ML20202F711
| ML20202F711 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 02/02/1998 |
| From: | GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20202F703 | List: |
| References | |
| 1000-PLN-3000.0, NUDOCS 9802190282 | |
| Download: ML20202F711 (18) | |
Text
_ _. _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ -
6L20-98-20072 Attachment L NUCLEAg GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nuclear Experimental Corporation Facility Decommissioning Revision No.
I Quality Assurance Plan 1
Applicability / Scope Responsible Office GPU Nuclear and Saxton Nuclear Experimental Corporation Wide Nuclear Safety Arsessment This document is within QA plan scope E Yes O No EITective Date Safety Reviews Required E Yes O No l
List of Effective Pages P!agg Bi i!g.g l
l 1.0 I
l 1.1 I
l 2.0 1
3.0 1
l 4.0 1
5.0 1
6.0 1
7.0 1
8.0 1
9.0 1
10.0 1
11.0 1
12.0 I
l 13.0 1
14.0 1
l 15.0 I
16.0 1
17.0 1
Signature Concurring Organization Element Date Originator A,., #]f M, ',,m NSA Assessor f..g f. 9 p Concurred jyM Director, Human and Administrative Services jJU/g l
[Qg}//Q Director, Engineering j / 7 f/(;7 pggg Director, TMI jgdf ej (
(/( )
C Director, Nuclear Safety Assessment J/g7M/
' gggg Program Director, SNEC Facility f M /pg
~ fgQ Responsible Technical Reviewer
,/zt /M5.,
L.,.g g j Corporate Procedure Coordinator
,j.j,,/9y Approved gQ Office of the President
.a/ y fg U
l 9802190282 980209 10 l
PDR ADOCK 05000146 p
Ip y
NUCLEAR GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN 3000.0.i Title Saxton Nuclear Expe imental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan.
I l
DOCUMENT HISTORY REV
SUMMARY
OF CHANGE DATE O
Original Revision 04/03/96 l
i In responding to the questions raised by the NRC's review of this plan, GPU Nuclear agreed te make three changes to the document. The first change is to add a requirement to section 3,1 of the plan, which requires NRC review of changes to this plan. The second change consists of providing more detail of the minimum content ofinspection records as defined in section 18.1 of the plan. The final change sdds 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 reDect a j
reorganization of GPU Nt ', lear Divisions.
(
l.1
~
.\\
CUCLCA3 GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDURE MANUAL 1000 PLN 3000.05
~
Titi, Saxton Nuclear Experirnental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 1
l 1.0 POLICY STATEMENT it 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 site. 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 responsive to, applicable d
federal, state and local requirements; 10CFRl9,10CFR20,10CFR21 and appropriate sections of 10CFR50; applicable industry codes and standards; and commitments made to the U.S. Nuclear Regulatory Commission. Appendix A of this document provides a detailed listing of the Quality i
Assurance Regulatory Guides, and associated ANSI Standards, which are required to implement this J
plan. The packaging had 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. Specine 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 ORG ANIZATION AND FUNCTIONAL OA RESPONSIBILITIES 2.1 General The persons and organizations performing QA functions report to a management level that assures the required authority and organizational freedom are provided, including sufficient independence from cost and schedule. The individuals assigned the responsibility for assuring effective execution of any portion of the QA Plaa have direct access to the levels of management necessary to perform QA functions.
2.2 Organization The Saxton Nuclear Experimental Corporation (SNEC) facility organization is structured on the basis that the attainment of the objectives of the QA Program relies on those who manage, perform, 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.
Specific QA requirements and organizational responsibilities for implementation of these requirements shall be specified in various implementing procedures and other documents. The requirements stipulated in the QA Program shall be imposed on all personnel and organizations, including contractors, who perform the decommissioning activities referenced in Section 3.0.
2.0
CUCLEAg GPU NUCLEAR CORPORATE N::mber POLICY & PROCEDURE MANUAL 1000 PLN.3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 1
l 2.3 Functional QA Responsibilities 2.3.1 GPU Nuclear Presiden!
The GPU Nuclear President has the overall responsibility for the establishment, implementation, and effectiveness of the SNEC facility Duommissioning QA Program.
This responsibility is administered through management staff as described below.
2.3.2 GPU Nuclear Director. Human tnd Administrative Services l
The GPU Nuclear Director, Human and Administrative 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 admiaistration of a goods and services nonconformance program, and warehousing.
l 2.3.3 GPU Nuclear Director. Ennineerine lhe GPU Nuclear Director, Engineering reports direct!y to the GPU Nuclear President.
This position is responsible for the overall SNEC Facility decommissioning program.
This director also shall furnish engineering services and technical support in areas such as nondestructive examination, design, modification, and procurement engineering to the facility.
2.3.4 GPU Nuclear Director. Three Mile Island l
The GPU Nuclear Director, T. ee Mile Island reports directly to the GPU Nuclear President. This position shall provide support to the facility in areas such as radiological controls, f.mergency preparedness, occupational safety, environmental affairs, maintenanc,:, calibration, and Quality Verification including the administration of a material nonconformance program.
2.3.5 Program Director. SNEC Facility l
The Program Director, SNEC Facility reports to the GPU Nuclear Director, Engineering. The Program Director is responsible to decommission the SNEC facility l
in a safe and eflicient manner in accordance with this QA Plan and with all applicable laws, regulations, licenses, and technical requirements.
2.3.6 Radiation Safety Officer (RSO) l The Radiation Safety Officer reports to the GPU Nuclear Director, Engineering, and is l
responsib,: for the conduct and oversight of all SNEC facility radiation safety activities through implementation of the QA."rogram and the Radiation Protection Plan.
3.0
CUCLEAg GPU NUCLE AR CORPORATE N:mber POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 1
l 2.3.7 SNEC Facility Site Supervisor l
The SMEC 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.
2.3.8 Radiation Safety Committee l
The Radiation Safety Committee repods to the GPU Nuclear Director Engineering and l is responsible for the review ofinspection and audit results and corrective actions for denciencies. The Committee has the organizational freedom, authority and capability to identify safety problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
2.3.9 GPU Nuclear Director. Nuclear Safety Asses'sment (NS A) l Veri 6 cation of effective QA nian implementation is the responsibility of the GPU Nuclear, NSA organization. NSA personnel shall have the authority 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 solution:,. The Director, Nuclear Safety Assessrrent reports directly to the GPU Nuclear President.
The audit function is provided by GPU Nuclear and is independent of SNEC facility management. The independence of the audit function is maintained by the auditors having unrestricted access to the GPU Nuclear Ofnce of the President. Thb access f
ensures that issues not capable of being resolved at a lower management level may be addressed to the highest management possible. GPU Nuclev's NSA Department is responsible to provide auditors certified to meet the rtquirements of ANSI N45.2.23 and to 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, Engineering and the Radiation Safety Committee within 60 days of l
the completion of the audit.
3.0 DECOM_MISSIONING OUALITY ASSURANCE PROGRAM 3.1 General This Decommissioning Quality Assurance Plan is the highest GPU Nuclear document which provides the generic and some specine requirements and methods to control activities. The term
" Program" as used herein includes this Plan and the approved documents which are used to implement this Plan. This Plan is implemented through such approved documents.
4.0
- _. _ -. ~ - -.... - -
J.
CuctsAn GPU NUCLEAR CORPORATE Nember POLICY a PROCEDURE MANUAL 1000-PLN.3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 1
l 5
The Saxton Nuclear Experimental Corporation Facility Decommissioning Quality Assurance j
Program has been established to control the activities performed by GPU Nuclear, and its -
contractors, within the scope of this 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.
Adherence to the requirements of this Plan is mandatory for Cl GPU Nuclear organizations and for all external organizations providing items, parts, materials, or 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.
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 NRC and after implementation of changes having no reduction in commitment.
3.2 Scope The scope of this Plan includes radiological safety and implemeritation of the regulations as committed to in Section 1.0 of this Plan. To ensure consistency in identifying those items.
parts, materials and activities within 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 Tor items shall be developed. This classification process shall produce a Quality Classification 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 added to the Quality Classification List subsequent to their installation, 3.2.2-'
Activities within the scope of this Plan are trose directly related to radiological safety and implementation of the regulations as committed to in Section 1.0 of this Plan.-
TWse activities are delineated below.
Support retivities within the scope of this Plan are system /compor ent/part
. classification, design, procurement, fabrication, handling, 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 teuing, maintenance (including lifting and handling which couldjeopardize 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.
5.0
CUCLEW)
GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan l
Assurance activities within the scope of this Plan are audit, inspection, non-destructive examination, monitoring, surveillance, and safety review. Assurance activities are performed by individuals who are not directly responsible for managing or perfonning the work or activity Nuclear Sal'ety Assessment personnel, who are independent of the organization performing the work :r activity, perform periodic assessments of th:
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 minimum, consistent with the requirements of this Plan. This Plan shall 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; suitabla 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 indoctrination and training of persannel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained, The program shall take into account the need for special controls, processes, test equipment, tools, and skills to attain the required qualD > and the need for verification of satisfactory implementation.
3.3.1 Training 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 ti.ese 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.
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 ofi.nplementing the training are documented.
d.
Methods are provided for docurating training sessions describing content, attendance, date of attendance, and the results of the training session, as appropriate.
4 6.0
CuctCAg GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDU35,' MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Faci :ty Revision No.
Decommissioning Quality Assurance Man 1
l 4.0 PROCEDURES AND DRAWINGS 4.1 Procedures, and drawings of a type appropriate to the circumstances, shall be provideo for the control and performance of activities which affect quality, health and safety of the public or project personnel, or regulatory requirements.
42 Proceduren and drawings shall include appropriate qucntitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
4.3 A procedure shall be implemented to control and delineate the requirements for the review and approval of documents implementing the requirements of this plan. These documents typically include, but are not ilmited to, those termed plans, 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 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 process procedures, Maintenance procedures, Dismantlement procedures, Audit procedures, Administrative control procedures, Emergency' procedures, Rigging, lifting and handling, inspection procedures.
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 specifying of design input, the correct translation of input in design documents, the verification of design by persons o:her than the originator, and the assurance that changes to the design beyond design tolerance are properly reviewed and controlled.
7.0
CucLEC1 GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDURE MANUAL 1000-PLN 3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance I'lan 1
l 6.0 PROCUREMENT DOCUMENT CONTROla 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 assurar.cc program consistent with the contractor's potential impact on quality or the health and safety of project personnel and the general public.
6.2 h r curement 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 sha'l be approved by appropriate management personnel and shall be subject to a quality review to ensure applicable regulatory requirements, design bases, quality assurance, and other requirements are adequately satisfied prior to reicase.
7.0 DOCUMENT CONTROL 7.1 Measures shall be established to centrol the irsuance of documents, such as procedures and drawings, including changes thereto, which prescribe activities affecting quality.
7.2 These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel, and are distributed to and used at tne location where the prescribed activity is performed.
7.3 Changes to documents shall be reviewed end approved by the same organization 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 organization responsible for the prescribed activity.
7.5 Significant changes to procedures within the scope of this Plan shall be reviewed and approved in the same manner as the original.
8.0 CONTROL OF PURCHASED MATERIAL. EOUIPMENT. AND SERVICES 8.1 Measures shall be established to assure that purchased material, equipment and services conform 8.0
~ _ _ _ _.
CUCLEAg GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1000-PLN-3000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan I
l to the procurement documents. These measures shall include 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.
8.3 The adequacy of vendor'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.
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 GPU Nuclear sites prior to use or stora e to determine that procurement requirements are satisfied.
o 8.5 Measures shall be established for identifying nonconforming material, 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 within the scope of this Plan.
9.2 These identification and control measures shall be designed to prevent the use ofincorrect or defective material, parts and components.
t 0.0 CONTROL OF SPECIAL PROCESSES 10.1 Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive examination are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
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 applicable codes and standards and shall be reviewed to assure their technical adequacy.
90
I CUCLEA]
GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDURE MANUAL -
1000.PLN 3000.05
' Title Sanan Nuclear Experimental Corporation Facility Revision No.
Decornmissioning Quality Assurance clan 1
l 10.5 Measures shall be establishec that a ssure NDE is performed by personnel quallned in accordance with applicable codes and standards, 11.0 INSPECTION 11.1 Measures shall be established for review of appropriate activities to verify conformance with the documented procedures and drawings for accomplishing the activity.
I l.2 If miendatory inspection hold points, which require witnessing or inspection and beyond which work shall not proceed without prior consent are required, the speci0c hold points shall be indiented in appropriate documents. The dceument containing the inspection hold points shall be re m.d pior to implementation by the organization required to perform the inspection.
11.3 Measures shall be vstr.blished which a.sure that activities associated with technical services (such as surveillanse testing, instrut..ent calibration, laboratory services, etc.) are reviewed, when detenuined 6ppropriate, by qualified personnel.
11A Required inspec' ans shall be performed in accorance 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 inspecticns shall be qualified based upon experience and training in inspection methods. Required inspections snall not be performed by individuals who performed the inspected activity or directly supervised the inspected activity.
12.0 TEST CONTROL 12.1 A documented test program shall be established to assure that al' 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 instructioas which inco,porate 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.
l Testir.q shall include proof tests prior to installation, hydtc testing, functional testing and pre y, rational tests.
l l
13.0 CONTROL OF MEASURING AND TEST EOUIPMENT 13.1 Measures shall be established to assure that tools, g4upe' aruments and other measuring and-testing devic:s used in ctivities affecting quality m ant to the protection of health and safety are properly controlled, calibrated and a 6 see gecified periods to maintain accuracy witFin necessary limits.
10.0
muctrA]
GPU NUCLEAR CORPORATE N::mbe.-
POLICY & PROCEDURE MANUAL 1000.PLN4000.05 Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assuran:e Plan I
l 14.0 [lANDLING. STORAGE. AND SillPPING 14,1 Measures shall be established and documented to control ha-dling, storage, and shipping, including cleaning, packaging, and preservation ofitems within the sec., i of this Plan in accordance with establithed instructions, procedures, and drawings to prevent damage, deterioration, or loss.
l $.0 INSPECTION.T5'ST. 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:
Inspection, test, and operating status for equipment within the scope of this Plan shall be a.
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.
16.0 NONCONFORMING MA ERIALS. PARTS OR COMPONENTS 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. Rese measures shall include, as appropriate, procedures for identification, 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 C_ORRECTIVE ACTION 17.1 Measures shall be established to assure that conditions adverse to quality, such as :ailures, malfunJ. ions, 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 Suflicient records shall be maintained to furnish evidence of activities afTecting quality (eg.
I j
i 1.0
CUCLfN3 GPU NUCLEAR CORPORATE N::mber POLICY & PROCEDURE MANUAL 1000 PLN 3000.05 Title Saxton Nuclear Experirnental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 1
l inspection reports, receipt inspection documents, engineering evaluations, m'onitoring repons etc.). These records shall document, when applicable, the identincation of the individual generating the document or the data recorder, the type of obsuvation, the results, the acceptability, and the action taken in connection with any denciencies noted.
18.2 Records shall be identinable 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.
18.4 Measures shall be established which assure that quali0 cation records of personnel performing special process activities, 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 estabil;hed which assure that appropriate records pertaining to audits are retained.
I G.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 OPU Nuclear NS A Department to verify compliance with appropriate requirer ~nts of the Program and to determine its effectiveness. The audits shall be performed in accordance with written procedures or checklists by appropriately quali0ed 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, identincation ofindividuals responsible for implementeion of the audited provisions and for performance of the audit, identincation 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 GPU Nuclear, Director, Engineering, the Radiation Safety Committee, a'id 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 12.0
.(2eu CUCLEA']
GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDURE MANUAL 1000 PLN 3000.0$
~lliii Saxton Nuclear fixperimental Corporation Facility Revision No.
)
Decommissioning Quality Assurance Plan I
l are resobed. These measures shall include noti 0 cation of the manager responsible for the discrepancy, recommended corrective action, and veri 0 cation of satisfactory resolution.
Disciepancies 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 resolution shall be escalated to the next level of rnanagement until the disputed discrepancy is resolved.
19.6 Monitoring is used to establish adequate con 0dence levels that activities within the scope of this Plan are being performed in accordance with the QA Program requirements and plant administrative controls. Monitoring will be performed and the degrce of monitoring performed shall be based typically upon the status and safety signincance of activities, extent of previous experience, thoroughness of overall coverage, uniqueness of the activity, and trending data.
19.7 Monitors shall be quali0ed 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.
13.0
.l Nu.tfAn GPU NUCLEAR CORPORATE Number POLICY & PROCEDURE MANUAL 1004PLN 3000.05 Title Saxton 14uclear Experimental Corporation Facility Revia 6en No, Decommissioning Quality Assurance Plan 1
l APPENDIX A COMMITMENT TO OUALITY ASSURANCE REGULATORY GUIDES FOR SNEC FACILITY DECOMMISSIONING DZGREE OF RF.G. G UIDE ANSI STD.
COMPLIANCE REMARKS l.58 9/80, Rev. I Qualifications of Nuclear N45.2.6 1978 Modified See attached Power Plant inspection, comments Examination and Testing Personnel l.88 1066, Rev. 2 Collection, S:orage and N45.2.9 1974 Modified See attached Maintenance of Nuclear comments Power Plant Quality Assurar.cc Records 1.123 707. Rev I QA Requirements for N45.2.13 1976 Modified See attached installation, inspection comments and Testing of Mechanical Equipment and Systems.
1.144 109 Requirements for N45.2.12 1977 Modified See attached Auditing of Quality comments Assurance Programs for Nuclear Power Plants 1.146 8/80 Qualification of Quality N45.2.23 1978 Full Comply with Assurance Program Regulatory Position Auditors for Nuclear Power Plants I 4.0
/%
'. DN CUCLEA3 GPU NUCLEAR CORPORATE N:anber j
POLICY & PROCEDURE MANUAL 1000.PLN 3000.0$
i Title Saxton Nuclear lixperimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan 1
l APPENDIX A (Cont.)
+
NRC Regulatory Guide 1.58. Rev.1. Scotember 1980 1
Dyalineations of Nuclear Power Plant inspretion. Examination. and Testinn Personnel The SNEC Facility Decommissioning Quality Assurance Program complies with this guide with the following clari0 cation,:
1.
The guidance of Regulatory Guide 1,58 shall be followed as it pertains to the qualifications of inspection personnel who verify conformance of work activities to quality requirements.1 he qualincation of other GPU Nuclear personnel shall be in accordance with GPU Nuclear established requirements.
No operational requirements of Regulatory Guide 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 in accordance with the requirements and recommendations of ASNT Recommended Practice No SNT TC 1 A,1980, Edition, in addition, SNT TC l A shall be used in conjunction with the additlenal provisions of the applicable ASME Boller and Pressure Vessel Code. Later editions of SNT TC I A may be utilized as referenced in Section XI of the Code provided that the edition of the Code has been incorporated by reference imo Title 10 of the Code of Federal Regulations, Part 50.55n.
Recertification of NDE Level ill 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-1A,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 applicable ASME Section XI as further permitted and accepted by ASME Section 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 and approved inspection and testing procedures, b.
Evaluate the adequacy of activities to accomplish the inspection and test objectives, c.
Evaluate the adequacy of specific programs used to train and test inspection and test personnel, d.
Certify Level 111 individuals in specific categories or classes, will be certified as meeting the Level 111 capability requirements of ANSI N45.2.61978.
15.0
.a
NUCLEAg GPU NUCLEAR CORPORATE N:mber POLICY A PROCEDURE MANUAL 1000-PLN.3000.05
~ Title Saxton Nuclear Experimental Corporation Facility Revision No.
Decommissioning Quality Assurance Plan I
l APPENDik A(Cont 3 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.
+
NEC,jigggjalorv Guide 1.88. Rev 2. October.1976 u
Collection. 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.I.1979, Supplement 17S and Appendix 17A 1 including Appendix 171, NQA 1 A.1981.
NRC Renulatorv Guide 1.123. Rev.1. July 1977 Ouality Assurance Reauirements for Control of Procurement ofitems and Services for Nuclear Power Plants The SNLC Facility Decommissioning Quality Assurance Program complies with this guide with the following clarification:
1.
Section C.3. A corrective action system may, depending upon complexity and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action is imposed on 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 personnel.
3.
Section 4.2a of ANSI N45.2.131976. When evaluation of a supplier is based solely on historical supplier data, thece data will primarily include records that have been accumulated in connection with previous prowrement actions. Data that includes experience of users of identical or similar products of the prospective supplier and product operating experience will be used if available.
4.
Section 4.2 of ANSI N45.2.13 1976. In the special case of" commercial grade items" the supplier does not has e to be evaluated by one of the methods identified; however, the 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 qualified in accordance with ANSI N45.2.6. Such personnel are qualified in accordance with Regulatory guide 1.146, dated 8/80.
i 16.0
GU CU_ LEA ?
GPU NUCLEAR CORPORATE N:mber POLICY & PROCEDURE MANUAL 1000-PLN 3000.05
'litle Saxton Nuclear Experimental Corpo;ation l'acility Revision No.
Decommissioning Quality Assurance Plan 1
l APPENDIX A (Con.U 6.
Section 10.2d of ANSI N45.2.131976. The requirements of this section are interpreted as follows: The person attesting to a certincate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.
7.
Section 10.2.1, Veri 0 cation of the Validity of Supplier Certificates and the Effectiveness of the Cenification System,is as follows: The veri 0 cation of the validity of supplier certificates and the effectiveness of the certi0 cation are accomplished as an integral part of the total supplier control and product acceptance program, and no separate GPU Nuclear system exists that addresses itself solely to such verification. The degree of veri 0 cation 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 review s; independent inspections at the time of material receipt; user tests on selected commodities, such as concrete components; and tests afler 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 Reculatory Guide 1.144. January 1970 Auditine of Ouality Assurance Procrams for Nuclear Power Plants 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 : overage of internal audits will be consistent with the plant technical specifications.
2.
Section C.3.b(1)
Source surveillance will be utilized in lieu of or in addition to receipt inspection. As permitted, external audits of such procurement actions will typically not be scheduled.
3.
Section C3.b(2)
External audits of selected suppliers of services which are within the scope of this Plan will be scheduled and conducted at least once within the life of the activi4y or every three years.
An annual evaluation of suppliers ofitems and services will be conducted. These evaluations will be conducted utilizing the results of source surveillance, source inspection, receipt inspection and/or audits; and, other factors. These evaluations will determine the need to conduct audits of suppliers of items, parts or materials; or, increase the frequency of conducting audits of suppliers of services.
17.0