ML20210P216

Rev 2 to 81A1050, QA Program Plan for Transport Casks

ML20210P216
Person / Time
Site:	07100512
Issue date:	04/21/1986
From:	Dalton J, May J NUCLEAR ENERGY SERVICES, INC.
To:
Shared Package
ML20210P190	List: ML20210P185 ML20210P193 ML20210P216
References
26866, 81A1050, NUDOCS 8605130124
Download: ML20210P216 (26)

Text

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M NUCLEAR ENERGY SERVCES DOCUMENT NO. 81A1050 REV.2 l

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dM of/wfS QUALITY ASSURANCE PROGRAM PLAN FOR TRANSPORT CASKS Project Appi at on CODY No Assigned To APPROVALS TITLE / DEPT. - SIGN ATURE - D ATE REV NO PREPARED BY Project Gen. Mgr.

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l 81A1050 l

DOCUMENT NO.

b OF NUCLEAR ENERGY SERVICES TABLE OF CONTENTS Page 1.

INTRODUCTION 4

2.

ORGANIZATION 7

2.1 Project Organization 7

2.2 Project Responsibilities 7

3.

QUALITY ASSURANCE PROGRAM 10 4.

DESIGN CONTROL 10 4.1 Design Criteria 13 4.2 Design Review 13 5.

PROCUREMENT DOCUMENT CONTROL 13 6.

INSTRUCTIONS, PROCEDURES AND DRAWINGS 14 7.

DOCUMENT CONTROL 17 8.

CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 18 9.

IDENTIFICATION AND CONTROL OF-QATERIALS, PARTS AND COMPONENTS 18 10.

CONTROL OF SPECIAL PROCESS 19 4

11.

INSPECTION AND TEST CONTROL 19 12.

CONTROL OF MEASURING AND TEST EQUIPMENT 20

^

13.

HANDLING, STORAGE AND SHIPPING 21 l

14.

INSPECTION, TEST AND OPERATING STATUS.

21 t

15.

CONTROL OF NONCONFORMING MATERIALS, PARTS OR COMPONENTS 22 l

16.

CORRECTIVE ACTION 22 17.

QUALITY ASSURANCE RECORDS' 23

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l f

18.

AUDITS 25 4

FORM 8NES 205 2/80

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NUCLEAR ENERGY SERVICES

1. INTRODUCTION 2

The Quality Assurance Program to be implemented by NES for transport casks shall be governed by the following documents:

1.

The NES Quality Assurance Manual (80A9036) 2.

The Quality Assurance Program Plan (81A1050)

The NES Quality Assurance Manual (30A9086) and associated implementing procedures (identified in Appendix C of the Manual) define the policies and practices employed by Nuclear Energy Services to satisfy the eighteen criteria common to both 10 CFR 50, Appendix B and 10 CFR 71, Subpart H.

The Quality Assurance Program Plan (81A1050) is specific to the transport cask program and serves to define detailed quality assurance requirements for the various tasks such as organization, document control and quality assurance audits.

The Quality Assurance Program Plan is intended to address the full scope of activities relative to transportation packages; design, fabrication, assembly and testing, as well as procurement, use, maintenance and repair. NES will perform all transport package operations and activities in accordance with the applicable sectior.; of this Q.A.

Program Plan (whether the package was designed and/or built by NES or not). For example, whenever NES is the user of a non-NES package, NES would not normally perform design activities, therefore, Section !+ (Design Control) would not apply.

Table 1.1 shows a matrix which delineates the relationships between the eighteen criteria of 10 CFR 71, Subpart H, the Quality Assurance Manual identified above, and the associated implementing procedures.

FORM 8NES 205 2/80

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NUCLEAR E ERGY SEMvX:ES

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TABLE 1.1 IMPLEMENTING PROCEDURES i

e 10 CFR 71 Appendix E Criteria Procedure No.

Procedure Title

1. Organization QAM, Section 1 Organization s

2. QA Program QAM, Section 2 QA Program '

3. Design Control QAM, Section 3 Design Control 80A9029 Project Control 80A9010 Computer Code Documentation 80A9004

+

Calculation Notebooks 80A9059 Fabrication Specification Preparations 80A9003 Document Control

4. Procurement Document QAM, Section 4 Procurement Document Centrol Control 30A9007

. Procurement Control

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5. Instruction, Procedures,. QAM, Section 5 Instructions, Procedures and Drawings

-and Drawings

' 80A9004 Calculation Notebooks 80A9059 Fabrication Specification Preparation 80A9024 QA Procedur<s Preparation

6. Document Control QAM, Section 6 Document Control c'

80A9003 Document Control

7. Control of Purchased QAM, Section 7 Control of Purchased Material, Equipment -

t Material, Equipment and Serviges and Services 80A9022

. QA Audit Procedure 80A9026 Qualification of QA Audit Personnel j

80A9034 Preparation of Inspection Plans and Reports i

l

8. Identification and QAM, Section 8

• Identification and Control of Materials, Control of Materials, Parts and Components Parts and Components

.. s j

9. Control of Special QAM, Section 9 Control of Special Process Processes f.

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10. Inspection QAM, Section 10 11spection

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FORM s NES 205 2/80

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NUCt. EAR ENERGY SERVICES TABLE 1.1 (continued) 10 CFR 71 Appendix E Criteria Procedure No.

Procedure Title

11. Test Control QAM, Section 11 Test Control

12. Control of Measuring QAM, Section 12 Control of Measuring and Test Equipment and Test Equipment

13. Handling, Storage QAM, Section 13 Handling, Storage and Shipping and Shipping

14. Inspection, Test and QAM, Section 14 Inspection, Test and Operating Status Operating Status

15. Nonconforming QAM, Section 15 Nonconforming Materials, Parts or Materials, Parts or Components Components 80A9003 Nonconformance Report Processing 80A9036 Compliance to 10 CFR 21

16. Corrective Action QAM, Section 16 Corrective Action

17. QA Records QAM, Section 17 QA Records 80A9099 Identification Storage, Retention of In Process Records 80A9009 Project Close-Out File Procedure

18. Audits QAM, Section 13 Audits 80A9026 Qualification of QA Audit Personnel 80A9022 QA Audit Procedures Notes:

1.

QAM, - NES Q.A. Manual 2.

80A9XXX - NES Implementing Procedure 4

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i FORM s NES 205 2/80

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2. ORGANIZATION This section describes the NES project organization as it applies to the Transport Cask program.

Waste Management Services (WMS), a unit of NES, is responsible for transport cask activities.

2.1 PROJECT ORGANIZATION For each transport cask project, the General Manager of Waste Management Services shall designate a Project Manager who has full access to the technical resources of the NES organization in the implementation of this program. The NES project organization is shown in Figure 2.1.

2.2 PROJECT RESPONSIBILITIES The responsibilities of key NES personnel are fully described in Section 1 of the NES QA Manual (80A9036).

The NES Division QA Manager has staff authority over the entire project organization shown in Figure 2.1.

Reporting directly to the Division President, the QA Manager is responsible for all quality assurance activities and has adequate authority and organizational freedom to stop work, implement corrective action and verify its completion when quality problems are identified.

Minimum job requirements are established for the position of NES Q.A. Manager to ensure that the appointed individual has adequate knowledge and experience to fulfill the associated responsibilities.

The actual implementation of the Quality Assurance Program Plan for the Transport Cask program is the responsibility of all designated members of the project team and their respective employees.

i l

The provisions of this QA Program Plan (81 A1050) shall be imposed upon all lower tier vendors and subcontractors as applicable. The NES Q.A. Department FORM # NES 205 2/80

DOCUMENT NO..

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I will perform audits of vendors and subcontractors to ensure adherence to quality requirements as provided for in this Quality Assurance Program Pian and applicable NES Technical Specifications.

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1 FORM s NES 205 2/80

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o NES M

un President E$.

a t'

8 Q.A. Manager l

z o.

Exec. V.P. Operations h

2 mzma General Manager Q

Waste Management Services mn<5 F-I m

(4 Mgr. Field Operations Project Manager Mgr. Engineering i

and Production U

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4 Field Engineers Project Engineers D

and Technicians gj CE mz*

Use

- Design 5

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• Maintenance Licensing

- Repair

- Fabrication

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= Line Authority g

= Staff Authority M

Figure 2.1 - Transport Cask Project Organization

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NUCt. EAR ENERGY SERVICES i

3. QUALITY ASSURANCE PROGRAM The documents which comprise the NES Quality Assurance Program for transport casks are identified in Section 1 (Introduction) of this document. The corresponding procedures and their relationship to the eighteen (IS) criteria of 10 CFR 71, Subpart H can be found in Table 1.1 of this Q.A. Program Plan which applies to the design, fabrication, assembly, testing, procurement, use, maintenance and repair of transport casks.

The NES QA Manual describes the methods used by NES to ensure that qualified personnel are utilized to perform tasks important to safety, verify adherence to quality assurance requirements. and resolve disputes (refer to Statement of Policy and Sections 1 and 2 of the NES QA Manual).

Detailed procedures which address specific transport cask activities important to safety shall be adhered to a; all times. As described in Section 18 of this document, the NES QA Department will be responsible for auditing NES operations, vendors and subcontractors to ensure adherence to these procedures.

4. DESIGN CONTROL In the case of NES designed transport packages, the design task shall be the responsibility of Waste. Management Services (WMS), a unit of NES, which is subject to the provisions contained in the NES QA Manual (SOA9036); specifically Section 3 and the implementing procedures referenced therein. For non-NES designed transport packages which are leased, purchased or built by NES, NES shall establish that the design was controlled by an NRC approved Q.A. program.

I t

j During the design phase of an NES cask design project, the designated WMS Project l

Manager (reference Section 2 herein) is responsible for organizing the project into i

distinct tasks, maintaining lines of communication, coordinating task interfaces and i

overseeing design control activities.

h The NES Project Control Procedure (30A9029) addresses the following design control activities which are applicable to the NES Transport Cask program:

FORM s NES 205 2/80

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PAGE II OF 26 NUCLEAR ENERGY SERVCES 1.

Project Initiation 2.

Project / Design Planning 3.

Design Input Definition 4.

Design Execution (performance of analyses, preparation of design documents, drawings, procedures and fabrication specifications) 3.

Design Verification 6.

Design Change 7.

Document Control 8.

Design Audits and Corrective Action 9.

Design Records Table 4.1 identifies the NES Implementing procedures that are applicable to the transport cask program.

l w.

FORM 8NES 205 2/80

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OF 26 NUCLEAR ENERGY SERVICES TABLE 4.1 IMPLEMENTING PROCEDURE INDEX NES Q.A. MANUAL PROCEDURE NUMBER TITLE 80A9029 Project Control Proce, dure 80A9010 Computer Code Documentation Control Procedure 80A9004 Calculation Notebook Procedure 30A9007 Procurement Control Procedure 30A9059 Procedure for the Preparation of Project Fabrication Specifications 80A9003 Document Control Procedure 30A9034 Procedure for Preparation of Inspection Plans and Reports 80A9008 Supplier Nonconformance Report Processing Procedure 80A9036 Procedure for Compliance to 10 CFR Part 21 30A9009 Project Close-Out File Procedure 80A9099 Procedure for the Identification,

Storage, and Retention of In-Process Records 80A9026 Qualification of Quality Assurance Program Audit i

Personnel 6

I 80A9022 Quality Assurance Audit Procedure l

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NUCLEAR ENERGY SERVICES 4.1 DESIGN CRITERIA The design of NES Transport Casks shall also meet the requirements of the project Design Criteria which (1) summarizes principle code and standard requirernents, (2) outlines supplemental requirements ir. areas where the codes and standards are considered to be unclear or incomplete, and (3) outlines other items such as functional requirements, material requirements and environmental factors. The Design Criteria is reviewed and approved by NES management before it is issued to project Task Engineers for use.

4.2 DESIGN REVIEW Project design reviews shall be held to evaluate the results of design activities, assure that all aspects of the design have been properly considered and to also assure coordination among Task Engineers and Quality Assurance. These reviews shall be documented in accordance with the Project Control Procedure (80A9029). Design checklists need be completed only at the 5096 and 10096 review meetings.

Design and/or analysis calculations shall be checked and verified by a qualified individual or group other than those who perform the original design but who may be f. rom the same organization.

Design notebooks shall be prepared and maintained in accordance with NES Procedure 80A9004.

5. PROCUREMENT DOCUMENT CONTROL The NES QA Manual (Section 4) outlines the procedures that have been established to control the preparation, review and approval of procurement documents.

i j

As a minimum, procurement documents shall include the following:

a.

A statement of the scope of work.

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b.

Technical requirements such as applicable drawings, specifications, codes and i

standards.

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NUCt. EAR ENERGY SERVICES f

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The requirements of the QA Program Plan that are applicable to the supplier or subcontractor.

d.

NES' right to access supplier's facility.

e.

Documents prepared by supplier which are to be reviewed and approved by NES.

f.

Records and documents which are to be retained and controlled.

g.

Provisions of 10CFR21 apply as applicable.

In the event that a previously approved procurement document needs to be revised, the revised document shall be subject to the same level of review and approval given the original procurement document.

Procurement documents for category 1 & 2 items shall be reviewed by QA prior to placement of orders for original materials or replacement parts.

6. INSTRUCTIONS, PROCEDURES AND DRAWINGS All activities important to safety shall be outlined in written procedures, specifications or drawings which have been reviewed and approved by the specified members of the NES organization. Table 6.1 identifies documents required for the Transport Cask Program, and the level of review and approval required for each.

These approvals shall be adhered to for the original document as well as for all subsequent revisions.

All project documents shall be prepared, reviewed and approved in accordance with the provisions of the NES QA Manual (Sections 5) and all applicable procedures referenced therein.

WMS reserves the right to approve all project documents. Activities important to safety that are performed by a vendor or subcontractor shall be performed in I

accordance with written procedures previously approved by WMS.

Documented i

j approval by the Project Manager shallindicate WMS approval.

I For activities critical to safety, the applicable procedures shall identify required Hold l

Points and inspections.

I FORM NNES 205 2/80

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TABLE 6.1 8

SUMMARY

OF RESPONSIBILITIES FOR PROJECT DOCUMENTS NES V. P, or Task Project QA General y

Document Engineer Manager Manager Manager p

E QA Manual A

A m

E QA Program Plan P/A A

A g

O Design Criteria P/A A

j m

Calculation Notebooks P

A T

E5 Detail Drawings P/A A

A Cask Fabrication Specification P/A A

A A

Auxiliary Equipment Fabrication Specification P/A A

A A

Weld Procedures and Qualifications P/A A

T C

NDE Procedures E

and Qualifications P/A A

T

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NDE Test Reports P/A E/A T

gj Weld Material Control P

A T

Repair Procedures P

A T

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I TABLE 6.1 (CONTINUED)

S S

SUMMARY

OF RESPONSIBILITIES FOR PROJECT DOCUMENTS NES V. P.or Task Project QA General z

Document Engineer Manager Manager Manager E

I Cleaning Procedure P

A T

m Material Certifications R

T g

m Nonconformance Reports P/A D/A P/A un Corrective Action Requests D

P/A D

$<6 QA Audit Reports R

P/A R

g Handling / Shipping Procedures P

A A

A

)

Loading /Use Procedures P

A A

A l'

Repair / Maintenance Procedures P

A A

A O

R CE m

Legend:

A = Review and Approve D = Disposition z

E = Evaluate S

.O P = Prepare R = Review T = Audit 5

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7. DOCUMENT CONTROL Project documents shall be controlled in accordance with the provisions stated in the appropriate sections of the NES QA Manual, as well as the procedures referenced therein. Documents to be controlled shall include, but not be limited to the following:

a.

Design documents b.

Procurement documents c.

QA Manuals and referenced procedures d.

Maintenance and repair procedures e.

Handling and shipping procedures f.

Loading and use procedures g.

NDE and test procedures h.

Nonconformance reports i.

Change request authorizations (CRA's) j.

Corrective action reports (CAR's)

The Project Manager is responsible for ensuring that all documents, and changes thereto, are available to all Task Engineers at the location where the activity is performed. Revised documents shall receive the same level of review and approval given the original documents.

A Master Document List of design, handling, loading and maintenance documents shall be maintained by the NES Document Control department per procedure 80A9003; a corresponding Document Distribution Log shall also be kept to ensure that revised documents are distributed to all persons designated by the Project Manager.

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3. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES The control of purchased material, equipment and services for the NES Transport Cask program shall be performed by NES in accordance with Section 7 of the NES QA Manual. The NES QA Department shall be responsible for evaluating vendors by means of routinely scheduled audits or by past technical and quality performance. WMS shall only place orders for Category 1 items (as defined in Section 4 of the NES QA Manual) with vendors judged suitable by the NES Q.A. Department which is evidenced by their listing on the NES Approved Vendor's List.

The applicable aspects of the Transport Cask QA Program Plan shall be imposed upon vendors including the provisions of 10 CFR 21.

All identified nonconforming conditions shall be submitted to WMS for disposition per Section 15 of the NES QA Manual. NES QA shall audit and perform source and receipt inspections to ensure adherence to project requirements indicated in the Fabrication Specification.

Certified Material Test Reports and/or Certificates of Conformance shall be required for all material and equipment purchased unless waived by WMS.

9. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS NES shall identify and control materials, parts and components by implementing the program outlined in Section 3 of the NES QA Manual. The NES Q.A. Department shall audit NES operations to ensure adherence to these requirements.

Vendor and subcontractor audits shall also be performed to verify the correct implementation of a traceability program approved by N ES.

Traceability of materials to original certifications shall be maintained.

I Routine maintenance performed by WMS shall adhere to the requirements outlined in the applicable procedures.

All nonconforming items shall be tagged as such and segregated until the disposition has been approved by WMS.

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10. CONTROL OF SPECIAL PP.DCESSES NES shall be responsible for the control of special processes which includes the preparation of procedures for each of the special processes identified in Table 6.1. All special process procedures shall be written in accordance with applicable codes and standards, and qualified accordingly.

Special process procedures performed by a vendor or subcontractor shall be submitted to WMS for review and approval prior to use. Personnel qualifications shall also be submitted.

If the procedure is approved with comment, it shall be revised and resubmitted to WMS for subsequent approval. Qualification records of procedures and personnel shall be maintained on file by the vendor or subcontractor. These records are subject to audit by the NES QA Manager or designated QA Engineer.

The applicable NES Fabrication Specification or Maintenance / Repair Procedure will outline the inspections to be performed on each special process operation. When performed by a subcontractor, these inspections shall be called out in the shop traveler or equivelent ppcess control sheet. If the work is judged acceptable by the qualified Inspector, he will so document. Work performed by NES personnel shall be subject to inspection by an NES Q.A. Engineer who is responsible for documenting the inspection.

11. INSPECTION AND TEST CONTROL NES' responsibilities shall include procedure preparation, implementation and documentation of the inspections and tests required by the Fabrication Specifications and Maintenance / Repair Procedures.

The required inspections and tests shall be identified in the appropriate specifications, procedures or shop travelers and shall be performed in accordance with Sections 10 and 11 of the NES Q.A. Manual, as i

appropriate. All procedures shall be approved by WMS prior to use and shall include f

sampling plans and acceptance criteria (as deemed necessary).

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Any equipment used to perform inspections and tests shall be of the proper range, type

,i and accuracy, and shall be controlled and calibrated in accordance with the appropriate QA Manual and procedures.

Nondestructive testing personnel shall be qualified in accordance with the applicable codes and standards.

Personnel qualifications and equipment calibration records will be subject to audit by NES Quality Assurance.

The required Hold Points and Witness Points shall be specified in the NES Fabrication Specifications and Maintenance Procedures. WMS and Q.A. reserve the right to attend all Witness and Hold Points. Subcontractors shall give WMS (5) working days notice so representatives may witness and verify the inspections and tests.

NES shall be responsible for ensuring that all inspections called for in the Handling, Shipping, Loading and Use Procedures are adhered to. NES QA shall periodically audit these operations to verify effective implementation.

l

12. CONTROL OF MEASURING AND TEST EQUIPMENT Measuring and test equipment used on the NES transport cask program shall be controlled per the provisions of Section 12 of the NES QA Manual. All equipment shall be calibrated and maintained at prescribed intervals, and so labeled.

Calibration records shall be traceable to applicable nationally recognized standards and kept on file. Calibration records are subject to audit by the NES QA Department. Any measuring or test equipment found to be defective will be brought to the attention of the NES QA Manager. All parts or materials inspected by the defective equipment shall be re-inspected.

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Subcontractor's procedures for the control of measuring and test equipment shall be 4

l reviewed and approved by NES prior to use, and its implementation shall be verified periodically by NES Q.A. audits.

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13. HANDLING, STORAGE AND SHIPPING f

WMS shall be responsible for documenting the cleaning, handling, storage and shipping requirements necessary to preclude damage or deterioration by environmental conditions in the NES Fabrication Specification or appropriate procedure.

NES' and subcontractor's responsibilities shall include the preparation and implementation of procedures incorporating the requirements for cask handling storage and shipping. These procedures shall be subject to WMS review and approval prior to use.

Adherence to approved procedures shall be verified by the NES Q.A. Department.

During routine use and maintenance, NES Q.A. shall verify the adherence of work performed by NES personnel to the applicable procedures.

14. INSPECTION, TEST AND OPERATING STATUS NES shall be responsible for controlling the status of all fabrication, maintenance and repair work associated with the NES Transport Cask program in accordance with i

Section 14 of the NES QA Manual.

i Shop travelers or process control sheets shallidentify required operations, inspections, tests and Hold Points. A qualified Inspector shall perform the specified inspections or tests and document the test accordingly. Nonconforming items shall be so tagged and j

segregated until approval of the disposition is obtained from WMS.

Adherence to these procedural requirements are subject to audit by the NES Quality Assurance Department.

Routine maintenance performed by NES shall adhere to approved procedures and shall be verified by the NES Q.A. Department.

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15. CONTROL OF NONCONFORMING MATERIALS, PARTS OR COMPONENTS f

NES shall be responsible for the control of nonconforming items in accordance with the procedure outlined in Section 15 of the NES QA Manual. Control includes the following:

Identification (tagging) a.

b.

Segregation c.

Preparation of Nonconformance Report d.

Determination of Cause and Action to Prevent Recurrence Recommended Disposition (Rework Traveler) e.

f.

Evaluation of Quality Trends (RN Log)

Af ter a subcontractor's Nonconformance Report has completed their internal review and approval cycle, it shall be submitted to WMS (through the Project Manager) for final review and approval (per Section 15 of the NES QA Manual and Procedure 80A9008). All nonconforming items shall remain tagged and segregated until written approval of the Nonconformance Report is obtained from WMS including approvals by the Project Manager and NES QA Manager.

The subcontractor's Q.A. Department shall verify by inspection or test that the approved disposition was implemented per the approved instructions received from NES.

16. CORRECTIVE ACTION Section 16 of the NES QA Manual outlines the measures established by NES to ensure that the causes of conditions adverse to quality are:

l a.

Identified to management b.

Evaluated to determine corrective action c.

Evaluated to determine actions to prevent recurrence d.

Corrected by implementation of the corrective action FORM s NES 205 2/80

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NUCt EAR ENERGY SERVICES In the case of ;nternal quality problems, the QA Manager shall issue Corrective Action Requests (CAP'd to the responsible individual for response. If the QA Manager judges the response to be adequate, he shall sign the CAR to signify his acceptance of the response.

For all conditions identified as adverse to quality on the NES Transport Cask program, approval by WMS is required prior to implementing the corrective action.

The NES QA Department shall be responsible for verifying that corrective actions and actions to prevent recurrence have been effectively implemented. Upon verification, Q.A. shall close out the applicable CAR.

Subcontractor's corrective actions are subject to monitoring and/or audit by NES QA.

17. QUALITY ASSURANCE RECORDS The NES Project Manager shall be responsible for maintaining the Project File for the NES Transport Cask program in accordance with Section 17 of the NES QA Manual and the implementing procedures referenced therein (80A9009 and 80A9099). The Project Documents to be retained by NES, and the duration of retention, are listed in Table 17.1.

Subcontractors shall be responsible for maintaining adequate manufacturing and quality control records as required by the QA Program Plan and applicable NES Fabrication Specifications. Copies of those documents identified in Table 17.1 which are maintained by the subcontractor shall be submitted to the NES Project Manager d

for inclusion in the Project File.

t Subcontractors shall maintain all records applicable to this project indefinitely. In lieu of this requirement, the subcontractor may submit a list of project files to the NES I

Project Manager for his determination as to which records must be retained and which can be disposed of.

The subcontractor will then submit those files selected for retention to the Project Manager for inclusion in the Project File.

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NUCLEAR ENERGY SERVICES TABLE 17.1

)

PROJECT QUALITY ASSURANCE RECORDS LIST Quality Assurance Record

• Retention Period 1.

Design Drawings Lifetime 2.

As Built Drawings Lifetime t

3.

Personnel Qualifications Lifetime

.i 4.

Fabrication Specifications Lifetime 5.

Fabrication Procedures and Qualifications Lifetime 6.

NDE Procedures and Qualifications Lifetime 7.

Inspection / Test Procedures Lifetime 8.

Cleaning Procedures Lifetime 9.

Handling, Packaging and Shipping Procedures Lifetime 10.

Loading and Use Procedures Lifetime 11.

Maintenance and Repair Procedures Lifetime 12.

Material Certifications Lifetime 13.

Project Specific Documents Lifetime a.

QA Program Plan i

b.

Design Criteria c.

Safety Analysis Report d.

NRC Certificate of Compliance j

14.

Purchase Orders Lifetime t

}

NOTE:

Lifetime indicates the useful life of the applicable cask which terminates upon expiration of the NRC Certificate of Compliance.

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18. AUDITS J

Planned and documented audits shall be performed to verify compliance with project design, fabrication, maintenance and repair activities as outlined in the QA Program Plan and related project documents.

The minimum level of audits for the NES Transport Cask program will be per the following as applicable:

a.

Design Audits i

For NES designed transport packages, the design phase of this project will have a minimum of two (2) scheduled audits.

The first audit will occur after approximately fifty percent (50%) of the final design is completed; the second audit wi" occur after the design phase has been completed. These design audits will be performed by the NES QA Department on NES personnel and activities.

b.

Fabrication Audits For a package constructed by NES or a subcontractor, the fabrication phase of the NES Transport Cask program will be subject to a minimum of two (2) scheduled audits by the NES QA Department. The first audit will occur af ter approximately thirty percent (30%) of the fabrication activities are completed; the second audit shall occur af ter seventy-five (75%) of the fabrication activities are completed. The areas audited sha:1 include, but not be limited to the following:

(

l.

Welder qualification j

2.

Use of approved procedures 3.

Material certification 7

l 4.

Receipt inspection

)

5.

Verification of Fabricator's QA Manualimplementation 6.

Implementation of inspection and test procedures i

7.

Implementation of packing and shipping procedures

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8.

Maintenance of QA records 9.

Verification of Fabricator's nonconformance reporting procedure

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t FORM s NES 205 2/80

2 11 DOCUMENT NO.

31 A 1050 W

NUCLEAR ENERGY SERVICES The subcontractor's QA Department shall incorporate NES Transport Cask activities into their routine internal audit schedule as deemed necessary.

c.

Maintenance The routine maintenance of the NES Transport Casks shall be incorporated into

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the Program Audit schedule of the NES QA Department to ensure adherence to procedures.

Audits performed by the NES QA Department shall be planned, scheduled and performed by qualified personnel in accordance with the provisions of Section 18 of I

j the NES QA Manual and referenced procedures.

l The responsibility for scheduling and conducting audits, reporting findings and verifying timely and effective implementation of corrective actions shall be the responsibility of the respective QA Managers.

I i

i 1,

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.I i

4 i

9 i

d l

I FORM 8 NES 205 2/80 t