Class Hand Polishing Procedure V HC-MF-004 Band Frame Disasse=bly Procedure V HC-MT-006 Handling, Rigging, Packing and Shipping XIII Procedure HC-MF-007 Radioactive Conta=ination Control Procedure V QA-AD-001 Quality Assurance Progra= I XVIII QA-AD-002 Field Audit Procedure XVIII QA-AD-003 Procur ement Document Review by Quality IV Assurance QA-AD-004 Supplier Surveillance VII QA-AD-005 Supplier Survey Procedure VII Supplier Furnished Records VII, VI, IX, XII QA-AD-006 QA-AD-007 Supplier Audit Procedure VII, XVIII DOCUMENT ' n E V. SHEET QA-AD-001 A 2-4 g >
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Criteria Pr dure Title Addressed Nu=ber Radiation Exposure Records and Procedures XVII RP-AD-001 V
SD-AD-001 Topical Report CNSI Radwaste Solidification Syste=
V SD-OP-001 Operating Precedure for CNSI Solidification Syste= Units 7 through 13 Transportation E=ergency Plan XIII TR-EM-001 Handling Procedure for CNSI Transport Cask XIII TR-OP-001 Number 6-101 Handling Procedure for CNSI Transport Cask XIII TR-OP-002 Nu=ber 4-45 Bandling Procedure for CNSI Transport Cask XIII TR-OP-003 Nu=ber 8-120 (LL-50-100)
Handling Procedure for CNSI Transport Cask XIII TR-OP-004 Nu=ber 4-85 (6244)
Bandling Procedure for CNSI Transport Cask XIII TR-OP-005 Nu=ber 7-100 Handling Procedure f or CNSI Transport Cask XIII TR-OP-006 I Nu=ber 14-190 (BC 48-220)
Handling Procedure for CNSI Transport Cask XIII TR-OP-007 Nu=ber 6-75 (AL-33-90)
Handling Procedure for CNSI Transport Cask XIII TR-OP-005 Nu=ber 14-195H Handling Procedure for CNSI Transport Cam'. XIII TR-OP-009 Nu=ber 15-160B (6144)
Handling Procedure for CNSI Transport Cask XIII TR-OP-010 Nu=ber 6-80-I XIII TR-OP-Oll Handling Procedure for CNSI Transport Cask Nu=ber 21-300 XIII TR-OP-012 Handling Procedure for CNSI Transport Cask Nu=ber 1-13C Handling Procedure for CNSI Transport Cask XIII TR-OP-013 Nu=ber 1-13G Cask / Trailer / Tractor Inspection Procedure XIII TR-OP-014 Interline Trafier Inspection XIII TR-OP-015 O
V R EV. SHEET DOCUMENT A 2-5 QA-AD-001 >
L CNSQ 1002/5-75 i
r 3 0 3.0 DESIGN CONTROL The Design Control Program at CNSI ensures that design characteristics, es-pecially those u lated to safety, are controlled, inspected, and tested; that designs developed by the CNS1 Engineering Department meet all applicable regulatory requirements; and that design activities are carried out in a planned, controlled, and orderly manner.
A comprehensive syste= of established procedures and policies is used for developing and implementing design projects, as well as controlling design documents (drawings) and design document distribution.
Various individuals in the CNSI Engineering Department bear respensibility for the selection and control of design parameters and for the development of design documents. Their responsibilities are summarized below:
- a. The Project Engineer is responsible for the initial interpretation of design requirements and for confirming that applicable regulatory re-quire =ents are correctly translated into specifications, drawings, procedures, and instructions. Design requirements are also reviewed by Quality Assurance to ensure that suitable design controls are applied to such activities as seismic, stress, thermal, lydraulic, radiation, and accident analyses; compatibility of materials; and accessibility for inservice inspection, maintenance, and repair.
- b. The Design Lead coordinates with the Project Engineer and serves as a liaison between the Drafting Department, the Project Engineer, and Quality Assurance. The Design Lead also supervises the Draf ting Department, confirms that design specifications are properly referenced on drawings and other desi;o documents, and controls access to the drawing vault.
- c. The Design Draftsperson produces accurate and precise drawings that con-form to the design specifications and that properly list or reference those specifications.
-d. The Design Checter reviews the drawings for technical accuracy and checks the design to ensure that the equipment can and will perform the functions q for which it was designed.
./ e. A representative from the Quality Assurance Department also reviews the design to confirm that all quality assurance requirements have been pro-DOCuaAENT A E V. sMEET QA-AD-001 A 3-1 L s _
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() perly identified and that the requirements have been met in the finished design.
- f. The Engineering Manager reviews the design and confirms that the total design package meets all regulatory requirements and is ready for release and fabrication.
i The Design Control Program also provides for design reviews at regular intervals '
to assure that design characteristics can be controlled, inspected, and tested, and that inspection and test criteria are identified. Formal design reviews take place at 25%, 501, and 1001 completion and include the Project Engineer, the Design Lead, and any other individuals or groups involved in the develop-ment of the design. The Engineering Manager participates in the 50% and 1001 i completion reviews. Design reviews may also be called at any time a proble=
is identified. Records are kept of these design reviews, and measures are i
taken to ensure that design errors are corrected and not repeated. Design controls also extend to other individuals or groups in interfacing design
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organizations.
Materials, parts, equip =ent, and processes are controlled according to procure-
! ment procedures outlined in Section 7.0 of this document. The procurement documens specify all design base requirements including the applicable regula-tory requirements, material and component requirements, drawing % specifications, codes and industrial standards, test and inspection criteria, and special procesr instructions. No equipment is released to the requisitioning party until it meets the requirements specified in the purchase order. All materfals, s
parts, and equipment are reviewed for suitability prior to selection.
Drawing chanbes are made in accordance with procedures outlined in Section 6.5 of this dccument. Engineering Change Orders (ECO's) and/or design docu-mants (drawings) must be approved by the Project Engineer, Quality Assurance,
- and the Engineering Manager before a revised drawing can be released and the design fabricated. Dr' awing revisions are subject to the same reviews and approvals as the original drawing. CNSI drawing control procedures ensure
- that obsolete drawings are destroyed at the time a revised drawing is released.
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4.0 PROCUREMENT DOCUMENT CONTROL n e procurement of materials, components, services at, or services af fecting assemblies, for use ci utility customer sites or other licensed activities is accomplished with a written Purchase Order. Purchase Order forms are controlled, and in the possession of a limited number of individuals. Only these individuals are authorized to release Purchase Orders, and are re-sponsible for conforming with established procurement and record keeping procedures. The sequence of events leading to Purchase Order issuance, and the associated record keeping activities, is in compliance with procedures published in ANSI N45.2.13.
It is CNSI's policy that procurement documents, except for administrative supplies, are reviewed by the cognizant department / site manager. Where the department / site manager or his designee determines that the procurement action is governed by an applicable standard, specification, code, regulation, license or Certificate of Compliance, the procurement document is submitted to Quality Assurance for revia and approval.
The Quality Assurance reviewer exacines the procurement document to assure that co=plete inf ormation is provided t.o identify:
- a. The applicable 10CTR Part 50, Appendix B and 10CTR71, Appendix E re-quirements which must be addressed;
- b. The design basis technical requirements including the applicable regula-tory requirements, material and component identification requirements, drawings, specifications, codes and industrial stand;rds, tests and in-spection requirements, and special process instructions;
- c. The documentation to be prepared, maintained, and submitted to the purchaser for review and approval;
- d. The records to be retained, controlled, and maintained by the supplier, and those delivered to the purchaser prior to use or installation of the materials or components;
- e. The procuring agency's right of access to supplier's facilities and records for source inspection and audit;
- f. Quality requirements, which must be correctly stated, inspectable and controllable with adequate acceptance and rejection criteria.
O REV. SHEET DOCum8ENT 4'I QA-AD-001 A J L CNso t002/s 7e
r 3 The individual authorized to control and release Purchase Orders prepares
( the Purchase Order, incorporating all applicable information referenced in the preceding paragraph. One copy of all Purchase Orders is maintained in a control file.
Procurement documents for spare or replacement parts shall be subject to the same controls that are applied to the original equipment. Changes and revisions to procurement documents are subject to the same review process as original documents.
Original and revised procurement documents shall be clearly annetated to indicate the completion of the aforementioned review and approval sequence.
Record copies rhall be maintained in accordance with document control pro-cedures in effect at time of preparation.
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DOCUh4ENT REV. SMEET QA-AD-001 A 4-2 esso tocus 7s
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l r 3 5.0 INSTRUCTIONS, PROCEDURES AND DRAVINGS Activities affecting product quality in design, manufacturing, operation, and maintenance are prescribed tf documented instructions, procedures or drawings of r. type appropriate to the ciretanstances. They include quantitative and/or qualitative acceptance criteria for determination that t the prescribed activities have been satisfactorily performed. The activities l are accomplished in accordance with the instructions, procedures or drawings.
4 The purpose of the instructions, procedures and drawings er described here-in is to provide and com=unicate standards for the quality determination within the company, to the vendors and to the customers and are directed at maintenance of an overall quality program. These instructions are avail-able for review by customer representatives, hacedures and instructions are prepared by the cognizant department. All instructions and procedures are maintained current with a documented method of revision. Instructions, procedures and drawings are readily available to personnel at locations requiring their use.
t The drawings, instructions and procedures detail, where applicable, any
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equipment, etr d onmental conditions and the exact method to be used to determine the condition of the item under examination. Prerequisite calibration of all special test equipment is clearly stated in :letail. All acceptance criteria are clearly defined. If visual aids or standards are available and applicable, they are referenced in drawings, instructions and procedures.
The CNS1's Quality Assurance organization reviews and concurs with in-spection plans; test, calibration and special process procedures; drawings and specifications and their changes; and verifies that methods for com-plying with regulations, such as Code of Federal Regulations (10CFR50, 10 FR71) a e specified in instructions, procedures and drawings requiring such verif: :ations.
O DocutaENT REV. SHEET QA-AD-001 5-1 L J cNs01002/s 7s
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F CNSI s 0. A. organization shall review instructions, procedures and drawings to ensure that adequste quantitative and qualitative acceptance criteria are
' present.
The CNSI procedure for document preparation shall be followed exactly in the course of preparation, review, approval and control of instructions and procedures. Drawings shall be prepared, reviewed, approved and controlled in accordance with engineering department procedures.
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r 3 6.0 DOCUMENT CONTROL Written CNSI procedures control drawings, specifications, procedures, in-structions and their respective changes to assure adequacy.
6.1 Document Types Controlled The control inelades all documents and their changes affecting the quality program. These documente include, but are not limited to, design drawings and specifications, manufacturing drawings, procure-ment documents, quality assurance manuals, manufacturing, inspection, operating and testing instructions, test procedures and design change requests. The control syste= provides adequate and timely distribution of all documents to recipients listed on a document distribution list and prompt removal of all obsolete documentation from defined docu-ment control centers.
6.2 Document Review All design drawings, design procedures and specifications are issued by Engineering. They are reviewed and approved by Quality Assurance for adequacy and compliance with applicable quality standards and/or contractual require =ents. The review assures the availability of all information required to produce an article in complete conformity with design require =ents. The review process is the same for document changes.
All procedures and instructions are reviewed by CNSI's Quality Assurance. Documents which are not safety-related are approved by the cognizant department or site manager. All safety-related documents are reviewed and approved by CNSI's Safety Review Board.
6.3 Document Control Execution of an effective document control system requires the following:
- a. Each document shall have an identifying number and a complete descriptive title.
- b. Each document shall have means for identifying the revision status and the effective date of each revision.
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r 3 The number of copies made and issued of a document is controlled by a document distribution list maintained in the document file.
The removal of obsolete documents, procedures, details, forms, etc. ,
is accomplished immediately when such material is made obsolete by a new or revised document. Obsolete documents are destroyed except for a history copy maintained in the document file.
Procedures and their changas arc distributed on a formal basis and are of standard format. In cases of emergency., however, approved handwritten procedures or marked-up changes can be considered satis-factory as long as they are converted to the standard form and be-come official within 30 days.
Drawings and/or documents sent to a customer or subcontractor are accompanied by a docu=ent transmittal letter showing the drawing and/or document nu=ber, revision and date of transmittal. A copy of the transmittal letter is kept in the project file.
. Purchase orders used on manufacturing type projects are changed to indicate the effect of engineering changes. On completed projects, as-built drawings and documents are maintained in the project control file to reference the documents to which the item was built.
1 6.4 Document Change Control (Excluding Drawings)
Proposed changes to existing documents shall be r'ecorded on CNSI Change P;.2 ;uest Fo rms . These forms are also used to submit proposed changes to customers when their approval is required prior to change incorporation.
All proposed changes are reviewed by Quality Assurance prior to their approval to determine the effect of the change on the quality of the article and the resultant changes in inspection, procedures or i
operations. Quality lasurance shall approve changes only af ter i
receipt of a completed Chtnge Request with authorized approval signatures. Departments approving the change (s) shall be the same as l () indicated on the approval page of the document to be changed.
WENT R E V. SHEET QA-Ah-LO1 A 6-2 t ;
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r Approved change documents are attached to the original document and
() are incorporated in the document. The changed document will be distri-buted by Quality Assurance to the individuals indicated in the document distribution log.
6.5 Drawing Control Drawing changes are made using the Engineering Change Order (ECO) form. The form is a one-part reproducible form used to specifically J
delineate a proposed change. The form is also used to submit proposed changes to customers when their approval is required prior to change incorporation. Minor design changes may be recorded directly on i
design drawings in the revision block. When this procedure is followed, an ECO is not required.
All proposed changes are reviewed by Engineering and Quality Assurance pria? to their approval to determine the effect of the change on the quality of the article and the resultant changes in inspection, procedures or operations. Revisions, changes and modifications of
- () affected syst ems are made only af ter approval of the ECO. Approved changes are maintained in an ECO file by Engineering. When changes are extensive, the ECO form may be attached directly to the drawing (s) re-issued.
i 6.6 Document Control for Suppliers Subcontractors and vendors are required to maintain an effective i
drawing change control system when these drawings are provided as part of the contractual requirements.
i Procurement of articles to CNSI's design requires a document control 2
system that includes assurance of notification of changes to the subcontractor or vendor, verification of change incorporation and i appropriate identification of those items on which the change is i
incorporated.
Procurement of articles of subcontractor's design requires a docu-s
() mant control system that assures notification of CNSI by the sub-1 DOcue4ENT REV. SMEET
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contractor of the proposed change, approval of the change by CNSI
(.e and appropriate identification of the items on which the change is incorporated.
6.7 Document Availability Documents will be avi;ilable, prior to consnencement of work, at the locations where activities involving them are to be performed.
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r 3 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES The procurement control methods CNSI uses establish measures to assure that
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u < procured items and/or services are clearly and adequately specified in pro-curement documents and are supplied by vendors and subcontractors who are capable of producing items and furnishing services which conform to pro-curement document requirements. These procurement control methods, which consist of procedures or instructions, include provisions for vendor evalua-tion, review of procurement requirements and surveillance of vendor's fa 111ty.
7.1 Supplier Evaluation CNSI Engineering, Procuremen; and Quality Assurance personnel parti-cipate in evaluation of procurement sources. Recommendation of procurement sources is based on these evaluations. Results of supplier evaluations performed prior te centract award are docu=ented and filfd. The evaluations cover review of capabilities and facilities for technical, manufacturing and quality performance, and include any or all o: the folleving as appropriate:
- a. Historical performance data, particularly in product quality
(} , an3 s'elivery;
- b. Review and co==ent on supplier's quality assurance progra=;
- c. Source audits to verify supplier's imple=entation of his quality assurance progra=, as required;
- d. Source qualification programs.
The evaluation considerations include the elements of the NRC's Quality Assurance Criteria to the extent these criteria are applicable to the equipment being procured. Actions to correct deficiencies in the supplier's organization or quality proEram are resolved with the supplier's manage =ent prior to fabrication of ordered items.
7.2 Procurement Requir e=ent s Requirements to be met by the ocpplier are detailed in the procurement documents which may include procurement specifications. This document details the aspects of supplier quality assurance, for example, inspection reports, provisions for inspection, equipment calibration prior to use, and provisions for inspection after DOCUMENT REV. SHEET A 7-1 QA-AD-001 ./
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component repair. The procurement specification may c100 rsquire the successful bidder to submit the following for CNSI's review:
- a. Special process procedures for performing welding, heat treat-ment, nondestructtre examination;
- b. Reccamended inspection point program;
- c. Appropriate documentation as required by applicable codes, standards and procurement documents;
- d. Notices of nonconformances and deviations;
- e. Test procedures in accordance with applicable codes and standards.
4 7.3 Supplier Surveillance CNSI Quality Assurance is responsible for conducting and documenting supplier surveillance. Surveillance activities typically include:
- a. Wittessing test in: pections and nondestructive examinations and various special process operations;
- b. Monitoring heat treatment, welding, cleaning, preserving, packing and packaging activities;
- c. Verifying supplier conformance with established procedures, such as:
( 1. use of CNSI accepted drawings and procedures
' 2. use of accepted product and procesc quality planning
- 3. document change control
- 4. material identification and traceability control
- 5. control and calibration of measuring equipment'
- 6. control of major repair welding
- d. Reviewing completed product quality documentation and/or checklists prior to release of rquipment for shipment.
s Documentation of nonconformances shall be provided by suppliers as prescribed in Section 15 of this program.
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CNSI's quality assurance personnel perford a review to assure the validity of supplier documentation during in-process, testing and final inspection stages.
The entire documentation package is reviewed prior to shipment of manufactured items. This documentation includes material test reports, inspection and test reports, NDE reports and applicable code data reports.
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r 3 The frequency and extent of the surveillance are consistent with the importance to safety, complexity, and quantity of the ite= or service being furnished. The measures to evaluate the effectiveness of the control of vendor quality are described above.
7.4 Receiving Inspection Receipt inspections shall be performed on purchased items (including spare or replacement parts) to assure that:
- a. Material, components or equipment are properly identified and corresponds to the receivins, documentation;
- b. Material, components, equipment and acceptance records are inspected and judged acceptable in accordance with specified requirements prior to installation and use;
- c. Inspection records or certificates of conformance attesting to the acceptance of material, components and equipment are available and are filed in the project file prior to ume;
- d. Items accepted and released are identified as to their inspection status prior to forwarding the= to a controlled storage area or releasing the for installation or furthet work.
7.1 Supplier Audit Measures fer auditing suppliers are described in Section 18 of this docu=ent.
O DOCuteE NT ngy, g,4g gy QA-AD-001 A 7-3 L J C8vSo 1002/s 7s
r 3 8.0 IDENTIFICATION AND CONTROL OF COMPONENTS AND MATERIAL.S
() The identification and control as described herein shall apply to components, production materials, tulk raw materials, parts and assemblics at all stages of fabrication and inst:illation from re.eipt of components and material to completion of the system or component supplied. These requirements shall be imposed on CNSl's subcontractors and suppliers.
8.1 Components and Materials The inspection status of all components and material shall be evident at all times. This shall be accomplished by marking, tagging or starping components or material and the stamping of work orders or material requests accompanying them at the appropriate stages of fabrication or installation.
Identification of components and material with an identification number shall be accomplished with a method that will provide legible ide.atification as permanent as the normal life expectancy of the item marked, without adverse effect on its life and utility.
O Components or material not suitable for individual marking, shall be individually tagged or shall be placed on an identified container.
The storage area shall contain only components or material which have been inspected and accepted. Surveillance shall be maintained over the storage areas to assure that materials subject to matching material certification control or age limit requirements are properly segregated,
- dated and controlled. This surveillance shall also include checking for conformance to proper standards of packaging and storage of all co=ponents, material, parts and asse=blies.
8.2 Bulk Raw Material Following the acceptance of bulk raw materials, a tag showing the purchase order, the material identification, mill heat number or
' heat code and the date of receipt shall be fastened to the material.
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f h lf during fabrication all identification has been removed from the d part of the material being used, the remnant shall be marked before being returned to stock.
Material marking shall be such that it shall not be affected by con-tact incident to normal handling, exposure to the elements, shipment or storage. All markings shall offer ready readability and prompt identification of the material. Physical marking of material shall be accomplished in a manner which will not adversely affect the machining, forming or fabrication of the material.
Identification requirements shall be determined during generation of specifications and design dr .iings. Identification of materials and parts for safety-relatea syste=s or components shall be traceable to the appropriate documentation, such as drawings, specifications, purchase orders, manufacturing and inspection documents, deviation reports and physical and che=ical mill test reports.
O Prior to release for fabrication, asse=bling, shipping and installa-tion the correct identification of material, parts and components must be verified and documented.
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i r 3 9.0 CONTROL OF SPECIAL PROCESSES All special fabrication, installation and inspection processes which could have an effect upon the quality of the component, system or fabrication operation shall be controlled by process procedures.
9.1 Personnel Certification Personnel responsible for performance, inspection and control of special processes and operations which require special skills and could have an effect upon quality shall be certified. Certification of personnel for these processes or operations (such as velding, heat treating and nondestructive testing) may include a forinal training program followed by mandatory testing to assure proficiency of each individual. Personnel certification requirements shall conform to the applicable codes and standards, such as ASME Section IX for welding and heat treating and SNT-TC-1A for nondestructive testing.
The period of effectivity for all certifications shall be specified and each individual shall be re-certified at the end of such period through re-testing. Persons failing the re-test shall be removed fro:
operations and shall be provided with additional training as required for re-certification. Inspection results and quality audits shall be used as indicators of the need for additional training and re-certification of fabrication, installation and inspection personnel without regard for established re-certification periods. Personnel shall also be re-certified in accordance with the applicable standard.
A record of the names of certified personnel,their skills and certification periods shall be maintained in quality assurance record files .
9? Subcontractor control Special processes performed by CNSI's subcontractors and suppliers shall be specified in p ocurement documents and shall be monitored by Quality Assurance for conformance to CNSI requirements. A certi-ficate of compliance shall be required from all subcontractors and suppliers performing special processes.
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9.3 Procedures O, Special process procedures shall be reviewed and approved by Quality Assurance which conducts a surveillance to assure that the approved procedures are adequately followed. Process procedures shall include the method required for periodic verification of adequacy of the pro-cessing materials, solutions, equipment and their associated control para:neters and the recording of the inspection results and process verifications performed.
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r 3 10.0 INSPECTION The established inspection program at CNSI verifies the conformance of quality
- related activities with the applicable requirements. The verification is performed in accordance with written inspection procedures, instructions or drawings. Personnel performing the inspection are independent from the individuals performing the activity being inspected. The inspectors are qualified in accordance with applicabic codes and standards and their qualifications and certifications are kept current.
Equipment modifications, repairs and replacements are inspected in accordance with the original design and inspection requirements unless an approved alternative exists. Provisions for mandatory inspection hold point identifi-cation requiring witnessing by an inspector are incorporated in the appropri-ate documents, such as procurement specifications, test procedures, etc.
The inspection program also provides for identification and documentation of deficiencies discovered during inspection and the required corrective action.
10.1 Inspection Procedures Inspection procedures and instructions are written documents which ,
provide the following information:
A. Identification of characteristics and/or activities to be l inspected; B. Identification of the individual or group responsible for per-forming the inspection;
- C. Acceptance and rejection criteria; D. A description of the inspection method; E. Recording evidence of completing and verifying a manufacturing, inspection, or test operation; F. Recording inspector or data recorder and the results of the inspection operation.
Inspection procedures anc'/or instructions are used in conjunction with the specified specifications or drawings when inspection operations are performed. Inspection procedures are maintained current by established document control measures. ,
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r 3 10.2 Supplier Inspection CNSI identifies inspection requirements in procurement documents O I issued to subcontractors and suppliers. The std, contractors and suppliers are responsible for inspection of their products, and CNSI Quality Assurance verifies their controls te assure adequacy of inspection. Supplier's inspection plans are required to recognize those CNSI notification or hold points specified by, procurement documents.
10.3 Indirect Control in the event that direct inspection is not possible, indirect control of the inspection process shall be provided through monitoring pro-cessing methods, equipment and personnel where applicable.
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r T date, test data and other essential test information.
The test record shall be signed by the individual performing the test and any test witnesses, if so required. Test records shall be maintained in quality assurance record files.
11.3 Test Control for Procured Items Test control requirements are imposed on suppliers by procurement documents. They identify the tests to be performed and stipulate that suppliers' test procedures be submitted for approval. Tests are conducted by groups within the supplier organization considered acceptable during supplier selection, and test control systems are monitored during Quality Assurance surveillance. Also, records of tests are reviewed for acceptability during surveillance, and this review includes consideration of the qualifications of the supplier group making acceptance disposition of test resul-ts.
11.4 Modifications, Repairs and Replace =ents Modifications, repairs and replacements shall be tested in accordance with the original design and test requirements ar acceptable alter-natives approved in the same manner es the original.
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12.0 CONTROL OF MEASURING AND TEST EQUIPMENT l
Measuring and test equipment with the necessary range and accuracy shall be providad to qualified personnel for the inspection, test and acceptance of material, parts, components and systems. Equipment occuracy shall be assured by calibration traceable to national standards or a documented alternative basis for calibration.
i 12.1 CNSI's Equip =ent Calibration and Control All inspection and test equipment shall be' subjected to maintenance end cslibration at periodic intervals by qualified personnel or sub-contrettors. Frequency of calibration shall be based cc the equipment type, historical experience and operational requirements. Calibrating standards have an uncertainty (error) require =ent of no more than 1/4th of the tolerance of the equipment being calibrated. A greater uncertainty may be acceptable when limited by the " state-of-the-art".
Each f re= of measuring and test equipment shall be serialized for record and identification purposes. A sticker shall be attached to the equipment to indicate date of calibration, due date of next calibratien and the stamp or signature of the person conducting the calibration. A status file shall be maintained for all calibratable equipment.
Measuring and test equipment shall be issued to and retained betwet:
calibrations by those requiring its use. Each user has the responsi-bility to ascertain, prior to use, that the measuring and test equipment calibration date has not expired and that dassge or rework has not I
taken place since the last calibration. Conpliance with the above l requirements is monitored by Quality Assurance.
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t 12.2 Measuring and Test Equipment at Subcontractors i
Measuring and test equipment used by subcontractors, vendors and sup-l l pliers engaged in fabricating and furnishing waterials, parts and l
components to CNSI shall be under the surseillance of CN51's Quality Assurance. The surveillance shall cover production tooling, jigs, i fixtures and other fabrication equipment which controls dimensions, O contours, etc., and which is used for acceptance. Surveillance DOCUMENT REV* sNEtT A 12 1 QA-AD-001
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activities include checks to assure that inspection operations are or have been performed with appropriate measurint and test equipment, currently adjusted with calibration traceable to national standards.
Where no national standards for equipment calibration exist, the documentation for the basis of calibration is audited.
12.3 Inspection Validity When measuring and test equipment is found to be out of calibration, l
measures shall be taken to ensure the validity of previous measure-ments and tests conducted during the period when the equip =ent is likely to have been operating in such a condition.
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g 3 13.0 HA':DLING , STOP>.CE AND SHIPPING 13.1 Procured Items Measures used to control packaging, shipping, storage and handling of ce*ca,nents and material to prevent damage or deterioration shall r
te dx umented to reflect contractual or CNSI specified requirements.
Procurement documents sball identify the required control measures to supr.11er.
The supplier must have adeauate written work and inspection in-structions for storage, preservation and packaging of shircent to protect the products f rom damage , loss, deterioration or substitution.
As required by the equipment specification and/or procurement docu-ments, these procedures may be subject to approval by CNSI.
13.2 Transport Casks Transport cask handling and operation shall confere to the written handling and ooeration procedure for each licensed cask.
Prior to the shipment of a transport cask all conditions of the NRC's Certificate of Compliance (specifications, tests, inspections) shall be satisfied. All required shipping papers shall be prepared and shall accompany the shipment.
Quality Assurance through the Q. A. personnel located at Barnwell, S.C.,
is responsible for auditing all critical cask handling, storage and shipping operations conducteo by Barnwell Site Operations personnel.
Established safety restrictions concerning handling, storage and i
shipping shall be included in the handling and operating procedures for transport casks.
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- r 3 14.0 INSPECTION, TEST AND OPERATING STATUS 1 14.1 Equipment Status The inspection, test and operating status of systems and components used for processing or transportation of radioactive materials shall be known at all times during manufacturing and use.
Tran<gortation and operating procedures shall include reporting re-quirements which establish the equipment status at key events (after unloading, prior to shipment, etc.).
Equipment status will be maintained by operating personnel who are responsible for critical inspection, test and operating activities.
Quality Assurance personnel shall verify equipment status and compliance with procedures. Bypassing of required tests or other critical operations shall be procedurally controlled under the 4
cognizance of Quality Assurance personnel with the concurrence of the Q. A. Manager.
14.2 Establish =ent of Examinations and Tests In-process and final examinations and tests shall be established to assure conforusnce with documented instructions, procedures, drawings, rules and regulations.
14.3 Hold Points The procurement documents, drawings, quslity plans, transportatier and operating procedures shal.t .stablish any required mandatory hold points which shall be reflected in fabrication or operational schedule.
Hold points shall be designated points in the fabrication or operation schedule beyond which the aparations shall not proceed without consent of quality assurance because of witreering, examination or testing requirements. ,
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3 14.4 Check Lists of Examinations, Tests and Inspections tA Prepared check lists shall include the document number and revision to which the examination, inspection or test shall be performed.
The check list shall have space provided for recording results of examinatica, test or inspection and for witness signatures, initials or stamp and date for activities witnesses.
14.5 Fva ination or Process Status Measures shall be established to indicate during receiving, fabri-cation and equipment operation the status of examinations and test performed upon ite=s, systems and components by use of markings that are attached to, remain with, or are traceable to the material, ite=,
systems and components such as stamps, tags, labels, routing cards or other suitable means. These measures shall provide identification of those items which cor'orm to examination and test requirements and those that do not c er form.
14.6 Inspection Status i
CNSI inspection sta=ps cr aathorized Quality Assurance signature
[} shall be applied to materials, ite=s, systems, components or the controlling documentation to indicate the inspection status and to provide traceability to the individual performing the inspection.
The inspection stamp shall normally be applied directly to the item l
which has been accepted by inspection, material which Fas been i
accepted for limited use, and to material which has been rejected and dispositioned as scrap. When size, material or finish, etc.,
preclude stamping the material, a tag shall be attached to the ite=
appropriately stamped to indicate the status.
14.7 Control of Inspection Sta=ps Inspection stamps shall be serialized for traceability to the in-dividual inspector. Quality Assurance shall control and issue in-spection stamps, as required, to authorized personnel. Records of individual issue shall be maintained and audits shall be periodically
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DOCUMENT REV. SHEET A 14-2 QA-AD-001 CNSo 100FS 78
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from service because of loss, employee termination, etc., shall be retired for a minimum of three months.
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g h 15.0 NONCONFORMING MATERIALS, PARTS OR COMPONENTS Procedures for control of nonconforming materials, parts or components assure that such materials are adequately identified and segregated from acceptable materials, if feasible, to preclude their inadvertent use.
I 15.1 Internal Nonconformances CNS1 system materials, parts and components which are determined to be discrepant shall be identified with a tag and a numbered Nonconformance Report and, when feasible, physically separated from acceptable ite=s.
The method of identification shall clearly describe the nature of the defect. The Nonconformance Report shall be forwarded to the designated department (s) for disposition. A holding area with controlled access shall be provided when necessary for material and/or component segre-gation. The Nonconformance Report shall indicate the nature and extent of the discrepancy and the disposition. Minor discrepancies that can be reworked shall be identified by an Inspection Tag until rework has been satisfactorily eccomplished.
15.2 Subcontractor control Subcontreters shall promptly notify CNSI of all deviations from the procurement requirements, such as deviations from the required codes or approved drawings. A noncon 9rmance notice shall be initiated by the subcontractor in accordance with the subcontractor's quality assurance manual. After detection of the deviation, further fabrication operations on the material or component shall not be performed until the nonconformance has been resolved by the subcontractor and CNSI. The subcontractor shall supply records of nonconformance reports dis-positioned " accept as is" or " repair". These reports shall be made part of the inspection records and forwarded with the hardware to Chem-Nuclear for review and assessment.
15.3 Verification of Rework or Repair Acceptability Acceptability of rework or repair of materials, parts, components, systems and structures shall be verified by reinspecting and retesting the item as originally inspected, or by a method which is at least equal to the original inspection and testing method. Inspection, c DOCUMENT R E Y. SHEET A
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r-testing, rework and repair records shall be documented and filed in CNSI quality records files.
15.4 Nonconfor=ance Disposition The individuals or groups identified on nonconformance forms shall have the responsibility and authority for disposition of nonconforming items.
CNSI Quality Assurance is responsible for reviewing, approving and verifying the disposition of nonconformances.
15.5 Assessment of Nonconformances Nonconformance reports shall be analyzed periodically to show quality trends, and the results reported to CNSI manage =ent for review and assessment, l
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16.0 CORRECTIVE ACTION CNSI shall evaluate conditions adverse to quality (e.g., nonconformances, failures, malfunctions, deficiencies, deviations, defective material, etc.)
to determine the need for corrective action in accordance with established procedures.
Corrective action shall be promptly initiated when it is determined that an existing nonconformity in a material, a process or a product is due to an assignable cause and in repetitive in nature.
The corrective action procedure is divided into five basic steps:
(a) Investigate discrepancy (b) Determine cause (c) Define corrective action (d) Implement corrective action (e) Evaluate corrective action Specific individuals from appropriate departments shall be assigned the responsibility of accomplishing each of the phases. Corrective action includes,
{) but is not limited to, procurement or manufacturing operations, design, construction and operation. The results of each phase shall be documented and become part of corrective action records. Quality Assurance shall review records to verify proper implementation of corrective action as soon as
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effectiveness can be measured. Effectiveness shall be continuously monitored as a function of quality surveillance. The corrective action documentation l
shall not be closed out until results of the cocrective action have been
! evaluated and approved by Quality Assurance. Significant conditions adverse
( to quality, the cause of such conditions, and the t - ire:tive action taken shall be reported to cognizant levels of CNSI managi at for review and assessment.
l When corrective action requests are addressed to a CNSI supplier, the supplier j shall be required to. provide the following information:
! s (a) A description of all factors contributing to the deficiency l l (b) A description of corrective actions taken to prevent recurrence of the discrepancy in future production
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('V (c) The identification of effectivity point An production.
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17.0 QUA1,ITY ASSURANCE RECORDS 17.1 Maintenance and Access to Records O The records system maintained by Chem-Nuclear Systems, Inc. includes the retention of those design, fabrication, inspection and surveillance records essential to demonstrate product quality. It provides for the identification of saterials and their corresponding manufacturing, installation, test and inspection records and certificates. Operating i
records maintained will include inspection, test and audit results.
All records pertaining to a specific project shall be available for review by the appropriate inspection agencies, the customer and/or j his representative. All records maintained according to established procedures will be identifiable and retrievable, a
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17.2 Contents of Record Files i
It is the policy of Quality Assurance that adequate records be maintained l of all component and material inspections and tests. Inspection and test records shall contain the following, when applicable:
- a. A description of the type of observation;
- b. Evidence of completing and verifying a manufacturing, inspection I
O or test operation;
- c. The date and results of the inspection or test; l
- d. Information related to conditions adverse to quality;
! e. Inspector or data recorder identification;
- f. Evidence as to the acceptability of the results;
- g. Identification of the procedure (s) and revision (s) used.
l Records shall also be maintained of supplier and subcontractor quality l assurance reviews, surveillances and audits, and documents pertaining to CNSI internal quality assurance audits.
l Records shall be kept for control and as evidence of inspections,
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teets, audits, monitoring of work performance, material analysis and certifications, i.e., recoro files shall contain all documents I
pertaining to product quality assurance functions. The files shall also contain procedures and specifications written for a specific project. Files of personnel qualifications and training shall also be maintained. ,
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r 3 17.3 Permanent Records Permanent records in the record file shall contain: design specifica-tions, stress reports or stress calculations, "as built" and inter-2 face control drawings, copies of all certified material test reports, tabulation of materials for "as built" configuration, nondestructive examination reports, including examination results, and disposition reports.
17.4 Non-permanent Records All non-permanent records required to verify compliance with the applicable codes and the supplier's or subcontractor's Quality Assurance Program shall be maintained until project completion, unless otherwise stipulated.
17.5 Record Storage Facilities Record storage facilities shall be constructed, located and/or secured to prevent destruction of records by fire, flood, theft, and deterior-stion due to environmental conditions such as temperature or humidity.
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r 3 18.0 AUDITS Planned audits shall be performed to provide comprehensive, independent
() verification and evaluation of the CNSI or supplier activity being audited.
The audit scope shall en ompras evaluation of quality system practices and/or procedurea and the effectivtaeas of their implementation, monitoring of operations and activities, and a review of pertinent documents and their control and maintenance. Audit checklists shall be estab1fshed prior to conducting an audit.
18.1 Audit Schedule Internal audits shall normally be conducted once every 12 months.
However, unscheduled audits may be performed more frequently in specific areas, if deemed necessary by Quality Assurance and/or when the need is indicated by the existence of chronic problems.
All audits shall be performed on a random, unannounced basis to assure optimum effectiveness and a prompt disclosure of deficiencies.
Supplier audits shall be conducted at least once every 36 months.
i 18.2 Audit Personnel Audits shall be performed by CNSI personnel with no direct line responsibility for the function audited. The audit personnel shall have the required level of technical capability to accomplish the audit functions satisfactorily and to conform to the requirements of ANSI N45.2.23. When required, representatives from various CNSI departments may be called upon for technical advice or assistance.
i 18.3 Audit Reports A verbal presentation of the findings and conclusions of the audit is made to management personnel affected by the audit findings. Recommend-ations for quality-related improvement are presented as well.
A written report containing the findings and recommendations reviewed in the verbal report is prepared and distributed to the responsible division and appropriate Headquarters management.
l Audits shall include an assessment as to how well the Quality
() Assurance Program meets regulatory or other requirements.
DOCUMENT REV SHEET QA-AD-001 A 18-1 L J CNe o 1002/s 7s
r 3 18.4 Audit Follow-Up The originatr - an audit report or a designated alternate is re-quired to open item until ection is taken to satisfy an audit act_ ..ecords of actions taken to achieve resolution are maintain %11ow-up actions are taken to verify corrective action is efte-6....
Responsible macigement personnel shall evaluate each audit report item and correct deficiencies as promptly as possible after they are revealed. ,
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3 APPENDIX D Solidification Testing Program
-PROPRIETARY-r Iw 4.
DOCUMENT REV. SHEET 4313-01354-01 -
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