ML20134L823
| ML20134L823 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 10/28/1996 |
| From: | GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20134L733 | List: |
| References | |
| 1000-PLN-3000.0, NUDOCS 9611220015 | |
| Download: ML20134L823 (16) | |
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C301-96-2051 Attachment 2 GPU NUCLEAR CORPORATE Number M& CLEAR POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experunental Corporation FL:ility Revision No.
Decommissioning Quality Assurance Plan 0 Applicability / Scope Responsible Office GPU Nuclear and Saxton Nuclear Experimental Corporatiort Nuclear Safety Assessment l Wide This document is within QA plan scope E Yes u No Effective Date
! Safety Remws Required E Yes O No (O-252- 76 i
List of Effective Pages l
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Signature Concurring Organization Element Date A ,; g7 p g _., , '.NSA Assessor i
_ Grynam 9; g 9g Concurred /s/ Robert L. Long Director, Nuclear Safety and Technical Services 10-4-96
, is/ f. E. Maricondo Director, Financial and Planrung Services 10-14-96 E'd .R. W. Keaten Director, Engtneering 10-10-96
~7il M. J. Ross for Director, TM1 10-11 90
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/ J. J. Curry Director, Nuclear Safety Auesstnent 10-14-96
/r/ G. A. Kuehn II Program Dtrector, SNEC I acility 10-8-96 Responsible Technical Ret.:wer N 1 N N 1/n w A /11,' #5' " ***'*' lO~l$~PE Appmved OM oR 2 dei
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ADM047 9611220015 961108 PDR ADOCK 05000146 P PDR
I GPU NUCLEAR CORPORATE Number NUCLEAR POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facihty Revision No.
Decommissioning Quality Assurance Plan 0 i
DOCUMENT HISTORY
- REV SUhBIARY OF CHANGE DATE O Original Revision I
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i GPU NUCLEAR CORPORATE Number MucLEA.r. POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton fFicYar Experimental Corporation Facility Revision No.
Decommissio. ling Quality Assurance Plan 0 i
1.0 POLICY STATEMENT It is the policy of GPU Nuclear to conduct decommissioning activities in such a manner as l to ensure protection of the health and safety of the public and the personnel on site. To l
implement this policy, GPU Nuclear will adhere to the Quality Assurance (QA) l requirements established in this Decommissioning Quality Assurance Plan and shall comp'.y I with, and be responsive to, applicable federal, state and local requirements; 10CFR19, l 10CFR20,10CFR21 and appropriate sections of 10CFR50; applicable industry codes and standards; and commitments made to the U.S. Nuclear Regulatory Commission. The packaging and transportation of radioactive waste will continue to comply with the
- requirements of 1000-PLN-7200.01, "GPU Nuclear Operational Quality Assurance Plan" and 10CFR71.
Project procedures shall provide for compliance with appropriate regulatory, statutory, license, and industry requirements. Specific quality assurance requirements and organintional responsibilities for implementation of these requirements shall be specified.
Compliance with this QA program and provisions of project procedures is mandatory for personnel with respect to decommissioning activities which may affect gaality or the health and safety of project personnel or the general public. Personnel shall, therefore, be familiar with the requirements of responsibilities of the QA program that are applicable to their individual activities and interfaces.
l 2.0 ORGANIZATION AND FUNCTIONAL OA RESPONSIBILITIES 2.1 General Th' persons and organintions performmg QA functions report to a management level that assures the required authority and organiurional freedom are provided, !
including sufficient independence from cost and schedule. The individuals assigned I the responsibility for assuring effective execution of any portion of the QA Plan have I direct access to the levels of management necessary to perform QA functions.
2.2 Orennf= tion The Saxton Nuclear Experimental Corporation (SNEC) facility orgamnrion is structured on the basis that the arrainment of the objectives of the QA Program relies on those who manage, perform, and support the activities within the scope of this i plan; and assurance of this attamment relies on those who have no direct i
responsibility for minnging or performmg the activity.
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I GPU NUCLEAR CORPORATE
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NUCLEAR POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 i
i Specific QA requirements and organmtional responsibilities for implementation of l these requirements shall be specified in v.rious implementing procedures and other documents. The requirements stipulnalin the QA Program shall be imposed on all personnel and organintions, including contractors, who perform the decommissioning activities referet ced in Section 3.0.
2.3 Functional QA Responsibilitiet 2.3.1 GPU Nuclear President The GPU Nuclear President has the overall responsibility for the establishment, implementation, and effectiveness of the SNEC fr.cility Decommissioning QA Program. This resporcibilityi:; admm nered through management staff as described below.
2.3.2 GPU Nuclear Director. Nuclear Safety & Techrtical Services The GPU Nuclear Director, Nuclear Safety & Technical Services reports directly to the GPU Nuclear President. This position is responsible for the overall SNEC facility decommissioning program and the various support elemems required to safely decommission the facility.
2.3.3 GPU Nuclear Director. Financial and Plannine Services The GPU Nuclear Director, Financial and Planning Services reports directly to the GPU Nuclear President. This position will provide support to the facility in areas such as procurement of goods and services, receipt inspections including the administration of a goods and services nonconformance program, and long range planning 2.3.4 GPU Nuclear Director. Engineering The GPU Nuclear Director, Engineering reports directly to the GPU Nuclear President. Engineering services and technical support in areas such as non-destructive examination, design, modification, and procurement shall be funushed to the facility by this director.
2.3.5 GPU Nuclear Director. Three Mile Ishnd The GPU Nuclear Director, Three Mile Island reports directly to the GPU
, Nuclear President. This position shall provide support to the facility in areas such as mamtenance, calibration, and Quality Verification including the aciministration of a material nonconformance program.
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l GPU NUCLEAR CORPORATE Number
- gyctjAg POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 i
~ Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 l
l 2.3.6 Program Director. SNEC Facility The Program Director, SNEC Facility reports to the GPU Nuclear Director, !
Nuclear Safety & Technical Services. The Program Director is responsible to decommission the SNEC facility in a safe and efficient manner in accordance with this QA Plan and with all applicable laws, regulations, licenses, and technical requirements.
2.3.7 Badiation Safety Officer (RSO)
The Radiation Safety Officer reports to the GPU Nuclear Director, Nuclear Safety & Technical Services, and is responsible for the conduct and
! oversight of all SNEC facility radiation safety activities through implementation of the QA Program and the Radiation Protection Plan. I 2.3.8 SNEC Facility Site Suoervisor 1
The SNEC Facility Site Supervisor reports to the Program Director, SNEC Facility and is responsible for on-site management and continuing oversight of production activities. The Site Supervisor is responsible for the safe conduct of production activities and effective implementation of QA Plan
- requirements.
2.3.9 Radiation Safety Committee The Radiation Safety Committee reports to the GPU Nuclear Director, 4
Nuclear Safety & Technical Services and is responsible for the eview of
- inspection and audit results and corrective actions for deficiencies. The Committee has the organintional freedom, authority and capability to identify safety problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
- 2.3.10 GEU Nuclear Director. Nuclear Safety Assessment (NSA)
Verification of effective QA plan implementation is the responsibility of the GPU Nuclear, NSA crganintion. NSA personnel shall have the authority and organintional fredom to idemify quality problems; to take action to
. stop unsatisfactory work; to initia;e, to recommend, or to provide solutions; and to verify implementation of solutions.
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l GPU NUCLEAR CORPORATE Number ' -
NUCLdAK POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 r
Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 l
The audit function is provided by GPU Nuclear and is independent of SNEC facility management. The independence of the audit function is maintained I by the auditors having unrestricted access to the GPU Nuclear Office of the President: This access ensures that issues not capable of being resolved at a lower management level may be addressed to the highest management possible. GPU Nuclear's NSA Department is responsible to provide auditors certified to meet the requirements of ANSI N45.2.23 and to establish an audit program for the activities listed in Section 3.0.~ The audit repons are forwarded to the GPU Nuclear Presirlent, the SNEC President, the GPU Nuclear Director, Nuclear Safety & Technical Services and the l
Radiation Safety Committee within 60 days of the completion of the audit.
3.0 DECOMMISSIONING OUALITY ASSURANCE PROGRAM 3.1 General This Decomnussioning Quality Assurnce Plan is the highest GPU Nuclear document ,
which provides the generic and some specific requirements and methods to control l
activities. The term " Program" as used herein includes this Plan and the approved l documents which are used to implement this Plan. This Plan is implemented through such approved documents. ,
The Saxton Nuclear Experimental Corporation Facility Decommissioning Quality Assurance Program has been established to control the activities performed by GPU Nuclear, and its cohtractors, within the scope of this Plan. This control is exerted
, prunarily through the provision of, and compliance with, implementing documents and assurance that such documents are adequate and consistently used.
Adherence to the requirements of this Plan is Innndatory for all GPU Nuclear organintions and for all extemal orgamnrions providing items, parts, materials, of conducting activities which are within the scope of this Plan.
This Plan shall be issued under the authority of the GPU Nuclear President, and shall be reviewed by the Director, Nuclear Safety Assessment. All changes to the Plan shall be reviewed by the Director, Nuclear Safety Assessment and approved by the GPU Nuclear President.
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( GPU NUCLEAR CORPORATE Number NUCLbut POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title. Saxton Nuclear Experimental Corporation Facility Revision No.
Decommbsioning Quality Assurance Plan 0 1
3.2 Scope The scope of this Plan includes radiological safety and implementation of the regulations as committed to in Section 1.0 of this Pian. To ensure consistency in identifying those items, parts, materials and activuies withia the scope of this Plan, a classification process shall be developed and documented. This process relies on the use of the term "QA Plan Scope".
3.2.1 A Quality Classification process for items shah be developed. This classification process shall produce a Quality Classi5 cation List which identifies the permanent plant structures, systems, and components that are within the scope of this Plan. New items to which this Plan applies shall be d
added to the Quality Classification List subsequent to their installation.
4 3.2.2 Activities within the scope of this Plan are those directly related to radiological safety and implementation of the regulations as committed to in Section 1.0 of this Plan. These activities are delineated below.
4 Support activities within the scope of this Plan are system / component /part
! classification, design, procurement, fabrication, bandling, shipping, storage, cleaning, erecting, installing, testing, repairing, training, welding, in-service inspection, heat treatment, document control and records management.
Decommissioning activities within the scope of this Plan are equipment control, surveillance testing, functional testing, maintenance (including lifting and handling which could jeopardize operability of QA Plan Scope equipment or whose potential drop could have adverse radiological impact),
housekeeping, fire protection, radiological controls, radiological.
environmental monitoring, technical specification compliance and emergency preparedness.
Assurance activities within the scope of this Plan are ardit, inspection, non-destructive examination, monitoring, surveillance, and safety review.
Assurance activities are performed by individuals who are not directly responsible for managing or performing the work or activity. Nuclear Safety Assessment personnel, who are independent of the organization performing the work or activity, perform periodic assessments of the assurance activities not performed by the Nuclear Safety Assessment Department to assure effectiveness and adequacy.
The above activities are controlled through the use of approved documents, which are, as a mimmum, consistent with the requirements of this Plan.
This Plan shall remam in effect throughout the decommissioning project.
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GPU NUCLEAR CORPORATE Number
- NUCLb2 POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 Activities affecting quality shall be accomp'ished under suitable controlled conditions. Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied.
3.3 Training The program shall provide for indoctrmation and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintamed The program shall take into account the need for special controls, processes, test equipment, tools, and skills to attam the required quality, and the need for verification of satisfactory implementation.
3.3.1 Trainmg programs shall be established for those personnel performing quality affecting activities such that they are knowledgeable in the quality assurance program and proficient in implementing these requirements.
These traming programs shall assure the following:
- a. Personnel responsible for perforrrmg these activities are instructed as to the purpose, scope, and implem.ntation of applicable procedures.
- b. Personnel performing such activities are trained and qualified, as appropriate, in the principles and techniques of the activity being conducted.
- c. The scope, objective, and method of implementing the trainmg are documented.
- d. Methods are provided for documenting traming sessions describing content, attendance, date of attendance, and the results of the training session, as appropriate.
4.0 PROCEDURES AND DRAWINGS 4.1 Procedures, and drawings of a type appropriate to the circumstances, shall be provided for the control and performance of activities which affect quality, health and safety of the public or project personnel, or regulatory requirements.
4.2 Procedures and drawings shall include appropriate quantitative or qualitative acceptance criteria for determmmg that important activities have been satisfactorily accomplished.
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' , GPU NUCLEAR CORPORATE Number NUCLntg POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 '
Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 4.3 A procedure shall be implemented to con:rol and delineate the requirements for the 1 review and approval of documents implementing the requirements of this plan. l These documents typically include, but are not limited to, those termed plans, I procedures, instructions, drawings, and specifications. This procedure shall include the review and approval requirements for the implementation of documents not specifically written for the site decomnussioning activities (eg. vendor documents, TMI documents, or Oyster Creek documents). This review must consider the appropriateness of the document for work at the site, and must ensure the document complies with higher tier site documents.
4.3.1 The following typical procedures shall be provided as appropriate:
Calibration procedures, Ra<iintion protection procedures, Special process procedures,
- Maintenance procedures, 1
Dismantlement procedures, Audit procedures,
- Administrative control procedures, i Emergency procedures, Rigging, lifting and handling,
- Inspection procedures.
J 5.0 DESIGN CONTROL 5.1 When decommissioning activities require design, or modification of existing design, controls shall be applied commensurate with the potential impact on quality or health and safety of project personnel and the general public.
5.2 Appropriate provisions of design control shall include the specifymg of design input, the correct translation of input in design documents, the verification of design by persons other than the originator, and the assurance that changes to the design beyond design tolerance are properly reviewed and controlled.
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GPU NUCLEAR CORPORATE Number '
NucitAR POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 t
Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 6.0 PROCUREMENT DOCUNENT CONTROL 6.1 Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by GPU Nuclear or by its contractors or subcontractors. ~ To the extent necessary, procurement documents shall require contractors or subcontractors to provide a quality assurance program consistent with the contractor's potential impact on quality or the health and safety of project personnel and the general public.
6.2 Procurement documents shall contain specific technical and quality requirements, as appropriate.
6.3 Procurement documents shall contain provisions which establish the right of access to vendor facilities and records for source inspection and audits as appropriate.
6.4 Documents, and changes thereto, initiating procurement of equipment, components, or services shall be approved by appropriate management personnel and shall be subject to a quality review to ensure applicable regulatory requirem.nts, design bases, quality assurance, and other requirements are adequately satisfied prior to release.
7.0 DOCUMENT CONTROL 7.1 Measures shall be established to control the issuance of documents, such as procedures and drawings, including changes thereto, which prescribe activities affecting quality.
7.2 These measures shall assure that documents, includmg changes, are reviewed for adequacy and approved for release by authorized personnel, and are' distributed to and used at the location where the presenkd activity is performed.
7.3 Changes to documents shall be reviewed and approved by the same orgamurion that performed the original review and approval or another designated responsible organization.
7.4 Procedures within the scope of this Plan shall be controlled to assure that current copies are made available to personnel performing the prescribed activities. These procedures shall be reviewed by a technically competent person other than the preparer, and shall be approved by a management member of the organintion responsible for the prescribed activity.
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, , GPU NUCLEAR CORPORATE Number NUCL g POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommasioning Quality Assurance Plan 0 i
7.3 Significant changes to procedures within the scope of this Plan shall be reviewed and approved in the same manner as the original. {
I 8.0 CONTROL OF PURCHASED MATERIAL. EOUIPMENT. AND SERVICES 8.1 Measures shall be established to assure that purchased material, equipment and services conform to the procurement documents. These measures shallinclude provisions, as appropriate, for vendor evaluation and selection, objective evidence of quality furnished by the vendor, inspection at the vendor source, and inspection of products upon delivery.
, 8.2 The effectiveness of the control of contractor services shall be assessed at intervals consistent with the importance of the service. i 8.3 The adequacy of vend.or's quality assurance program specified in procurement documentation shall be verified prior to use when appropriate. Vendors' adherence to their quality assurance program shall also be verified as appropriate.
1 8.4 Commensurate with potential adverse impacts on quality or health and safety, !
material and equipment shall be inspected upon receipt at the SNEC facility or other l GPU Nuclear sites prior to use or storage to determine that procurement I requirements are satisfied.
8.5 Measures shall be established for identifying nonconforming material, parts and components.
t 9.0 IDEN'ITFICATION AND CONTROL OF MATERIALS. PARTS ASV i
COMPONENTS 9.1 Measures shall be established for the control of materials, parts, and components which are within me scope of this Plan.
4 9.2 These identificatiol and control measures shall be designed to prevent the use of incorrect or defective material, parts and components.
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10.1 Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive exammation are controlled and accomplished by qualified per*annel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
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, GPU NUCLEAR CORPORATE Number
- MucL W POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 '
Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 10.2 Welding of equipment within the scope of this Plan shall be performed in accordance with qualified procedures. Such procedures shall be qualified in accordance with applicable codes and standards and shall be reviewed to assure their technical adequacy.
10.3 Measures shall be established that assure welding of equipment within the scope of .
this Plan is performed by qualified personnel.
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10.4 Nondestructive exarmnations (NDE) of equipment within the scope of this Plan shall be performed in accordance with procedures formulated in accordance with applicable codes and standards and shall be reviewed to assure their technical adequacy.
10.5 Measures shall be established that assure NDE is performed by personnel qualified in ,
accordance with applicable codes and standards.
11.0 INSPECTION 11.1 Measures shall be established for review of appropriate activities to verify i
conformance with the documented procedures and drawings for accomplishing the '
. activity.
i 11.2 If mandatory inspection hold points, which require witnessing or inspection and beyond which work shall not proceed without prior consent are required, the specific )
hold points shall be indicated in appropriate documents. The document contaming the inspection hold points shall be reviewed prior to implementation by the l organization required to perform the inspection.
11.3 Measures shall be established which assure that activities associated with technical services (such as surveillance testing, instrument calibration, laboratory services, etc.) are reviewed, when determmed appropriate, by qualified personnel .
11.4 Required inspections shall be performed in accordance with appropriate procedures.
Such procedures shall contain a description of objectives, acceptance criteria and prerequisites for performing the inspections. These procedures shall also specify any special equipment or calibrations required to conduct the inspection.
11.5 Personnel performing required inspections shall be qualified based upon experience and trammg in inspection methods. Required inspections shall not be performed by . I individuals who performed the inspected activity or directly supervised the inspected activity.
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, GPU NUCLEAR CORPORATE Number NucL M POLICY 6 PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 12.0 TEST CONTROL 12.1 A documented test program shall be established to assure that all required testing is performed to demonstrate that the structures, systems or components within the scope of this Plan will perform satisfactorily in service. The tests shall be performed in accordance with written, approved, and controlled test procedures or instructions whi6h incorporate or reference the requirements and acceptance standards contained in the applicable design documents. The extent of the testing shall be based on the i
complexity of the modification, replacement, or repair. Testing shall include proof -
tests prior to installation, hydro testing, functional testing and preoperational tests.
13.0 CONTROL OF MEASURING AND TEST EOUIPMENT 13.1 Measures shall be established to assure that tools, gauges, instruments and other measurmg and testing devices used in activities affecting quality or important to the protection of health and safety are properly controlled, calibrated and adjusted at specified periods to mainrain accuracy within necessary limits.
14.0 HANDLING. STORAGE. AND stilrriNG 14.1 Measures shall be established and documented to control bndling, storage, and shipping, including cleaning, packaging, and preservation of items within the scope of this Plan in accordance with established instructions, procedures, and drawings to prevent damage, deterioration, or loss.
15.0 INSPECTION. TEST. AND OPERATING STATUS 15.1 Inspection, test, and operating status of equipment and components within the scope of this Plan shall be established based upon the following criteria:
- a. Inspection, test, and operating stafus for equipment within the scope of this Plan shall be indicated and controlled by established procedures.
- b. Status of such equipment shall be indicated by tag, label, marking or log entry.
- c. Status of nonconforming parts, components, or materials shall be positively maintained by established procedures.
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i GPU NUCLEAR CORPORATE Number -
WuCLbut POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 16.0 NONCONFORMING MATERIALS. PARTS OR COMPONESTS 16.1 Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition and notification to affected organintions.
16.2 Nonconformance items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with dociunented procedures. I 17.0 CORRECTIVE ACTION s 17.1 Measures shall be established to assure that conditions adverse to quality, such as j failures, malfunctions, discrepancies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
17.2 The identification of the condition adverse.to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of .
management.
18.0 OUALITY ASSURANCE RECORDS 18.1 Sufficient records shall be maintained to furnish evidence of activities affecting )
quality (eg. inspection reports, receipt inspection documents, engineering evaluations, I monitoring reports etc.).
18.2 Records shall be identifiable and retrievable.
18.3 Requirements shall be established concerning record retention, such as duration, location, and assigned responsibility. Such requirements shall be consistent with the potential impact on quality, health and safety of the public, safety of project personnel, and applicable regulations.
l 18.4 Measures shall be established which assure that qualification records of personnel performing special process activities, such as welding, NDE, inspection, etc., are l
retained. i l
18.5 Measures shall be established which assure that quality related procurement documents are retained.
4 18.6 Measures shall be established which assure that aopropriate records pertaining to audits are retained, i 14.0
,! ', GPU NUCLEAR CORPORATE Number NUCLWAR POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 0 18.7 Measures shall be established which assure that records associated with personnel exposure control are retained.
19.0 AUDITS 19.1 A prograni of assessment will be conducted by the GPU Nuclear NSA Depamnent.
The assessment program will combine elements of monitoring and auditing to assess the adequacy of performance for activities within the scope of this Plan.
19.2 Planned audits shall be conducted by the GPU Nuclear NSA Department to verify compliance with appropriate requirements of the Program and to determine its effectiveness. The audits shall be performed in accordance with written procedures or checklists by appropriately qualified personnel not having direct responsibility in the areas being audited. Audit results shall be documented, and reviewed by management having responsibility in the area audited. Follow-up action, including re-audit of discrepant areas, shall be taken where indicated.
19.3 Reports of the results of each audit shall be prepared. These reports shall include a description of the area audited, identification of individuals responsible for implementation of the audited provisions and for performance of the audit, identification of discrepant areas, and recommended corrective action as appropriate.
19.4 Audit reports shall be distributed to the GPU Nuclear President, the SNEC President, the Vice President, Nuclear Safety & Technical Services, the Radiation Safety Committee, and to those individuals responsible for implementation of audited provisions.
19.5 Measures shall be established which assure that discrepancies identified by audits or other means are resolved. These measures shallinclude notification of the manager responsible for the discrepancy, recommended corrective action, and verification of satisfactory resolution. Discrepancies shall be resolved by the management responsible for the discrepancy. Line management should resolve disputed discrepancies. If line management is not capable of resolving disputed discrepancies, the resolution.shall be escalated to the next level of management until the disputed discrepancy is resolved.
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( GPU NUCLEAR CORPORATE Number ~
- N&CLAAg POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Sanon Nuclear Experimental Corporation Facility Revision No.
Decommusioning Quality Assurance Plan 0 1
19.6 Monitoring is used to establish adequate confidence levels that activities within the l scope of this Plan are being performed in accordance with the QA Program
- requirements and plant administrative controls. Monitoring will be performed and 1 J the degree of monitoring performed shall be based typically upon the status and o
safety significance of activities, extent of previous experience, thoroughness of ;
overall coverage, uniqueness of the activity, and trending data.
I 19.7 Monitors shall be qualified in accordance with a documented Nuclear Safety Assessment procedure that ensures Monitors are knowledgeable in the activities they are monitoring to the extent that they can readily verify compliance of the activity l performed. l 1
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