ML20041F465

QA Program for Procurement,Use,Maint & Repair of Packaging Used to Transport Spent Fuel,Radioactive Matl & Pu

ML20041F465
Person / Time
Site:	University of Virginia
Issue date:	03/11/1982
From:	VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:
Shared Package
ML20041F460	List: ML20041F465
References
NUDOCS 8203160526
Download: ML20041F465 (11)

Text

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Quality Assurance Program APPENDIX I Quality Assurance Program Applicable to Procurement, Use, Maintenance, and Repair of Packaging used to Transport Spent Fuel, Radioactive Material, and Plutonium TABLE OF CONTENTS A. Introduction B. Quality Assurance Program

1. Scope

2. Responsibilities

3. Organization

4. Design Control

5. Procurement Document Control

6. Instructions, Procedures, and Drawings

7. Document Control

8. Control of Purchased Equipment, Material, and Services

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

10. Control of Special Processes

11. Inspection Control

12. Test Control

13. Control of Measuring and Test Equipment

14. Handling, Storage, and Shipping

15. Inspection, Test, and Operating Status

16. Control of Nonconforming Materials, Parts, or Components

17. Corrective Action-

18. Quality Assurance Records

19. Audits LIST OF FIGURES

1. UVAR Reactor Staff Organization l

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Quality Assurance Program applicable to Procurement, Use, Maintenance, and Repair of Packaging Used to Transport Spent Fuel, Radioactive Material, and Plutonium A. Introduction This part of the Quality Assurance Program is applicable to procurement, use, maintenance, and repair of packaging used to transport spent fuel, high level materials, and plutonium.

It is designed to assure the safety of the general public during packaging and transportation of the above mentioned materials.

This program applies to items 30 days subsequent to the date of NRC approval of this program and to those activities related to the procurement of packaging and shipment of radioactive materials.

B. Quality Assurance Program

1. Scope -

The description of the QA program, contained within, will include a discussion of which requirements of 10 CFR PART 71 Appendix E are applicable and how they will be satisfied.

Establishment of the QA program deems that all quality related activities applicable to the design, fabrication, inspection, testing, purchase, use, maintenance, repair, and modification of packages are implemented with written procedures approved by appropriate levels of management and are contained in quality assurance / quality control (QA/AC) manuals.

The licensee-user retains the responsibility for the overall effectiveness of the QA program. The licensee-user must determine that during design and fabrica' tion of the shipping package that all quality assurance provisior.s applicable to packaging have been followed and will submit to the NRC Regulatory Commission for evaluation how this determination has been made.

Indoctrination and training programs will be established so that personnel performing quality related activities are trained and qualified to perform these activities. Upgrading of personnel performing quality related work will be on a continuing basis as changes are implemented in quality assurance procedures.

2. Responsibilities -

The Reactor Safety Committee is responsible for reviewing the facilities quality assurance policies, goals, and objectives.

The Reactor Supervisor retains over all authority and responsibility for the quality assurance program.

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3. organization -

The facility organization is shown in Fig. #1. Any or all of these personnel may perform functions under this OA program as designated by the Reactor Supervisor or higher-level management. The Reactor Supervisor will insure that measures are established to provide adequate control over any designated quality-related activities. If multiple functions are performed by the same individuals, which includes-quality assurance, those individuals when performing QA and QC functions have the responsibility and authority to stop unsatisfactory work and delivery or installation of nonconforming materials and have direct access to the Reactor Supervisor or higher-level management that can ensure accomplishment of quality-related activities.

The duties and qualifications required for the Reactor Supervisor who retains overall authority and responsibility for the QA program and other principal personnel performing quality related functions will be established and documented in the QA/QC manual.

4. Design Control -

As users of packaging, design activities will not normally be performed by this facility. Consequently, this criterion of 10 CFR PART 71 Appendix E is not applicable. Assurance that the design of packaging used was accomplished under control of a NRC approved QA program is required. This will be accomplished by requiring the supplier of packaging to submit documented proof of package design under a NRC approved QA plan. This documented proof will be kept in the QA/QC manual.

5. Procurement Document Control -

The licensee-user when procuring packaging will assurd that the manufacturers of packaging will supply appropriate I certifications verifying that the designated (model and serial number) packaging was manufactured under an approved NRC QA program. Other pertinent documentation (as built drawings, photographs, sketches, use and maintenanca manuals, e tc . ) are to be furnished by the manufacturer with the packaging. The l Reactor Supervisor will determine all pertinent documentation l required. Also to be supplied with the procurement of the I package will be identification of the type of verification activities required during use and maintenance of packaging.

! If safety related replacement parts are required to be procured for the packaging, the Reactor Supervisor will designate QA personnel to ensure that appropriate technical and QA requirements are included in purchase orders and that the purchase orders are placed with suppliers previously qualified during fabrication of packaging.

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6. Instructions, Procedures, and Drawings -

In the preparation of packaging for use the licensee-user shall ascertain that the package with its contents satisfies the applicable requirements of 10 CFR 71.54 and of the licensee. The Reactor Supervisor or higher-level management must ap9 rove for placing the packaging in use. A listing of the applicable requirements as stated will be maintained in the QA/QC manual.

If repair, rework, or maintenance is required to be performed on packaging, a written procedure will be used and coordinated with quality assurance personnel to ensure that appropriate inspection and test points are incorporated in the procedure and that effective repairs or rework have been satisfactorily performed. Any plans for maintenance will be reviewed by designated QA personnel to verify that the plans emphasize those characteristics that are most significant to safety.

Measures will be established to ensure that the loading or unloading of radioactive material from packages is controlled.

QA personnel will submit a written procedure outlining the steps to be performed (e.g. surveys for contamination and radiation, adequate venting of package, rigging and hoisting the package) to the Reactor Supervisor for his approval.

Eor all radioactive material shipped, designated QA personnel will ensure that packages are in good condition, adequately secured within or on the transport vehicle and properly sealed. All U.S. D.O.T. shipping requirements and University of Virginia Radiation Safety Of fice requirements will be satisfied prior to shipment. Departure time, arrival time and destination of package vill be established and monitored to a degree consistent with the safe transportation of the package.

7. Document Control -

Each of the documents under control of the QA program will be identified in the QA manual. A listing of these documents will be maintained in the QA/QC manual. All documents, including changes thereto, will be reviewed annually by appropriate personnel as specified by the Reactor Supervisor for adequacy and approved for release by authorized personnel to those persons responsible for using these documents. Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the Reactor Supervisor designates another organization.

As a minimum, control shall be exercised over the following documents:

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a. QA/QC manual

b. Operating procedures

c. Maintenance procedures

' d. . Inspection and test procedures

e. Loading and unloading procedures

f. Packaging and transport procedures

g. Repair procedures

8. Control- of Purchased Material, Equipment, and Services -

Designated QA personnel will take the necessary measures to assure that purchased material, equipment and services, whether purchased directly or through contractors and sub-contractors, conform to the procurement requirements.

Documentary evidence that the package conforms to procurement specifications shall be supplied with the package. Such documentation should be referenced in the certificate of compliance and should relate to the use and maintenance of the packaging and should identify the necessary actions to be taken prior to delivery of the licensed material to a carrier for transportation. This documentary evidence shall be retained and shall be sufficient to identify the specific requirements met by the purchased material or equipment.

9. Identification and control of Materials, Parts, and Components -

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To prevent the use of incorrect or defective materials, parts and components, identification and control measures shall be established. The identification of t'e item must be maintained by heat number, part number, or other appropriate means, either on the item or on records directly traceable to the item.

Where replacement of limited life items are specified, measures will be taken to preclude use of items whose shelf life or operation times have expired.

10. Control of Special Processes -

Special processes are not normally performed by the users of packaging. However, if packaging requires major repairs necessitating the use of these processes, measures will be taken to ensure that controls over special processes are subject to the following criteria:

a. Procedures, equipment, and personnel are qualified in accordance with applicable codes, standards and speci fica tions .

b. The operations are performed by qualified personnel and accomplished in accordance with written process sheets with recorded evidence of verification.

c. Qualification records of procedures, equipment, and personnel are established, filed, and kept current.

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11. Inspection Control -

Visual inspections by designated QA personnel will be performed upon receipt of packaging to ensure compliance with procurament documentation. The criteria for acceptance of each of these inspections and action to be taken if non-compliance is encountered will be determined by the Reactor Supervisor.

These visual inspections should include an inspection of the following:

a. Surface conditions

b. Weld and structual integrity

c. Condition of flange or sealing faces

d. Gaskets and seals

e. Gauges, rupture disks, valves, pressure relief devices

f. Condition of tiedown members

g. Labeling and marking

h. Leak tightness of the packaging The inspection program should ensure adequate maintenance of packaging. The manufacturer of the packaging should identify all items to be_ maintained, criteria for acceptability or replacement, and the frequencies of inspection assigned to each item during use of the package.

Final inspections will be performed with a checklist to verify as a minimum that the following items are complied with:

a. Packages are properly assembled

b. Moderators and/or neutron absorbers are present

c. Valves through which primary coolant flows are protected against tampering

d. Valves are set to specifications

e. All shipping papers are properly completed

f. Packages are conspicuously and durably marked as required by DOT regulations

g. Measures are established to ensure that an individual designated by the owner or user of packages signs the shipping tags or indicators prior to authorization for shipping.

For all inspections that are identified above, the inspection personnel will be designated by the Reactor Supervisor and will be independent from the individual performing the activity being inspected.

12. Test Control -

A test program or verification of completed testing shall be established to assure that all testing required to demonstrate that packaging components will perform satisfactorily in service, will be identified and performed in accordance with written test procedures. These written procedures will incorporate the acceptance limits contained in the package approval, provisions for assuring that all prerequisites for a given test have been met, that adequate test instrumentation is available and used and that the test is performed under suitable environmental conditions. Test results shall be documented and evaluated to assure that test requirements have been satisfied prior to delivering packages for transport to a carrier. The ,

following items shall be contained in typical tests:

a. Structural integrity

b. Leak tightness (on containment vessel as well as auxiliary equipment and shield tanks)

c. Component performance for the following:

1.) Valves 2.) Gaskets 3.) Fluid transport devices <

d. Shielding integrity

e. Thermal integrity Maintenance test programs shall be established to ensure that packages remain usable and free of excessive radiation and contamination.

13. Control of Measuring and Test Equipment -

All tools , gages, instruments, and other measuring and testing devices used in activities affecting quality shall be properly controlled, calibrated, and adjusted at specified times to maintain accuracy within necessary limits. This includes measuring and test equipment used for maintenance of safety related items. Inspection and test equipment will be tagged or labelled to indicate the date of the next planned calibration.

All calibration test data shall be maintained with facility records or be readily traceable. In-house reference or transfer standards that are used in calibrating measuring equipment will be traceable to a nationally recognized standard.

14. Handling, Storage, and Shipping -

Measures will be taken to control the handling, storage, shipping, cleaning, and preservation of materials and equipment to be used in packaging to prevent damage or deterioration. The following actions will be taken when handling or storing packages:

a. If packaging requires special handling and lifting equipment it will be used to move packaging from one station to another.

b. Special handling or storage provisions for packaging (e.g. shock absorbers, tags or markings to adequately protect and identify critical components) will be identified and used,

c. Special protective environments (e.g. inert gas atmosphere, specific moisture content levels, and temperature levels) shall be specified and provided where required.

d. All conditions identified in a certificate of compliance when unloading packaging will be adhered to.

When preparing a package for shipment the following applicable measures will be taken:

a. Cavities within gas-cooled package containments have been adequately dried and cavities within liquid cooled packages have been drained to allow adequate void space,

b. All conditions, including specified operations, inspections, and tests have been completed prior to delivery to a carrier. _

c. All NRC and DOT requirements have been satisfied prior to deliver to a carrier.

d. All necessary shipping papers have been prepared as required.

e. Departure and arrival times will be recorded, and, if required, transport of package will be under surveillance until delivered to the carrier.

15. Inspection, Test and Operating Status -

The status of inspections and tests performed on individual items of packaging will be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means. These markings shall provide for the identification of items that have satisfactorily passed required inspections and tests, where necessary to preclude inadvertent by-passing of such inspections and tests. The operating status of components of the packaging will be identified (e.g. tagging valves and switches) to prevent inadvertent operation.

16. Control of Nonconforming Materials, Parts, or Components -

Measures shall be established to control materials, parts, or components which do-not conform to specified requirements in order to prevent their inadvertent use or installation. All materials, parts, or components for use by this facility which must be quality controlled will be inspected upon receipt by designated QA personnel. This inspection will include as a minimum:

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a. Proper identification

b. -Identification of any nonconformances

c. Segregation of nonconforming items '

d. Disposition

e. Evaluation All nonconforming items will be placed in designated control hold areas until proper disposition is completed.

Nonconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.

The acceptability of nonconforming items after designated repair or rework will be vertified by QA personnel (other than personnel who performed original inspection upon receipt) by reinspecting or retesting the item against'the original requirements. All information that is found out concerning a nonconforming item will be recorded and kept with OA records such that_it can be analyzed by QA personnel to determine quality trends for appropriate management review and assessment.

17. Corrective Action -

Conditions that are adverse to quality, such as deficiencies, deviations, defective material and equipment and nonconformances shall be promptly identified. These conditions shall be reported to the Reactor Supervisor or appropriate levels of management.

In the case of a significant condition adverse to quality, the cause of the condition shall be determined and prompt corrective action taken to preclude repetition. The Reactor Supervisor shall be responsible for obtaining corrective actions from suppliers. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented to verify that corrective actions were implemented and effective. Individuals or organizations responsible for closing out corrective actions and documenting their resolution shall be identified.

18. Quality Assurance Records -

Suf ficient written records shall be maintained to furnish evidence of activities af fecting quality. The records shall include the following:

a. Design records

b. Records of use and results of reviews

c. Inspections

d. Tests

e. Audits

f. Monitoring of work performance

g. Material analyses t

h. Qualifications of Personnel

i. Maintenance

j. Delivery of packages to a carrier (including proof that all NRC and DOT requirements have been satisfied)

Records that are to be retained for the lifetime of packaging should include appropriate design and production-related records, which are generated throughout manufacturing and furnished with packaging; records demonstrating evidence of operational capability and records verifying repair, rework, and replacement that are used as a baseline for maintenance.

QA records shall be adequately stored to prevent loss or deterioration and marked so as to be readily identifiable and retrievable.

Inspection and test records shall as a minimum:

a. Identify the inspector or data recorder

b. The type of observation

c. Results

d. Acceptability

e. Actions taken in connection with any deficiencies noted

19. Audits - .

A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the QA program and to determine the effectiveness of the program.

The audits shall be performed in accordance with pre-established written procedures or checklists and will be conducted by qualified personnel not having direct responsibility in the areas being audited. A listing of quality-related activities to be audited and frequency at which each activity is to be audited shall be established and maintained to reflect current status. Audits shall also include the manufacturers of packaging to determine the extent of compliance with the purchase order l

and that the work is being controlled by a QA program approved by the NRC. Individuals or groups having responsibility and authority for ensuring that corrective actions resulting from findings during audits are accomplished on a timely basis shall be identified. Audit results shall be documented and reviewed by management having responsibility in the area audited. Followup action, including reaudit of deficient areas, shall be taken where indicated.

FISURE 1 UNIVERSITY OF VIRGINIA NUCLEAR REACTOR FACILITY

, Organization Chart December 1981 DIREdOR'

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Bryce L. Shriver I

REACTOR OPERATIONS RESEARCH PROGRAMS REACTOR SERVICES l l l

REACTOR SUPERVISOR RESEARCH ENGINEER REACTOR ENGINEER Charles A. Bly (80%)

Paul E. Benneche J. Preston Farrar Bo Hosticka l

RESEARCH ASSISTANTS RESEARCH ASSISTANTS I

REACTOR MAINTENANCE REACTOR OPERATIONS REACTOR OPERATIONS AND RESEARCH SUPPORT AND T. RAINING AND ENGINEERING i i ELECTRONIC SHOP MACHINE SH0 REACTOR MAINTENANCE SENIOR REACTOR SUPERVISOR SUPERVISOR OPERATOR A!4D ENGINEERING I

Frank Hoss V. G. Hampton J. S. Baber Tom L. Porter Charles Bly (20%)

REACTOR OPERATORS REACTOR OPERATORS