ML20202B254

Rev 1 to Saxton Nuclear Experimental Corp Facility Decommissioning QA Plan

ML20202B254
Person / Time
Site:	Saxton, 05000246  File:GPU Nuclear icon.png
Issue date:	02/02/1998
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20202B237	List: ML20202B235 ML20202B247 ML20202B254
References
1000-PLN-3000.0, 1000-PLN-3000.05-R01, 1000-PLN-3000.05-R1, NUDOCS 9802110153
Download: ML20202B254 (22)

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Attachment 7

, Revised Saxton Nuclear Experimental Facility Decommissioning Quality Assurance Plan I Complete Document

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Q,u NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No, Quality Assurance Plan i Appliesbility/ Scope Responsible Omce GPU Nuclear and Saxton Nuclear Experimental Corporation Wide Nuclear Safety Assessment This document is within QA plan scope N Yes O No Effective Date Safety Reviews Required E Yes O No l List of Effective Pages

['ags Revision 1.0 1 1.1 1 2.0 1 3.0 1 4.0 1 5.0 1 6.0 1 7.0 1 3.0 1 9.0 1 10.0 1 11.0 1 12.0 1 13.0 1 14.0 1 15.0 1 16.0 1 17.0 l l

Signature Concurring Organization Element Date Originator A . ,- @ M _ * , m NSA Assessor /- 2/ 9 P ,

Concurred jyy Director, Human and Administratise Services jjq/q l

[Qgjff( Director Engineering j/7j//f7 py ([ g Q Director, TMI /)dfg

}( Q f M C Director, Nuclear Safety Assessment J/g7/g

, _gggg Program Director, SNEC Facility f M /py

' g>q- {l _ Responsible Technical Reviewer ,/2,/m

[.,,2,f k[7Jh Corporate Procedure Coordinator ,jj,j/py Approved h Office of the President .a/ yis U _.

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Pil sucLEAN GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000 PLN.3000.05 Title Saxton Nuclear Experi:nental Corporation Decommissioning Revision No.

Quality Assurance Plan 1 l

I DOCUMENT HISTORY REV

SUMMARY

OF CHANGE DATE O

Original Revision 04/03/96 I in responding to the questions raised by the NRC's review of this plan, GPU Nuclear agreed to make three changes to the document. The Grst change is to add a requirement to section 3.1 of the plan, which requires NRC review of changes I '

to this plan. The second change consists of providing more detali of the minimum content ofinspection records as defined in section 18.1 of the plan. The fmal change adds Appendix A to the plan to provide a detailed list of the Quality Assurance Regulatory Guides utilized to implement the plan. An additional change was made to Section 2.3.3 to reDect the reorganization of the Financial and Planning Division, and changes were made throughout Section 2.3 to reacct a

. reorganization of GPU Nuclear Divisions.

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. I WUCMAN GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000 PLN4000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

Assurance Plan 1

_ l 1.0 POLICY STATEMENT li is the policy of GPU Nuclear to conduct decommissioning activities in such a manner as to ensure protection of the health and safety of the public and the personnel on sie. To implement this policy, GPU Nuclear will adhere to the Quality Assurance (QA) requirements established in this Decommissioning Quality Assurance Plan and shall comply with, and be responsise to, applicable federal, state and local requirements including 10CFR19,10CFR20,10CFR21 and appropriate sections of 10CFR$0; applicable industry codes and standards; and commitments made to the U.S. Nuclear Regulatory Commission. Appeadix A of this document provides a detailed listing of the Quality 4r.irance Regulatory Guides, and associated ANSI Standards, which are required to implement this plan. 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 10Cl R71.

Project procedures shall provide for compliance with appropriate regulatory, statutory, license, and industry requirements. Specific quality assurance requirements and organizational 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 quality or the health and safety of project personnel or the general public. Personnel shall, therefore, be familiar with the requirements and responsibilities of the QA program that are applicable to their individual activities and interfaces.

2.0 QRGANIZATION AND FUNCTIONAL OA RESPONSIBILITIES 4

2.1 General The persons and organization 1 performing QA functions report to a management level that assures the required authority and organizational freedom are provided, including sufficient indeoendence from cost and schedule. The individuals assigned ne iesponsibility for assuring effective execution of any portion of the QA Plan hase direct access to the lesc's of management necessary to perform QA functions.

2.2 Organization The Saxtan Nuclear Experimental Corporation (SNEC) facility organization is structured on the basis that the attainment of the objectives of the QA Program relies on those w ho manage, oerform, and support the activities within the scope of this plan; and assurance of this attainment relies on those who have no direct responsibility for managing or performing the activity.

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. l NUCf.fAR GPU NUCLEAR CORI-ORATE Number POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommitsioning Quality Revision No.

Assurarse Plan 1 l

Specific QA requirements and organizational responsibilities for imt cmentation! of these requirements shall be speciGed in various implementing procedures and other documents.

The requirements stipulated in the QA Program shall be imposed on all personnel and organizations, including contnctors, who perform the decommissioning activities referenced in Section 3.0.

2.3 Functional QA Responsibilities e

2.3.1 GPU Nuclear President The GPU Nuclear President has the overall responsibility for the establishment, g

implementation, and effectiveness of the SNEC facility Decommissioning QA Program. This responsibility is administered througn management staff as described below. u 2.3.2 GPU Nuclear Director. Human and Administrative Smice, The GPU Nuclear Dhector, Human and Administrative Services reports d rectly to l the GPU Nuclear President. This position will provide support to the facility in areas such as procurement of goods and suvices, receipt inspections, and ,

wawhousini,. l 2.3.3 GPU Nuclear Director. Engineerina l

The GPU Nuclear Director, Engineenng reports directly to the GPU Nuclear President. This position is responsible for the overall SNEC Facility decommissioning program. This director also shall fumish engineering sersices and technical support in areas such as nondestructive examination, dega, moo!6 cation, and procurement engineering to the facility.

2.3.4 GPU Nuclear Director. Three Mile Island l The GPU Nuclear Director, Three Mile Island repcrrs directly to the GPU Nuclear President. This position shall provide support w nr scility in areas such as radiological controls, emergency preparednesa, . %pational saferv. environmental affairs, maintenance, calibration. and Quality Verification.

2.3.5 Program Director. SNEC Facility l

The Progrcm Director, SNEC Facility reports to the GPU Nuclear Director, Engineering. The Program Directer is responsible to decommissien th: 5NEC l facility in a safe and efficient manner in accordance with this QA Plan and wi:h all applicable las, regulations,1: censes, and technical requirements.

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NUCLEAN GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No, Assurance Plan I l

23.6 Radiation Safety Offger (RSO) l The Radiation Safety Officer reports to the GPU Nuclear Dirt.rtor, Engmeering, l and is responsible for the conduct and oversight of all SNEC fa;ility radiation safety activities through implementation of the QA Program and the Radiation Protection Plan.

2.3.7 SNEC Facility Site Supervisor j 3

,y The SNEC Facility Site Supervisor reports to the Program Director, SNEC Facility 9f; and is responsible for on site management and continuing oversight of pioduction

}." activities. The Site Supervisor is responsible for the enfe conduct of production

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c.ctivities and effective implementation of QA Plan requirements.

2.3.8 Radiation Safety Committee l

b , The Radiation Safety Commi; tee reports to the GPU Nuct:ar Director, Engineering l and is responsible for the review afinspection and audit results and corrective actions for deficiencies. The Committee lias the organizatior al freedom, authority and capability to identify safety problems, to initiate, recommend, or provide solutions; and to verif> implementation of solutions.

2.3.9 GPU Nuclear. Nuclear Safety Assessment (NS A) Staff l

Veri 6 cation of effective QA plan implementation is the responsibility of the GPU Nuclear, NSA organization. NSA personnel shall have the authcrity and organizational freedom to identify quality problems; to take action to stop unsatisfactory work; to initiate, to recommend, or to provide solutions; and to verify implementation of solutions. The Director, Nuclear Safety Assessment reports directly to the GP'J Nuclear President.

The audit function is provided by GPU Nuclear and is independent of SNEC facility maaagement. The independence of the audit function is maintained by the auditors having unrcstricted access to the GPU Nuclear Ofnce of the President.

This access ensures that issues not capable of being resolved at a lower management level may be addremd to the highest management possible. GPU Nuclear's NSA Dep;.rtment is re ponHble to provide auditors certified to meet the requirements of ANSI N45.2.23 and s establish an audit program for the activities listed in Section 3.0. The audit reports are forwarded to the GPU Nuclear President, the SNEC President, the GPU Nuclear Director, Engir.eering and the l Radiation Safety Committee within 60 days of the completien or the audit.

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suctrAN GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE h1ANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

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c 3.0 DECO 3thtISSIONING OUALITY ASSURANCE PROGRAh!

3.1 General h This Secommissioning Quality Assurance Plan is the highest GPU Nuclear document which provides the generic and some speci6c requirements and methods to control octivitics. The term " Program" as used herein includes this Plan and the apptc,ced cocuments which are used to implement this Plan. This Plan is implemented through such a,3 proved documents.

The Saxton Nuclear Experimental Corporaticn Decommissionir,3 Quality Assurance

} Program has been established to control the activities performed by GPU Nuclear, and its

_ contractors, within the scope of tais Plan. This control is exerted primarily through the provision of, and compliance with, implementing documents and assurance that such documents are adequate and consistently used.

b Adherence to the requirements of this Plan is indatory for all GPU Nuclear orgarizations k and for all external organizations providing items, parts, materials, or conducting stivities which are within the secpe of this Plan.

This Plan shall be issued under the authority of the GPU Nuclear President, and shall be reviewed by the Dire: tor, Nuclear Safety Assessment. All changes to the Plan shall be reviewed by the Director, Nuclear Safety Assessment and approved by the GPU Nuclear President. Revisions to this plan will be submitted to the NRC: prior to the implementation of changes which involve a reduction in commitments previously accepted by the NhC n.d after implementation of changes having no reduction in commitment.

3.2 Scope The scope of this Plan includes, but is not limitrd to, items and activities related to the .

protection of site persennel and the public. To ensure consistency in identifying those items, parts, materials and activities within the scope of this Plan, a classification process shall be developed 6..d documentoc This proces: relies on the use of the term "QA Plan Scope" 3.2.1 A Quality Classi6 cation process for items shall be developed. This classincation process shall produce a Quality Classification List which ide iti6es the permanent plant structures, systems, and components that are within the scope of this Plan.

New items to which this Plan applies shall be added to t. Quality Classi6 cation y List subsequent to their installation.

3.2.2 Activities within the scope of this Plan are those directly related to radiological safey, and protection of site personnel and the public. These activities are delineated below.

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" NUCLkAN GPU NUCLEAR CORPORATE Number

, POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decomniissioning Quality Revision N(

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Support activities within the scope of this Plan are system / component /part classification, design, procurement, fabrication, handling, shipping, storage, cleaning, crecting, inttalling, 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, in-service 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, udiological environr ental monitoring, technical specification compliance and emergency preparedness.

Assurance activities within the scope of this Plan are audit, inspection, non.

destructive exammation, monitoring, surveillance, and safety review. Assurance auivities are performed by individuals tho are not directly responsible for mar. aging 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 xntrolled through the use of approved documents, which are, as a minimum, consistent with the requirements of this Plan. This Plan shall l remain in effect throughout the decommissioning project.

Activities affecting quality shall be accomplished under suitable controlled conditions. Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequam cleanliness; and assurance that all prerequisites for the given activity have been satisfied.

, 3.3 Training The program shall provide for indoctrination and training of personnel perform:ng activitics iffecting quality as necessary to assure that suitable proficiency is achieved and maintained.

The program shall take into account the ned for special conttois, processes, t:st equipment, tools, and skills to attain the required quality, and the need for verification of satisfactory implementation.

3.3.1 Training ;,rograms shall be estabished for those personnel performing quality asTecting activities such the f4ey are knowledgeable in the quality assurance program and proficient in ing ... .enting these requirements. These training programs shall assure the following:

a. Personnel responsible for performing these activities are instructed as to the purpose, scope, and implementation of applicable procedures.

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I muctrAs GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN.3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No, Assurance Plan 1 l

b. Personnel performing such activities are trained and quali6cd, as appropriate, ,

in the principles and techniques of the t.ctivity being conducted.

u The scope, objective, and method of implementing the training are documented.

d. Methods are provided for docu,reating training sessions describing content, attendance, date of attendance, and the results of the training session, as appiopriate.

4.0 PROCEDURES AND DRW'INGS 4.1 Procedures, and drawings of a type aprimpriate to the circumstances, shall be provided for the control and performance of activities wnich < tiect quality, health and safety of the public or project personnel, or regulatory requirements.

4.2 Procedures and drawings shall include appropriate quantitative or qualitsuve acceptance criteria for determining that important activities have been satisfactorily accomplished.

43 A procedure shall be implemented to control and delineate the requirements for the review and approval of documents implenviting the requirements of this plan. These documents typically include, but are not limited to; those termed plans, procedures, 'astructic.ns, drawings, and speci6 cations. This procedure shall include the review and approval requirements for the i.nplementation of documents not specifically written for the site decommissioning 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, Radiation protection procedures, Special procen procedures, Maintenance procedures, Disiaantlement procedures, Audit procedures, Administrative control procedures, Emergency procedures, Rigging, lifting and handling, inspection procedures. ,

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Qeu nuctrAs GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000.PLN-3000.05 title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

Assurance Plan 1 l

5.0 DESIGN CONTROL 5.1 When decommissioning activities require design, or modi 6 cation 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 it.clude the specifying of design input, the correct translation ofinput 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.

6.0 PROCUREMENT DOCUMENT 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 procorement of material, equipment, and services, whether purchased by GPU Nuclear or by its contractors or subcontractors. To the extent necessary, procurement documents shall reouire 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 docements shall contain speci6c technical and quality requirements, as appropriate.

6.3 Procurement documents shall contsin provisions which establish the right of access to vendor facilities and records for source inspection and audits o appropriate.

6.4 Docoments, and changes thereto, initiating procurement of equipment, components, or services shall be approved by appropriate management personnel and shall be subject to a a quality review to ensure applicable regulatory requirements, 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 docaments, including changes, are reviewed for adequacy and appraved for release by authorized personnel, and are distributed to and used at the lo:ation where the prescribed activity is performed.

7.3 Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval or another designated responsible organization.

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g, NUCLEAM GPU NUCLEAR CORPORATE Number I

s POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

Assurance Plan 1 l

7.4 Procedures within the scope of this Plan shall be controlled to assure that current copies are

, made available to personnel performing the presuibed activities. These procedures shall be reviewed by a technically competent person other than the preparer, and shall be approved by . .nanagement member of the organization responsible for the prescribed activity.

7.5 Significant changes to procedures within the ; cope of this Plan shall be reviewed and approved in the same manrser as the original.

8.0 CONTROL OF PURCHASED MATERIAL. 'EOUIPMENT. AND SERVICES 8.1 Measures shall be established to assure that purchased matc*ial, equipment and services conform to the procurement documents. These measures shall include provisions, as appropriate, for vendor evaluation and selection, objective evidence of quality fumished by 3 '

the vendor, inspection at the vendor source, and inspection of products epon delivery.

8.2 The effectiveness of the control of contractor services shall be assessed at intervals consistent with the importance of the se-vice.

l 8.3 The adequacy of vendor's quality assurance program specified in procurement l documentation shall be verified prior to use when appropriate. Vendors' adherence to their quality assurance program shall also be verified as appropriate.

8.4 Commensurate with potential adverse impacts on quality or health and safety, material and equipment shall be inspected upon receipt at th SNEC facility or other GPU Nuclear sites prior to use or storage to determine that procurement requirements are catisfied.

8.5 Measures shall be established for identifying nonconforming materirJ, parts and components.

9.0 IDENTIFICATION AND CONTROL OF MATERIALS PARTS AND COMPONENTS 9.1 Measures shall be established for the control of materials, parts, and components which are

'vithin the scope of this Plan.

9.2 These identification and control measures shall be designed to prevent the use ofiacorrect or defective material, parts and components.

10.0 CONTROL OF SPECIAL PROCESSES 10.1 Measures shall be established to asare that special processes, including welding, heat treating, and nondestructive examination are controlled and accomplished by qualified personne, using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

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I suctsAN GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nuclear Expericnental Corporation Decommissioning Quality Revision No.

Assurance Plan l l

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.

10.4 Nondestructive examinations (NDE) of equipment within the scope of this Plan shall be performed in accordance with procedures formulated in accordance with appliceb!e codes and standards and shall be reviewed to assure their technical adequacy, 10.5 Mea ures shall be established that assure NDE is performed by personnel qualified in accordance with applicable codes and standards.

I 1.0 INSPECTION I

l 11.1 Measures shall be established for review of appropriate activities to verify conformance with the documented procedures and drawings for accomplishing the activity.

11.2 If mandatory inspection hold point: which require witnessing or inspection and beyond which work shall not proceed without prior consent are required, the specific hold points shan oc indicated in appropriate documents.

11.3 Measures shall be established which assure that activities asa ciated with technical services (such as surveillance testing, instrument calibration, laboratory services, etc.) are reviewed by qualified personnel when determined appropriate.

I 1.4 Required inspections shall be performed in accordance with appropriate procedures. Such procedures shall contain a description of objectives, acceptance criteria and prerequisites for perfctming the inspections. These procedures shall also specify any special equipment or ,

calibrations required to conduct the inspection.

I 1.5 Personnel performing required inspections shall be qualified based upon experience and training in inspection methods. Required inspections shall not be performed by indis iduals who performed the inspected ctivity or directly supervised tne inspected activity.

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NucurAs GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLNd000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

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12.0 TEST CONTROL 12.1 A documented test program shall be established to assure that all testing to demor. strate that the structures, systems or components within the scope of this Plan will perform satisfactorily in sewice. The tests shall be performed in accordance with written, approved, and controlled test procedures or instructions which incorporate or reference the requirements and acceptance standards contained in the applicable design documents. The extent of the testing shall be based on the complexity of the modification, replacement, or repair. Testing shall include proof tests prior to installation, hydro testing, in service testing (IST) and preoperational tests.

13.0 CONTROL OF MEASURING AND TFST EOUIPMENT 13.1 Measures shall be established to assure that tools, gauges, instruments and other measuring I 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 l maints accuracy witun necessary limits.

14.0 HANDLING. STORAGE. AND SHIPPING f

14.1 Measures shall be established and documented to control handling, 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 status 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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Q,nuev.m GPU NUCLEAR CORPORATE Number I

POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton ScEAEE.hperimental Corporation Decommissioning Quality ' Revision No.

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16.0 t ONCONFORMING MATERIALS. PAJIS Ok COMPONENTS

' 6.1 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 identi0 cation, documentation, segregation, disposition and notification to affected organizations.

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

17.0 CORRECTIVE ACTIO3 17 ) Measures shall be established to assure that conditions adverse to quali:y, such as failures, malfunctions, discrepancies, deviations, oefective 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.

I 8.0 OUALITY ASSURANCE RECOP.DS l b.1 Sufficient records shall be maintained to furnish evidence of activities affecting quality (eg.

inspection reports, receipt inspection documents, engineering evaluations, monitoring reports etc.). These records shall document, when applicable, the identification of the individual generating the document or the data recorder, the type of obwrvation, the results, the acceptability, and the action taken in connection with any deficiencies noted.

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 applicabt:

r:gulations.

18.4 Measures shall be established which assure that qualification records of personnel performing special process activitier, such as welding, NDE, inspection, etc., are retained.

18.5 Measures shall be established which assure that quality related procurement documents are retained.

18.6 Measures shall be established which assure that appropriate ret.ords pertaining to audits are retained.

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% NUCLEAR GPU NUCLEAR CORPORATE POLICY & PROCEDURE MANUAL .

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1000 PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No, Assurance Plan I

, l-18.7 Measures shall be established which assure that records associated with personnel exposure control are retained.

19.0 AUDITS 19.1 A program of assessment will be conducted by the GPU Nuclear NSA Department. 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 mmpliance 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 repc.rrs shall include a desciption of the area audited, identification ofindividuals responsible for implementation of the audited provisionr 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 Director, Engineering, the Radiation Safety Committee, and to those individuals responsible l 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 shall include notification of the manager responsible for the disc epancy, 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. Ifline management is not capable of resolving disputed discrepancies, the esolution shall be escalated to the next level of management until the disputed discrepancy is resolved.

19.6 Monitoring is used to establish adequate confidence levels that activities within de scope of this Plan are being performed in accordance with the QA Program requirements and plant administrative controls. Monitoring will be performed and the degree of monitoring perforn:cd shall be based typically upon the status and safety significance of activities, extent of previous experience, thoroughness of overall coverage, uniqueness of the activity, and trending data.

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 performed.

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% NUCLEAN GPU NUCLEAR CORPORATE Number l

POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

l Assurance Plan  ! , l APPENDIX A COMMITMENT TO O.UALITV ASSURANCE REGULATORY GUIDES FOR SNEC FACILITY DECOMMISSIONING

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DEGREE OF REG. GUIDE ANSI STD. COMPLIANCE REMARKS l.58 9/80, Rev, t Quali6cetions of Nuclear N45.2.6 1978 Modified See attached Power Plant inspection, comments Examinaticn and Testing Personnel 1.88 10/76, Rev. 2 Collection, Storage and N45.2.9 1974 Modified See attached Maintenance of Nuclear comments Power Plant Quality Atsurance Records T.123 7/77. Rey I QA Requirements for N45.2.13 '1976 Iodified See attached Installation, inspection comments and Testing of Mecha 'ical Equip nent and Systems.

1.144 t/79 Requirements for N45.2.12 1977 Modined See attached Auditing of Quality comments Assurance Programs for Nuclear Power Plants 1.146 8/80 Quali6 cation of Quality N45.2.23 1978 Full Comply with Assurance Program Regt.latory Position Auditors for Nuclear Power Plants i

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POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Decommissioning Quality Revision No.

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APPENDIX A (Cont.)

COMMITMENT TO OU ALITY ASSURANCE REGULATORY GUIDES FOR SNEC FACFLITY DECOMMISSION.QLQ

+ NRC Regulatory Guide 1.58. Rev.1. Scotember 1980 Oualifications of Nuclear Power Plant Insocction. Examination. and Testine Personnel The SNEC Facility Decommissioning Quality Assurance Program complies with this guide with the following clarification:

1. The guidance of Regulatory Guide 1.58 shall be followed as it pertains to the qualifications ofinspection personnel who verify conformance of work activities to quality requirements. The qualification of other GPU Nuclear personnel shall be in accordance with GPU Nuclear established requirements.

No operationt.t requirements of Regulatory C'iide 1.58 will be implemented due to the cessation of operation and defueled status of the SNEC Facility.

The qualification of nondestructive testing personnel shall be ia accordance with the l requirements and recommendations of ASNT Recommended Practice No. SNT-TC-1 A, l

1980, Edition. In addition, SNT-TC 1 A shall be used in conjunction with the additional ,

provisions of the applicable ASME Boiler and Pressure Vessel Code. Later editions of SNT-TC-1 A may be utilized as referenced in Section X! 9f the Code provided that the edition of the Code has been incorporated by reference into Title 10 of the Code of Federal Regulations, Part 50.55a.

Recertification of NDE Level !!! personnel shall be at an interval of every 5 years as noted by ASME Code Case N 341 and N-356 rather than the 3 year interval recommended by SNT-TC-l A,1980.

Qualification and subsequent requalification of personnel conducting visual examination activities within the scope of the applicable ASME Section XI edition shall be performed consistent with that applicabic ASME Section XI as further permitted and accepted by ASME f,eten XI Code Cases associated with qualification in visual examination endorsed by the current revision of Regulatory Guide 1.147.

2. Not all personnel who:

a. Reviewed a.id approved inspection and testing procedures,

b. Eva! rate the adequacy of activities to accompiish the inspection and test objectives, 15 3

. l muctaAs GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nucicar Experimental Corporation Decommissioning Quality Revision No, Assuruce Plan 1

,, l APPENDIX A (Cont.)

COMMITMENT TO OUALITY ASSURANCE REGULATORY GUIDES FOR SNEC FACILITY DECOMMISSIONING

c. Evaluate the adequacy of specific programs used to train and test inspection and test personnel, .-

d. Certify Level til individuals in specific categories or classes, will be certified as meetirq the Level 111 capability requirements of ANSI N45.2.6-1978.

Rather these personnel will be determined by management through evaluation of their education, experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented.

• NBC Regulatory Guide 1.88. Rev 2. October.1926 -

Cohection. Storane and Maintenance of Nuclear Power Plant Availability Assurance Records GPU Nuclear will comply with the intent of this regulatory guide by compliance with the ,

requirements of ANSI /ASME NQA-t-1979, Supplement 17S and Appendix 17A-1 including Appendix 171, NQA-l A 1981.

+ NRC Regulatory Guide 1.123. Rev.1. July 1977 Ouality Assurance Reauirements for Control of Procurement ofitems and Service 1for Nuclear Power Plants The SNEC Facility Decommissioning Quality Assurance Program complies with this guide with the following clarification:

1. Section C.). A corrective action system may, depending upon complexity and/or importance to safety of the item or s ovice provided, be imposed upon the supplier.

When a corrective action is imposed an a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.

2. Section C.4. Applicable information concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personoe!.

3. Section 4.2a of ANSI N45.2.13 1976. When evaluation of a suppher is based solely on historical supplier data, these data will primarily include records that have been au umulated in connection with previous procurement actions. Data that includes experience of users ofidentical or similar products of the prospective supplier and product operating experience will be used if available.

16.0

o 1 l '

WUCLKAN GPU NUCLEAR CORPORATE Number i POLICY & PROCEDURF kl.ANUAL 1000 PLN .3000.05 Title Saxton Nuclear Experimental Cogoration Decommissis Sg Quality Revision No.

Assurance Pian 1 l

APPENDIX A(Cont]

l COMMITMENT TO OUALITY ASSURANCE REGULATORY GUIDES FOR SNEC FACILITY DECOMMISSIONING 1

4 Section 4.2 of ANSI N45.2,13-IP76. In the special care of" commercial grade items" the supplier does not have to be evaluated by one of the methods identified; howevei, the i procurement documents shall contain requirements specific to the item being procured.

5. Section 7.5. As a point of clarification, personnel who perform the audit (s) as described in Section 19.0 of this Plan will not be quali.ied in accordance with ANSI N45.2.6. Such personnel are qualified in accordance with Regu'atory guide 1.146, dated 8/80.

6. Section Id.2d of ANSI N45.2.13 1976. The requirements of this section are interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier

7. Section 10.2.1, Ver:fication of the Validity of Supplier Certificates and the Effectiveness of the Certification System,is as follows: The verification of the validity of supplier certificates and the effectiveness of the certification are accomplished as an integral part of the tott.1 supplier control and product acceptance program, and no s< parate GPU Nuclear system exists that addresses itself solely to y;..h verification. The degree of verification required will depend upon the type ofitem or service and their safety importance. The means of verification may include source witness / hold points, source audits, and document reviews; independent inspections :.t the time of material receipt; user tests on selected commodities, such as concrete components; and tests after installation on selected components and systems. All of these means verify whether or not a supplier has fulfilled procurement document requirements and whether or not a certification system is effective.

+ NRC Regulatorv Guide 1.144. Januarv 1979 Auditing of Ouality Assurance Programs for Nuclear Power Plants r

GPU Nuclear is in basic agreement with the position set forth in the Regulatory Guide subject to the following comments:

1. Section C.3a(1) and C.3a(2)

The frequency of performance and minimal topical coverage ofinternal audits will be consistent with the plant technical specifications.

2. Section C3.b(1)

Source surveillance will be utilized in lieu of or in addition to receipt inspection. As permitted, external audits of such procurement actior..; will typically not be scheduled.

17.0 t

0 o 6L20-98-20036 A"achment 8 l

{

l Attachment 8 Revised Post Shutdown Activities Report Figurcs 2,2-4 and 2.3-2 t

.O Fig. 2.2-4 Saxton Decommissioning Project Schedule Task Name Start Finish 3Q97 4Q97 1Q98 2Q98 3Q98 4Q98 1Q99 2Q99 3Q99 4Q99 1Q00 2Q00 3Q00 4Q Decommissioning Preparations Complete 10/1/97 10/1/97 <>

Large Compenent Removal Project - Off-site Work 10/1/97 "f31/98 E M Approval of TSCR 59 1/2/98 1/2/98 4>

Prepare CV For Large Component Removal 1/2/98 8/3/98 E Mg Submit License Termination Plan (LTP) 8/1/98 8/1/98 l$

Mobilize On-site for Large Component Removal 8/3/98 8/3/98 $

Remove Large Components 8/25/98 10/15/98 E Ship Large Components to Barnwell 10/15/98 11/2/98 $

Decommissioning Operations 10/16/98 9/30/99 M Comr**te Physical Decommissioning Tasks 9140/99 9/30/99 <>

Final Status Survey 10/1/99 5/31/00 gg NRC Review of Compliance w/ LTP 6/1/00 8/31/00 M License Termination 9/1/00 9/1/00 l l $

Site Restoration 9/2/00 10131/00 g L_-- - ,, m

pr .

Q .

Figure 2.3-2 SAXTON ORGANIZATION - OPERATIONAL PHASE GPU Nuclear Presidat -- ---

i l I i Nuclear Safety Assessment Vice President Engineering Additional Nuclear Divisional Support j l

i i Radiation SafetyCommittee -

j I I I i i

Decommissioning Director Program DirectorSNEC Facility - - -

Radiation Safety Officer

• 9 "9""'

~

Manager,Dt.D Engineering SNEC FacilitySite Supervisor cup adologica:ContoisSupesor Engineering Support -

D & D Supervisor

~

Waste Supervisor RaditjogicalControls Technicians Scheduler / Planner Security Key:

Clerical Direct Reporting Relationship Indirect Reporting Relationship i

L---_ -