ML20203C463

Issue a to QAPD-9009-2, Triga Reactor Facility Decommissioning QA Program Document

ML20203C463
Person / Time
Site:	General Atomics
Issue date:	10/16/1998
From:	Bramblett G, Greenwood J, Nicolayeff V GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:
Shared Package
ML20203C460	List: ML20203C457 ML20203C463
References
QAPD-9009-2, NUDOCS 9902120074
Download: ML20203C463 (24)

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GENERAL ATOMICS

Title:

TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT Doc. No. QAPD-9009-2 Page I of 24 ISSUE

SUMMARY

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GENERAL ATOMICS

Title:

TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT Doc. No. QAPD-9009-2 Issue: A Page 2 TRIGA REACTOR FACILITY DECOMMISSIONING QUALITY ASSURANCE PROGRAM DOCUMENT GENERAL ATOMICS PROJECT NO. 9009.303 APPROVED BY: '

WM /* - Z - 7 6 V. Nicolayeff, ManagIr7 Environmental Quality Assurance APPROVED BY: OC 20cxP6 J. Greenwood, Manager, TRIGA Reactor Facility APPROVED BY,: v

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G. Bramblett, Manager, D&D Projects APPROVED BY: d I. Ne -- - /o//F/fJ B. L. Coleman, Director, Quality Assurance CONCURRENCE: woe /o/6/9F K. Asmuss'en,6irector, Licensing, Safety,'an'd Niiclear Compliance l

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GENERAL ATOMICS N-

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TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT Doc. No. QAPD-9009 2 Issue: A Page 3 TABLE OF CONTENTS

1. GENER.AL i 1

1.1 Purpose l 1.2 Scope of Work l 1.3 Waste Disposal 1.4 Application

2. ORGANIZATION i 2.1 GA Organization 2.2 Authority of QA Personnel

3. QUALITY ASSURANCE PROGRAM

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'v' 3.1 Requirements 3.2 Implementation 3.3 Graded QA Program 3.4 Personnel Training

4. DESIGN CONTROL 4

5. PROCUREMENT DOCUMENT CONTROL

6. INSTRUCTIONS, PROCEDURES, AND DRAWINGS

7. DOCUMENT CONTROL

8. CONTROL OF PURCHASED ITEMS AND SERVICES

9. IDENTIFICATION AND CONTROL OF ITEMS

10. CONTROL OF PROCESSES

11. INSPECTION, OBSERVATION, CHARACTERIZATION, AND RADIOLOGICAL SURVEYS

( 12. TEST CONTROL

13. CONTROL OF MEASURING AND TEST EQUIPMENT

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14. HANDLING, STORAGE, AND SHIPPING

15. INSPECTION, TEST, AND OPERATING STATUS

16. CONTROL OF NONCONFORMING ITEMS

17. CORRECTIVE ACTION

18. QUALITY ASSURANCE RECORDS

19. QUALITY ASSURANCE AUDITS AND SURVELLLANCES i

FIGURE 1 GA ORGANIZATION FOR THE TRFD PROJECT  !

1 TABLE 1 QUALITY ASSURANCE PROGRAM INDEX TABLE 2

SUMMARY

OF INSPECTION, OBSERVATION, CHARACTERIZATION, AND O SURVEY RESPONSIBILITIES TO SUPPORT WASTE CERTIFICATION TABLE 3 QUALITY ASSURANCE RECORDS RETENTION RESPONSIBILITIES O

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1. GENERAL l 1.1 Pumose 1.1.1 This Quality Assurance Program Document (QAPD) establishes the quality assurance requirements implemented by General Atomics (GA) for the TRIGA*)(Training, Research, Isotope j Production, GA) Reactor Facility Decommissioning (TRFD) Project. The QAPD invokes the GA Quality Assurance Manual (QAM) for use on this project, establishes the authority for quality assurance activities, and identifies project-specinc quality assurance requirements.

1.1.2 The mission of the TRFD Project is to decommissan the TRF, obtain a release to unrestricted use of the TRF and site by the U.S. Nuclear Regulatory Commission (NRC) and the State of California Department of Health Services (CAL-DHS), and to dispose of all nuclear and hazardous waste at approved federal and/or commercial disposal sites.

1.2 Scone of Work

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The scope of work covered by this QAPD is described in GA Document No. PC-000482, I l " General Atomics TRIGA Reactor Facility Decommissioning Plan." Work activities include decommissioning planning; dismantlement of the Mark I (NRC License No. R-38) and Mark F (NRC License No. R-67) TRIGA reactors; radiological surveys; packaging, certification, and disposal of waste; remediation of soil to acceptable levels; performance of final site radiological survey; and obtaining regulatory release of the site for unrestricted use. This project is funded entirely by GA.

1.3 Waste Disnosal 1.3.1 The main disposal site for low-level radioactive waste (LLW) will be at the U.S. Department of Energy (DOE) Nevada Test Site (NTS). This waste must comply with the requirements of DOE Document NTSWAC, " Nevada Test Site Waste Acceptance Criteria." This disposal will be coordinated with DOE-Oakland (formerly DOE-San Francisco) and DOE-Nevada (DOE-NV).

Waste Disposal at the NTS shall also be consistent with GA Document No. PC-000391," General Atomics Low-Level Waste Certification Program Plan (WCPP)" that covers all GA waste shipments to the NTS.

1.3.2 Shipment to NTS is restricted to those waste streams that are covered by DOE-approved NTS Waste Profiles prepared in accordance with NTSWAC, Section 2.1.1.1.

• 'TRIGA is a registered trademark of General Atomics i

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1.3.3 Spent fuel will be shipped to the Idaho National Engineering and Environmental Laboratory (INEEL), or to an alternate location designated by DOE. Status of the spent fuel is documented in G A Document PC-000488, " Fission Product and Decay Heat Calculations for Irradiated TRIGA Fuel Elements at General Atomics," and in PC-000482.

1.3.4 Radioactive mixed waste will generally be sent to the GA Nuclear Waste Processing Facility (NWPF) for storage, treatment and shipment to a final disposal site. NOTE: The term mixed waste refers to waste containing both radioactive and hazardous components as defined by the Atomic Energy Act and the Resource Conservation and Recovery Act (RCRA), respectively.

1.3.5 Other disposal sites such as Envirocare in the State of Utah will be approached and used for disposal of LLW and mixed waste when technically and economically acceptable.

1.3.6 Nonradioactive waste will be disposed of at a licensed hazardous waste depository or at a local landfill, as appropriate.

1.4 Annlication The requirements of this QAPD are mandatory for all organizations within GA where work is conducted for the TRFD Project. For work conducted at the NWPF, the requirements of this QAPD are supplemented by QAPD-9445," Quality Assurance Program Document - Nuclear Waste Processing Facility." For work subcontracted by GA to outside suppliers, applicable QA requirements shall be specified in the procurement documents.

2. ORGANIZATION 2.1 GA Organization 2.1.1 The current organization for the TRFD Project is shown in Figure 1. It complies with the requirements of the technical specifications for NRC Licenses No. R-38 and R-67 and of the NTSWAC for waste characterization and certification, and reflects QA organization and Waste Certification Official (WCO) independence.

2.1.2 The D&D Projects Manager, reporting to the Facilities Director, is also the TRFD Project Manager. On matters relating to reactor licensing he also reports to the Sr. Vice President of Advanced Technologies. He has overall responsibility for the TRFD Project, including decommissioning of reactors, shipment of spent fuel and waste, and assuring that personnel working in the TRF are properly trained.

2.1.3 The TRE Manager, reporting to the TRFD Project Manager, is also the Physicist in Charge and is responsible for operation and maintenance of the TRF, for managing decommissioning activities, for preparation of the Work Authorization and supporting procedures, and for assuring that all work

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i is in compliance with the NRC Licenses, the Work Authorization, the Decommissioning Plan, this QAPD, the QAM, PC-000391, and NTSWAC. He has direct access to the Sr. Vice President of Advanced Technologies for all areas concerning safety of the reactors and fuel, and for limiting i exposure of personnel and dispersal of radioactive material.

l 2.1.4 The Waste Management and Disposal Manager is also the NWPF Manager. He is responsible for preper inventory, characterization, and packaging of waste from the TRF, for procurement of sMpping containers, for procurement of waste transportation services, for processing waste at the NWPF, and for making arrangements for waste disposal at various disposal facilities.

2.1.5 The Director of Licensing, Safety, and Nuclear Compliance (LSNC) is responsible for I implementing the Company policies and regulatory requirements for radiological, nuclear, and l l

environmental safety, including compliance with RCRA. LSNC provides administration for GA l licenses and permits which cover the TRIGA reactors and the receipt, use, storage, and transport of l radioactive materials. The Director of LSNC is responsible far communications with the NRC and the State of California regarding all activities under these licenses.

2.1.6 The Health Physics Manager, reponing to the LSNC Director, is responsible for all Health Physics-related tasks, including radiological surveillance, radiological characterization, and q development of Health Physics procedures for the TRFD Project. i 2.1.7 The Criticality and Radiation Safety Committee (CRSC) Chairman, reponing to the Sr. Vice President of Advanced Technologies, is responsible for independent review of TRF activities to  ;

assure criticality and radiation safety.  ;

4 2.1.8 The Waste Observers are responsible for performing 100% in-process observations of all waste packaging activities and preparation of waste documentation for the TRFD Project. For waste  ;

packaged for shipment to the Nevada Test Site, the Waste Observers verify that only dry low-level radioactive waste is accepted and loaded into the waste containers in accordance with NTSWAC, Section 3.1. " General Waste Form Criteria."

2.1.9 The Director of Quality Assurance is responsible for rieveloping, directing, and implementing an effective company-wide Quality Assurance Program. The QA Director is at the same or a higher organizational level as the managers directly responsible for performing activities affecting quality.

He has knowledge and experience in the areas of Quality Assurance and management, and he is independent of undue cost and schedule influences. The QA Director has direct access to the Chairman of GA for all areas concerning the implementation of the QA Program.

A V 2.1.10 The Manager of Environmental Quality Assurance, reporting to the Director of Quality Assurance, is also the Project Quality Engineer (PQE). He works directly with the Project Manager and is responsible for implementing and managing the QA Program described in this QAPD.

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Doc. No. QAPD-9009-2 Issue: A Page 8 2.1.11 The Manager of Quality Systems, reporting to the Director of Quality Assurance, is responsible for company-wide audits, calibration, and QA document control.

2.1.12 The Waste Ceni5 cation Official (WCO), reponing to the Manager of Environmental Quality Assurance is also the alternate PQE. He is independent of those who have direct responsibility for performing waste generation activities, and has direct reporting access to the TRFD Project Manager (see Figure 1). He is responsible for verifying implementation of the WCPP and of this QAPD and  ;

for cenifying that all waste packages and documentation shipped to Nevada Test Site from the TRF and from the NWPF comply with the NTSWAC. The WCO is also responsible for ensuring the performance ofintemal audits, inspections and surveillances pertaining to waste certification, and for ensuring timely identification of deficiencies and effective corrective action.

2.1.13 The Alternate Waste Certification Official has the same reporting lines as the WCO and is responsible for performing the duties of the WCO when the WCO is not available.

2.1.14 Support work, such as Configuration Management, Records Management, and Purchasing, is provided through various support organizations, as required.

2.2 Authority of OA Personnel 2.2.1 Quality Assurance personnel have sufficient authority, access to work areas, and organizational freedom to: (1) identify quality problems; (2) initiate, recommend, or provide solutions to quality problems through designated channels; (3) verify implementation of solutions; j and (4) assure that further processing, delivery, installation, or use is controlled until proper j disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.

2.2.2 Authority to stop work is assigned to the Director of QA and is delegated down through all )

levels of the QA organization. This authority includes the right to stop or control unsatisfactory ]

work or further processing of unsatisfactory material.

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2.2.3 Verification activities performed by personnel who are not part of the formal Quality f Assurance organization (that is, they are pan of another organization) are subject to direction and/or I overview by the Quality Assurance organization.

3. QUALITY ASSURANCE PROGRAM 3.1 Reauirements i

3.1.1 QA requirements for research reactors operation and decommissioning are given in ANS Standard 15.8," Quality Assurance Program Requirements for Research Reactors." NRC Regulatory guide 2.5, with the same title as ANS 15.8, endorses ANS 15.8.

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( GENERAL ATOMICS

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TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT Doc. No. QAPD 9009-2 Issue: A Page 9 3.1.2 The NTSWAC (to fulfill the requirements of DOE Order 5820.2A, " Radioactive Waste Management"; and of 10CFR830.120 " Quality Assurance Requirements"), requires a Quality Assurance Program that complies with the applicable requirements of ASME NQA-1, " Quality Assurance Program Requirements for Nuclear Facilities."

3.1.3 The Code of Federal Regulations, Title 10, Part 71 (10CFR71), " Packaging and Transportation of Radioactive Materials," requires compliance with 10CFR71 Subpart H. " Quality Assurance." NRC Regulatory Guide 7.10 " Establishing Quality Assurance Programs for Packaging l

Used in the Transport of Radioactive Material," provides NRC integretation for compliance with 10CFR71, Subpart H.

3.1.4 Appendix F of 10CFR20," Requirements for low-level Waste Transfer for Disposal at Land l Disposal Facilities and Manifests," requires any generating licensee who transfers radioactive waste i

! to a land disposal facility to have a QA Program that assures compliance with 10CFR61.55, " Waste j Classincation," and 10CFR61.56," Waste Characteristics." '

lO 3.1.5 NUREG CR-5849, " Manual of Conducting Radiological Surveys in Support of License Termination," provides quality assurance guidance for decommissioning activities, with emphasis  !

on radiological considerations. I 3.2 Imnlementation 3.2.1 The GA company-wide QA Program is described in the GA Quality Assurance Manual (QAM) The QAM defines procedures for implementing the applicable requirements of ASME NQA-1,1989 edition, through the NQA-le-1992 addenda and all supplements, of ANS 15.8, and of 10CFR71 Subpart H.

3.2.2 The GA QA Program as it applies to radioactive material packages, was reviewed and approved by the NRC Transportation and Storage Inspection Section, Spent Fuel Project OfGce, Nuclear Material Safety and Safeguards, Approval No. 0030, Revision 6, dated July 9,1996, expiration date June 30,2001.

3.2.3 The QA Program implemented specifically for the TRFD is described in this QAPD and in

, PC-000391," General Atomics Low-Level Waste Certification Plan." This QAPD satisfies the requirements of Section 3.1 above.

3.2.4 Applicable quality assurance requirements are integrated into the implementing procedures listed in Sections 3.2.5 through 3.2.9 below, i[

3.2.5 Detailed instructions for Reactor Operations are given in the Operations Procedures (ops) for the TRF.

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Doc. No. QA.PD-9009-2 Issue: A Page 10 3.2.6 Detailed instructions for Decommissioning activities are described in Decontamination and Decommissioning (D&D) Procedures and in Nuclear Waste Processing Facility (NWPF) Procedures.

D&D Procedures include applicable procedures previously prepared for other GA D&D projects (e.g., FMPs, HCDs, FQCIs), as well as new procedures prepared specifically for the TRFD Project.

3.2.7 Detailed instructions for the Quality Assurance organization are described in Quality Division Instructions (QDIs).

3.2.8 Detailed instructions for Health Physics activities are described in GA Health Physics (HP) procedures.

3.2.9 Detailed instructions for engineering activities are provided in the Program / Resource Procedures Manual (PRPM).

3.2.10 Procedures, instructions, and other documents used to implement the quality assurance requirements for the TRFD Project are listed in Table 1, Quality Assurance Program Index (QAPI),

as they apply to each of the 18 Requirements of NQA-1 and the 19 Requirements of ANS 15.8. The order of precedence of GA quality assurance documents for this project are this QAPD, PC-GCO391, the QAM, and the procedures listed in 3.2.5 through 3.2.9 above.

33 Graded OA Progra:D 3.3.1 Consistent with the QA Manual and NRC Regulatory Guide 7.10 Appendix A, the QA Program is applied to the various project activities in a graded approach; i.e., the quality assurance effort extended on an activity is commensurate with its imponance to safety and its impact on project goals, compliana with regulations, licenses and the NTSWAC, and financial risk to General Atomics.

3.3.2 Items and activities important to nuclear safety are designated Quality Assurance Level I (QAL-1 items) and are subdivided into three categories: QAL i A,1B, and 1C, for critical, major and minor impact on public health and safety, respectively.

3.3.3 For QAL IA items, the QAM requirements that are specified for QAL I, II, and III shall be applied. For QAL IB items, the QAM requirements that are speciGed for QAL 1, II, and QAL III shall be applied, except that procurement of materials and services may be from a quali0ed supplier who is not on the QA Approved Suppliers List, but whose QA Program was veriGed by the Project QE to be commensurate with the items or services ordered. For QAL IC items, the QAM requirements that are specified for QAL III shall be applied, except that procurement of materials and services may require a qualified supplier on the QA Approved Suppliers List. ,

3.3.4 Items and activities with major impact on industrial and chemical safety of public and project personnel, compliance with non-nuclear requirements of NTSWAC, project cost and schedule, and

GENERAL ATOMICS

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TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT Doc. No. QAPD 9009-2 Issue: A Page 11 special environmental matters are designated QAL II. For QAL IIitems, the QAM requirements that are specified for QAL II and QAL III shall be applied.

3.3.5 QAL III items and activities are those with a non-critical application. For QAL III items, the QAM requirements that are specified for QAL III shall apply.

3.4 Personnel Training 3.4.1 The training program for the TRFD Project shall focus on safety, knowledge of applicable regulations and technical requirements. The program shall comply with the applicable training requirements specified by DOE-NV in NTSWAC; by the NRC in 10CFR19.12 (as described in more detail in the GA Radiological Contingency Plan) and 10CFR71.105(d); by the Occupational Safety and Health Administration (OSHA) in 29CFR1910.120(e) and 29CFR1910.1200(h); by the Environmental Protection Agency (EPA) in 40CFR265.16; by CAL-EPA in CCR22-66265.16; and by the Department of Transportation (DOT) in 49CFR172.704.

( 3.4.2 The Training Program for the TRFD project shall be implemented using procedure NWPF-AP-1.2, "NWPF Training Program" as a guideline. Special training requirements will be specified in individual procedures, as appropriate. Equipment operators shall be certified using r,rocedure NWPF-SOP-2.4 "Opemtor Training and Qualification Program Procedure," as a guidcis. Reactor operators shall be certified in accordance with NRC requirements.

3.4.3 TRFD Project personnel shall be indoctrinated in the following basic subjects: radiation safety; task responsibilities and authority; general and specific procedures that apply to assigned l

work tasks; EPA OSHA ~and state regulations related to hazardous waste activities; and quality assurance program elements as defined by this QAPD. For personnel involved in packaging and shipping waste to the NTS, this indoctrination shall be supplemented by training in the " General Atomics lww-level Waste Certification Program Plan," Document No. PC-000391, and in the NTS Waste Profiles. Personnel associated with the NTSWAC waste management and certification program, shall be trained to the applicable requirements of NTSWAC on an annual basis.

l 3.4.4 Training at the NWPF shall be in accordance with QAPD-9445.

4. DESIGN CONTROL 4.1 The requirements of QAM QP-3, as modified by Section 3.3 of this QAPD, will apply to major hardware or process design activities (if any), associated with the TRFD project.

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D 4.2 . Calculations supporting nuclear shipments and any incidental hardware design shall be in accordance with EP-4000 series procedures of the PRPM. At the discretion of the Project Manager, calculations supporting nuclear shipments may also be prepared, reviewed, and approved in

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Doc. No. QAPD-9009-2 Issue: A Page I2 accordance with Procedure FMP-1832," Radioactive Waste Shipments to the NTS," or an equivalent procedure, and filed with the shipping papers for the corresponding waste package.

4.3 Computer programs shall be controlled as stated in Section 12.5.

4.4 Existing TRF drawings are being used for reference only.

5. PROCUREMENT DOCUMENT CONTROL 5.1 The procurement of items and services important tc waste certification, shall be in accordance with QAM QP-4, as modified by Section 3.3 of thi' QAPD.

5.2 All Procurement Requisitions for items and services (and Service Requests for in-house procured items and services) shall be reviewed and approved, prior to issue, by the PQE or his designee.

5.3 Procurement documents for waste shipping containers shall include applicable DOT and disposal site requirements.

6. INSTRUCTIONS, PROCEDURES, AND DRAWINGS 6.1 The requirements of QAM QP-5 shall apply. Work instructions and procedures shall clearly prescribe how to perform specific tasks and shall be reviewed and approved prior to use.

6.2 Work involving radioactive material shall be performed in accordance with a valid Work Authorization (WA) or Radiological Work Permit (RWP).

6.3 WAs shall be reviewed and approved by LSNC in accordance with 11ealth Physics procedure lip-172, " Preparation and Issuance of a Work Authorization." RWPs shall be reviewed and approved by Health Physics.

6.4 The Manager of Nuclear Safety shall review all procedures involving potential nuclear criticality concerns. If required, the Criticality and Radiation Safety Committee (CRSC) shall also review the procedures.

6.5 Work involving hazardous operations, chemicals, and gases, or enough kinetic and/or potential energy that, if inadvertently released, may cause irreversible injury or illness to persons involved, shall be performed in accordance with a liazardous Work Authorization (HWA).

6.6 HWAs shall be reviewed and approved by the TRF Manager, the liuman Resources Safety Manager, and GA's LSNC department, as required by the GA's Accident Prevention Program Manual's "Special Permit Program."

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7. DOCUMENT CONTROL 7.1 The preparation, issue, and change of GA documents shall be in accordance with the existing GA document control procedures, and QP-6 of the QAM. Control of Operations Procedures shall be in accordance with the Technical Specifications.

7.2 Control of D&D Procedures shall be as follows: 1 1

7.2 1 1New pieedures shall be reviewed by the TRFD Project Manager, the TRF Manager, the l Health Physics Manager, and QA. Procedures shall be approved by the TRF Manager, QA, and the I Project Manager. The procedures shall be released by signature of the Project Manager and then processed to become part of the Work Authorization.

7.2.2 Existing procedures shall be evaluated by the TRF Manager for applicability and, if 1 applicable as is, may be processed to become part of the Work Authorization without the  !

review / approval required by Section 7.2.1.

V 7.2.3 A copy of the released procedures shall be filed with the QA Records Center (QARC).

Review records are not required. An index of procedures shall be maintained by the TRF Manager.

7.2.4 Revisions to D&D Procedures shall be reviewed, approved, and processed per Section 7.2.1.

7.2.5 Field changes for minor revisions, as determined by the TRF Manager, shall be marked-up on the Work Authorization copy of the procedure and initialed / dated by the TRF Manager, Health Physics and QA. If the procedure will be used again, it shall be revised to incorporate the field changes within 30 calendar days of field change approval; otherwise, a copy of the marked-up procedure shall be filed with the QARC.

7.3 NWPF procedures shall be controlled in accordance with procedure NWPF AP-1.1,"NWPF System of Controlling Documents."

7.4 Project control documents and design documents shall be controlled in accordance with the PRPM. All project control documents and design documents shall be approved by the author, Quality Assurance, the TRF Manager, and the TRFD Project Manager. Additional approvals shall be at the discretion of the TRFD Project Manager.

8. CONTROL OF PURCHASED ITEMS AND SERVICES 8.1 Purchased items shall be inspected and/or tested, if appropriate, prior to use to assure conformance with specified Purchase Order requirements,in accordance with QP-7 of the QAM.

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L Doc. No. QAPD-9009-2 Issue: A Page 14 8.2 Analyticallaboratories shall not be used for performing EPA-required analyses unless they are state-certified, have been evaluated by QA, and placed on the QA Approved Suppliers List (ASL).

9. IDENTIFICATION AND CONTROL OFITEMS 9.1 Items shall be identined and controlled as required by QAM QP-8, the controlling procedure and/or the Purchase Order.

9.2 Identification shall be maintained either on the item or in documents traceable to the item, or in a manner which assures that identiDeation is established and maintained.

9.3 The requirements of QAM OP-8 shall also apply to samples and radiological swipes taken for characterization purposes. For RCRA analyses, sample custody shall be documented in accordance with procedure NWPF-WI-3.34," Chain of Custody."

9.4 Procedures used for processing, packaging, and shipping radioactive waste shall have sufficient requirements to assure that for each specific package shipped to the disposal site, traceability and consistency are maintained between package contents and waste certiDeation, waste -

profile, sampling and analysis results, characterization, supporting calculations, receipt inspection of the shipping container, and shipping documentation, from the point of waste generation through shipment.

10. CONTROL OF PROCESSES 10.1 The requirements of QAM QP-9 that are applicable to the TRFD Project shall be implemented.

10.2 Procedures shall be prepared and approved for processing, neutralizing and solidifying waste and for other activities important to waste certiGeation, as required. The procedures shall provide the specinc information required to set up and perform the special process activities.

10.3 Process flow diagrams for current waste streams for the NTS are depicted in GA Document No. PC-000391," General Atomics Low-level Waste Certincation Program Plan." These diagrams also show hold points for required inspections.

11. INSPECTION, OBSERVATION, CHARACTERIZATION, AND RADIOLOGICAL SURVEYS 11.1 The requirements of QAM QP-10 shall apply. TRFD project activities that have acceptance criteria shall be inspected, observed, sampled, analyzed, charauerized, and surveyed, as appropriate, to verify conformance to requirements. Results of these activities shall be documented. Table 2

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Doc.No. QAPD 9009 2 Issue: A Page 15 l

shows inspection, observation, characterization, and radiological survey responsibility and procedures that support waste certification.

I 11.2 Personnel selected for performing inspection, observation, sampling, analysis, characterization, and radiological surveys shall have experience or training commensurate with the scope, complexity, or special nature of the activity. Inspectors shall be certified in accordance with l QDI 2-6, " Inspector Certification."

11.3 Personnel performing inspections shall be independent from the individual or group performing or directly supervising the activity being inspected.

I 11.4 A QA Inspector shall perform receiving inspection of all waste containers to be used for l waste shipments to verify that waste containers comply with requirements of the procurement i documents.

j 11.5 A QA Inspector shall inspect for damage all containers in which waste is shipped, including visible cracks, holes, significant corrosion, or other damage that could compromise integrity, prior j to use, and after packages have been loaded for shipment. He shall verify that each closure device i I

of the packaging, including any required gasket, is properly installed, secured, and free of defects.

He shall also review waste container cenifications to verify that all waste containers comply with DOT requirements and waste container criteria of the disposal site.

I 1.6 Waste Observers shall perform 100% in-process visual observation of all waste container ,

loading activities to verify that waste (a) is packaged in accordance with the applicable procedure, l (b) complies with the NTS acceptance criteria for proper waste form, and (c) excludes dangero is I waste as defined by EPA, State of California and the State of Nevada. i

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11.7 All waste shipped to NTS shall be characterized physically, chemically, and radiologically, and shall meet NTSWAC requirements. The characterization shall be documented and shall be traceable to the Waste Profile and to each shipping / disposal package. When similar requirements are listed in separate regulations (i.e., EPA and California EPA), the most stringent shall be met.

I 1.8 Waste characterization may be conducted using process knowledge (PK), sampling and  !

analysis, or a combination of both, in accordance with PC-000487, " Procedure for Waste Characterization."

! 1.9 The WCO or his designee shall verify that applicable disposal site acceptance criteria and lq DOT regulatory requirements are satisfied during waste cenification activities.

U l 11.10 The WCO or his designee shall verify prior to shipment to the disposal site that all applicable requirements have been satisfied.

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12. TEST CONTROL 12.1 Testing shall be performed in accordance with approved procedures.

12.2 For tests conducted by outside suppliers, applicable test procedures shall be speciGed in procurement documents.

12.3 Tests shall be conducted by appropriately trained and qualified personnel.

12.4 Development test activities shall be planned and controlled. Prior to starting any major development activity, a Test Plan, Test Specification / Procedure or a Procedure shall be prepared and released in accordance with the PRPM, or Procedure NWPF-AP-1.1, as appropriate. Development test activities may be performed to standard GA laboratory practices with the development data recorded in GA laboratory notebooks. Control of GA laboratory notebooks to the " general guidelines" provided in procedure CP-203 is required.

12.5 Computer prograns used in the waste certi6 cation process shall be tested and verified in accordance with NQA-1 Requirement llS-2. The test requirements for each program shall be documented in a Test Plan (TPL). The verification results shall be documented in a Test Data Report (TDR). The TPL and TDR shall address the applicable requirements of NQA-1, Supplement 1 IS-2. Sections 3 and 5, respectively and shall be released in accordance with procedure EP-4060 of the PRPM (R&D Release). Note: Spread sheets are considered to be hand calculations and not computer programs.

13. CONTROL OF MEASURING AND TEST EQUIPMENT 13.1 Gages, instruments, meast -ing, recording, and testing devices, and special tooling used for inspection and acceptance shall be calibrated and controlled in accordance with QP-12 of the QAM.

13.2 When test and measuring equipment (i.e., health physics survey instruments) are found to be out-of-tolerance by the GA Calibration Lab or outside canSration suppliers, the PQE shall be notined immediately. The PQE is responsible for assuring that an evaluation is performed using a GA Nonconformance Report to control and document the reinspection or resurvey of items that were inspected or surveyed with the speci0c out-of-tolerance test and measuring equipment.

14. HANDLING, STORAGE, AND SHIPPING 14.1 Low-level radioactive waste sFall be processed and packaged for disposal in accordance with applicable procedures, loading pi ... and checklists. Packaging shall be in accordance with procedures FMP-1828, "Packafag Solid Waste," FMP-1829, " Packaging Liquid Waste." and NWPF-Wl-3.3, " Radioactive W.tste Packaging," as appropriate. Shipping to NTS Ldl be in accordance with procedure FMS1832," Radioactive Waste Shipments to the NTS." If a need arises

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l to ship to NTS bulk LLW such as large Surface Contaminated Objects not suitable for conventional  !

packaging, then such waste, under certain conditions may be shipped unpackaged, provided the  !

cxternal contamination is fixed, covered, or contained sufficiently to meet DOT, NRC, and NTSWAC requirements.

14.2 Mixed waste shall be labeled and controlled in designated mixed waste accumulation areas, and then transferred to the NWPF. Mixed waste shall not be sent to the NTS.

14.3 The WCO or the Alternate WCO shall sign the certification statement for each waste container to be shipped to NTS.

14.4 Checklists shall be used by waste shipping personnel to ensure that each shipment oflow-level radioactive and mixed waste has been accomplished in accordance with the applicable procedure. Checklists shall identify required activities and the organization (s) responsible for each activity, and include a location for sign-off for each activity by the responsible organization (s).

Before a waste shipment can leave the GA site, checklists shall be reviewed for completeness and

, signed off by the WCO, or the Alternate WCO.

l 14.5 The WCO or the Altemate WCO is responsible for assuring that all waste containers shipped to NTS are properly marked and labeled in accordance with DOT regulations and the requirements of NTSWAC.

l 14.6 Waste shipments to the NWPF shall comply with procedures NWPF-WI-3.1 " Radioactive Material Transfer Request (RMTR)" and NWPF-WI-3.3, " Radioactive Waste Packaging," as a minimum.

• 1 14.7 Nuclear Material Accountability shall be notified before making any snipments with nuclear materials.  ;

15. INSPECTION, TEST, AND OPERATING STATUS The requirements of QAM QP-14 shall apply with the following exceptions: Green " Accept" tags are not required on QA-accepted drums and boxes that are in storage, provided the drum / box is uniquely identified with a Production Control (PC) number and/or a serial number and is on the list of accepted drums / boxes provided by QA.

16. CONTROL OF NONCONFORMING ITEMS

,9 yf 16.1 The requirements of QAM QP-15 shall apply, with the following clarifications.

j 16.2 Nonconforming items, including empty waste containers that do not comply with purchase order requirements or exhibit damage, weld defects, or other quality problems shall be documented i

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GENERAL ATOMICS

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TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT . .

Doc. No. QAPD-9009-2 Issue: A Page 18 on a Nonconformance Report (NR). NRs shall also be used for loaded waste packages that are rejected prior to shipment.

16.3 The Material Review Board (MRB) shall consist of the PQE or alternate PQE who shall act as the Chairman of the MRB and the TRF Manager, as a minimum.

16.4 Health Physics and/or the cognizant Engineer shall approve the location of all nonconforming items prior to segregation to preclude inadvertent exposure, cross contamination and RCRA noncompliance. Segregated materials which are contaminated shall be effectively isolated.

17. CORRECTIVE ACTION 17.1 Significant quality problems shall be promptly identified, documented, and corrected in accordance with QP-16. Corrective Action Requests (CARS) shall be prepared, processed, and closed-out in accordance with QDI 16-5," Corrective Action Request Preparatic."

17.2 The following conditions shall be considered to be significant quality problems: Lilure of responsible organizations to establish and implement the Waste Certification Program and procedures; deficiencies in requirements, plans, or procedures which remain uncorrected after formal reviews (i.e., audits and assessments); continuing or repetitive procedural deviation, nonconformance, or noncompliance, and the failure of responsible organizations to provide proper direction, overview, and correction; any deficiency detected after formal review, verification, and acceptance that could have an adverse effect on safety; and failure of responsible organizations to take prompt and effective action to identify and correct deficiencies.

17.3 Affected organizations and subcontractors shall be notified of the need for response as to cause, corrective action taken, and action to prevent recurrence.

17.4 Action taken shall be followed-up by the PQE or designee to assess its effectiveness. The follow-up shall be documented and reponed to appropriate levels of management in accordance with QP-16 of the QA Manual.

17.5 Quality information, such as audit reports, assessment reports, surveillance reports, nonconformance reports, corrective action requests, and other deficiency documents, shall be analyzed at least annually by the PQE, or designee, to identify quality trends. Quality trends shall be evaluated and significant adverse quality trends shall be reported to the responsible organization for corrective action. Trend reports shall be distributed to upper management per QP-16.

18. QUALITY ASSURANCE RECORDS 18.1 Records listed in Table 3 shall be collected, stored, maintained, and indexed in accordance with QP-17 of the QAM.

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18.2 All records listed in Table 3 shall be maintained for at least five years after the completion j of the project, or after shipment of waste from GA, whichever is later.

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18.3 Waste shipment folders shall contain sufficient information, traceable to each shipment and  !

shipping container, to identify the waste stream, sampling and analysis results, package contents, i supporting calculations, receipt inspection of the shipping container, and shipping documentation.

18.4 Procedures shall specify records that need to be generated for the work covered by the procedure.

19. QUALITY ASSURANCE AUDITS AND SURVEILLANCES 19.1 QA shall audit TRFD project activities at least once per year in accordance with QP-18 of ,

the QAM to evaluate effective implementation of the Quality Assurance Program and to assess i performance of the Waste Certification Program. ]

CT 19.2 QA surveillances shall be conducted periodically in accordance with QDI 10-2," Surveillance l V Performance and Repor:ing" to verify compliance with procedures and other governing documents.  !

Surveillance repons shall be distributed to the WCO, the TRF Manager, the TRFD Project Manager, and the Manager of Environmental Quality Assurance.

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O Fig.1 GA Organization for the TRFD Project

GENERAL ATOMICS

Title:

TRIGA REACTOR FACILITY DECOMMISSIONING - QUALITY ASSURANCE PROGRAM DOCUMENT Doc.No. QAPD 9009 2 Issue: A Page 21 TABLE 1 QUALITY ASSURANCE PROGRAM INDEX This Quality Assurance Program Index (QAPI) sets forth the procedures, instructions, and other documents which will be used to implement the Quality Assurance Program for the TRFD Project.

Definition: AP: Administrative Procedure CP: Company Policy Manual Procedure D&D Decontamination and Decommissioning (Procedure)

FMP: Fuel Manufacturing Procedure FQCI: Fuel Quality Control Instructions NWPF: Nuclear Waste Processing Facility (Procedure) ops: Operations Procedures PRPM: Program / Resource Procedures Manual QAM: Quality Assurance Manual QP: Quality Procedure in QAM QAPD: Quality Assurance Program Document QDI: Quality Division Instructions y SOP: Standard Operating Procedure NQA-1 ANS 15.8 QAPD Section Section NQA-1 Regt. Section GA Document I. 2.1 Organization 2 QAM-QP-1

2. 2.2 Quality Assurance Program 3 QAM-QP-2 2 S4. 2.2 Indoctrination and Training 3.5 QAM-QP-2/QDI 2-6,2-9/NWPF-AP-1.2, SOP-2.4

3. 2.3 Design Control 4 QAM-QP-3/PRPM

4. 2.4 Procurement Document Control 5 QAM-QP-4/QD14-1,4-2

5. 2.5 Instructions, Procedures, and 6 QAM-QP-5/QDI 5-1/NWPF.

Drawings SOP-2.2/ ops

6. 2.6 Document Control 7 QAM-QP-6/PRPM/QDI 6-1/ NWPF-AP-1.1/ CP-203/D&Ds

7. 2.7 Control of Purchased Items and 8 QAM-QP-7/QDI 7-2,7-5 Services

8. 2.8 Identification and Control of items 9 QAM-QP-8/QDI 8-2/FMPs/

l FQCIs/NWPFs/D&Ds l

l 9. 2.9 Control of Processes 10 QAM-QP-9/NWPFs V 10. 2.10 Inspection 11 QAM QP-10/QDI 2-6,10-1/FQCis I i 1. 2.11 Test Control 12 QAM-QP-11/PRPM l

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Doc. No. QAPD-9009 2 Issue: A Page 22 h TABLE 1 (Cont'd)

NQA-1 ANS 15.8 QAPD Section Section NQA-1 Regt. Section GA Document

12. 2.12 Control of Measuring and Test 13 QAM-QP-12/QDI 12-8,12-11 Equipment

13. 2.13 Handling, Storage, and Shipping 14 QAM QP-13/NWPFs/

FMPs/FQCIs/D&Ds

14. 2.14 Inspection Test, and Operating 15 QAM-QP-14/QDI 14 2/FQCis/FMPs Status

15. 2.15 Control of Nonconforming items 16 QAM-QP-15/QDI 15-1

16. 2.16 Corrective Action 17 QAM-QP-16/QDI 16-5 ,

17. 2.17 Quality Assurance Records 18 QAM-QP-17/QDI 17-3/NWPFs/FMPs/FQCis/D&Ds

18. 2.18 Audits /Surveillances 19 QAM-QP-18/QDI 10-2,18-2,18-3 2.19 Experimental Equipment NA NA )

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TABLE 2

SUMMARY

OF INSPECTION, OBSERVATION, CHARACTERIZATION, AND SURVEY RESPONSIBILITIES TO SUPPORT WASTE CERTIFICATION Title Responsibilities Controlling Documents  !

QA Inspector +

Inspection of empty waste containers, sealing surface / gasket +

QDI 10-1 l and loaded waste packages. + NWPF Procedures l

+

D&D Procedures I

+

Inspection of waste package shipping preparation, loading, + FMP-1828,1829, l and transport. 1832 Waste Observer +

Visual observation c,f waste container loading activities to + NWPF Procedures verify that waste contents are in strict compliance with the + D&D Procedures applicable procedure and contain no dangerous wastes. + FMP-1828,1829, i 1832  ;

+

l Preparation of waste documentation for each waste package  !

l per the applicable waste packaging procedure.

J l(A'j Technician Engineer, or

+ Radiological and hazardous characterization of waste + PC-00(M87 l

+ Sampling and analysis of waste + NWPF Procedures l Scientist + Process knowledge documentation + D&D Procedures Health Physics +

Radiological survey to support characterization, packaging +

NWPF Procedures  ;

Technician and transport of waste packages.

• Health Physics l

Radiological survey of transport vehicle prior to shipment. Procedures l a D&D Procedures

+ FMP-1828,1829, I832 l

Quahty Engineer

• Scheduled and unschedulec! assessments /surveillances of

• NWPF Procedures or Waste above listed responsibilities to verify compliance with

• D&D Procedures Certification applicable controlling docuinents. +

QDI 10-2 Official (or Alternate)

! Waste +

Review of waste shipment folder prior to approving each + NWPF Procedures Certification waste shipment.

• D&D Procedures

+

Official (or Final approval of all waste shipments. Signs Waste + FMP-1832 i

Alternate) Certification papers.

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Doc. No. QAPD-9009-2 Issue: A Page 24 TABIE3 QUALITY ASSURANCE RECORDS RETENTION RESPONSIBILITIES Transmittal To Record Storage Storage Record Type Form Responsibility Responsibility

1. Quality Assurance Program Document Microfilm QARC Quality Systems

2. Quality Assurance Manual Microfilm QARC Quality Systems

3. Project Control and Design Documents as Microfilm Corporate Corporate defined in PRPM Records Configuration Management Management

4. Inspection Records Microfilm QARC Quality Engineer

5. Surveillance Plans and Reports Microfilm QARC Quality Engineer

6. Nonconformance Reports and Supplier's Microfilm QARC Quality Engineer Disposition Requests

7. Personnel Training and Indoctrination Records Microfilm QARC Quality Systems (Note 1)

8. QA Audit Reports Microfilm QARC Quality Systems

9. Corrective Action Requests Microfilm QARC Quality Systems

10. Personnel Qualification Records (Note 1) Microfilm QARC Quality Systems

11. Evaluations of Suppliers Microfilm QARC Quality Systems

12. Waste Shipment Folders Microfilm QARC WCO

13. NWPF Procedures Microfilm QARC D&D Records Mgmt.

Coordinator

14. D&D Procedures Microfilm QARC Quality Engineer Notes:

1. Except for Health Physics records which shall be stored by Health Physics in accordance with Health Physics procedures.

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