ML20209D539

Rev 29 to Yaec Decommissioning QA Program

ML20209D539
Person / Time
Site:	Yankee Rowe
Issue date:	06/22/1999
From:	Bourassa J, Peterson W, Reid D YANKEE ATOMIC ELECTRIC CO.
To:
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ML20209D493	List: ML20209D488 ML20209D539
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NUDOCS 9907130159
Download: ML20209D539 (58)

Text

l YANKEE ATOMIC ELECTRIC COMPANY l DECOMMISSIONING QUALITY ASSURANCE PROGRAM YDQAP 1

PREPARED BY: b .ehs 3 e twwe< '

JeephT. Bourassa l

Manager, Decommissioning QA REVIEWED BY: N M1Ah M Walter K. Peterson Oversight Manager

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Donald A. Reid Decom ning Mana APPROVED BY; h Don K. D'3'vis President and Chief Executive Officer DR W

Title:

YDOAP Page: 1 Rev.: 29 Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY YDQAP TABLE OF CONTENTS /INDEX Section No. Title Revision AMENDMENT / REVISION 29 POLICY STATEMENT 29 I ORGANIZATION 29 i

ll QUALITY ASSURANCE PROGRAM 29 l til DESIGN CONTROL 29 IV PROCUREMENT DOCUMENT CONTROL 29 1

VI DOCUMENT CONTROL 29 Vil CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND 29 SERVICES i

Vill IDENTIFICATION AND CONTROL OF MATERIAL, PARTS, AND 29 COMPONENTS  ;

IX CONTROL OF SPECIAL PROCESSES 29 X INSPECTION 29 I

XI TEST CONTROL 29 l

XII CONTROL OF MEASURING AND TEST EQUIPMENT 29 Xill HANDLING, STORAGE, AND SHIPPING 29 l XIV- INSPECTION, TEST, AND OPERATING STATUS 29 XV NONCONFORMING MATERIALS, PARTS, AND COMPONENTS 29 XVI C0RRECTIVE ACTION 29

Title:

YDOAP Page: 11 Rev.: 29 Date: June 22,1999

F l-l YANKEE ATOMIC ELECTRIC COMPANY YDQAP

! TABLE OF CONTENTS /INDEX l (Continued)

Section No. Title Revision l

XVil QUAtlTY ASSURANCE RECORDS 29 XVill ' AUDITS 29 APPENDIX A -QUALIFICATION REQUIREMENTS 29 APPENDIX B DECOMMISSIONING QUALITY ASSURANCE PROGRAM 29 EXCEPTIONS APPENDlX C YR SYSTEMS, STRUCTURES AND COMPONENTS a 29 CLASSIFICATION

Title:

YDOAP Page: lll Rev.: 29 Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY YDQAP AMENDMENT / REVISION SHEET Revision No. Date Reason 0 12/10/76 To address questions submitted by letter from NRC (K. R.

(Amendment 1) Goller) to L. H. Heider (11/1/76).

0 1/13/77 To address questions submitted by letter from NRC (K. R.

(Amendment 2) Goller) to L. H. Heider (12/28/76).

1 9/15/77 To address organizational, programmatic, and editorial changes.

2 11/01/77 To address organizational changes.

3 11/25/77 To address organizational changes at Vermont Yankee.

4 1/13/78 To address combined inspection numbers 50-29/77-20; 50-271/77-15; and 50-309/77-16 unresolved item 4.a.

5 1/30/78 To address change in exception for ANSI N45.2.3-1973.

6 10/19/78 To address exceptions to ANSI N45.2.2-1972.

6 3/29/79 To resolve items submitted by letter from NRC (W. P. Haass) to (Amendment 1) L, H. Heider (3/6/79).

7 9/11/79 Tu address changes to Yankee Rowe (Appendix D) and Vermont Yankee (Appendix E) Safety Classifications.

8 4/04/80 To address organizational changes.

9 3/09/81 To address organizational changes.

10 4/03/81 To add " Packaging of Radioactive Materials" and " Fire Protection of Safety-Related Areas" to "Other items Requiring Quality Assurance".

11 3/01/82 To resolve items submitted by letter from NRC (W. P. Haass) to W. P. Johnson (6/10/81).

12 3/11/83 To address organizational changes.

13 To address organizational and programmatic changes.

14 10/12/83 To address organizational changes.

15 2/15/84 To address programmatic changes.

Title:

YDOAP Page: IV

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Rev.: 29 Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY YDQAP

- AMENDMENT / REVISION SHEET (Continued)

Revision No. Date Reason 16 10/31/85 To address organizational and programmatic changes.

17 12/05/86 . To address organizational and programmatic changes.

17A 8/14/87 To clarify surveillance activities and change VP-MOO responsibilities for the level of deficiencies requiring evaluation.

18 4/29/88 To address organizational and programmatic changes.

19 10/02/89 To address organizational and responsibility changes and deletion of Appendix C.

19A 6/01/90 To update organizational chart (for VY) to be consistent with Proposed Change No.157 and to address organizational changes at Vermont Yankee.

20 12/21/90 To update organizational changes at Yankee and change QAD's responsibility from reviewing design documents to auditing those documents for inclusion of quality requirements.

21 11/15/91 To update organizational changes at Yankee and Vermont Yankee and change QAD responsibility from revising recommendations to prevent recurrences of significant condition adverse to quality to providing the option to review and/or audit recommendations.

22 4/15/92 To delete Appendix D listing and reference Yankee Safety Classification of Systems Manual.

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~23 9/30/92 To address organizational and responsibility changes.

24 12/15/93 To address organizational changes, and DQA/NSARC reporting clarifications for Vermont Yankee.

25 12/15/94 To address organizational changes made at the Yankee Nuclear Power Station addressing the decommissioning organization. Clarifications in the revised corrective action process at Vermont Yankee, and to address an exception to Regulatory Guide 1.64, and to clarify responsibilities between the Yankee and Vermont Yankee Plants.

Title:

YDOAP Page: V

- Rev.: 29 Date: June 22,1999 I

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YANKEE ATOMIC ELECTRIC COMPAA YDQAP l

AMENDMENT / REVISION SHEET I

l (Continued)

Revision No. ' Date Reasgn 26 12/21/95 To address organizational changes at the Yankee Nuclear Power Station and the Vermont Yankee Nuclear Power Station.

To address exceptions to ANSI 18.7 and Regulatory Guide 1.33.

27 12/20/96 To address organizational changes.

28 5/30/97 To update organizational changes. Changed exception to Regulatory Guide 1.26 for VY only. (This was withdrawn in BYR 98-025. dated 4/14/98.)

28 10/16/98 Resubmit Rev. 28 to update organizational changes, delineate decommissioning organization and eliminate all references to Vermont Yankee Nuclear Power Corporation.

29 6/22/99 To update the Program to include 10CFR72 and to redefine responsibilities and requirements based on the current status of the plant.

Title:

YDQAP Page: VI Rev.: 29 Date: June 22,1999 l

YANKEE ATOMIC ELECTRIC COMPANY POLICY STATEMENT DECOMMISSIONING QUALITY ASSURANCE PROGRAM lt is the policy of those organizations operating under this Decommissioning Quality Assurance Program to strive for excellence in all aspects of nuclear power plant decommissioning and spent fuel storage. This goal can only be attained if each individual recognizes that Quality is everyone's

responsibility. Each worker, supervisor, and manager has a role to play in achieving the goal of "doing it right the first time." Only if we recognize that Quality is of paramount importance can we continue to provide for safe decommissioning and fuel storage.

This Decommissioning Quality Assurance Program applies to all activities associated with structures, systems, and components which are safety-related or important to safey controlled by 10CFR71 and 10CFR72. This program implements 10CFR50, Appendix B, and satisfies 10CFR71, Subpart H; and 10CFR72, Subpart G. Certain additional administrative requirements are applied to other items and activities that are important as defined in aaministrative procedures. DQAP applicable structures, systems, and components are defined in Appendix C.

I The function of the Quality Oversight Program is to assess and communicate to management the adequacy, content, and appropriateness of the work being performed and to facilitate continuous enhancements. However, supervision and management does not rely solely upon the efforts of the Quality Assurance Groups for quality oversight; they also take an active role in self-assc:ssment of those activities under their control to identify problems. As previously noted, the ultimate responsibility for quality lies with each individual.

Under the program, The Yankee Atomic Electric Company President and Chief Executive Officer i.s the final management authority responsible for assuring that this policy statement and the Decommissioning Quality Assurance Program are implemented within the Yankee Atomic Electric

! Company.

The President and Chief Executive Officer has overall responsibility for assuring implementation of the program. The President has delegated to the Decommissioning Quality Assurance Manager under the cognizance of the Oversight Manager the responsibility for establishment, control, and distribution of the Decommissioning Quality Assurance Program and revisions thereto, and establishment of policies under which the Quality Assurance Department operates. The Quality Assurance staff shall have the I

authority and organizational freedom to meet the requirements of 10CFR50, Appendix B, which satisfies 10CFR71, Subpart H; and 10CFR72, Subpart G.

l l The Decommissioning Manager shall be responsible for the day-to-day implementation of the l

program's procedural requirements.

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Title:

Policy Statement l

Page: 1 of 2 Rev,:

29 Date: June 22,1999

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YANKEE ATOMIC ELECTRIC COMPANY An independent Review and Audit Committee shall review the adequacy and effectiveness of this program as defined in the Defueled Technical Specifications. Any recommendations for corrections,

enhancements, or concems shall be reported to the President and Chief Executive Officer.

l The safe and reliable decommissioning and spent fuel storage can only be achieved with the

,. cooperation and support of all personnel. Every individual is expected to perform his or her task with the skill, professionalism, and dedication necessary to ach' eve this goal, p

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Title:

. . Policy Statement Page: . 2 of 2 ~

. Rev.: - 29 Date: ' June 22,1999 :

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YANKEE ATOMIC ELECTRIC COMPANY I. ORGANIZATION A. SCOPE This section of the Decommissioning Quality Assurance Program describes the duties and responsibilities of the personnel involved in establishing and executing the Decommissioning Quality Assurance Program.

B. RESPONSIBILITY The responsibility for decommissioning and spent fuel storage at the Yankee Nuclear Pcwer Station rests with the Yankee Atomic Electric Company. The responsibility for j developing and implementing the Quality Assurance Program within the Yankee Site is l

vested in the President and Chief Executive Officer of the Yankee Atomic Elect!ic Company. He has delegated certain areas of authority for the development and implementation of certain phases of the Program as set forth in the following paragraphs

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of this section. , j l

Duke Engineering and Services (DE&S) has been retained by the Yankee Atomic Electric Company (YAEC) to provide certain OA management, engineering and related technical and administrative support services. All work performed by DE&S under the terms of the agreement, shall be performed in accordance with the applicable programs and procedures required per this manual, or the DE&S OA Program as approved by YAEC.

The Outsourced Quality Assurance Organization, reporting to the President and Chief Executive Officer for YAEC *.hrough the Oversight Manager nas the organizational responsibility for the continuing rcview and audit of the implementaiion of the Decommissioning Quality Assurance Program.

C. ORGANIZATIONAL RELATIONSHIPS The lines of authority of all personnel and functional positions involved in the implementation of the Decommissioning Quality Assurance Program are shown in Figure 1.

l D. QUALITY ASSURANCE PROGRAM RESPONSIBILITIES

1. Chairman, Chief Executive Officer and President The Chairman, Chief Executive Officer (CEO), and President reports to the YAEC Board of Directorsi. This individual has overall responsibi;ity for the j development and implementation of the DOAP, while ensuring an organization is

Title:

Section I, Organization Page: 1 of 4 i Rev.: 29' '

Date: June 22,1999 i

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YANKEE ATOMIC ELECTRIC COMPANY ensure the effective implementation of the program. The Chairman, CEO, and President has delegated the necessary authority and has assigned responsibility for implementation of the DQAP for the Yankee Nuclear Power Company to the l

Decommissioning Manager. The Decommissioning Quality Assurance Manager  !

under the cognizance of the Oversight Manager has assigned responsibility for the development of the DQAP and oversight of its implementation.

2. Decommissioning Manager The Decommissioning Manager acts as the Site Manager as defined in the Final Safety Analysis Report. The Decommissioning Manager has responsibility for I providing the overall implementation of the DQAP and in providing support services to the operating staff. The Decommissioning Manager is responsible for 4 the safe operation of facility systems, structures, and components and for providing support activities necessary for safe operation, maintenance, and decommissioning of the plant. The Decommissioning Manager is responsible for the administration of Engineering, Decommissioning Planning and I Implementation, Configuration Control, and the Management of Safety, Radiation Protection, Licensing, Training, Chemistry, Procurement, and Radioactive Waste.

The responsibility for plant operational activities is delegated to the Plant Superintendent.

,. Plant Superintendent t

The Plant Superintendent is responsible for the direction and administration of the i Operations, Maintenance, and Security of the plant.

4. Oversight Manager The Oversight Manager reports to the Chairman, CEO, and President and is responsible for overview of the outsourced DE&S Quality Assurance Orgar.ization. This individual is also responsible for providing oversight of the development, implementation, and maintenance of the DOAP and implementing procedures. The Oversight Manager provides for review and evaluation of l compiiance with state and federal regulatory requirements for nuclear power facilities. This individual onsures that the Quality Assurance Function has sufficient organizational freedom and authority to identify problems, to initiate, recommend or provide solutions and to verify implementation of solutions.

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Title:

Section I, Organization Page: 2 of 4 Rev.: 29 Date: June 22,1999

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YANKEE ATOMIC ELECTRIC COMPANY

5. Decommissioning Quality Assurance Manager The Decommissioning Quality Assv:ance Manager reports to the Oversight Manager and is responsible for diracting and administering the audit, surveillance and inspection activities performed by the outsourced Quality Assurance

- organization. This individual is responsible for the verification of compliance with the DQAP; Licensing Requirements; 10CFR50, Appendix B; 10CFR71, Subpart H; 10CFR72, Subpart G; and other regulatory requirements. The Decommissioning Quality Assurance Manager is also responsible for maintaining the DOAP current and has the authority to stop unsatisfactory work.

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6. Independent Review Committees Independent Review Committees are responsible for those activities defined in Section 6 of the Technical Specifications. Section 6 also defines the functional reporting requirements.

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Title:

Section I, Organization

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YANKEE ATOMIC ELECTRIC COMPANY IL QUALITY ASSURANCE PROGRAM A. SCOPE This section establishes the criteria to be applied to the structures, systems, and components. These structures, systems, and components are listed in Appendix C.

B. RESPONSIBILITIES 1

1. Compliance with the requirements of the Decommissioning Quality Assurance Program - based on the criteria of 10CFR50, Appendix B, which satisfies 10CFR71, Subpart H and 10CFR72, Subpart G shall be the responsibility of all personnelinvolved with quality activities. The performance of quality-related activities shall be accomplished with appropriate equipment under suitable environmental conditions.

Note: Each section of the Program incorporates the designation of specific j organizational responsibilities. l

2. Individuals having overall responsibility for the establishment / distribution control and implementation of the DQAP are delineated in Section i" Organization" of the Program.

3. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

C. IMPLEMENTATION Establishment of an effective Quality Assurance Program is assured through implementation of 10CFR50, Appendix B, which satisfies the requirements of 10CFR71, Subpart H; .0CFR72, Subpart G, as applied to those systems, structures, and components important to safety. Programs and/or procedures are developed to implement the DOAP. The following regulatory positions in the below listed Regulatory Guides and ANSI Standards are utilized to meet the applicable requirements.

Implementation of this Program is assured through Quality Assurance and the applicable procedures derived from Quality Assurance policies, goals and objectives. The Outsourced Quality Assurance Organization shall review Quality Assurance Program l

procedures to assure their derivation from the policies, goals and objectives established by the CEO and President.

! 1. 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants

Title:

Section 11, Quality Assurance Program Page: 1 of 4 Rev.: 29 l . Date: June 22,1999 i

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l YANKEE ATOMIC ELECTRIC COMPANY

2.

• ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.33, Revision 2)

3. ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (Endorsed by Regulatory Guide 1.38, Revision 2)

4.

• ANSI N45.2.6-1978, Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.58, Revision 1)

5.

• ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants (Endorsed by Regulatory Guide 1.88, Revision 2)

6.

• ANSI N45.2.10-1973, Quality Assurance Terms and Definitions

7. ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (Endorsed by Regulatory Guide 1.64, Revision 2)

8. ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Program for Nuclear Power Plants (Endorsed by Regulatory Guide 1.144, Revision 1)

9. ANSI N45.2.13-1976, Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants (Endorsed by Regulatory Guide 1.123, Revision 1)

10. ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Endorsed by Regulatory Guide 1.146, August 1980)

11. ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel (Endorsed by Regulatory Guide 1.8, Revision 1-R)

12.

• Regulatory Guide 1.26 Revision 3, Quality Group Classifications and Standards for Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants Notes: 1) When conflicts in similar requirements contained in Technical Specifications l and the above documents exist, the requirements contained in Technical Specifications override those in the documents. Requirements in the

Title:

Section 11, Quality Assurance Program Page: 2 of 4 Rev.: 29 Date: June 22,1999

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YANKEE ATOMIC ELECTRIC COMPANY l documents will be considered when they supplement and are not in conflict I

l with similar requirements in Technical Specifications.

2) Revisions to the above listed documents will be considered for applicability to the Yankee Decommissioning Quality Assurance Program upon written direction thereof by the Regional Administrator, Nuclear Regulatory 4 Commission - Office of Inspection and Enforcement - Region 1. l

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3) Only those documents listed above shall be considered applicable to the Yankee plant. Documents further referenced by the above listed documents shall not be considered applicable. They may, however, be considered as guidelines.

• Exceptions and alternatives to the provisions contained in this Standard / Guide are detailed in Appendix B.

This Program shall be applicable to those activities requiring quality assurance which occur commencing within 90 days after acceptance of the Program by the Nuclear Regulatory Commission.

The NRC shall be notified of changes, that reduce commitments in the accepted description of the DOAP, for their review and acceptance prior to implementation.

Acceptance will oe assumed 60 days after submittal unless notified otherwise. A previously approved NRC SER may be used to make changes which reduce commitments under the same approval conditions.

Changes that do not reduce DOAP commitments er were made based on previously approved NRC SER shall be submitted to the NRC at least annually.

Editorial changes or personnel reassignments of a nonsubstantive nature do not require NRC notification.

D. MANAGEMENT EVALUATION The CEO and President ensures the performance of periodic evaluations of the DQAP.

The review is performed to evaluate compliance with the DQAP and to evaluate its effectiveness.

E. TRAINING l

The Decommissioning Manager is responsible for ensuring indoctrination and training of staff personnelinvolved with DQAP activities.

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Title:

Section 11, Quality Assurance Program l Page: 3 of 4 l Rev;: 29 Date: June 22,1999

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I YANKEE ATOMIC ELECTRIC COMPANY l

This indoctrination and training shall include the following:

1. Instruction as to the purpose, scope, and implementation of applicable quality-related manuals, instructions, and procedures.

2. Training and qualification in the principles and techniques of the activity being i performed.

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3. Documentation of the training implementation.

4. . Maintenance of personnel proficiency by retraining, re-examining, and/or recertifying.

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Title:

Section 11, Quality Assurance Program Page: 4 of 4

. Rev.: 29 Date: June 22,1999 -

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YANKEE ATOMIC ELECTRIC COMPANY 111. DESIGN CONTROL

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A. SCOPE This section of the DQAP establishes measures to assure that the design of and changes to structures, systems, and components covered by the DQAP are controlled.

A. RESPONSIBILITIES

1. Design activities associated with applicable SSCs have been outsourced to Duke Engineering & Services (approved vendor). The vendor shall provide for;

a. The control of design activities for applicable structures, systems, or components, including the requirement for independent review. This review shall be performed by an uninvolved, but technically knowledgeable, person in the engineering discipline.

b. Identification, documentation, and control of deviations from specified design requirements and/or quality standards.

c. Design analysis and delineation of acceptance criteria for inspections and tests when required.

d. Verification of the adequacy of a specific design feature by implementation of a prototype test when requimd. i l

f. Review of inspection and test data for compliance with established engineering criteria when required.

2. Independent review committee activities shall be performed by Section 6 of the 1 Defueled Technical Specifications as required.

3. The Decommissioning Manager shall be responsible for ensuring the appropriate review and approval of proposed plant changes.

B. IMPLEMENTATION l 1

1 Satisfaction of this criterion shall be assured through the implementation of the actions l listed below: 1

1. Correct translation of applicable regulatory requirements and design bases into specifications, drawings and written documents.

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Title:

Section 111, Design Control Page: 1 of 2 Rev.; 29 Date: June 22,1999

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2. Application of suitable design controls to such activities as seismic, stress, l: thermal, hydraulic, radiation, and accident analyses; compatibility of materials; and accessibility for inservice inspection, maintenance and repair.

3. Design reviews to assure that design characteristics can be controlled, inspected and tested. l

4. Performance of proper selection and accomplishment of design verification or checking process such as design reviews, alternate calculations, qualification testing or test programs. When a test program is used to verify the adequacy of a design, a qualification test of a prototype unit under the most adverse design  ;

conditions shall be used. The responsibilities and qualifications of the verifier, the 4

areas and features to be verified, the pertinent considerations to be verified, and  !

the extent of documentation are identified in procedures.

The criteria that specify when verification should be performed by test will be

provided. If the verification method is by test only, prototype, component, or j l feature testing is performed in accordance with written procedures prior to relying j l upon the component, system, or structure to perform its function. I l

S. Subjection of design and specification changes to the same design controls and I approvals that were applicable to the original design cnless deligated in writing to -;

another responsible organization. l 6.. Documenting errors and deficiencies in the design process that adversely affect j safety-related classified structures, systems, and components and the performance of corrective action to preclude repetition. i l

7. Review of standard "off-the-shelf' commercial or previously approved materials, ,

parts, and equipment that are essential to the quality functions of structures, l

l systems, and components, for suitability of application prior to selection.

8. Selection of suitable materials, parts, equipment, and processes for quality classified structures, systems, and components.

9.- Establishment of procedures to assure that computer programs are verified and validated for a particular application.

Title:

Section Ill, Design Control

~ Page: 2 of 2 Rev.: 29-l Date: - June 22,1999

f YANKEE ATOMIC ELECTRIC COMPANY l

IV. - PROCUREMENT DOCUMENT CONTROL A. SCOPE This section of the DOAP establishes the measures necessary 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.

B. RESPONSIBILITIES

1. This activity has been outsourced to DE&S (approved vendor). DE&S shall provide for:

a. The preparation of detailed procedures as to how purchase documents are prepared, reviewed, approved, issued, and controlled.

b. The integration of appropriate quality assurance requirements into procurement requisitions. i l

2. The Decommissioning Manager shall be responsible for ensuring:

a. The preparation of engineering specifications which detail the technical and quality requirements for material, equipment and services,

b. The periodic review of purchasing documentation for material, equipment, and services required to support applicable plant changes.

3. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

F. IMPLEMENTATION Satisfaction of the criterion shall be assured through the implementation of the actions listed below:

1, Documentation of the review and approval of procurement documents prior to release and maintain availability of this documentation for verification.

2. Identification of the vendor's applicable quality assurance requirements of 10CFR50, Appendix B and/or ANSI N18.7, and/or other applicable codes, standards or regulatory documents referenced in procurement documents which l

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Title:

Section IV, Procurement Document Control

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1 of 2 l

Rev.: 29 Date: June 22,1999

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r YANKEE ATOMIC ELECTRIC COMPANY are to be reviewed by the qualified personnel knowledgeable in decommissioning quality assurance.

3. Identification in the procurement documents of the applicable documentation to be prepared, maintained, and/or submitted to the purchaser prior to purchase, such as:

a. Drawings, specifications, procedures;

b. Inspection and falsrication plans;

c. Inspection and test records;

d. Personnel and procedure qualifications;

e. Chemical and physical test results of material; and

f. Right of access to the vendor's facilities and records for surveillance and/or audit of procurement documentation.

4. Review and approval of changes and revisions to procurement documents at least equivalent to those for the original document.

5. . Control of procurement documents for spare and replacement parts at least equivalent to that used for the original equipment.

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Title:

Section IV, Procurement Document Control Page: 2 of 2 Rev.: 29 Date: June 22,1999 1

YANKEE ATOMIC ELECTRIC COMPANY V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS i

A. SCOPE This section of the DQAP establishes the measures for prescribing and accomplishing activities requiring quality assurance in accordance with approved drawings, instructions, or procedures. )

l B. RESPONSIBILITIES l

1. The Decommissioning Manager is responsible for ensuring applicable procedures governing the activities affecting quality are established and followed.

2. Persons preparing and approving documents are responsible for assuring that specifications, instructions, procedures, and drawings include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished; assuring that the applicable criteria of 10CFR50, Appendix B which satisfies the requirements of 10CFR71, Subpart H and 10CFR72, Subpart G and/or ANSI N18.7 are specified; and assuring that the documents are kept current. In addition, the following departments have the distinct responsibilities delineated below,

a. The Decommissioning Manager shall be responsible for ensuring the preparation, approval, maintenance, and implementation of all instructions, drawings, and procedures associated with plant and contracted services quality activities.

b. The Independent Review Committee shall be responsible for reviewing those items defined in the Defueled Technical Specifications.

3. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

C. IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of the actions i listed below.

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1. Establishment of provisions which clearly delineate the sequence of actions to be i accomplished in the preparation, review, approval, and control of instructions, l procedures, and drawings.  !

Title:

Section V, Instructions, Procedures, and Drawings Page: 1 of 2 Rev.: 29 Date: June 22,1999

o 3 YANKEE ATOMIC ELECTRIC COMPANY

2. Review of quality procedures, drawings and specifications and changes thereto by knowledgeable personnel.

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Title:

Section V, instructions, Procedures, and Drawings -

Page: 2 of 2 .-

Rev.: 29 Date: June 22,1999

L YANKEE ATOMIC ELECTRIC COMPANY i VI. DOCUMENT CONTROL )

i j A. SCOPE l

1 This section of the Decommissioning Quality Assurance Program establishes the measures for controlling the issuance of documents, ' including revisions thereto, which affect quality activities.

B. RESPONSIBILITIES

1. The Decommissioning Manager shall ensure document control measures are established which provide for the following:

a. Identification of controlled documents utilized for performing quality activities. I

b. Identification of organizations responsible for preparation, review, l

approval, and control of documents. j

d. Coordination and control ci interface documents.

e. Establishment of distribution lists.

f. Action to be taken for obsolete or superseded documents.

2. The OutsourcM Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

D. IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

1. Review and approval of document changes by the same " effected" organizations that performed the original review and approval p_r by other responsible organizations delegated by the controlling authority.

.L Inclusion of approved changes in instructions, drawings, and other applicable

. documents prior to placing the system in operating status.

3. Provision to allow availability of documents, as needed, at the location where the activity is to be performed prior to commencing the work.

Title:

Section VI, Document Control l- . Page: 1 of 2 Rev.: 29-Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY

4. Establishment, revision, and distribution of a master list or equivalent to identify l the current revision number of instructions, specifications, drawings, procurement

' documents, or other quality assuring documents. (Cancelled procedures are not required for inclusion within the list.)

5. Control of documents as identified in administrative procedures.

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6. Appendices to the Decommissioning Quality Assurance Program are considered

( to be part of the Program and are reviewed and approved in accordance with the Program. l l-l-

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Title:

Section VI, Document Control

- Page: 2 of 2 -

Rev.: 29 Date: - June 22,1999 l

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n YANKEE ATOMIC ELECTRIC COMPANY Vll. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES l

A. SCOPE I

This section of the DOAP establishes measures to assure that purchased material, equipment and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.

B. RESPONSIBILITIES i

1. The outsourced Quality Assurance Organization shall be responsible for

a. Audits and Commercial Surveys of vendor quality assurance programs.

b. Surveillances of vendor activities.

l. c. Maintenance of the Duke Engineering & Services Decommissioning Vendors List.

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d. Audits and/or surveillance of the implementation of this DQAP criteria.

3. The Decommissioning Manager shall ensure that provisions have been  ;

established for the-

a. Receipt inspection and contro. of material and equipment.

b. Evaluation of purchased services during and/or after completion of the service.

c. Control of purchased material, parts and components untilissued for installation or use.

C. IMPLEMENTATION l Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

1. ' Auaits and Commercial Surveys of vendors based on one or more of the following, as appropriate to the scope of procurement activities:

a. When required in order to verify vendor capabilities to comply with the applicable criteria of 10CFR50, Appendix B, which satisfies the l

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Title:

Section Vil, Control of Purchased Material, Equipment, and Services Page: 1 of 2 Rev.: 29 Date: June 22,1999 L

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YANKEE ATOMIC ELECTRIC COMPANY requirements of 10CFR71, Subpart H; 10CFR72, Subpart G; l

ANSI N18.7, or other quality program baselines.

b. When required, based on the results of a review and evaluation of vendor performance history.

c. When required in order to observe vendor facilities / service activities to assure conformance to purchase specifications.

2. Surveillances of vendors which provide for;

a. Specification of applicable quality controls, processes to be witnessed or verified, documentation required, and personnel responsible for performing the surveillance,

b. Verification that the vendor complies with the quality requirements specified in procurement documents by observation of in-process work.

1. Transfer of the following records from the vendor to the plant:

a. Documentation that identifies the purchased material / services and compliance with the applicable procurement document requirements.

b. Documentation that identifies any deviation (s) from procurement requirements, including a description of those deviations dispositioned

" accept as is" or " repair".

4. Review and acceptance of vendor documentation by a responsible qualified individual.

5. Receipt inspections of vendor furnished material / services, in accordance with predetermined instructions.

6. Evaluations of vendor effectiveness to control quality is performed at intervals consistent with the importance, complexity and quality of the item / services.

Title:

Section Vil, Control of Purchased Material, Equipment, and Services Page: 2 of 2 Rev.: 29 Date: June 22,1999 l

YANKEE ATOMIC ELECTRIC COMPANY

! Vill. IDENTIFICATION AND CONTROL OF MATERIAL, PARTS, AND COMPONENTS l

A. SCOPE l

This section of the DOAP establishes the measures for identification and control necessary to prevent the use of incorrect or defective material, parts, and components.

B. RESPONSIBILITIES

1. The outsourced Quality Assurance Organization shall be responsible for review, evaluation, or verification (audit, commercial survey or surveillance) of vendor l quality controls and work processes for traceability of materials through the use of l

heat number, part number, or serial number, either on the item or on records traceable to the items.

2. The Plant shall be responsible for:

a. Preparing and approving of documents for the identification and control of materials, parts, and components.

b. Maintaining of traceability of materials, parts, and components which received, stored, installed, and used at the Plant.

l 3. The Decommissioning Manager shall be responsible for:

a. Assuring that specifications contain appropriate requirements for the identification and control of materials, parts, and components.

b. Providing review and approval of documentation for the purchase of materials, parts, and components.

4. The Outsourced Quality Assurance Organization will perform audits and/or surveillances cf the implementation of this DQAP criteria.

C. IMPLEMENTATION Satisfaction of this cnterion shall be assured through the implementation of the applicable actions listed below:

1. Traceability of the identification of materials and parts to the appropriate documentation such as drawings, specifications, purchase orders, manufacturing

Title:

Section Vlli, Identification and Control of Materials, Parts, and Components Page: 1 of 2 Rev.: 29 Date: June 22,1999 1

1

YANKEE ATOMIC ELECTRIC COMPANY and inspection documents, deviation reports, and Physical and Chemical Material Test Reports.

2. Identification of the item in a location and with a method which does not affect its fit, function or quality.

3. . Documented verification of correct identification of materials, parts, and components prior to release for use.

Title:

Section Vill, Identification and Control of Materials, Parts, and Components Page: 2 of 2 Rev.: 29.

Date: June 22,1999

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l YANKEE ATOM!C ELECTRIC COMPANY l

IX. CONTROL OF SPECIAL PROCESSES A. SCOPE l

This section of the Decommissioning Quality Assurance Program establishes the measures necessary to assure that special processes, including welding, heat treating, l and nondestructive testing, are controlled and accomplished by qualified personnel in accordance with applicable codes, standards, specifications, criteria and other special requirements.

B. RESPONSIBILITIES 1 1, The Decommissioning Mar,ager shall ensure the following:

a. Preparation and implementation of documents for welding, heat treating, filler metal control, and ncndestructive examinations. I

b. Review and approval of special process documents provided by the vendor for use on-site and when otherwise specified.

I

c. Assurance that maintenance and change work involving special processes are performed by qualified personnel in accordance with approved documents.

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d. Control of material used in special processes by plant personnel. I

e. Training, qualification, and requalification of personnelin nondestructive testing, such as liquid penetrant examination.

2. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DOAP criteria.

D. IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

1. Completion of qualification records of documents, equipment, and personnel connected with special processes in accordance with applicab!e codes, standards, and specifications.

Title:

Section IX, Control of Special Processes l Page: 1 of 2 Rev.: 29 Date: June 22,1999

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1 YANKEE ATOMIC ELECTRIC COMPANY

2. Pe'iconance of special processes accomplished in accordance with written process sheets or equivalent with recorded evidence of verification.

3. Maintenance and updating of qualification records of special process documents, equipment, and personnel.

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Title:

Section IX, Control of Special Processes  !

Page: 2 of 2 Rev.: 29 Date: June 22,1999 l-I'

YANKEE ATOMIC ELECTRIC COMPANY X. INSPECTION A. SCOPE This section of the Decommissioning Quality Assurance Program establishes measures for inspection of activities requiring quality assurance to verify cufornece with approved procedures, drawings, specifications and instructions.

B. RESPONSIBILITIES

1. The outsourced Quality Assurance Organization shall be responsible ft i

a. Surveillance of vendor inspec. tion activities and personnel.

b. Incorporation of mandatory notification / hold points for plant / vendor / service group activities into the QA surveillances and mandatory hold points for inspections.

. c. Writing, reviewing and approving quality control inspection checklists.

d. Performing QC inspection activities to assure that predetermined requirements have been met.

2. The Decommissioning Manager shall be responsible for;

a. Writing and approving inspection instructions and check lists.

b. Assuring that activities requiring quality assurance meet predetermined requirements.

c. Providing qualified personnel and necessary equipment for inspections to assure quality work.

d. Perform inspection activities to assure that predelermined requiremen4 have been met.

e. Hold points incorporation where applicable.

C. IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of the actions listed below:

Title:

Section X, inspection Page: 1 of 2 Rev.: 29 Date: June 22,1999 :

L

YANKEE ATOMIC ELECTRIC COMPANY

-1. Independence of personnel performing the inspection from the personnel performing the activity being inspected.

2. Use of instructions or checklists. l

, 3. Use of necessary drawings and specifications when performing inspection operations.

l

4. Inspection of repairs and replacements in accordance with the approved design and inspection requirements or acceptable alternatives.

5. Surveillance of processing methods, equipment, and personnel when direct inspec+ ion is not possible.

6. Qualification of inspectors in accordance with applicable codes, standards, and

' company training programs; and maintenance of qualifications and certifications.

l 7. Review of maintenance documents by knowledgeable personnel to determine the l need for inspection, identification of Inspection personnel, and documentation of inspection results.

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Title:

Section X, inspection l

Page: 2 of 2 Rev.: 29 Data: June 22,1999 L

1

YANKEE ATOMIC ELECTRIC COMPANY

- XI. TEST CONTROL A. SCOPE I This section of the Decommissioning Quality Assuranca Program establishes the measures for a test program to demonstrate that structures, systems, and components  ;

will perform satisfactorily in service. I B. RESPONSIBILITIES i

1. The outsourced Quality Assurance Organization shall be responsible for audit and/or surveillance of test program activities and associated documentation. l 2.- The Decommissioning Manager shall be responsible for ensuring a testing process is developed and implemented for applicable plant changes. The testing l

process which performs the test evaluates the results and approves the results.

This process shallinclude the provision of qualified personnel and calibrated equipment for testing.

I C. IMPLElWENTATION I

Satisfaction of this criterion shall be assured through the implementation of the actions i listed below:

1. Assurance that changes, repairs, and replacements are tested in accordance with the approved design and testing requirements or acceptable alternatives. l

2. Review and acceptance of written test docum3nts and test results. Consideration shall be given to the following items:

a. Requirements and acceptance limits contained in applicable design and procurement documents.

b. Instructions for performing the test.

c. Test prerequisites.

d. Mandatory inspection hold points for witness by owner, contractor or inspector, when applicable.

k. Acceptance and rejection criteria.

Title:

Section XI, Test Control Page: 1 of 2' Rev.: 29 Date: - June 22,1999 l:

. YANKEE ATOMIC ELECTRIC COMPANY

1. ' Method of documenting test data and results.-

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Title:

Section XI, Test Control '

Page: 2 of 2 l Rev.: 29 l Date: . June 22,1999 J l

YANKEE ATOMIC ELECTRIC COMPANY XII. CONTROL OF MEASURING AND TEST EQUIPMENT A. SCOPE This section of the DQAP establishes the measures for the contro , calibration and periodic adjustments of tools, gages, instruments, and other measuring and test devices used to verify can'armance to established requirements.

B. RESPONSIBILITIES 1 I

i

1. The Decommissioning Manager shall be responsible for ensuring the j development and implementation of documents for control of measuring and test

)

equipment, including identification, calibration, ard documentation.

2. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

C. IMPLEMENTATION

1. Satisfaction of this criterion shall be assured by identifying, controlling, and calibrating measuring and test equipment with traceability to the calibration and test data.

i

2. Calibration of measuring and test equipment at specified intervals and maintaining associated documentation based on required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.

3. Traceability of reference and transfer standards to nationally recognized standards, or, documen'ation of the basis for calibration where national standards are nonexistent.

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Title:

Section Xil, Control of Measuring and Test Equipment Page: 1 of1 Rev.: 29 Date: June 22,1999 w

YANKEE ATOMIC ELECTRIC COMPANY Xlli. HANDLING, STORAGE AND SHIPPING A. SCOPE  !

This section of the Decommissioning Quality Assurance Program establishes measures to control the handling, storaje, shipping, cleaning and preservation of material and equipment to prevent damage or deterioration.

B. RESPONSIBILITIES

1. The Decommissioning Manager shall be responsible for ensuring the:

a. Development and implementation of documents for the handling, storage and shipping of materials and equipment.

l

b. Providing suitable facilities and equipment for handling, storage, and I shipping of materials.

c. Inspections and tests of special handling tools and eauipment.

2. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the irnplementation of this DQAP criteria.

C. IMPLEMENTATION Satisfaction of this criterion shall be assured through the development at:d implementation of documents for special handling, preservation, storage, cleaning, packaging, and shipping, by qualified individuals, in accordance with predetermined work and inspection j instructions.'

]

Title:

Section Xill, Handling, Storage, and Shipping Page: 1 of 1 Rev.: 29

~ Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY XIV. - INSPECTION, TEST AND OPERATING STATUS A. SCOPE This section of the Decommissioning Quality Assurance Program establishes the measures for indicating the status of items undergoing inspections and tests (via tags, labels, logs, data sheets, etc.), to prevent the unintentional bypass of required tests. In addition, this section establishes measures for indicating the operating status of components and systems to prevent their inadvertent operation.

B. RESPONSIBILITIES

1. The Decommissioning Manager shall be responsible for ensuring the control of operating equipment or systems, including the use of qualified personnel.

2.- The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

C. IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of procedurs!

controls for inspecting, testing, and operating status of structures, systems, and components, utilizing status indicators, such as tags, markings, labels, and stamps.

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Title:

Section XIV, inspection, Test, and Operating itatus l Page: 1 of 1 Rev.: 29 Date: June,221999

4 L-YANKEE ATOMIC ELECTP.lc COMPANY l

XV. NCNCONFORMING MATERIALS, PARTS, AND COMPONENTS l A. SCOPE ,

This section of the DQAP establishes the measures to control materials, parts, components, or any other activities which do not conform to requirements, in order to prevent their inadvertent use.

B. RESPONSIBILITIES The Decommissioning Manager shall be responsible for ensuring the:

1. Writing of implementation documents for the identification, documentation, and corrective action for services, material, installation, testing, operation, and/or surveillance nonconformances.

2. Initiating nonconformance reports when conditions are found which may adversely affect the quality of plant systems, structures, components, or activities. I

3. Review of nonconforming services or items which cannot be corrected by vendor action.

4. Preparation or upproval of implementing documents for repair and/or rework of nonconforming items.

5. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria.

~ C. IMPLEMENTATION i

1. Satisfaction of this criterion shall be assured through the development and implementation of the actions listed below;

a. Identification, disposition, inspection and segregation of nonconforming items, services, or activities, including associated documentation.

b. Identification of those individuals or groups delegated the responsibility  !

and authority for the disposition and written approval of nonconforming 1 items or activities.

c. Subsequent inspections and tests of reworked or repaired items which require reinspection and retest to original methods or methods equivalent thereto.

Title:

Section XV, Nonconforming Materials, Parts, and Components Page: 1 of 2 Rev.: 29 Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY

d. Inclusion of nonconformance reports dispositioned " accept as is" or

" repair" as part of the inspection records furnished to the plant.

e. Periodic analysis n' onconformance reports to show quality trends with the results reportou to management for review and assessment.

2. The identification, description, disposition, inspection and signature approval of the final disposition of nonconformances shall be documented in a Condition Report.

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Title:

Section XV, Nonconforming Materials, Parts, and Components Page: 2 of 2 Rev.: 29 i Date: June 22,1999 i: .. . .!

YANKEE ATOMIC ELECTRIC COMPANY l XVI. CORRECTIVE ACTION

! A. ' SCOPE This section of the Decommissioning Quality Assurance Program establishes measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment are promptly identified and corrected, j

B. RESPONSIBILITIES i

1. The' Decommissioning Manager shall be responsible for the development and implementation of a process for identifying, documenting, and correcting conditions adverse to quality, including the identification of causes for significant conditions adverse to quality.

2. The Outsourced Quality Assurance Organization will perform audits and/or surveillances of the implementation of this DQAP criteria-C. IMPLEMENTATION l

l Satisfaction of this criterion shall be assured through the identification, documentation, j and implementation of the actions listed 'celow:

2 l

l 1. Documentation of conditions adverse to quality.

2. Initiation of corrective action for conditions adverse to quality, including, the identification of the cause of significant conditions adverse to quality, with corrective actions taken, to preclude recurrence.

3. Periodic reviews to verify proper imolementation of corrective actions.

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Title:

Section XVI, Corrective Action l

Page: 1 of 1

- Rev.: 29 Date: June 22,1999

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YANKEE ATOMIC ELECTRIC COMPANY XVsil. QUALITY ASSURANCE RECORDS A. SCOPE l

1. This section of the DOAP establishes the measures for maintenance of records which provide documentary evidence of the quality of items and the activities affecting quality. Requirements shall be established for identification, transmittal, retrievability and retention of quality assurance records including duration, location, protection and assigned responsibility.

2. The quality assurance records shall include, but not be limited to, applicable plant J

history; operating logs; principal maintenance; design change activities; reportable occurrences; nonconformance reports; results of reviews, inspections, tests, audits and material analyses; monitoring of work performance; qualification of personnel, documents and equipment; drawings; specifications; procurement documents; calibration documents and reports; corrective action reports, and other applicable decommissioning and spent fuel storage records.

B. RESPONSIBILITIES l J

1. The outsourced Quality Assurance Organization shall be responsible for the control of applicable records and for performance'of audits and/or surveillance of this DQAP criteria.

2. The Decommissioning Manager shall be responsible for establishing a system for the identification, review, approval and retention of documents relating to quality assurance records and its implementation as defined above and in Section 6 of the Defueled Technical Specifications and for assuring its implementation.

C. IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of an established process which provides for administration, recelot, storage, preservation, safe keeping, retrieval, and finalinspection of records.

The construction location and security of record storage facilities to prevent destruction of the records by fire, flooding, theft, and deterioration by environmental conditions such as j temperature or humidity. Duplicate records shall be stored in a separate remote location j when the type of document is not permanently maintained in the record storage facility.

TITLE: SECTION XVil, QUALITY ASSURANCE RECORDS l PAGE: 2OF2 1 REV.: 29 DATE: JUNE 22,1999 i

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YANKEE ATOMIC ELECTRIC COMPANY XIX. AUDITS c l A. SCOPE l This section of the DQAP establishes the measures for a comprehensive system of planned and documented audits and in-plant surveillances to verify compliance with all i aspects of the DQAP and to assess the effectiveness of the DOAP. l l

l B. RESPONSIBILITIES

1. The outsourced Quality Assurance Organization shall be responsible for:

a. Providing objective evidence for audit / surveillance activities l encompassed by the 18 criteria of 10CFR50 Appendix B; 10CFR71, Subpart H; 10CFR72, Subpart G; and the DQAP, as applicable, and ANSI N18.7.

b. Training of audit and surveillance personnel.

c. Scheduling, coordinating, and implementing the formal Audit /

Surveillance Programs.

d. Preparing information regarding the Audit / Surveillance Program for review by the IRAC.

e. Performing vendor oversight.

f. Following up of findings discovered during audits.

g. Providing recommendations to preclude recurrence of audit / surveillance

' findings ,

h. Performing periodic audits of functional areas under the DQAP.

2. The Decommissioning Manager shall be responsible for correcting findings identified during audits and surveillances.

C. ' IMPLEMENTATION Satisfaction of this criterion shall be assured through the implementation of the following actions:

Title:

Section XVill, Audits

. Page: 1 of 2 Rev.: -29 Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY i

1. Documentation and review of audit / surveillance results and review with management having responsibility in the area. i l 2. Management action to correct findings identified audit / surveillance.

3. Review of corrective action effectiveness during audits.

4. Evaluation of quality-related practices, procedures, instructions and the effectiveness of theirimplementation. j l

5. Performance of audits as defined in Appendix D of the DOAP. I

6. Scheduling of audits on the basis of the status and safety importance of the activities being performed.

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Title:

Section XVill, Audits j i ' Page: 2 of 2

' Rev.: 29

Date: June 22,1999 l

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX A Qualification Requirements for l Management of Quality Assurance Manager tent of Quality Assurance must meet the below listed qualification requirements:

A. EDUCATION:

Bachelor's degree in Science or Engineering, or the equivalent in practical experience.

B. EXPERIENCE:

1. Four years experience in the field of Quality Assurance, or

2. Equivalent number of years of nuclear plant experience in a supervisory position preferably at an operating or decommissioning nue' ear power plant or a combination of the two.

a. At least one year of this four years experience shall be nuclear power plant experience in the implementation of the Quality Assurance Program, and

b. Six months of the one year experience shall be obtained within a Quality Assurance organization.

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Title:

Appendix A, Qualifications Requirements Page: 3 of 3 Rev.: 29 Date: June 22,1999 L

l YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B Decommissioning Quality Assurance Program Exceptions l The sub-categories of this Appendix summarize the exceptions noted in Section ll of the Yankee Atomic Electric Company Decommissioning Quality Assurance Manual.

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l Appendix B Standard / Guide Title Sub-Category i

l. ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Pcwer Plants li. ANSI N45.2.10-1973 Quality Assurance Terms and Definitions 111. R.G.1.64, Rev. 2 Quality Assurance Requirements for the Design of i Nuclear Power Plants IV. ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of items for Nuclear Power Plants V. ANSI N45.2.6-1978 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants VI. R.G.1.26, Rev. 3 Quality Group Classifications and Standards for Water , 1 Steam- and Radioactive-Waste-Containing Components of Nuclear Power Plants Vll. ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants l

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Title:

Appendix B, DQAP Exceptions Page: 1 of 13 Rev.: 29 Date: June 22,1999 l

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YANKEE ATOMIC ELECTRIC COMPANY APPENDIX B (Continued)

1. ANSI N45.2 9 - 1974, Reauirements for Collection. Storaoe. and Maintenance of Quality l

Assurance Records for Nuclear Power Plants A. EXCEPTION:

i Subsection 5.6(3) Facility The Yankee plant takes exception to " structures, doors, frames, and hardware should be i

i Class A fire rated with a recommended four hour minimum rating."

ALTERNATIVE:  ;

)

i

" Doors, structures, frames, and hardware shall be designed to comply with the requirements of a minimum two (2) hour fire rating, meeting NFPA No. 232 guidelines."

JUSTIFICATION:

3 The two (2) hour rating has been endorsed by the NRC Standard Review Plan NUREG- I 0800, Revision 2, dated July 1981,

Title:

" Appendix B, DOAP Exceptions Page: 2 of 13 Rev.: 29 Date: June 22,1999 j i

YANKEE ATOMIC ELECTRIC COMPANY APPENDlX B

. (Continued) l

11. ANSI N45.2.10 - 1973, Quality Assurance Terms and Definitions A. EXCEPTION:

I Subsection 2 -Terms and Definitions The Yankee plant takes exception to the definitions of" Certificate of Conformance" and

" Certificate of Compliance".

ALTERNATIVE:

The Yankee plant shall reverse the definitions of the above terms so our Program will be in compliance with the implied definitions in the ASME B&PV Code and Yankee specifications.

Title:

Appendix B, DOAP Exceptions Page: 3 of 13 Rev.: 29 Date: June 22,1999

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YANKEE ATOMIC ELECTRIC COMPANY l

APPENDlX B l I

(Continued) l l Ill. Regulatory Guide 1.64, Revision 2, " Quality Assurance Reouirements for the Desian of Nuclear Power Plants" A. EXCEPTION:

- Subsection c.2 The Yankee plant takes exception to the regulatory guide position on the exclusion of supervisors performing design verification.

ALTERNATIVE:

.The Yankee plant will continue the accepted practices for independent design verification in accordance with the provisions of ANSI N45.2.11-1974, Section 6.1.

JUSTIFICATION:

The exclusion of line supervision to perform design verification has proven to be an unnecessary burden on the resources within the engineering organizations of the company, and counterproductive during heightened periods of engheering activities.

ANSI N45.2.11 contains specific limitations on the situations in which a supervisor is permitted to perform design verification. The standard states,"This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, or rule out certain design considerations and did not establish tha design inputs used in the design, or if the supervisor is the only individual in the organization competent to perform the verification." This control was developed through realistic evaluation of the practicable limits that restrictions impose on engineering organizations by the working group that developed ANSI N45.2.11.

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Title:

Appendix B', DQAP Exceptions Page: 4 of 13 Rev.: -29 Date: . June 22,1999

l YANKEE ATOMIC ELECTRIC COMPANY APPENDlX B (Continued)

IV. ANSI N45.2.2 - 1972, Packaaina. Shiopina. Receivina. Storace & Handlina of items for Nuclear  ;

Power Plants A. EXCEPTION:

l Subsection 3.7.1 & A3.7.1- Containers The Yankee plant takes exception to the specific requirements for containers.

ALTERNATIVE:

i Containers shall be of suitable construction to msure material is received undamaged.  !

JUSTIFICATION:

Container 3 shipped by closed carrier, stored inside and not subjected to a wet environment do not require weather resistant fiberboard, therefore, this is an unnecessary expense. Additionally, numerous vendors utilize shipping containers that do not comply j with the specific requirements of this section, i.e., flaps overlap. The acceptance criteria '

for a shipping container should be established based on the capability of the container to maintain the component materialin a safe condition. Technology has advanced beyond  ;

the standard. I B. EXCEPTION:

Subsection 3.7.2 - Crates and Skids The (ankee plant takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.

ALTERNATIVE:

Skids or runners shall be used on boxes with a gross weight of 100 pounds or more if practical.

JUSTIFICATION:

Storage methods and container design frequently are such that runners or skids are not feas'ble.

Title:

Appendix B, DOAP Exceptions Page: 5 of 13 Rev.: 29 Date: June 22,1999

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r. - 1 YANKEE ATOMIC ELECTRIC COMPANY -

APPENDIX B i

(Continued)

C. EXCEPTION:

Subsection 5.2.1 - Shippino Damaae Inspection l

The Yankee plant takes exception to the requirement that a preliminary visualinspection l or examination be performed prior to unloading.

ALTERNATIVE:

The Yankee plant shall perform those required inspections after unloading. In special i

instances, preunloading inspections shall be performed.

JUSTlFICATION:

l Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling.

D. EXCEPTION-1 i

Subsection 5.2.2 -item inspection i

l The Yankee plant takes exception to the requirement, that "The inspections shall be performed in an area equivalent to the level of storage requirements for the item."

i ALTERNATIVE:

1 The Yankee plant shall perform receiving inspection in a manner and in an environment which do not endanger the requisite quality of the item; however, receiving erea environmental controls may be less stringent than storage environmental controls for that item. When inspections are performed in receiving areas with environmental controls less j stringent than storage area environmental controls, a time limit shall be established on a l case basis for retention of items in the receiving area. Retention time shall be such that I deterioration is prevented and applicable manufacturer recommendations are addressed.

JUSTIFICATION:

Receipt inspection activities are for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for storage.

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Title:

Appendix B, DQAP Exceptions l

Page: 6 of 13 Rev.: 29 Date: June 22,1999 l

e YANKEE ATOMIC ELECTRIC COMPANY I I

1 i APPENDIX B h (Continued) l l' E. EXCEPTION:

L Subsection 5.2.3 - Special Inspection The Yankee plant takes exception to attaching special inspection procedures to the item

- or container.

ALTERNATIVE: i Special inspection procedures shall be readily available to personnel performing inspections.

JUSTIFICATION:

1 Procedures are subject to less abuse and more stringent controls when maintained on file and not attached to the item. Inspection status is maintained by tagging and procedure l control.

F. EXCEPTION:

. Subsection 6.1.2 - Levels of Storaae The Yankee plant takes exception to two specific requirements associated with fuel l; storage (classified Level A). j l

' ALTERNATIVE:

l The Yankee plant shall meet the requirements of Level A storage for new fuel with the l l exception of special air filtering; and temperature and humidity controls.

l JUSTIFICATION:

l The existing storage conditions at the Yankee plant is consistent with the protection l provided to the fuel while in storage at the manufacturer (vendor) and/or while in transit to the plant site and are judged to provide adequate protection to the fuel assembly structure which is of highly corrosion resistant materials. We believe that the above listed requirements are intended for application at the manufacturing facility (vendor) where the uranium pellets may be exposed to the atmosphere and not in its fully encapsulated, and l

therefore, fully protected form in a completed fuel assembly.

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Title:

Appendix 8, DOAP Exceptions l' - Page: 7 of 13 ,

Rev.: 29 i

i. Date: June 22,1999 l

F l YANKEE ATOMIC ELECTRIC COMPANY l

APPENDIX B (Continued)

G. EXCEPTION:

Appendix A-3 Subsection A3.5.1(1)- Caos & Pluas The Yankee plant takes exception to the requirement that nonmetallic plugs and caps shall be brightly colored.

ALTERNATIVE:

Nonmetallic plugs and caps shall be of a contrasting color.

JUSTlFICATION:

The purpose of utilizing brightly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating components or systems. By using plugs and caps of a contrasting color this objective can be achieved.

H. EXCEPTION:

Accendix A-3 Subsection A3 9(1)- Second Group. Markinas The Yankee plant takes exception to the requirement that container markings shall appear on a minimum of two sides.

ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievability.

JUSTlFICATION:

Containers are tagged to provide identification and inspection status. Employment of two tags on small containers adds bulk and confusion and does not provide for better identification or traceability.

l. EXCEPTION:

Appendix A-3. Subsection A.3 9(4)- Second Group. Markina The Yankee plant takes exception to the requirement that container markings shall be no less than 3/4" high, container permitting.

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Title:

Appendix B, DQAP Exceptions

. Page: 8 of 13 -

Rev.: 29 Date: June 22,1999

YANKEE ATOMIC ELECTRIC COMPANY I

APPENDIX B

- (Continued)

AL.TERNATIVE:

Container markings shall be of a size which permits easy recognition.

JUSTIFICATION:

Markings were intended to provide identification and instructions. The criteria should be i that the markings clearly provide the same.

J. EXCEPTION:

Accendix A-3 Subsection A.3.9(6)- Second Group. Markina j The Yankee plant takes exception to the information required for container marking.

ALTERNATIVE:

J Marking shall be adequate in each case to provide identification, traceability and instructions for special handling, as applicable.

I JUSTIFICATION:

The information required is excessive. Cluttering a container with excessive markings only reduces the main objectives, maintaining identification and establishing special controls.

Title:

Appendix B, DQAP Exceptions Page: 9 of 13 Rev.: 29 Date: June 22,1999

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APPENDlX B  !

(Continued)

V. ANSI N45.2.6 - 1978, Qualification of Inspection. Examination and Testina Personnel for Nuclear i Power Plants A. EXCEPTION:

The Yankee plant takes exception to the application of the Standard to all Yankee and Vermont Yankee personnel performing inspection, examination and testing. I ALTERNATIVE: l 1

Yankee personnelidentified in ANSI N18.1-1971 who perform inspection, examination l and testing will be qualified to ANSI N18.1-1971.

Yankee personnel not identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N45.2.6-1978.

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Title:

Appendix B, DQAP Exceptions  !

Page: 10 of 13 -  ;

Rev.: 29 Date: June 22,1999 L

l YANKEE ATOMIC ELECTRIC COMPANY i

APPENDIX B I l (Continued) j VI. Regulatory Guide 1.26, Rev. 3, (2/76), Quality GrouD Classifications and Standards for Water .

Steam- and Radioactive-Waste-Containino Components of Nuclear Power Plants A. EXCEPTION:

The Yankee plant takes exception to the Regulatory Guide in its entirety.

ALTERNATIVES:

The Yankee plant shall continue to classify structures, components and systems in accordance with ANSI Standard N18.2, January 1973, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants", as in the past.

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Title:

Appendix B, DOAP Exceptions Page: 11 of 13 Rev.: 29 l

Date: June 22,1999 m .

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YANKEE ATOMIC ELECTRIC COMPANY l APPENDIX B l (Continued)

Vill. ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants I I

EXCEPTION: )

Subsection 5 2.15 - Review. Aporoval and Control of Procedures The Yankee Plant takes exception to the following paragraph:

" Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable".

1 ALTERNATIVES:

i Plant procedures will be periodically reviewed in accordance with administrative controls. These j controls will establish a schedule for these periodic reviews. All applicable plant procedures will l

- be reviewed following an unusual incident, unexpected transient, operator error, or equipment failure (malfunction), and following a modification to a system, Nonroutine procedures such as Emergency Plan Implementing Procedures, or other procedures whose use may be event driven, will be reviewed every two years.

However, if a nonroutine procedure '.s fully exercised and there is a detailed scrutiny of the entire procedure as part of a documente6 training program, this may serve as the biennial review of the procedure used.

]

At least every two years, the Quality Assurance (or other independent) organization shall audit a representative sample of routine plant procedures that are used more frequently than every two years. The audit is to ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies is to be determined and corrected.

. Routine plant procedures that have not been used for two years will be reviewed before use to determine if changes are necessary or desirable.

Title:

Appendix B, DQAP Exceptions Page: 12 of 13 Rev.: 29 Date: June 22,1999 e

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YANKEE ATOMIC ELECTRIC COMPANY APPENDlX B (Continued)

' JUSTIFICATION:

The current requirement to review each safety-related procedure on a biennial cycle results in the expenditure of significant technical and administrative resources. Programmatic controls and practices are in place to provide adequate reviews, including the following:

. The plant modification processes require that procedures affected by the modification be identified during the' design change preparation, and revised prior to closure of the modification package, e Administrative controls currently exist requiring that if a procedure cannot be performed as written, a procedure change must be. completed prior to continuation of the procedure.

. Temporary changes are occasionally generated during, or prior to procedure use. ' Current administrative controls require that those changes that are permanent shall be incorporated into the procedure via the procedure revision process.

e ' As part of the audit and surveillance process, procedures are evaluated as to adequacy, ease of use, proper technical content, and compliance with applicable plans and programs.

. The corrective action process requires that a root cause analysis be performed for events, violations and nonconforming conditions. Where identified as contributing factors, procedure changes are initiated.

e. Changes to Technical Specifications and the FSAR are reviewed for potential impact on, and -

initiation of changes to plant procedures.

• ' Plant procedures are approved by appropriate personnel prior to initial use. Current administrative controls also require pre-job briefings for procedures identified as infrequent.

This modification meets the intent of published regulatory requirements involving activities

!mportant to safety.

Title:

L _ Appendix B, DQAP Exceptions Page: 13 of 13

. Rev.: 29-Date: June 22,1999

1 YANKEE ATOMIC ELECTRIC COMPANY APPENDlX C Classification of Structures, Components, and Systems l Safetv-Related None.

Important to Safety as Defined in 10CFR72 i

SSCs listed in the NRC-approved Certificate of Conformance.

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Title:

Appendix C, Yankee Classification Page: 1 of 1 Rev.: 29 Date: June 22,1999

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