ML20237C702
| ML20237C702 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/15/1998 |
| From: | UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | |
| Shared Package | |
| ML20237C694 | List: |
| References | |
| NUDOCS 9808240079 | |
| Download: ML20237C702 (120) | |
Text
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APPLICATION FOR UNITED STATES NUCLEAR REGULATORY CO.TDilSSION CERTIFICATION h
PADUCAll GASEOUS DIFFUSION PLANT REMOVE / INSERT INSTRUCTIONS AUGUST 15,1998 REVISION 26 Remove Pages Insert Pages VOLUME 1 List of Effective Pages List of Effective Pages LOEP-1/LOEP-2, LOEP-3/LOEP 4, LOEP-1/LOEP-2, LOEP-3/LOEP-4, LOEP-5/LOEP-6, LOEP-7/LOEP-8 LOEP-5/LOEP-6, LOEP-7/LOEP-8 Section 1.0 Section 1.0 1-7/1-8, 1-9/1-10 1-7/1 8, 1-9/1-10 Section 3.3 Section 3.3 3.3-57/3.3-58 3.3-57/3.3-58 Section 3.6 Section 3.6 3.6-5/3.6-6 3.6-5/3.6-6 VOLUME 2 List of Effective Pages List of Effective Pages LOEP-1/LOEP-2, LOEP-3/LOEP-4, LOEP-1/LOEP-2, LOEP-3/LOEP-4,
/~'T LOEP-5/LOEP-6, LOEP-7/LOEP-8 LOEP-5/LOEP-6, LOEP-7/LOEP-8 b
Section 4.3 Section 4.3 4.3-3/4.3-4, 4.3-4a/4.3-4b 4.3-3/4.3-4, 4.3-4a/4.3-4b VOLUME 3 Quality Assurance Program Quality Assurance Program Entire Plan Entire Plan Emergency Plan Emergency Plan ill/iv,1-1/1-2,1-9/1 10,1-11/1-12, 4-1/4-2, 4-3/4-4, iii/iv,1-1/1-2,1-9/1-10,1-11/1 12, 4-1/4-2, 4-3/4-4, 6-5/6-6 6-5/6-6 FNMCP FNMCP lii/iv, xi/xii, 2-9/2-10, 4-1/4-2, 4 3/4-4, 4-5/4-6, iii/iv, xi/xii, 2-9/2-10, 4-1/4-2, 4-3/4-4, 4-5/4-6, 4-13/4-14, 7-3/7-4, 7-5/7-6, 9-3/9-3a,12-1/12-2, 4-13/4-14, 7-3/7-4, 7-5/7-6, 9-3/9-3a, 12-1/12-2, 12-5/12-6, 13-3/13-4 12-5/12-6, 13-3/13-4 Transportation Security Plan Transportation Security Plan iii/iv,1/2 ill/iv,1/2 I
VOLUME 4 List of Effective Pages List of Effective Pages il ii
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B T5
SAR-PGDP -
August 15,1998
/3 Rev. 26 U
Recirculating Pumps One of the two recirculating pumps is operating continually to supply lube oil to the unit supply header and the supply tank. A!! lube oil alarms and automatic pump starts are checked on a weekly basis.
The normal power supply to the lube and hydraulic oil pumps in C-333 and C-337 is fed from the 480-volt auxiliary power system. In C-333 and C-337, the system contains permanent ties from two different substations plus an automatic tie-breaker system that will furnish power from either substation.
In C-331 and C-335, a manual disconnect can be closed to furnish auxiliary power from a different pair of substations. The C-310 building has both a manual dir.onnect and an automatic tie-breaker that will fumish power from another substation. Each of these substations receive power from a separate feeder so that one feeder can be out and normal power is still available to the lube oil pumps.
The supply line motor-operated valve is also electrically interlocked to prevent the recirculating pumps from operating when the valve is closed. Another electrical interlock prevents the valve from being closed when either pump is running.
Recycle Line The lube oil system maintains a proper supply tank level by using a recycle line. All of the unit tube
' oil systems are equipped with a manual recycle valve for coarse adjustments and all buildings, excluding C-315 have an automatic recycle adjustment used for fine control. When the oil level in the gravity l
(g supply tank increases or decreases, the float connected to the system's level-indicating instrumentation V) changes, and therefore, increases or decreases the controlled pneumatic output to the connected pressure switches, pressure gauges, and level controls. Upon low level, the lube oil systems with automatic recycle control close the automatic recycle control valve in the lube oil pump recycle piping, allowing the entire pump output to be pumped to the building cell header system with the excess being pumped to the supply tank, if the oil level drops further, a pressure switch closes and actuates an ACR alarm and automatically energizes the motor circuit to the standby lube oil pump. When the standby pump has I
increased the level of oil to a predetermined high point, the alarm clears, but the standby tube oil pump remains in operation until manually shut down. If the supply tank oil level drops even lower, the low-low alarm in C-300 is actuated. However, if the lube oil level becomes too high, the pressure switches actuate high-level alarms in the ACR and in C-300 (see Table 3.3-11). In process buildings that have automatic lube oil recycle control, the level controller opens the control valve to allow more lube oil to recirculate through the pumps. In both instances, the manual recycle valve must be set in proper position for the automatic recycle valve to function properly.
To correct a high lube oil level condition in the gravity supply tank for C-315 which does not have autott.atic recycle, operations personnel manually adjust the lube oil recycle control valves. Only one lube oil pump is operating under a high lube oil level condition. The recycle system, both manual and automatic, bypasses enough lube oil to the suction of the pumps to maintain the lube oil at the operating level. If for some reason an automatic recycle control system fails and the supply tank lube oil level increases beyond the operating level, an alarm would be received and the manual recycle valves must be adjusted to return the supply tank level to normal.
O V
3.3-57
SAR-PGDP-September 15,1995 Rev.I Strainers After the oil is discharged from the recirculating pumps, it passes through an oil strainer for the removal of foreign material that can damage bearing surfaces. Lube oil strainers in the *00" buildings are of the double basket or " twin" type, while the "000" buildings contain duplex strainers with four baskets in each side. Operations personnel switch a strainer if the differential pressure across the strainer exceeds normal. The normal pressure drop across the strainer varies from unit to unit. Operations personnel check each strainer for plugging. During each shift, the differential pressure across the filter and the oil temperature are checked and logged.
The only instmmentation on the unit strainer in C-337 is a pressure gauge located in the tube oil pit area. The gauge is valved to measure pressures from either upstream or downstream of the strainer. In the other process buildings, the differential pressure across the unit strainer is indicated by an upstream and a downstream pressure indicator.
The pressure gauge or gauges checking differential pressure across the unit strainer give only a local indication of strainer conditions. Operations personnel are made aware of an immediate plugging condition by visual and audible alarms in the ACR. The alarm is activated by a pressure switch located in the tube oil header on the inlet to the unit tube oil strainer. The lube oil acts as a pressure medium to this switch. The pressure switch is set to actuate an alarm in the ACR when the tube oil operating pressure increases approximately 2.5 psig above normal.
Lube Oil Cooler The lubricating oil leaves the strainer to pass through a shell and tube heat exchanger which removes heat from the oil before it is pumped to the equipment bearings on the cell floor. Cooling water from the RCW system flows through the tubes of the heat exchanger while the oil enters on the shell side.
The lube oil temperature is maintained at 115-125*F in the buildings. This is obtained by regulating the water inlet valve manually in C-310, C-315, and C-337. In C-331, C-333, and C-335, the temperature regulation is accomplished automatically. The instrumentation associated with the lube oil heat exchanger in C-331, C-333, and C-335 controls the flow of RCW from the RCW supply header through the exchanger. C-310, C-310-A, C-315, and C-337 use manual valves for controlling RCW flow. The main lube oil piping leav.ng the lube oil exchangers contains the temperature sensor for the temperature control system.
Operations personnel can read the RCW pressure that is present in the lebe oil coolant system by means of a pressure gauge. The normal water pressure in the exchanger tubing is approximately 20 psig.
In C-331 and C-335, the lube oil pressure is maintained higher than the RCW pressure by means of an orifice plate on the exchanger oil outlet. This pressure differential is maintained by a manual oil discharge valve in C-337. C-333 has uprated lube oil pumps which maintain the oil pressure above water pressure.
3.3-58
SAR-PGDP--
August 15,1998
(~]
Rev.26 V
The building is constructed of structural steel with build-up roof, cement-asbestos, and metal siding and has concrete floor slabs and foundations. Seismic design consideration is in accordance with Energy Research and Development Agency (ERDA) Criteria Appendix 6301 and Universal Building Code (UBC)
Zone 3.
Ventilation for the general work area in C-360 is provided by one 50,000 cfm supply fan and six 47,150 cfm exhaust fans. The supply fan is in operation prior to draining UF. to the transfer station at the basement level. The fan and UF. drain valve are interlocked to ensure ventilation in this area.
Louvers provided in the building siding aid ventilation. Each autoclave is connected to a small 1,500 cfm exhaust system that provide local ventilation for occasional small releases of UF. exhaust that may occur when making or breaking pigtail connections. Operation of the exhaust system is actuated by a manually operated switch located between autoclaves 2 and 3, and the exhaust effluent is passed through a high efficiency particulate filter for removal of any uranium particles prior to venting to the atmosphere.
There is an exhaust hood over the transfer filling station. The effluent from this hood is also passed through high efficiency particulate filters prior to release to the atmosphere.
3.6.3 Autoclaves C-360 has four containment-type autoclaves used to heat cylinders for sampling and transferring UF.
Each autoclave is a steam-heated pressure vessel with an MAWP of 150 psig and with the necessary instrumentation for the sensing and containment of UF releases that might occur when a cylinder containing UF. is being heated, sampled, or transferred. These units are approximately 23 ft long with an internal diameter of 8 ft and are mounted with their long axis horizontal. One section of the autoclave (head) is permanently fixed in position, while the remaindsr of the vessel (shell) is movable to permit the p)
('
introduction and removal of UF. cylinders. The cylindrical autoclave is parted normal to its axis about j
3% ft from one head. The shell section is mounted on a wheel and track system, which allows opening i
and closing of the autoclave by translation down its main axis. This motion is provided by a hydraulic
{
ram. When in the closed position, the shell is secured to the head by a hydraulically operated locking
]
ring and a captured 0-ring seal. To protect personnel from potential steam burns, an interlock prevents opening the autoclave shell if pressure in the autoclave exceeds 1.25 psig. Travel time to fully open the autoclave is approximately one minute.
In the open position, each autoclave has an extended length of about 39 ft and an opening 15 ft long through which a cylinder is placed on the horizontal support chain inside the autoclave. The overhead crane is used to position the cylinder. The support chain is power-driven to permit the cylinders to be rotated for sampling and transfer operations. When the autoclave is in the open position, a tilting mechanism can be used to elevate the plugend of the cylinder a distance of about 18 in. to enhance liquid transfer from the cylinder inside the autoclave to the receiving cylinder positioned at the withdrawal station. An air buffer flow to the actuator motor and cylinder roll motor is maintained to keep steam out of the electrical circuits and aid in cooling the motors and circuits. A roll interlock system prevents I
rotation of the cylinder. The pigtail is pressurized by monitoring the UF. manifold pressure.
I Service lines that penetrate the autoclave are controlled by redundant isolation valves which close automatically when the autoclave goes into containment to prevent the escape of reaction products in the event of a release inside the autoclaves. Penetrations through the head include the steam supply line, UF6 1
d 3.6-5 l
l
SAR-PGDP-August 4,1997 Rev.13 sa- )le transfer line, condensate drain line, buffer air line, vent line, UF drain line, valve closer, aunclave temperature thermowell, and electrical connection to roll and tilt. Figure 3.6-3 provides a simplified schematic of a C-360 autoclave and the associated piping.
The following valves / barriers isolate service lines:
Steam supply line - valves XV *S3 and FV *05, and FV *24.
Conductivity cell sample line - valves FV *00 and FV *10.
UF sample transfer line - valves XV *48, XV *51, and PL *33.
Condensate drain line - valves FV *03 and FV *46.
Buffer air line - valves XV-511 *A, XV-511 *B, XV-511 *C, TP-511
- and check valve CKV-511 *.
Vent line - valves FV *00 and XV *34, vacuum breaker valve PSV *20 and PSE *32.
UF. drain line - valves XV *50, XV *52, FV *47, and PL *35.
Drain line to sample cabinet valves XV *49 and XV *52.
Each autoclave is designed to withstand the pressure developed by the exothermic reaction of UF.
with the steam vapor and the condensate present. The pressures generated in an autoclave are a function of the autoclave free-volume and total water inventory (see Section 4.2.3).
2 The C-360 sample-transfer autoclaves have a 1,100 ft volume and are designed for a 150 psig maximum allowable working pressure at 235'F. To ensure the maximum allowable water inventory the autoclave is maintained below the amount necessary to overpressurize the autoclave in the event of a UF6 release. Redundant condensate high level probes, LE *07 and LE *08, are mounted at the same elevation in the condensate drain slightly below the autoclave floor. Any abnormal accumulation of condensate in the drain line reaching the level of these probes automatically shuts the steam isolation valves, XV *S3 and FV *05, and the thermovent line block valve FV *34, and prevents the addition of more water.
l As a protection against catastrophic overpressure, each autoclave is provided with a rupture disc in series with a pressure relief valve set at 150 psig. In the event of a UF release in which a failure of the 6
condensate level system had allowed the autoclave to accumulate an excessive water inventory, the resulting overpressure would be relieved to the atmosphere by a vent line above the C-360 roof. The autoclave would then contain all reaction products remaining at a pressure below the set point of the relief valve.
Steam is introduced into the autoclave as a heating medium and to maintain cylinder temperature.
In the event of a UF release, reaction products of UF and water are detected by redundant conductivity 6
cells which constantly monitor a sample of the autoclave atmosphere. The conductivity cells are intended to detect small releases of UF. that do not generate a significant pressure rise within the autoclave. The cell is extremely sensitive to the HF component of the UF. reaction with water and detects concentrations of only a few parts per million. When triggered, this cell initiates an autoclave containment signal that closes the steam supply line, vent line, UF sample transfer line, condensate drain line, and buffer air line 6
isolation valves. If the conductivity cell detects reaction products in the steam condensate, the condensate drain line valve automatically closes. Operator action is required to switch the discharge path from the storm sewer to two condensate holding tanks. Tests of this cell by controlled release of HF into an operating autoclave have shown the response time to be in the order of 30 to 60 seconds.
3.6-6 l
l
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)
i Because the cylinder valve is always in the 12 o' clock position, any UF. released from a leak at the valve or pigtail connection would be in the vapor phase. The UF, would react with the available water to form HF which would be detected within 30 see by the conductivity cells. If the leak were small, the autoclave pressure would not rise rapidly and the conductivity cells would detect the leak and sound an alarm locally and in the control room. A loss of power or a containment signal generated either by the conductivity cells or the autoclave high pressure isolation safety system will also cause the cylinder valve to automatically close, thus terminating the UF release into the autoclave. The cylinder valve is closed 6
with an air-operated cylinder valve closer at each autoclave.
It is expected that the cylinder valve will close in no more than 2 minutes. The amount of UF 6
released inside the autoclave would depend on the size of leak, but would be no more than 80 lbs/ min.
The only reaction products to leave the autoclave would be those exiting through the condensate drain line (and the vent line during initial heatup) in the time required to detect the release and isolate the i
autoclave. Any release large enough to cause a significant release via the condensate sample line would also cause a pressure great enough to actuate the autoclave UF high pressure isolation safety system.
6 The autoclave steam pressure control safety system utilizes pressure sensors which are set to close the steam inlet valve if autoclave pressure exceeds 8 psig. If the autoclave pressure continues to rise, the autoclave high pressure isolation safety system will put the autoclave into containment at 15 psig. All redundant block valves will close within 10 see following the signal from the pressure sensors.
Figure 4.3-2, from the Barber calculations, shows that during a large release the autoclave pressure t
-Q rises rapidly, reaching a maximum in less than 30 seconds.2 In this case, the use of a pressure sensor l
provides a more rapid isolation than that obtained frem a conductivity cell. Because the Barber calculations are based on a completely closed vessel, tests have been conducted to prove that the pressure rise is fast enough to actuate a pressure sensor for rapid isolation of the autoclave, despite the pressure loss caused by the open condensate drain and conductivity cell sample line isolation valves. These valves would be open during operation. Figure 4.3-3 shows that pressure decay characteristics of a typical l
l autoclave from 90 psig with the drain and sample line valves open. Figure 4.3-4 shows the pressure decay from 50 psig with selected valves closed. Consequently, the autoclave isolation system is initiated L
by the pressure sensor for those releases having a large and rapidly rising pressure for which the reaction time of the conductivity cell could be marginal, and by the conductivity cell for those releases which are small and result in a pressure below the trip point of the pressure sensor.
l The amount of reaction products lost through the condensate drain line would be too small to present any health hazard. The amount of UF./H O reactica products released through the condensate drain is 2
i l
4.3-3
SAR-PGDP-August 15, 1998 Rev. 26 not vastly different regardless of whether the incident is detected and terminated by the conductivity system or by the autoclave high pressure isolation system. The following discussion assumes the conductivity system fails.
For very small releases from the cylinder (2 lb/ min UF ), the pressure rise would be slow, resulting in the condensate drain remaining open for a longer period of time until the pressure rises to a level sufficient to actuate either the autoclave steam pressure control or the autoclave high pressure isolation system. However, because of the low release rate, a relatively small quantity of UF /H O reaction 2
products are available for release out the condensate drain. The estimated release of UF /H:0 reaction products through the condensate drain line is 0.1 pound UO F if the conductivity system detects and 2 2 terminates the incident, and 2.9 pounds UO F if the autoclave high pressure isolation system detects and 2
terminates the incident.
As the UF release rate from the cylinder / pigtail increases, the amount of UF. /4 0 reaction products 6
available for release increases accordingly. However, the pressure transient would be correspondingly more rapid, resulting in quicker detection and termination by the autoclave high pressure isolation system.
Consequently, the condensate drain line would be open for a shorter period of time. The estimated release of UF./H O reaction products through the condensate drain line for a release rate of 20 lb/ min 2
UF. from the cylinder is 2.4 pounds of Up2F if the conductivity system detects and terminates the incident, and 2.4 pounds UO:F: if the autoclave high pressure isolation system detects and terminates the incident. At release rates greater than 20 lb/ min UF from the cylinder, the autoclave high pressure isolation system detects the incident more rapidly, and the amount of UO F released decreases (to 2 2 0.2 pounds UO:F at an 80 lb/ min UF release rate from the cylinder).
2 The feed autoclaves are designed with a maximum allowable working pressure (MAWP) of 200 psig.
Assuming full UF. reaction with the maximum allowable water inventory in the autoclave, there would be no release to the atmosphere. Calculations show that following an initial pressure spike to 103 psia, autoclave pressures will not exceed 87 psia as a result of the accident postulated above. Should the UF.
react with an excessive amount of water, the autoclave is protected from overpressurization by the autoclave pressure relief safety system. This system consists of a rupture disk and relief valve which vent reaction products to the atmosphere. The relief system is sized to prevent pressures from exceeding 110% of the MAWP. The relief valve recloses at the MAWP to limit any potential release.
The likelihood of su:h an a:cident happening in an autoclave is considered to be low due to the administrative controls concernmg testing of cylinder valves, pigtails, and connections.
A release resulting from a valve or pigtail failure with the autoclave open would be detected by the UF. release detection system lateJ above the autoclave locking ring and alarmed in the local area, the ACR, and C-300. An aute:la,e closure button is available near the autoclave head which must be continuously depressed to clme the autoclave. The administrative controls referenced above are relied upon to prevent releases with the autoclave open.
A release from a line outside the autoclave would be detected by the UF. release detection system located in the heated housing, at the jet stations, and in piping trenches and alarmed in the local autoclave area, the OMR, and the associated ACR. The autoclave manual isolation system provides a remote isolation device at the feed facility operations monitoring room (OMR), at the cylinder yard crane bay exit, which is the most libly point of egress from the autoclave area, and the ACR.
4.3-4
i SAR-PGDP~
August 15, d98 (7
Rev. 26 G'
4.3.1.1.2 Cylinder Drop and Puncture All UF. feed cylinders are moved to the autoclaves with overhead cranes. The possibility of a cylinder drop due to crane or lifting fixture failure is always present. The drop and subsequent puncture of a UF. feed cylinder does not present a serious safety concern because the US in the cylinder is in the solid state. Cylinders are empty (except for heel quantities of UF and/or non-volatile uranium-bearing 6
compounds such as UO:F ) when removed from the autoclaves and no unique safety hazard is present 2
in this operation.
On rare occasions, a cylinder which is filled or partially filled with liquid UF may develop a 6
plugged valve. If this condition should arise, the cylinder is not removed from the autoclave until it has solidified. It can then be moved to the cylinder yard. The feed facility overhead cranes are not approved for handling liquid cylinders. Options are being pursued to approve the C-337-A double hook crane to handle liquid cylinders.
Failure of crane cables, hooks, brakes, and controls are considered unlikely because of the routine maintenance and periodic inspections by qualified inspectors.
4.3.1.1.3 Autoclave Leakage The autoclave / gasket / isolation valve system will be tested at accident pressure. The accident pressures appear to spike to approximately 103 psia and then relax to about 85 psia for the C-360 p) t autoclaves; the other autoclaves will reach a pressure of about 96 psia. Therefore, a test pressure of 90 psig (104.7 psia) will be used for all autoclaves.
The leakage of the autoclave may be measured as an air leak rate or pressure decay rate. The allowable leakage will be less than or equal to 12 standard cubic feet of air per minute or a pressure decay ofless than 10 psig in one hour with the autoclave at peak accident pressure. Derivation of these leak rates is shown below.
The autoclave containment system will be tested quarterly and prior to the routine replacement of the gasket. The time to gasket failure and the number of use cycles to failure will be recorded. The proofing of an adequately installed new gaskct shall be by a pressure decay test or leak rate test. The autoclave containment system will also be tested every time a component whose performance could impact containment performance is replaced.
Allowable Leakage Rates The allowable leakage of the autoclave should be less than or equal to 12 standard cubic feet of air per minute or a pressure decay of less than 10 psig in one hour with the autoclave at peak accident pressure. These limits are derived as follows:
U 4.3-4a l
I
SAR-PGDP-May 31,1996 Rev. 3 1.
This leak rate, assuming the instantaneous dispersion within the hemispherical volume defined by the point of the leak and the exit from the facility, approximately 75 feet, limits the intake to a worker following the plant "see and flee" policy to less than 10 mg of uranium. According to the NUREG-1391, a 10 mg intake of uranium is approximately the threshold value for transient kidney l
damage. It is also the weekly limit for soluble uranium intake specified in 10 CFR 20. The l
Statement-of-Considerations for 10 CFR 76 identifies a 30 mg uranium acute intake as a level where l
kidney damage may result.
l l
2.
Exposure Volume = 2/3 x x x (75)' = 883,575 ft' or 883,575 x 2.832E-2nf /ft' - 25,022 nl l
l 2
3.
Intake = Average Air concentration (mg/m ) x 1.2 m3/hr x Exposure Time (minutes)/60.
Air Concentration - intake x 60/1.2 or 500 mg/m' I
4.
This concentration is an average concentration for the workers intake, therefore the pounds of l
uranium leaked is equal to the concentration times the exposure volume divided by 454,000 mg/#.
l
- U leaked = 500 x 25,022/454,000 = 27.5 pound 5.
The appropriate leak rate is 27.5 pounds per minute; this converts to a leak rate of 160 scfm.
l For a one minute exposure, the HF concentration derived in NUREG-1391 as 137 mg/m'. Four moles of HF are formed when one mole of UF. reacts with water vapor and condensate. The concentration of uranium associated with 137 mg/m of HF is:
3 2
1.
1/4 x (137/20,000) x 238,000 or 408 mg/m l
l 2.
The uranium release, for a one minute release that is, produces an exposure of 408 mg/m is l
2 l
408/454,000 x 25,022 = 22.4 pounds per minute.
3.
This couverts to a leak rate of 132 standard cubic feet per minute at peak accident pressure.
If the above leak rates are divided by a factor of 10 to account for dispersion model and evacuation time uncertainties, it is recommended that 12 scfm be used as the leak rate for the test at peak accident pressure. This corresponds to a pressure loss of 24 psig per hour and 12 psig per hour for the feed and sampling autoclaves respectively.
I The pressure decay (in psi per hour) for a feed autoclave with a volume of 622 ft' is computed as l
follows:
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Quality Assurance Program - GDPs August 15,1998 Rev.26 LIST OF EFFECTIVE PAGES Eggs Revision Pagt Revision lii 26 36 26 iv 26 37 26 v
26 38 26 vi 26 39 26 vii 26 40 26 viii 26 41 26 42 26 1
26 A-1 26 2
26 A-2 26 3
26 A-3 26 4
26 A-4 26 5
26 A-5 26 6
26 A-6 26 7
26 A-7 26 8
26' A-8 26 9
26 A-9 26 10' 26 A-10 26 11 26 A-11 26 12 26 A-12 26 13 26 A-13 26 s
14 26 A-14 26 15 26 A-15 26 16 26 A-16 26 17 26 A-17 26 18 26 A-18 26 19 26 A-19 26 20 26 A-20 26 21 26 A-21 26 22 26 A-22 26 23 26 B-1 26 24 26 B-2 26 25 26 C-1 26 26 26 C-2 26 27 26 C-3 26 28 26 C-4 26 29 26 30 26
-31 26 32 26 33 26 34 26 35 26 i
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Quality Assurance Program - GDPs August 15,1998 C
Rev.26 CONTENTS Paan
- 1. INTRODUCTION 1
- 2. REQUIREMENTS.............
................................ I t
2.1 ORG ANIZATION.......................................
1 2.2 QUALITY ASSURANCE PROGRAM..........................
2 2.2.1 General.........................................
2 2.2.2 Scope..........................................
2 l
2.2.3 Program Implementation.............................
4 2.2.4 Indoctrination and Training 4
l 2.2.5 Review and Assessment
............................... 5 2.3 DESIGN CONTROL
.....................................6 2.3.1 General.........................................
6 p,
2.3.2 Responsibilities....................................
6 Q
2.3.3 Requirements.....................................
6 2.4 PROCUREMENT DOCUMENT CONTROL......................
9 2.4.1 General.........................................
9 2.4.2 Responsibilities.................................... 10 l
2.4.3 Requirements..................................... 10 2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS............... 11 2.5.1 General......................................... 11 2.5.2 Responsibilities.................................... 12 l
2.5.3 Requirements..................................... 12 i
2.6 DOCUMENT CONTROL.................................. 13 l
L l
2.6.1 General......................................... 13 l
2.6.2 Responsibilities.................................... 13 l
2.6.3 Requirements..................................... 13 Ov V
L_____-----_---_------------_----_---
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l CONTENTS (continued) l Pace i
1 2.
CONTROL OF PURCIIASED ITEMS AND SERVICES.............. 14 1
2.7.1 General....
14 2.7.2 Responsibilities.........
14 l
2.7.3 Requirements....
15 i
I 2.8 IDENTIFICATION AND CONTROL OF ITEMS 20 l
2.8.1 General........................................
20 l
2.8.2 Responsibilities.................................... 20 2.8.3
. Requirements.......................
21 l
2.9 CONTROL OF PROCESSES............
22 l
2.9.1 General......
22 l
2.9.2 Responsibilities...................................
22 l
2.9.3 Requirements..................................... 22 l
2.10 INSPECTION...................
23 l
2.10.1 General 23 2.10.2 Responsibilities 23 2.10.3 Requirements..................................... 24 l
2.11 TEST CONTROL..........................
25 l
2.11.1 General............
25 l
2.11.2 Responsibilities...........
26 l
2.11.3 Requirements..................................... 26 l
2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 28 l
2.12.1 General............
28 2.12.2 Responsibilities.................................... 29 2.12.3 Requirements.................................
29 2.13 HANDLING, STORAGE, AND SHIPPING......
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2.13.1 General..........
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2.13.2 Responsibilities....
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2.13.3 Requirements....
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CONTENTS (continued)
Pace 2.14 INSPECTION, TEST, AND OPERATING STATUS...........
31 l
2.14.1 General..................................
31 2.14.2 Responsibilities...................................
31 2.14.3 Requirements..................................... 31 l
2.15 CONTROL OF NONCONFORMING ITEMS.........
32 l
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2.15.1 General......................................... 32 l
2.15.2 Responsibilities....................
32 l
2.15.3 Requirements........
32 l
l 2.16 CORRECTIVE ACTION...................................
33 l
2.16.1 General........................................
3 3 2.16.2 Responsibilities.................................... 33 2.16.3 R equirem ents..................................... 34 l
2.17 QUALITY ASSURANCE RECORDS..........................
34 l
(
2.17.1 General
.............................. 34 l
2.17.2 Responsibilities....
............................... 34 2.17.3 Requirements.................
34 l
2.18 AUDITS..
........................................ 36 l
2.18.1 General
......................................... 36 2.18.2 Responsibilities 36 2.18.3 Requirements
..................................... 37 j.
l APPENDIXES 1
1 A
AUGMENTED QL'ALITY PROGRAM
......... A-1 B
PADUCAll AND PORTSMOUTH ITEMS ADDRESSED BY l
COMPLIANCE PLAN
....................... B-1 C
TECIINICAL Jt'STIFICATIONS FOR EXCEPTIONS TO THE QAP..... C-1 1
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Quality Assurance Program - GDPs August 15,1998 Rev. 26 CONTENTS (continued)
LIST OF FIGURES 1
Ficure Pace 2-1. Hierarchy of technical documents 41 l
2-2. USEC oversight organization......
42 l
A-1. Deleted A 2. Deleted e
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- 1. INTRODUCTION l
The United States Enrichment Corporation (USEC) is required by 10 CFR 76.35(d) to submit, as part of its application for a certificate of compliance, a quality assurance program that meets the l
requirements of 10 CFR 76.93. USEC is required by 10 CFR 76.93 to: " establish, maintain, and l
execute a quality assurance program satisfying each of the applicable requirements of ASME NQA-1, 1989, " Quality Assurance Program for Nuclear Facilities," or acceptable alternatives to those requirements." Section 76.93 also states that "the Corporation shall execute the criteria in a graded approach to an extent that is commensurate with the importance to safety."
l USEC's Quality Assurance Program (QAP) for the Paducah and Portsmouth Gaseous Diffusion Plants follows and satisfies the Basic Requirements and Supplementary Requirements of ASME NQA-1, 1989 as described herein.
- 2. REQUIREMENTS l:
2.1 ORGANIZATION The organizational relationships, responsibilities, authorities, delegations, lines of communication, s
position locations and qualifications, and organizational charts are described in Section 6.1 in the Safety Analysis Report (SAR), Figure 2-2 of this program, and the following paragraphs.
Independent Assessment Independent Assessment performs audits and assessments of plant activities affecting safety, quality and the environment, and performs follow-up to ensure that corrective actions have been effective.
Quality Systems Quality Systems maintains the Quality Assurance Program, prepares procedures, reviews other selected procedures for inclusion of quality requirements, performs a quality help role for others, and participates in operational readiness reviews.
Nuclear Safety Assurance Nuclear Safety Assurance performs independent engineering assessments, provides operational nuclear safety oversight, and performs selected operational experience reviews for the affect on the safety of the plant.
Individual responsibilities are also identified within the various responsibility sections throughout this program, l
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i Quality Asstrrance Program - GDPs August 15, 1998 Rev. 26 The Independent Assessment and Quality Systems groups report to managers who report to the Safety, Safeguards and Quality Manager. Members of Nuclear Safety Assurance report directly to I
Safety, Safeguards and Quality Manager.
j 2.2 QUALITY ASSURANCE PROGRAM 2.2.1 General This QAP sets forth the minimum requirements for those items, activities, and services within the scope of this QAP. This QAP is established, maintained, and executed as described in this document.
Unless specifically identified within this document, USEC commits to the Basic Requirements and Supplementary Requirements of ASME NQA-1,1989.
Those requirements of this QAP which are not fully implemented at the present time are identified in Appendix B of this document and the Plans for Achieving Compliance with NRC Regulations at the Paducah/Portsmouth Gaseous Diffusion Plants prepared and approved by DOE.
The GDPs were constructed over 40 years ago and were operated by DOE and its predecessors under different quality assurance criteria. USEC assumed responsibility for operations in accordance l
with the July 1,1993 Lease Agreement, as amended, between USEC and DOE. This QAP is submitted as part of the USEC application for a certificate of compliance and governs those activities within USEC's control and responsibility for the management, operation, maintenance, and modific:*. ion of the GDPs.
USEC applies quality assurance in a graded approach commensurate with the category of the structures, systems, and components (SSC), and activities and services associated with the SSCs.
This QAP has been established to achieve the required level of safety and quality in accordance with the requirements referred to in the following sections.
2.2.2 Scope This QAP establishes a graded. three<ategory quality assurance program for categorizing items and activities and to establish a level of quality in accordance with the relative importance to safety, a.
Categorv 0 Category Q applies to the safety systems within the boundaries described in SAR Section 3.15 (Paducah) and SAR Section 3.8 (Portsmouth). QAP Sections 2.1 through 2.18 apply fully to Q items and activities.
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b.
Category AO Category AQ applies to SSCs within the boundaries described in SAR Section 3.15 (Paducah) and
- SAR Section 3.8 (Portsmouth). This QAP applies to AQ items and activities to the extent described in Appendix A.
c.
Catecory NS a
The remaining SSCs are categorized as non-safety (NS).
d.
Discussion SSCs are categorized Q, AQ, or NS by Engineering using established procedures. Once s
categorized using the graded approach methodology, SSCs are placed in SAR Section 3.15 (Paducah) or SAR Section 3.8 (Portsmouth). The Q and AQ systems and boundaries described in SAR Section 3.15 (Paducah) and SAR Section 3.8 (Portsmouth) form the basis and identify the SSCs to which this QAP is applied. Appendix A describes the extent to which QAP Sections 2.1 through 2.18 apply to AQ items and activities. This QAP does not apply to items categorized as NS.
The requirements of this QAP apply to activities affecting the ability of Q SSCs to perform their intended Q functions. These activities include designing, purchasing, fabricating, handling, receiving, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, and modifying.
Procedures are established which ensure the requirements of this QAP are applied to Q items and activities in a graded approach. This graded approach is based on an assessment of the relative
- importance of an SSC to safety, taking into consideration: (1) the requirements of applicable regulations, codes, and standards; (2) the complexity or uniqueness of an item (or activity) and the l
environment in which it has to function, as determined by specification, design, or fabrication methods; L
(3) the quality history of the item in service; (4) the degree to which functional compliance may be demonstrated or assessed by testing, by inspection, and by preventive maintenance methods applied; (5) the anticipated life span of the item; (6) the degree of standardization of the item; (7) the importance of -
data generated; (8) reproducibility of the results; and (9) the consequence of failure.
After determining the relative importance of an SSC to safety and prior to design or procurement activities, USEC: (1) identifies and categorizes the Q function (s) to be performed by the SSC; (2) l identifies the design considerations and critical characteristics for the item, which are necessary to ensure that the Q function (s) can be performed; and (3) identifies the necessary technical and quality requirements.
The results of the application of the graded approach to quality for the Q and AQ SSCs are incorporated into specifications, procedures, instructions, drawings, and other documents which establish
- the requirements for item (s) or activities covered by this QAP.
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The degree of independent audit given to an item or activity may also be determined on a graded approxh as determined by the Safety, Safeguards and Quality Manager. Consideration is given to: (1) importance to safety; (2) the previous experience or history of problem areas; (3) those activities conducted by personnel or organizations for which no previous record of past performance is available, such as past assessments or audits; and (4) information from industry problems or lessons learned.
Quality requirements to be applied to an item, process, activity, or service (as determined by the graded approach) are identified in procedures, drawings, specifications, or other appropriate documents.
2.2.3 Program Implementation This QAP, along with associated policies, procedures, and contractual documents provide the means of communicating and documenting the program goals, objectives, requirements, and elements to all organizational levels. Refer to Figure 2-1 of this section for the hierarchy of technical documents.
This QAP is implemented through policies, procedures, instructions, specifications, drawings, procurement documents, contractual documents, and other documents. Procedures are established to ensure that these documents are consistent with the requirements of this QAP, the SAR, the Technical Safety Requirements, and regulatory requirements. These documents also provide measures which ensure that activities within the scope of this QAP are planned and accomplished under suitably controlled conditions as necessary to accomplish the goals and objectives of this QAP. The provisions contained in this QAP are applicable after the date NRC assumes regulatory oversight of the GDPs.
The terms used in this QAP are as defined in Supplement S-1 to ASME NQA-1,1989 except the following:
The term "important to safety" is defined as follows: Those Q and AQ items and activities described in SAR Section 3.15 (Paducah) and SAR Section 3.8 (Portsmouth).
2.2.4 Indoctrination and Training As an alternative to Supplement 2S-1 to ASME NQA-1,1989, for personnel performing tests other than inspection personnel (Quality Control), the training programs described in SAR Section 6.6 provide confidence that suitable proficiency is achieved and maintained in the performance of quality affecting activities defined in this QAP. Each organization manager is responsible for assuring their personnel who perform activities affecting quality receive required indoctrination and training in accordance with the requirements of Supplement 25-4 of ASME NQA-1,1989. Training sessions are documented as to objective, content of the session, attendees, and date of attendance. For example, personnel who are relied upon to operate, maintain, or modify Q systems are trained and qualified under a documented training program based upon a systems approach to training.
Training records for nondestructive examiners, auditors, and inspection personnel delineate the specific activities those personnel are qualified to perform, and the criteria used to qualify personnel in each activity. Periodic requalification is provided for such personnel who are required to maintain their proficiency.
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The qualification and requalification of inspection personnel is performed in accordance with the requirements of Supplement 2S-1 to ASME NQA-1,1989. Nondestructive examination personnel are qualified and requalified in accordance with the requirements of Supplement 2S-2 of ASME NQA-1, 1989, and SNT-TC-1A,1980 Edition, and its applicable supplements.
USEC commits to the requirements of SNT-TC-1 A with the following clarifications:
1 The word "should" in the following paragraphs shall be considered "shall": 4.3(1), 4.3(2), 4.3(3),
a.
6.3, 7.1, 7.2, 8.1, 8.1. l(1), 8.1.1(2), 8.1.1(3), 8.1. l(4),J.1.2(1), 8.1.2(2), 8.1.3(1), 8.1.3(2),
8.1.4(1), 8.1.4(2), 8.1.4(3), 8.1.5, 8.3, 8.3.1(1), 8.3. l(2), 8.3.2(3), 8.3.4, 8.4.2, 9.7.1, 9.7.3; b.
Paragraph 8.4.4 recommends a composite grade of 80% and a grade of 70% for the general, 3
specific, and practical or the basic method, and specific examination. USEC commits to this recommendation; and c.
Paragraph 9.7.2 provides recommended re-examination criteria.
USEC commits to this
[
recommendation.
The qualification and requalification of auditors and lead auditors is performed in accordance with Supplement 2S-3 to ASME NQA-1,1989.
2.2.5 Review and Assessment
/
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Management of those organizations implementing this QAP, or portions thereof, shall regularly
~
assess the adequacy of that part of the program for which they are responsible and shall assure its effective implementation in accordance with applicable procedures.
l The Safety, Safeguards and Quality Manager at each GDP is responsible for the performance of internal and external audits in accordance with the requirements of Section 2.18 and Appendix A of this QAP, to verify the performance of activities required by this QAP. The results of these audits and assessments are provided to the respective General Manager and the Executive Vice President, Operations.
The USEC Executive Vice President, Operations, is responsible for determining the status, adequacy, and effectiveness of this QAP, at least once every 24 months, through review and audit of each of the GDPs in accordance with applicable procedures. This QAP is also reviewed annually by the USEC Executive Vice President, Operations, and revised as necessary.
Suppliers of non-commercial grade items and services are required by procurement documents to evaluate their lower-tier suppliers that supply Q items or services within the scope of the QAP.
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Quality Assurance Program - GDPs August 15,1998 Rev.26 2.3 DESIGN CONTROL 2.3.1 General A design control system is established for Q items and related activities and services within the scope of this QAP as identified in Section 2.2. This system is in accordance with ASME NQA-1,1989, Basic Requirement 3, and Supplement 3S-1. These requirements and controls ensure that new design and design change activities are carried out in a planned, controlled, and orderly manner, and that design requirements such as design bases, regulatory requirements and appropriate quality standards are correctly translated into design output, procurement, and procedural documents. These controls also establish provisions for verifying or checking the technical adequacy of design documents including computer codes. They also provide for the control of design changes. The design control provisions contained in this QAP are applicable to design activities taking place after the date NRC assumes regulatory oversight for the plant. Reconstitution of the design is not required; however if a deviation to the design is discovered, engineering shall resolve the deviation and as-built the drawings if necessary.
2.3.2 Responsibilities The Engineering Manager is the plant design authority having responsibility for the implementation and execution of the design control system in accordance with the requirements of this section.
Design changes and new designs are authorized by responsible management and are reviewed (as described in SAR Section 6.2) by the Plant Operations Review Committee (PORC) prior to implementation in accordance with the provisions of 10 CFR 76.68. Management is responsible for ensuring that completed plant changes are tested and for assuring that personnel affected by the change are adequately trained as described in procedures.
2.3.3 Requirements 2.3.3.1 Design Inputs Procedures for design input activities are established to ensure the following:
1.
Design inputs, such as approach to design bases, performance requirements, regulatory requirements, cedes, and standards, are identified and documented, and their selection reviewed and approved by the responsible design organization; 2.
Design inputs are approved on a timely basis and to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for making design decisions, accomplishing design verification measures, and evaluating design changes; and 3.
Changes from approved design inputs, including the reason for the changes, are identifled, approved, documented, and controlled.
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Rev. 26 l v 2.3.3.2 Design Process Procedures are established to ensure the following:
1.
Design activities are planned on a timely basis and to the level of detail necessary to permit the design process to be carried out in a correct manner and to permit verification that the design meets requirements. Design inputs are correctly translated into design documents; 2.
Appropriate quality standards are identified and documented and their selection reviewed, approved, and controlled including changes thereto; 3.
Design methods, materials, parts, equipment, and processes that are essential to the function of the 9SC are selected and reviewed for suitability of application; and 4.
Final design output documents including changes thereto are:
Relatable to the design input by documentation in sufficient detail to permit design a.
verification, b.
Identify assemblies and/or components that are part of the item being designed. When such an assembly or component part is a commercial grade item, the requirements of Section 2.7.3.9 are also applied.
2.3.3.3 Design Analyses Procedures for design analyses activities are established to ensure the following:
1.
Design analyses are performed in a planned, controlled, and documented manner; 2.
Design analyses documents are legible and in a form suitable for reproduction, filing, and retrieval; 3.
Design analyses documents contain sufficient detail as to the purpose, method, assumptions, design, input, references, and units such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without recourse to the originator; 4.
Calculations are identifiable by subject, originator, reviewer, and date or by other data such that the calculations are retrievable; l O
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5.
When computer programs are utilized for design analyses, the requirements of Section 3.l(a) of Supplement 3 S-1 of ASME NQA-1,1989 are applied; and 6.
Design analyses documents include the requirements of Section 3.l(b) of ASME NQA-1,1989 l
Supplement 3 S-1, 2.3.3.4 Design Verification 4
Procedures for design verification activities are established to ensure the following:
1.
Design verification is performed by competent individual (s) or group (s) other than those who performed the original design; 2.
Verifiers are knowledgeable in the areas to be verified.' The verifier may be a supervisor, provided the supervisor was not directly responsible for the design (i.e., did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs used in the design);
3.
Design verification is completed prior to relying upon the component, system, structure, or computer program to perform its function; 4.
The extent of the design verification is a function of the importance to safety, the complexity of the design, the degree of standardization, the state of the art, past performance, and similarity with previous proven designs. Where changes to previously verified designs are made, design verification is perfcuned for the changes, including an evaluation of the effects of the changes on the overall desige..2 on any 2: sign analysis for which the design is based; and 5.
Acceptable methods of design verification are identified which include, but are not limited to, any one or a combination of the following: design reviews, alternate calculations, and qualification testing. Procedures identify the criteria for determining the method of design verification.
Verification by testing shall demonstrate adequacy of performance under conditions that simulate the most adverse design requirements. Verification of computer programs includes appropriate testing in accordance with the requirements of Section 2.11.3.2.
1 2.3.3.5 Design Changes l
Procedures for design change control are established to ensure the following:
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L Changes to final designs, field changes, modifications, and nonconforming items dispositioned
use-as-is" or " repair" are justified, documented, and evaluated against criteria established by the Engineering Manager; 2.
Design documents, including changes thereto, are controlled in accordance with Section 5 of Supplement 3 S-1 to NQA-1,1989 and Section 2.6 of this QAP. When a significant design change is found.to be necessary because of an incorrect design, the design. process and verification l
procedure are reviewed and modified as necessary; and 1
3.
Changes to the plant are evaluated and processed in accordance with the provisions of f
2.3.3.6 Design Interfaces Procedures for design interface control are established to ensure the following:
1.
Internal and external design interfaces are identified and controlled and design efforts are coordinated among participating organizations; 2.
The responsibilities for the preparation, review, approval, release, distribution, and revision of documents involving design interfaces are defined; and 3.
Design information transmitted across interfaces is documented and controlled.
2.3.3.7 Design Documentation and Records Design documentation and records that provide evidence that the design and design verification 1
processes were performed in accordance with this section are collected, stored, and maintained in accordance with Section 2.17.
I 2.4 PROCUREMENT DOCUMENT CONTROL I
2.4.1 General i
l A procurement document control system is established for Q items and related activities and services within the scope of this QAP as identified in Section 2.2. The procurement document control system is in accordance with ASME NQA-1,1989, Basic Requirement 4, and Supplement 4S-1. The l
procurement document control system ensures that applicable regulatory requireraents, technical
]
requirements, and QAP requirements are included or referenced in procurement documents for the l
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l Quality Assurance Program - GDPs August 15, 1998 Rev. 26 procurement ofitems and services. This system also establishes provisions for the preparation, review, approval, and control of procurement documents, inc!uding changes thereto.
2.4.2 Responsibilities The Engineering Manager is responsible for the preparation and maintenance of design specifications (including specifications for spare and replacement parts) and for identifying the technical and ouality requirements necessary to ensure item acceptability. These specifications are subject to th' req irements of Section 2.3 of this QAP. The Engineering Manager is also responsible for
. velonx mt of procedures that define these activities, including the criteria for developing the necessary tec: uncal and quality requirements for procurement.
The Central Procurement Director is responsible for purchasing activities and for ensuring that items are procured from approved suppliers on the approved suppliers list.
2.4.3 Requirements The requirements of Section 2.4.3.1 apply to non-commercial grade items. The requirements cu Section 2.7.3.9 apply to commercial grade items.
2.4.3.1 Procurement Document Contents Procedures governing procurement document content are established to ensure the following:
1.
Procurement documents shall contain a statement of work as appropriate.
l 2.
Technical requirements are specified in procurement documents by specific reference to drawings, l
specifications, codes, standards, regulations, procedures, or instructions, including revisions thereto, that describe the items or services to be furnished. These procurement documents also are required to provide identification of any special instructions and requirements for designing, fabricating, cleaning, erecting, packaging, shipping, handling, storing, testing, inspecting, and accepting.
3.
Procurement documents, for non-commercial grade items, require that the supplier implement a l
documented quality assurance program that is equivalent to the requirements of ASME-NQA-1, 1989. The procurement documents also require the supplier to extend the applicable requirements of the procurement documents to the supplier's subtier procurement documents. The extent of the program required is dependent upon the importance to safety, type, and use of the item or service being procured.
4.
Procurement documents, for non-commercial grade items, provide for access to the selected l
supplier's facilities and records for inspection or audit by the purchaser, its designated representative, and/or other authorized parties.
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5.
Procurement documents identify the documentation required to be submitted for information, l
review, or approval. The time of submittal shall be established. Requirements for the supplier to j
maintain specific quality assurance records, the retention times, and disposition are also identified.
Record requirements for the supplier to collect, store, and maintain specific quality assurance records are identified in applicable procurement documents and as required by Section 2.17.3.9 of this QAP. Procurement documents establish the requirements for reporting and approving disposition of nonconforming items and services. The identification of appropriate spare and replacement parts or assemblies and the identification of the technical and quality requirements equal to or better than the original requirements are provided for ordering replacement parts or assemblies.
2.4.3.2 Procurement Document Review Procedures for the review of procurement documents are established to ensure the following:
1.
Documents transmitted to the prospective supplier (s) include appropriate provisions to assure that items or services will meet the specified requirements.
2.
Reviews are performed and documented to provide objective evidence of satisfactory accomplishment of such review prior to contract award, p
3.
Changes made as a result of the bid evaluation or precontract negotiations are incorporated in h
(j procurement documents. The review of these changes are completed prior to contract award. This 1
review shall ensure the requirements of Section 3 of Supplement 4S-1 to ASME NQA-1,1989 are
- satisfied.
4.
The reviews and approvals required by this section are performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and the procurement documents.
2.4.3.3 Procurement Document Changes Procedures ensure that p.xurement document changes are subject to the same degree of control as utilized for the preparation of the original procurement document.
l 2.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 2.5.1 General The requirements for instructions, procedures, and drawings are applied to Q items and related activities and services within the scope of this QAP as described in Section 2.2, are in accordance with ASME NQA-1,1989, Basic Requirement 5, and this section. Measures are in place to ensure that f
activities affecting quality are prescribed by documented procedures, drawings, and instructions, appropriate to the circumstances, and are accomplished in accordance with these documents. These
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documents also include quantitative and qualitative acceptance criteria to ensure that important operations have been satisfactorily accomplished.
2.5.2 Responsibilities The Training and Procedures Manager at PORTS and the Procedures manager at PGDP are l
responsible for the system of preparation, review, approval and use of procedures and instructions in accordance with the requirements of this section of this QAP.
The Engineering Manager is responsible for the system of preparation, review, and approval of drawings in accordance with the requirements of this section and Section 2.3 of this QAP.
Organization / Group Managers are responsible for developing and approving procedures which control functions or activities within their area of responsibility, as defined within this QAP.
All personnel are required to use and adhere to the requirements of applicable procedures, instructions, and drawings for activities within the scope of this QAP.
2.5.3 Requirements Procedures are established to ensure the following:
1.
Q activities affecting safety or quality which are within the scope of this QAP as described in Section 2.2 are prescribed and performed in accordance with docum: ted instructions, procedures, or drawings of a type appropriate to the circumstances. These documents include or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed activities are satisfactorily performed.
2.
Activities that require skills normally possessed by qualified personnel do not require detailed step-by-step delineation in a procedure but are performed in accordance with instructions, procedures, or drawings of a type appropriate to the circumstances for the control of maintenance and modification work. The following are examples of the types of activities (otherwise known as
" skill-of-the-craft") which are among those that do not require detailed step-by-step written procedures: gasket replacement; trouble shooting electrical circuits; changing chart or drive speed gears or slide wires on recorders; seal replacement on small pumps; torquing of flanged covers, pipe connections, etc.; lapping and packing of manual-operated valves, erection of nonpermanent structures such as scaffolding; and rigging of chains, hoists, and slings.
3.
Written procedures shall be prepared, reviewed, approved, implemented, and maintained in accordance with the Technical Safety Requirements (TSRs) and SAR Section 6.11.
4.
Instructions, procedures, including temporary procedures, and drawings and changes thereto are reviewed in accordance with 10 CFR 76.68.
12
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l Quality Assgrance Program - GDPs August 15,1998 Rev. 26 2.6 DOCUMENT CONTROL 2.6.1 General l
A document control system is established for Q items and related activities and services within the I
scope of the QAP as described in Section 2.2. The document control system is in accordance with ASME NQA-1,1989, Basic Requirement 6, and Supplement 6S-1. This system ensures that documents defining the performance of quality-related activities are controlled so only current and correct information is available at the location where the activity is performed prior to commencing the work.
2.6.2 Responsibilities The Administrative Support Manager has the overall responsibility for the development and implementation of the document control system.
Organization Managers are responsible for (1) identifying documents to be included in the
)
controlled document system; (2) ensuring instructions, procedures, drawings, and other specified documents are reviewed for adequacy and approved for release; (3) complying with document distribution requirements; and (4) ensuring these documents are maintained and used by personnel performing the prescribed activity.
2.6.3 Requirements -
'kq
).
Procedures for the control of document preparation, review, approval, and issuance are established to ensure the following:
1.
A controlled master list is established which identifies the current revision and any subsequent changes to controlled documents. The document control system applies to documents that specify quality requirements or prescribe activities affecting quality such as:
a.
Design documents including documents related to computer codes and calculations.
b.
c.
Instructions and procedures, including temporary procedures, for such activities as fabrication, construction, modification, installation, testing, inspection and operation.
d.
Documents pertaining to as-built conditions.
e.
Application for Certificate of Compliance, and amendments.
2.
Responsibility is assigned for preparing, reviewing, approving, and issuance of documents.
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i Quality Assurance Program - GDPs August 15, 1998 Rev.26 3.
Documents are reviewed for adequacy, completeness, and correctness prior to approval and issuance. These reviews ensure technical adequacy and inclusion of appropriate safety and quality requirements.
l 4.
Drawings depicting as-built conditions, including changes thereto, and related documentation are prepared in a timely manner and accurately reflect the actual design. Reconstitution of all drawings is not required; however when inaccuracies are discovered, the variances will be resolved and drawings as-built if necessary.
5.
Document controls used to specify the current revision and any changes to instructions, procedures, specifications, drawings, and procurement documents are identified. This document control system has provisions for updating and for distribution to predetermined personnel.
6.
Except for minor changes, changes to documents are reviewed and approved by the same organization that performed the initial review and approval or delegated to other qualified orgamzations. The reviewing organization has access to pertinent background data or information upon which to base their approval.
7.
Minor changes to documents, such as inconsequential editorial corrections do not require that the revised documents receive the same review and approval as the original documents. The review and approval for minor changes is specified in procedures.
8.
Use of documents is prescribed in procedures.
9.
Obsolete or superseded documents are removed and/or replaced in a timely manner.
- 10. Documents including changes thereto are reviewed in accordance with 10 CFR 76.68.
2.7 CONTROL OF PURCIIASED ITEMS AND SERVICES 2.7.1 General A system for the control of purchased items and services is established for Q items and services within the scope of this QAP as described in Section 2.2. The requirements for the control of purchased items and services are in accordance with Basic Requirement 7 and Supplement 7S-1 of ASME NQA-1,1989.
2.7.2 Responsibilities The Safety, Safeguards and Quality Manager is responsible for evaluation of the QA capabilities of suppliers and for providing the necessary QA functions to support procurement. These QA functions include review of supplier quality documentation and supplier evaluations and audits when specified.
The Safety, Safeguards and Quality Manager is responsible for the development and maintenance of an j
approved suppliers list. Suppliers are placed on the approved suppliers list in accordance with O
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Quality Assurance Program - GDPs August 15, 1998 Rev.26 evaluations of the suppliers technical and quality capabilities or history of satisfactory performance or the evaluation of the suppliers current quality records as determined and approved by the Engineering Manager and the Safety, Safeguards and Quality Manager. The Safety, Safeguards and Quality Manager is also responsible for developing and implementing procedures which meet the requirements of this
)
section of the QAP.
The Production Support Manager provides support functions such as source verification or surveillance, receipt inspections, installation inspections, and review of procurement documents during i
receipt inspections. This manager is also responsible for developing and implementing procedures which meet the requirements of this section of the QAP.
l l
The Engineering Manager is responsible for evaluation of suppliers' technical capabilities and for determining the methods of acceptance to be applied to purchased items and services. The Engineering Manager is also responsible for the approval of dispositions and technical evaluations for supplier-generated nonconformances for items and services. The Engineering Manager is also
- responsible for providing measures which ensure the proper selection, application, methods of acceptance, and use of items.
The Central Procurement Director is responsible for purchasing activities and ensuring that items are procured from approved suppliers on the approved suppliers list when required.
~ 2.7.3 Requirements i
The requirements of Sections 2.7.3.1 through 2.7.3.8 apply to services and non-commercial grade items. For commercial grade items, the requirements of Section 2.7.3.9 apply.
2.7.3.1 Procurement Planning l
Procedures are established to ensure the following:
1.
Procurement activities are planned and documented to assure a systematic approach to the procurement process.
j 2.
Procurement planning results in the documented identification of procurement methods and organizational responsibilities.
3.
Planning activities meet the requirements of Section 2 of Supplement 7S-1 to ASME NQA-1,1989.
2.7.3.2 Supplier Selection Procedures are established for the selection of a potential supplier and are in accordance with an evaluation of its capability to provide items or services in accordance with the requirements of procurement documents. An assessment of the potential supplier's technical and quality capability is performed in accordance with one or more of the following:
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An evaluation of the potential supplier's history of providing an identical or similar product which performs satisfactorily in actual use.
I 2.
The potential supplier's current quality records supported by documented qualitative and quantitative information that can be objectively evaluated.
3.
The potential supplier's technical and quality capability as determined by a direct evaluation of his facility and personnel and the implementation of the potential supplier's quality assurance program.
2.7.3.3 Bid Evaluation Procedures are established which provide measures for the performance of bid evaluations. These procedures ensure the requirements of Section 4 of Supplement 7S-1 to ASME NQA-1,1989 are met prior to award of the contract.
2.7.3.4 Supplier Evaluation Procedures governing interface with the supplier are established and conducted as early as practicable which provide measures to verify the supplier's performance. The purchaser's verification activities, however, shall not relieve the supplier of his responsibilities for verification of quality achievement. The measures include:
l 1.
Establishing an adequate understanding between Purchaser and Supplier of the provisions and specifications of the procurement documents.
2.
Requirements for the supplier to identify the methods and processes to be used by the supplier in fulfilling the requirements of the procurement.
3.
Reviewing the supplier documents generated or processed during acti cities fulfilling procurement requirements.
4.
Identifying and processing necessary change information.
5.
Establishing methods for exchange of information with the supplier.
6.
Establishing the extent of source surveillance and inspection activities.
The above verification activities are based on the importance to safety, complexity, and quantity of the items or services provided and are performed by personnel assigned to check, inspect, audit, or
'vitness the activities of the supplier. These personnel meet the qualification requirements of Section(s) 2.10 or 2.18 of this program. Activities performed to verify conformance to requirements of procurement documents such as source surveillance and inspections, surveys, audits, receiving inspections, nonconformances, dispositions, and corrective actions are documented and/or recorded in accordance with procedures.
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2.7.3.5 Control of Supplier Documents and Changes to Procurement Documents Procedures are established to determine the acceptability of supplier-generated documents. These measures assure that submittal of these documents is accomplished as required by the procurement documents. These procedures provide measures for the acquisition, processing, and recorded evaluation of technical, inspection, and test data against acceptance criteria. Procedures also are established for the control and documentation of changes to procurement documents. The requirements of Section 2.4.3 are followed when changes to procurement documents are made.
2.7.3.6 Methods of Acceptance for Items Procedures are established which govern the acceptance of items. Prior to offering the item for
[
acceptance, the supplier shall verify that the item being furnished complies with the procurement l
requirements. Where required by code, regulation, or contract requirement, documentary evidence that l
items conform to procurement documents shall be available at the facility site prior to installation or use.
l Any one or more of the following methods of acceptance are used:
1.
Certificate of Conformance - When this method is utilized, the following minimum criteria are met:
The cenificate identifies the purchased material or equipment.
a.
(3 Q
b.
The cenificate identifies the specific procurement requirements met.
The cenificate identifies any procurement requirements that were not met.
c.
d.
The cenificate is authenticated by the person responsible for the quality assurance function and whose function and position is described in the purchaser's or supplier's quality assurance program.
The procedures used for the preparation, review, and approval of the certificate are described e.
in the purchaser's or supplier's quality assurance program.
f.
The validity of the supplier's cenificates and effectiveness of cenification system is verified and the interval of verification is based on the supplier's past quality performance.
2.
Source Verification - When this method is utilized, it is perfonned at intervals consistent with the imponance to safety and complexity of the item or service and it shall be implemented to monitor, witness or observe activities. This method provides plans to perform inspections, examinations, or tests at predetermined points. Upon purchaser acceptance of source verification, documented evidence of acceptance shall be furnished to the receiving destination of the item, to the purchaser, and to the supplier.
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3.
Receiving Inspection - This method is utilized for all purchased items to verify conformance to l
lg procurement documents. This method verifies by objective evidence such features as proper 17 I
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Quality Assurance Program - GDPs August 15, 1998 Rev. 26 configuration; identification; dimensional, physical, or other characteristics; freedom of damage from shipping; cleanness; and review of supplier documentation when procurement documents require the documentation to be furnished. Upon completion of receipt inspection, acceptable items are released for storage or issued for installation or use. Items determined to be nonconforming after completion of the receipt inspection are documented and processed as described in Section 2.15.
4.
Post-Installation Testing - When this method is utilized, post-installation test requirements and acceptance documentation are established by the purchaser and supplier.
2.7.3.7 Acceptance of Services Prior to offering the service for acceptance, the supplier shall verify that the service being furnished l
complies with the procurement requirements. Procedures allow for the acceptance of services by one l
or more of the following methods:
1.
Technical verification of data produced.
2.
Surveillance and/or audit of the activity.
3.
Review of objective evidence for conformance to procurement document requirements.
2.7.3.8 Control of Supplier Nonconformances Procedures are established to provide methods for disposition of nonconforming items and services that do not meet procurement documentation requirements. These procedures contain provisions for the following:
1.
Evaluation of nonconforming items.
2.
Submittal of nonconformance notice to the purchaser by the supplier. The submittal includes a recommended disposition and technicaljustification. The following nonconformances are submitted to the purchaser for approval of the recommended disposition:
a.
Violation of technical or material requirement.
b.
Violation of requirement of purchaser-approved supplier document.
c.
Nonconformances which cannot be corrected by continuation of the manufacturing process or by rework.
d.
Items that do not conform to the original requirements even though the item can be restored to a condition such that the capability of the item to function is unimpaired.
3.
Purchaser disposition of the supplier recommendation.
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4.
Verification of the implementation of the disposition.
5.
Maintenance of records of supplier submitted nonconformances.
2.7.3.9 Commercial Grade Items Procedures are established governing the application and use of commercial grade items:
1.
Methods for determining whether an item can be purchased as commercial grade and dedicated for use in a Q application. A commercial grade item is an item satisfying all of the following:
Not subject to design or specification requirements that are unique to the nuclear facility.
a.
b.
Used in applications other than nuclear facilities.
Is to be ordered from the manufacturer / supplier on the basis of a specification set forth in the c.
manufacturer's published product description (e.g., catalog).
2.
The criteria and methods for identifying the critical characteristics that are essential to ensure that the item will perform its intended Q function.
(q The criteria for determining the type and depth of product acceptance and the criteria for 3.
j detennining the point of dedication at which time USEC assumes the responsibility for deportability.
Dedication of a commercial grade item occurs after receipt when that item is designated for use in a Q application.
4.
Methods used to accept (dedicate) commercial grade items are receipt inspection as required by 2.7.3.9.10 or one or more of the following as determined by engineering:
a.
Special test b.
Commercial grade survey of supplier 1
c.
Source verification i
d.
Acceptable supplier and item performance record 5.
The selection of the method or combination of methods in 4. above is based on the following:
a.
Selected critical characteristics b.
Available supplier information i
c.
Quality history 7(a) 19
l Quality Ass 5rance Program - GDPs August 15, 1998 Rev. 26 d.
Degree of standardization e.
Importance to safety and complexity of the item 6.
Alternate commercial grade items are allowed provided the Engineering Manager provides verification that the alternate commercial grade item will perform its intended Q function.
7.
Source evaluation and selection, where determined necessary by the engineering based on complexity and importance to safety, shall be in accordance with the requirements of Section 3.1 of Supplement 7S-1 of ASME NQA-1,1989.
8.
Procurement documents are issued and controlled in accordance with the requirements of J
Sections 2.4.3.2 and 2.4.3.3 of this QAP.
9.
Commercial grade items are identified in the purchase order by the manufacturer's published product description.
- 10. Receipt inspections are performed to determine that damage was not sustained during shipment, that the item received is the item ordered, and that inspection and testing are performed as required, to ensure conformance with manufacturer's published requirements; and to ensure that required documentation is received and is acceptable.
- 11. The requirements of other sections of this QAP apply once a commercial grade item is dedicated and determined acceptable for use in a Q application.
2.8 IDENTIFICATION AND CONTROL OF ITEMS 2.8.1 General A system is established for the identification and control of Q items within the scope of the QAP as described in Section 2.2. The requirements for the identification and control of such items are in accordance with Basic Requirement 8 and Supplement 8S-1 of ASME NQA-1,1989. This system establishes the requirements for the identification and control of such items and associated materials, consumables, parts, spare parts, components, and sub-assemblies.
2.8.2 Responsibilities The Engineering Manager is responsible for specifying requirements for identification methods, traceability, shelflife, and operating life of items when required by codes, standards, or specifications.
Engineering specifies these requirements during the generation of specifications, drawings, procurement documents, or other documents appropriate to the circumstances.
The Production Support Manager is responsible for verifying that items are correctly identified through receipt inspection, storage, installation, and use as required.
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Organization Managers are responsible for maintaining and implementing identification, traceability, I
and shelf life and operating life requirements for items under theirjurisdiction.
The Materials Management Manager is responsible for receipt, delivery, storage, traceability, identification, and control of materials.
2.8.3 Requirements 2.8.3.1 Identification ofItems Procedures are established to ensure that items are identified from initial receipt and fabrication of the items up to and including installation and use to assure that only correct and accepted items are used
)
or installed as required by applicable codes, standards, or specifications. Identification shall relate an l
item to an applicable design or other pertinent specifying document. Physical identification shall be used to the manmum extent possible. Where physical identification to control the item is either impractical or insufficient, physical separation, procedural controls, or other means are employed. When markings
)
are used, measures are established to ensure that the markings are clear, legible and do not have a l
detrimental effect on the function or service life of the item. Markings are transferred to each part of l
an identified item when subdividing and are not to be obliterated o: hidden by surface treatments or coatings unless other means of identification are provided.
p 2.8.3.2 Traceability of Items C/
Procedures are established for the traceability of items, when specified by codes, standards or specifications.
2.8.3.3 Limited Life Items Procedures are established to ensure that items which have a limited operating life or shelf-life are identified and controlled to preclude use of items whose operating life or shelf-life has expired. These procedures also establish the requirements for the identification and control of items such as chemicals and reagents.
2.8.3.4 Maintaining Identification of Stored Items Procedures are established for the control of item identification consistent with the planned duration and conditions of storage such as (1) provisions for maintenance or replacement of markings and identification records due to damage during handling or aging, (2) protection of identifications on items subject to excessive deterioration due to environmental exposure, and (3) provision of updating existing plant records.
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2.9 CONTROL OF PROCESSES 2.9.1 General A system to control processes that affect the quality of items or services is established for Q items and related services within the scope of this QAP as described in Section 2.2. The requirements for the control of special processes are in accordance with Basic Requirement 9, and Supplement 9S-1 of AShfE NQA-1,1989. This system establishes the requirements for the control of special processes used in the course of maintenance, modification, and testing activities.
2.9.2 Responsibilities The Engineering hianager is responsible for determining special processes, providing technical requirements for identified special processes, and reviewing and concurring with all special process procedures including the utilization and application of nondestructive examination (NDE) procedures.
These responsibilities are met in accordance with the requirements of this section of the QAP.
The Production Support hianager is responsible for the qualification of NDE personnel, including welder / brazer qualifications, in accordance with the requirements of this section of the QAP.
Organization / Group hianagers ensure that identified special processes are performed by qualified personnel, using qualified and approved procedures or documents of a type appropriate to the circumstances.
2.9.3 Requirements 2.9.3.1 Procedures are Established to Ensure the Following:
1.
Special processes that control or verify quality, such as those used in welding, heat treating, and nondestructive examination, are performed by qualified personnel using qualified procedures in accordance with specified requirements; l
2.
Shall assure that process parameters are controlled and that specified environmental conditions are l
maintained; l
3.
Trauung, testing, qualification, and certification requirements for personnel who perform or inspect l
special process operations (nondestructive examination personnel qualifications are described in Section 2.2.4 of this document); qualification of equipment and procedures used for special processes; documentation of process results, procedures, personnel qualification and certification; and equipment qualifications; l
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Conditions necessary for accomplishment of the process shall be included in procedures or instmetions. These conditions shall include proper equipment, controlled parameters of the process, and calibration requirements; and 22 l
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For special processes not covered by existing codes and standards or where quality requirements specified for an item exceed those of existing codes or standards, the necessary requirements for qualifications of personnel, procedures, or equipment shall be specified or referenced in the precedures or instructions.
2.9.3.2 Acceptance Criteria Procedures are established to ensure that special process procedures include or reference the requirements of applicable codes and standards, including acceptance criteria for the process.
2.9.3.3 Records Procedures are established to ensure that qualification records of procedures, equipment, and personnel associated with special processes are maintained, filed, and kept current in accordance with the requirements of Section 2.17.
2.10 INSPECTION 2.10.1 - General q
A system for inspection is established for Q items which are within the scope of this QAP as Q
identified in Section 2.2. The requirements for inspection are in accordance with Basic Requirement 10, and Supplement 10S-1 of ASME NQA-1,1989. This system provides measures to ensure that maintenance, repair or modification work is completed satisfactorily.
2.10.2 Responsibilities The Production Support Manager is responsible for inspection planning, for ensuring inspections are performed, and for utilizing qualified and certified inspection personnel.
Organization / Group Managers responsible for the system or activity being inspected are responsible for specifying " hold" and " witness" points in applicable work control documents and ensuring work quality is in accordance with inspection procedures, plans, and checidists. Such work control documents are developed from approved design documents, which specify the criteria for acceptance of the work.
Management establishes measures to ensure that the requirements of this section of the QAP are met.
23
Quality Assurance Program - GDPs August 15, 1998 Rev.26 2.10.3 Requirements Procedures are established for governing the inspection of items and activities to ensure the following:
1.
Inspection for acceptance is performed by persons other than those who performed or directly supervised the work being inspected.
2.
Each person who verifies conformance of work activities for purposes of acceptance is qualified to perform the assigned inspection task. The qualifications of inspection personnel meet the requirements as described in Section 2.2.4. Inspections by persons during on-the-job training for j
qualification shall be performed under the direct observation and supervision of a qualified person l
and verification of conformance shall be by the qualified person until certification is achieved.
l When inspection techniques require personnel with specialized skills, those skills are attained in accordance with applicable codes and standards.
3.
Inspection hold points are established to ensure that work does not bypass required inspections.
These hold points are established in work controlling documents. Work shall not proceed beyond an inspection hold point without specific consent of the designated inspection representative.
Consent to waive hold points is recorded prior to continuation of work beyond the designated hold point.
4.
When the quality of work cannot be verified during inspection of the end product, quality control personnel utilize direct in-process inspections of work activities. If inspection of work is impossible or inconclusive, indirect control by the monitoring of process methods, equipment, and personnel is provided. Both inspection and process monitoring are provided when necessary to ensure quality. A combination of inspection and process monitoring methods, when used, shall be performed in a systematic manner to assure that the specified requirements for control of the process and quality of the item are being achieved throughout the duration of the process.
I Controls, where required, shall be established and documented for the coordination and sequencing of these activities at established inspection points during successive stages of the conducted process or construction.
5.
Inspection activities are performed to verify the quality and conformance of the item to specified retirements.
6.
The identification of inspection activities and attributes is based on the complexity of the item or l
activity to be inspected, on mandatory inspections required by codes, standards, regulatory requirements, commitments, and inspection requirements established by the Engineering Manager.
The depth and extent of inspections are determined by the significance of the Q function, and the complexity of the item or activity.
7.
Final inspections include a records review of the results and resolution of nonconformances identified by prior inspections. The final inspection arrives at a conclusion regarding conformance of the item to specified requirements.
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Repairs, replacements, and modifications performed subsequent to final inspection require 8.
reinspection or retest, appropriate to the circumstances, to verify acceptability.
9.
Inspections of items or activities are documented and approved by authorized personnel. The l
documentation identifies the characteristics, methods, and acceptance criteria, and provides for the recording of the objective evidence of the inspection results.
- 10. Where a sample is used to verify accepta'oility of a group of items, the sampling procedure is documented and clearly identifies the sampling basis (typically based on recognized standard / practices).
- 11. Required inservice inspection or surveillance of structures, systems, or components shall be plannedl and executed by or for the organization responsible for operation. Inspection methods shall be established and executed to verify that the characteristics of an item continue to remain within specified limits. Inspection methods shall include evaluations of performance capability of essential emergency and safety systems and equipment, verification of calibration and integrity of instruments and instrument systems, and verification of maintenance, as appropriate.
l
- 12. Inspection records contain the following as a minimum:
l l
a.
item inspected n
(
)
b.
date ofinspection LJ l
t c.
inspector d.
type of observation i
J e.
results or acceptability f.
reference to information on action taken in connection with nonconformances 2.11 TEST CONTROL j
l 2.11.1 General
{
A systern for test control is established for Q items within the scope of this QAP as described in Section 2.2. The requirements for the test control system are in accordance with Basic Requirement 11 and Supplement 11S-1 of ASME NQA-1,1989. This system is planned and executed to assure that testing is performed to demonstrate that SSCs will perform satisfactorily in service. The system requires written test procedures identifying prerequisites with provisions for documenting and evaluating test results to assure that requirements are satisfied. This section also contains amplified requirements for testing of computer programs and associated computer systems within the scope of this QAP as described q'V 25
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1 in Section 2.2 The requirements for computer program te:; ting are in accordance with Supplement 11S-2 of ASME NQA-1,1989.
2.11.2 Responsibilities The Engineering Manager is responsible for providing technical criteria for plant modification testing. The Engineering Manager is also responsible for the evaluation of test results and resolution of deficiencies identified from these tests.
Management is responsible for the conduct of testing activities under their cognizance which are in accordance with procedures consistent with the requirements of this section of the QAP.
2.11.3 Requirements 2.11.3.1 Test Control Procedures are established for the control of testing activities that provide measures that ensure the following:
1.
Test requirements and acceptance criteria are based upon specified requirements contained in applicable design or other pertinent technical documents.
2.
Test procedures contain the fc!!owing inforraation as appropriate to the test:
Test purpose or objectives and characteristics to be tested and test methods to be employed.
a.
b.
References and related documents.
c.
Provisions for assuring that prerequisites for a given test have been met.
d.
Adequate instrumentation is available and suitable environmental conditions are maintained.
Provisions for establishing prerequisites and precautions, as applicable: calibration e.
instrumentation, appropriate equipment, trained personnel, condition of test equipment, and the item to be tested, and provisions for data acquisition, f.
Provisions for documenting and evaluating the test results for conformance with acceptance criteria.
g.
In lieu of wrinen test procedures, appropriate sections of related doct.ments, such as ASTM methods, vendor manuals, maintenance instructions, or approved drawings or travelers with l
acceptance criteria may be used. Such documents must include adequate instmetions to j
assure the required quality of work.
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Quality Assurance Program - GDPs August 15,1998
[O Rev. 26 L) 3.
Tests required to collect data, such as for siting or designing input are planned, executed, documented, and evaluated.
4.
Test records contain the following information as a minirnum: item tested, test date, tester or data recorder, type of observation, results and acceptability, actions taken with any deviations noted, and identification of the person evaluating the results.
2.11.3.2 Computer Program Testing Procedures are established to provide measures to ensure the following:
1.
Test requirements and acceptance criteria are provided or approved by the organization responsible for the design or use of the program to be tested unless otherwise designated in procedures.
2.
Required tests, including (as appropriate) verification tests, hardware integration tests, and in-use tests, are controlled.
3.
Test requirements and acceptance criteria are in accordance with applicable design or other pertinent technical documen3.
4.
Verification tests encompassing the range of permitted program usage as specified by the program g
documentation demonstrate the capability of the computer program to produce valid results.
- "j Testing of the computer program is dependent upon its complexity and may range from a single test of the completed computer program to a series of tests performed at various stages of the program development to verify correct translation between stages and proper working of the individual modules, followed by an overall computer program test. Regardless of the number of stages of tests, verification testing shall be sufficient to establish that test requirements are satisfied and that the computer program produces a valid result for its intended function. Acceptable test problem verification methods may include one or more of the following features
I 1
a.
Hand calculations.
b.
Calculations using comparable proven programs.
I c.
Empirical data and information from technical literature.
i 1
1 5.
Operational verification testing includes the following features:
l a.
Test problems are developed and documented to permit confirmation of acceptable performance of the computer program in the operating system.
b.
Test problems are run whenever the computer program is installed on a different computer, l
or when significant hardware or operating system configuration changes are made.
l p
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Quality Assurance Program - GDPs August 15,1998 Rev. 26 i
c.
Periodic in-use manual or automatic self-check routines are required and are performed for l
those applications where computer failures or drift can affect required performance.
l 6.
Test procedures or plans specify the following as applicable: required tests and test sequence, required ranges of input parameters, identification of the stages at which testing is required, criteria for established test cases, requirements for testing logic branches, requirements for hardware integration, anticipated output values, acccptance criteria, reports to be generated during the test, records of test results to be generated, standard formatting and conventions of electronic media generated, and provisions for the documentation and evaluation of test results by a respomible authority to assure that test requirements are met.
7.
Verification test records identify the following: computer program tested, computer hardware used, test equipment and calibrations if applicable, date of test, tester or data recorder, simulation models used if applicable, test problems, results and acceptability, actions taken in correction (with any deviations noted), and the person evaluating the test results.
8.
In-use test records identify the following: the computer program tested, computer hardware used, test equipment and calibrations if applicable, date of test, tester or data recorder, simulation models used, test problems, results and acceptability, actions taken in connection with any deviations noted and the person evaluating test results.
9.
In-use test records identify the following: computer program tested, computer hardware used, test equipment and calibrations, where applicable, date of test, tester or data recorder and the acceptability.
2.12 CONTROL OF MEASURING AND TEST EQUIPMENT 2.12.1 General A system is established for the control of measuring and test equipment (M&TE) for Q items within the scope of this QAP as described in Section 2.2. The requirements for the control of measuring and test equipment are in accordance with Basic Requirement 12 and Supplement 12S-1 of ASME NQA-1, 1989. This system establishes measures that ensure that tools, gauges, instruments, reference and transfer standards, nondestructive test equipment, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified intervals to maintain equipment performance within required limits.
This system also establishes measures to ensure that devices and standards used for measurement, tests, and calibration activities are of the proper type, range, and accuracy. In addition, calibration control requirements are applied to permanently installed facility instrumentation which are used to verify that operating specifications or code requirements are met.
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Quality Assurance Program - GDPs August 15,1998
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)
v 2.12.2 Responsibilities The Maintenance Manager has the overall responsibility for the calibration control system for M&TE including plant installed process instrumentation. The calibration control system meets the requirements of this section of the QAP.
Organization / Group Managers are responsible for implementation of the calibration control system for M&TE including plant installed process instmmentation under his/her cognizance.
2.12.3 Requirements Procedures are established for the control of M&TE to ensure the following:
1.
A list of devices (and their assigned location) is established to identify those items within the calibration control system. This identification listing includes, as a minimum, the due date of the next calibration and any use limitations (when it is calibrated for limited use). Calibration controls are not necessary for rulers, tape measures, levels, and other such devices if the commercial equipment provides adequate accuracy.
,n
!k-2.
M&TE is calibrated at specified intervals or prior to use against cenified equipment having known valid relationships to nationally recognized standards. If no nationally recognized standard exists, the bases for calibration are documented.
i 3.
When M&TE is found to be out of calibration, an evaluation is made and documented as to the validity of previous inspection and test results and of the acceptability of items previously l
inspected or tested. Out-of-calibration devices are tagged or segregated and are not used until recalibrates. When M&TE is consistently found to be out of calibration, it is repaired or replaced. Also, calibrations are performed when the accuracy of the equipment is deemed suspect by personnel performing measurements and tests.
4.
M&TE is properly handled and stored to maintain accuracy.
5.
Records are maintained and equipment is suitably marked to indicate its calibration status, 1
l l
1
\\
l 1
orting and documenting nonconforming items or related activities and services.
The Materials Management Manager is responsible for development and maintenance of the nonconformance control system for materials which meet the requirements of this section of the QAP until the materials are issued for installation or use.
The Engineering Manager is responsible for providing documented technicaljustification for the acceptability of nonconforming items dispositioned "use-as-is" or " repair."
This manager is also responsible for applying the design control measures of Section 2.3 of this QAP to those nonconformances to design requirements that are dispositioned "use-as-is" or " repair," and for ensuring that as-built records reflect the accepted deviation.
The Plant Shift Superintendents (PSS) are responsible for evaluating identified and reported nonconformances for impact on system operability and reponability to the NRC.
2.15.3 Requirements Procedures are established to provide measures for the control of Q items and related activities and services that do not conform to specified requirements. These measures ensure the following.
1 1
1.
Nonconforming items are identified in a manner that does not adversely affect the end use of the item, by markings, tagging, and other appropriate methods. When identification of the item is not practical, the container, package, or segregated storage area is identified; 2.
Nonconforming items are segregated, when practical, by placing them in a clearly identified and designated area until properly dispositioned. When segregation is impractical or impossible due to physical conditions such as size, weight, or access lhnitations, other measures are err. ployed to preclude inadvenent use of the item; 3.
Nonconforming characteristics are reviewed and dispositions are recommended.
Funher processing, delivery, installation or use of the nonconforming item is controlled pending an 32
Quality Assurance Program - GDPs August 15, 1998
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Rev.26 G
evaluation and approved disposition by authorized personnel, and notification to affected organizations is provided; 4.
Nonconforming items or services are evaluated to determine whether reporting is required; 5.
Nonconforming items or services identified by suppliers are reviewed to determine applicability and to initiate corrective action if required; 6.
The responsibility and authority for the evaluation and disposition of nonconforming items is defined. The personnel performing evaluations to determine the disposition have demonstrated competence in the specific area they are evaluating, have an adequate understanding of the requirements, and have access to peninent background information:
7.
The disposition of nonconforming items is identified and documented. Technicaljustification for the acceptability of nonconforming items dispositioned " repair" or "use-as-is" are also documented; 8.
Nonconformances to design requirements dispositioned "use-as-is" or " repair" are subject to design control measures as described in Section 2.3. The as-built records, if such records are required, reflect the accepted deviation. This as-built requirement applies only to those as-built conditions captured after the effective date of this QAP; and g
Repaired or rew eked items are reexamined in accordance with applicable procedures and with the 9.
Q original acceptance criteria unless the nonconforming i:em disposition has established alternate acceptance criterra.
2.16 CORRECTIVE ACTION 2.16.1 General A corrective action system is established for those Q items and related activities and services within the scope of the QAP as described in Section 2.2. This system is in accordance with Basic Requirement 16 of ASME NQA-1,1989 and this section. This system establishes measures which ensure that conditions adverse to quality are identified and corrected as soon as practical. The system also ensures that, in the case of significant conditions adverse to quality, the cause of the condition is determined, and corrective action is taken to preclude recurrence. These actions are documented and reported to appropriate levels of management. This system also ensures that follow-up actions are taken to verify implementation of the corrective action.
2.16.2 Responsibilities The Commitment Management Manager is responsible for development, maintenance, and j
i implementation of the corrective action system. This manager is also responsible for verifying that adverse conditions are reviewed and assessed by appropriate levels of management.
33
l l
Quality Assurance Program - GDPs August 15,1998 Rev. 26 Organization / Group Managers are responsible for evaluating and performing assigned corrective actions in a timely manner in accordance with procedures that implement the requirements of this section of the QAP. They are also responsible for assuring the identification and documentation of conditions adverse to quality in accordance with applicable procedures.
2.16.3 Requirements Procedures for the corrective action process are established to ensure the following:
1.
Conditions adverse to quality are promptly identified and corrected as soon as practical; 2.
For significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude recurrence; and 3.
The identification, cause, and corrective action for significant conditior;s adverse to quality are documented and reported to appropriate levels of management; follow-up action is taken to verify implementation of the corrective action.
2.17 QUALITY ASSURANCE RECORDS 2.17.1 General A records management system is established for Q items and related activities and services within the scope of this QAP as described in Section 2.2. The records management system is in accordance with Basic Requirement 17 and Supplement 17S-1 of ASME NQA-1,1989. The records management system provides measures to control quality assurance records.
2.17.2 Responsibilities The Administrative Support Manager is responsible for the development, maintenance, and implementation of the records control system consistent with the requirements set forth in this section of the QAP.
Orgamzation/ Group Managers are responsible for (1) identifying quality assurance records initiated by their organization / group including those received from suppliers of items and services; (2) controlling the records within ' heir jurisdiction; and (3) transferring records, for which their group previously had record copy responsibility, to the Administrative Support Manager for retention consistent with governing procedures meeting the requirements established in this section of the QAP.
2.17.3 Requirements Procedures for the identification and control of quality assurance records are established to ensure the following:
34
Quality Assurance Program - GDPs August 15, 1998 O
Rev. 26 b
1.
Applicable design specifications, procurement documents, test procedures, operational procedures or other documents specify the records to be generated, supplied, or maintained. These documents are designated to become records and are legible, accurate, and complete; 2.
Methods of authentication or validation of documents as records are identified; 3.
Documents shall be considered valid records only if signed and dated by authorized personnel; l
4.
Establishment of a records indexing and classification system, including record retention times, l
and the location of the record within the record system, which meets the requirements of the Technical Safety Requirements document, the provisions of 10 CFR Part 76, and other regulatory requirements; 5.
Methods are established to permit identification between the record and the item (s) or activity (ies) l to which it applies; 6.
Corrections to records are approved by the originating organization and the corrections include the l
date and the identification of the individual authorized to issue the correction:
7.
Establishment of a record receipt control system which meets the requirements of Supplement
[
17S-1, Section 3 of ASME NQA-1,1989;
,m
(}
8.
Requirements for records storage, preservation, and safekeeping satisfy the requirements of l
Supplement 17S-1, Sections 4.1,4.2, and 4.3 of ASME NQA-1,1989; 9.
Quality Assurance recorcb are stored in facilities which meet the requirements of Supplement 17S-l 1, Section 4.4 of ASME NQA-1,1989, except as noted in Appendix C of this QA.P; 10.
Record requirements for procured services or non-commercial items are identified in applicable l
procurement documents. These documents contain provisions for the following:
Assuring that supplier methods for the collection, storage, and maintenance of records is a.
commensurate with the above requirements,
- b. Identification of required records and the required retention periods, c.
A record index which includes sufficient identifying information for record retrieval,
- d. A record submittal plan,
- e. The availability, accessibility, and if applicable, the disposition criteria of records retained by l
the supplier, and f.
The accessibility of the supplier's records prior to final transfer to the purchaser and the method of transmittal.
()
35 l
1
Quality Assurance Program - GDPs August 15, 1998 Rev. 26 l
11.
The storage system provides for retrieval of information in accordance with planned retrieval l
times based upon the record type. A list is maintained designating those personnel who have access to the files within the storage system; 12.
Single copy records shall only be allowed out of permanent storage if they cannot be copied and l
then only for a maximum of 90 days.
2.18 AUDITS 2.18.1 General An audit system is established for Q items and activities and services within the scope of this QAP as described in Section 2.2. The audit system is in accordance with Basic Requirement 18 and Supplement 18S-1 of NQA-1,1989. This system establishes planned and periodic audits to verify the compliance and the effectiveness of this QAP in meeting quality requirements. Audit personnel have l
sufficient authority and organizational freedom to make the audit process meaningful and effective.
l Audits are executed in accordance with established procedures and are performed by personnel having no direct responsibilities in the areas being audited.
Internal audits of selected aspects of operational activities are performed with a frequency commensurate with their importance to safety and in such a manner as to assure that audits of activities within the scope of this QAP, as described in Section 2.2, are completed within specified time periods.
Extemal audits of selected suppliers and service contractors, in keeping with the procurement and service activities, are performed to verify and evaluate their Quality Assurance Programs, procedures and activities to ensure that they are complying with applicable aspects of this QAP and procurement requirements. This includes verification that the suppliers and contractors similarly review and audit the quality assurance programs of their suppliers as required.
2.18.2 Responsibilities The Safety, Safeguards and Quality Manager is responsible for the development, maintenance, scheduling and performance of the internal audit and external supplier audit system consistent with the requirements of this section of the QAP.
Audited organizations are responsible for providing assistance as required during the planning and perfonnance of audits, for providing access to facilities, personnel, documents, and records, as required, and for ensuring that requests for corrective action are promptly answered and that actions taken to correct any discrepancy are adequate and timely.
36 1
Quality Assurance Program - GDPs August 15,1998-b(~'\\
Rev.26 2.18.3 Requirements 2.18.3.1 Training and Qualification
- 1. Procedures are established to ensure that audit personnel are provided with appropriate training such 7
+ that they are competent to perform the required audits; and
- 2. Procedures also require that auditors and lead auditors meet the training and experience requirements as described in Section 2.2.4. Technical specialists may participate as audit team members provided they receive the required indoctrination and guidance during the audit.
2.18.3.2 Scheduling l.'
Procedures are established'to ensure internal and external audits are scheduled in a manner to provide coverage and coordination with ongoing QAP activities, at a frequency commensurate with the status and importance to safety of the activity. The audit schedule is reviewed periodically and revised as nxessary to assure coverage is maintained current;
- 2. ' The frequency for regularly scheduled internal and external audits is based upon evaluation of all applicable and active elements of this QAP. These evaluations include an assessment of the
, effectiveness of the applicable and active elements of the program based upon such information as-the following:
' ~O
.importance to safety a.
- b. ' previous audit results and corrective action c.
nonconformance reports 5
- d. indepetxient information (e.g., from sources such as generic industry experience, ASME, peer inspections, regulating bodies, etc.);
- 3. External audits of approved non-commercial grade suppliers are scheduled and performed at least every three years from the date of the initial acceptable supplier evaluation. Approved non-commercial grade suppliers performance shall be evaluated annually in the years between audits.
l-Extemal audits of non-commercial grade suppliers, after award of a contract, are not necessary for procurement actions when the items or services are all of the following: (1) relatively simple and standard in design, manufacture. and test; (2) subject to standard or automated inspections or tests
- of the end product to' verify quality characteristics after delivery; and (3) such that receiving
. _ inspection does not require operations that could adversely affect the integrity, function or cleanness of the item. In addition:
Approved non-commercial grade suppliers, if used infrequently, do not require reaudit every a.
three years. However, they shall be audited prior to use if their QAP approval has lapsed.
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Quality Assurance Program - GDPs August 15, 1998 Rev. 26
- b. Suppliers of services do not require external audit if they perform work on site using the USEC QAP and procedures under direct USEC supervision. Otherwise, external audit will be required for suppliers of services;
- 4. Internal audits are regularly scheduled and performed such that the requirements of Section 2 of this QAP are audited at least once every three years. To form the basis for determining audit cycies longer than one year, the Independent Assessment group performs a documented evaluation of performance history of the audit area. This evaluation and assessment will be performed annually for those areas with audit cycles longer than one year. The evaluation of performance history will include review of such information, as applicable or available, as: event reports, problem reports, nonconformance reports, QA surveillance reports, self-assessment reports, NRC inspection and observation reports, trend reports, management assessments, or other management reports as applicable or available in addition to the criteria of 2 above; and
- 5. Regularly scheduled audits are supplemented by additional unscheduled audits or surveillance for one or more of the following conditions:
To determine the capability of a supplier's QA Program prior to award of a contract or purchase a.
- order,
- b. When, after award of contract, sufficient time has elapsed for implementing the QA Program and it is appropriately performing the functions as defined in the QA Program, codes, standards, and other contract documents, When significant changes are made in functional areas of the QAP such as significant c.
reorganization or procedure revisions,
- d. When it is suspect that safety, performance, or reliability may be in jeopardy due to deficiencies in the QAP or an approved supplier's QA Program, e.
When a systematic independent assessment of program effectiveness or item quality or both is considered necessary, and f.
When it is necessary to verify implementation of required corrective actions.
2.18.3.3 Audit Plan Procedures are established to ensure that the auditing organization develops and documents an audit plan for each audit. The plan is required to identify the audit scope, requirements, audit personnel, activities to be audited, organizations to be notified, applicable documents, schedule, and applicable written procedures and approved checklists, of questions covering the items to be audited.
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Quality Assurance Program - GDPs August 15,1998
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%-)
2.18.3.4 Personnel and Selection of Audit Team
- 1. Procedures are established which provide measures for the selection of the audit team, and audit team familiarization. These measures ensure consideration is given to special abilities, specialized technical training, prior experience, personal characteristics, and education when personnel are selected as audit team members;
- 2. Procedures also require that the selected auditors be independent of any direct responsibility for performance of the activities which they will audit and, in the case of internal audits, personnel having direct responsibility for performing the activities being audited are not involved in the selection of the audit team;
- 3. Procedures also require that an audit team be identified prior to the beginning of each audit. The team contains one or more auditors and shall have an individual appointed to lead the team who l
organizes and directs the audit, coordinates the preparation and issuance of the audit repon, and evaluates the responses; and
- 4. These procedures also establish measures for audit team preparation ppor to initiation of the audit, particularly that pertinent infomtation including policies, procedures, standards, instructions, codes, regulatory requirements, and prior audit repons, is available for review by the auditors for formulation of the checklist and the conduct of the audit.
OQ 2.18.3.5 Audit Performance Procedures are established for governing the activities associated with audit performance. These procedures establish requirements for audit performance which are in accordance with performance-based principles and satisfy the requirements of Supplement 18S-1, Section 4 of ASME NQA-1,1989.
2.18.3.6 Reporting Procedures establish measures for the preparation and issuance of an audit report within 30 days of the post-audit conference. The audit report is distributed to the responsible management of both the auditing and the audited organizations. These procedures ensure that the minimum information of i
ASME NQA-1,1989, Supplement 18S-1, Section 5 is included in the audit report which is prepared, signed, and issued by the audit team leader.
2.18.3.7 Response and Follow-Up Action t
j
- 1. Procedures require that the management of the audited organization or activity investigate adverse audit findings, identify and schedule corrective action, identify and schedule measures to prevent i
recurrence, and notify the appropriate organization in writing of the actions taken or planned. The adequacy of the written audit responses is evaluated by or for the auditing organization; and i
- 2. Procedures require follow-up actions to be taken to verify that corrective actions are completed as scheduled.
O V
39
Quality Assurance Program - GDPs August 15, 1998 Rev. 26 2.I8.3.8 Records Audit records include audit plans, audit replies, written reports, and record of completion of I
corrective action.
4.
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l (t Rev. 26 l
l Hierarchy of Technical Documents Federal (CFRs), State, and Local Regulations 4
Certificate of Compliance Includes:
Technical Safety Requirements Safety Analysis Report Fundamental Nuclear Material Control Plan Security Plan Emergency Plan Quality Assurance Program Radioactive Waste Management Program Depleted Uranium Management Plan Nuclear Safety Programs Nuclear Criticality Safety Program O
li mP ance Plan USEC Policies 4
Procedures i
Note 1. Listed documents are for information, not all documents are included in the scope of the quality program.
Note 2. Not all layers of documents need to be present to flow down requirements to a lower level document.
Figure 2-1. Ilierarchy of technical documents.
41
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Quality Assurance Program - GDPs August 15,1998
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Rev. 26 -
Appendix A AUGMENTED QUALITY PROGRAM This Appendix describes the extent to which QAP Sections 2.1 through 2.18 apply to AQ items and activities or describes alternatives. Section 3.15 of the Paducah Safety Analysis Report and Section 3.8 of the Portsmouth Safety Analysis Report describe the AQ systems and boundaries to which this appendix applies. Appendix A, Section i describes the QAP applicability for Nuclear Criticality Safety.
Section 2 describes the QAP applicability for the remaining AQ systems. Section 3 describes the quality requirements for AQ structures.
l
'AQ items and activities are important to safety. Sections 1, 2, and 3 describe the extent of applicability of the Q quality assurance program or provide alternatives to Q requirements, i
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A-1
Quality Assurance Program - GDPs August 15,1998 Rev. 26 l
l Appendix A Section 1 AQ - Nuclear Criticality Safety The following elements apply as specified below to those SSCs identified in NCSAs/NCSEs required to meet the double contingency principle.
1.1 QAP Organization Section 2.1 " Organization" of the Q program applies.
1.2 Quality Assurance Program Section 2.2 " Quality Assurance Program" of the Q program applies.
1.3 Design Control Section 2.3 " Design Control" of the Q program applies.
1.4 Procurement Document Control Section 2.4 " Procurement Document Control" of the Q program applies.
1.5 Instructions, Procedures, and Drawings Section 2.5 " Instructions, Procedures, and Drawings" of the Q program applies.
1.6 Document Control Section 2.6 " Document Control" of the Q program applies.
1.7 Control of Purchased Items and Senices Section 2.7 " Control of Purchased Items and Services" of the Q program applies.
1.8 Identification and Control of items Section 2.8 " Identification and Control of Items" of the Q program applies.
1.9 Control of Processes l
Section 2.9 " Control of Processes" of the Q program applies.
A-2
Quality Assurance Program - GDPs August 15,1998 Rev.26 1.10 Inspection Section 2.10 " Inspection" of the Q program applies.
1.11 Test Control Section 2.11 " Test Control" of the Q program applies.
1.12 Control of Measuring and Test Equipment Section 2.12 " Control of Measuring and Test Equipment" of the Q program applies.
1.13 Handiing, Storage and Shipping Section 2.13 " Handling, Storage, and Shipping" of the Q program applies.
1.14 Inspection Test and Operating Status Section 2.14 " Inspection, Test, and Operating Status" of the Q program applies.
1.15 Nonconformance Control
/'N -
g Section 2.15 "Nonconformance Control" of the Q program applies.
1.16 Corrective Action Section 2.16 " Corrective Action" of the Q program applies.
1.17 Quality Assurance Records Section 2.17 " Quality Assurance Records" of the Q program applies.
1.18 Audits Section 2.18 " Audits" of the Q program applies.
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Quality Assurance Program - GDPs August 15, 1998 Rev.26 l
Appendix A Section 2 AQ - Other SSCs The following elements apply as specified below for AQ SSCs (except NCS) contained within the boundaries discussed in SAR Section 3.15 (Paducah) and SAR Section 3.8 (Portsmouth).
2.1 Organization Section 2.1 " Organization" of the Q program applies.
2.2 Quality Assurance Program Section 2.2 " Quality Assurance Program" of the Q program applies with the following alternatives:
- 1. Training for AQ activities differ from training for Q activities in the rigor and formality for individual SAT elements, and includes as a minimum:
Conduct of needs/ job analysis and identification of tasks for training - The needs/ job a.
analysis is an informal table-top discussion or a subject matter expert interview to identify training needs, b.
Development of learning objectives - The learning objective is a single overall terminal objective rather than a breakdown of multiple enabling or learning objectives tied back l
to the overall objective.
c.
Development of lesson plans and training guides - The lesson plan development and approval process is less formal and limited to technical reviews in lieu of additional instructional technologist review and approval.
1 I
d.
Evaluation of trainee mastery of learning objectives - The evaluation of trainee mastery l
oflearmng objectives is determined by the needs/ requests of line management. Written performance evaluations are not required.
e.
Evaluation of the effectiveness of training - The evaluation of the effectiveness of training is determined by the needs/ requests of line management. Formal assessments and I
surveys are not required.
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Quality Assurance Program - GDPs August 15,1998
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2.3 Design Control 2.3.1 General A design control system is established for AQ items and related activities and services within the scope.of this Appendix as identified in Section 2.2. This system is in accordance with ASME NQA-1, 1989, Basic Requirement 3, and Supplement 3S-1. These requirements and controls ensure that new design and design change activities are carried out in a planned, controlled, and orderly manner, and that design requirements such as design bases, regulatory requirements and appropriate quality standards are correctly translated into 6 sign output, procurement, and procedural documents. These controls also establish provisions for verifying or checking the technical adequacy of design documents including computer codes. They also provide for the control of design changes. The design control provisions contained in this Appendix are applicable to design activities taking place after the date NRC assumes regulatory oversight for the plant. Reconstitution of the design is not required; however if a deviation to the design is discovered, engineering shall resolve the deviation and as-built the drawings if necessary.
2.3.2 Responsibilities The Engineering Manager is the plant design authority having responsibility for the implementation and execution of the design control system in accordance with the requirements of this section, Design changes and new designs are authorized by responsible management and are reviewed (as (g")
described in SAR Section 6.2) by the Plant Operations Review Committee (PORC) prior to f
implementation in accordance with the provisions of 10 CFR 76.68. Management is responsible for ensuring that completed plant changes are tested and for assuring that personnel affected by the change are adequately trained as described in procedures.
2.3.3 Requirements 2.3.3.1 Design Inputs Procedures for design input activities are established to ensure the following:
- 1. Design inputs, such as approach to design bases, performance requirements, regulatory requirements, codes, and standards, are identified and documented, and their selection reviewed and approved by the responsible design organization;
- 2. Design inputs are approved on a timely basis and to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for making design decisions, accomplishing design verification measures, and evaluating design changes; and 1
l
- 3. Changes from approved design inputs, including the reason for the changes, are identified, approved, documented, and controlled.
p V
A-5
Quality Assurance Program - GDPs August 15,1998 Rev. 26 2.3.3.2 Design Process Procedures are established to ensure the following:
- 1. Design activities are planned on a timely basis and to the level of detail necessary to permit the design process to be carried out in a correct manner and to permit verification that the design meets requirements. Design inputs are correctly translated into design documents;
- 2. Appropriate quality standards are identified and documented and their selection reviewed, approved, and controlled including changes thereto;
- 3. Design methods, materials, parts, equipment, and processes that are essential to the function of the SSC are selected and reviewed for suitability of application; and
- 4. Final design output documents including changes thereto are:
a.
Relatable to the design input by documentation in sufficient detail to permit design verification, b.
Identify assemblies and/or components that are part of the item being designed.
2.3.3.3 Design Analyses Procedures for design analyses activities are established to ensure the following:
- 1. Design analyses are performed in a planned, controlled, and documented manner;
- 2. Design analyses documents are legible and in a form suitable for reproduction, filing, and retrieval;
- 3. Design analyses documents contain sufficient detail as to the purpose, method, assumptions, design input, references, and units such that a person technically qualified in the subject can l
review and understand the analyses and verify the adequacy of the results without recourse to the originator;
- 4. Calculations are identifiable by subject, originator, reviewer, and date or by other data such that the calculations are retrievable;
- 5. When computer programs are utilized for design analyses, the requirements of Section 3.1(a) of Supplement 3 S-1 of ASME NQA-1,1989 are applied; and
- 6. Design analyses documents include the requirements of Section 3.1(b) of ASME NQA-1,1989 Supplement 3 S-1.
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l Quality Assurance Program - GDPs August 15,1998 Rev. 26
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2.3.3.4 Design Verification Procedures for design verification activities are established to ensure the following:
l
- 1. Design verification is performed by competent individual (s) or group (s) other than those who-l performed the original design;-
- 2. Verifiers are knowledgeable in the areas to be verified, The verifier may be a supervisor, L
provided the supervisor was not directly responsible for the design (i.e., did not specify a l
singular design approach or rule out certain design considerations and did not establish the design inputs used in the design);
l-
- 3. Design verification is completed prior to relying upon the component, system, structure, or computer program to perform its function;
- 4. The extent of the design verification is a function of the importance to safety, the complexity l
of the design, the degree of standardization, the state of the art, past performance, and l.
similarity with previously proven designs. Where changes to previously verified designs are l
made, design verification is performed for the changes,- including an evaluation of the effects l'
of the changes on the overall design and on any design analysis for which the design is based; and
- 5. Acceptable methods of design verification are identified which include, but are not limited to, any one or a combination of the following: design reviews, alternate calculations, and L
qualification testing. Procedures identify the criteria for determining the method of design verification. Verification by testing shall demonstrate adequacy.of performance under j
conditions that simulate the most adverse design requirements. Verification of computer
[
programs includes appropriate testing in accordance with the requirements of Section 2.11.
2.3.3.5 Design Changes i
Procedures for design change control are established to ensure the following:
1
- 1. Changes to final designs, field changes, modifications, and nonconforming items dispositioned a
"use-as-is" or " repair" are justified, documented, and evaluated against criteria established by the Engineering Wnager; L
- 2. Design documents. including changes thereto, are controlled in accordance with Section 5 of Supplement 3 S-1 to NQA-1-1989 and Section 2.6 of this Appendix. When a significant design J.
' change is found to be necessary because of an incorrect design, the design process and L
verification procedure are reviewed and modified as necessary; and
- 3. Changes to the plant are evaluated and processed in accordance with the provisions of 10 CFR 76.68.
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Quality Assurance Program - GDPs August 15, 1998 Rev. 26 2.3.3.6 Design Interfaces Procedures for design interface control are established to ensure the following:
- 1. Internal and external design interfaces are identified and controlled and design efforts are coordinated among participating organizations;
- 2. The responsibilities for the preparation, review, approval, release, distribution, and revision of documents involving design interfaces are defined; and
- 3. Design information transmitted across interfaces is documented and controlled.
2.3.3.7 Design Documentation and Records Design documentation and records that provide evidence that the dedgn ar;d design verification processes were performed in accordance with this section are collected stored, and maintained in 4
accordance with Section 2.17.
l 2.4 Procurement Document Control 1
1 2.4.1 General A procurement document control system is established for AQ items and related activitics and services within the scope of this Appendix as identified in Section 2.2. The procurement document control system is in accordance with ASME NQA-1,1989, Basic Requirement 4, and Supplement 4S-1.
The procurement document control system ensures that applicable regulatory requirements, technical requirements, and QAP requirements are included or referenced in procurement documents for the procurement of items and services. This system also establishes provisions for the preparation, review, approval, and control of procurement documents, including changes thereto.
2.4.2 Responsibilities The Engineering Manager is responsible for the preparation and maintenance of design specifications (including specifications for spare and replacement parts) and for identifying the technical and quality requirements necessary to ensure item acceptability. These specifications are subject to the requirements of Section 2.3 of this Appendix. The Engineering Manager is also responsible for development of procedures that define these activities, including the criteria for developing the necessary technical and quality requirements for procurement taking into consideration the importance to safety.
The Central Procurement Director is responsible for purchasing activities and for ensuring that items are procured in accordance with the technical and quality requirements specified by engineering.
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Rev.26 L) l 2.4.3 Requirements l
f AQ items are procured as commercial available in accordance with the criteria in this section and Section 2.7 of this Appendix. Procurement documents for AQ services shall meet the requirements of Section 2.4 of the Q program.
2.4.3.1 Procurement Document Contents Procedures governing procurement document content are established to ensure the following:
- 1. Items are purchased by reference to the manufacturers part number and nomenclature unless other technical requirements are specified by engineering, taking into consideration the importance to safety. When specified by engineering, technical requirements are included in I
procurement documents by specific reference to drawings, specifications, codes, standards, l
regulations, procedures, or instructions, including revisions thereto, that describe the items or services to be furnished. Procurement documents identify any special instructions and requirements for designing, fabricating, cleaning, erecting, packaging, shipping, handling, storing, testing, inspecting, and accepting.
- 2. Procurement documents specify appropriate quality requirements needed to ensure acceptability and useability of the items being procured.
O'")
- 3. Procurement documents identify the documentation required to be submitted for information, t
review, or approval. The identification of technical and quality requirements equal to or better than the original requirements are provided for ordering replacement parts or assemblies.
l 2.4.3.2 Procurement Document Review Procedures for the review of procurement documents are established to ensure the following:
1
- 1. A review of procurement documents and changes thereto shall be made to assure that documents transmitted to the prospective supplier (s) include appropriate provisions to assure i
that items or services will meet the specified requirements; I
- 2. Changes made as a result of the bid evaluation or precontract negotiations are incorporated in procurement documents. The review of these changes are completed prior to contract award.
l This review shall ensure the requirements of Section 3 of Supplement 4S-1 to ASME NQA-1, l
1989 are satisfied; and l
- 3. The reviews and approvals required by this section are performed by personnel who have access to pertinent information and who have an adequate understanding of the requirements and the procurement documents.
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1 Quality Assurance Program - GDPs August 15,1998 Rev. 26 2.4.3.3 Procurement Document Changes l
Procedures ensure that procurement document changes are subject to the same degree of control
)
as utilized for the preparation of the original procurement document.
2.5 Instructions, Procedures, and Drawings Section 2.5 " Instructions, Procedures, and Drawings" of the Q program applies.
2.6 Document Control Section 2.6 " Document Control" of the Q program applies.
2.7 Control of Purchased Items and Senices 2.7.1 General A system for the control of purchased items and services is established for AQ items and services within the scope of this Appendix as described in Section 2.2. The requirements for the control of purchased items and services are in accordance with Basic Requirement 7 and Supplement 7S-1 of ASME NQA-1,1989.
2.7.2 Responsibilities The Safety, Safeguards and Quality Manager is responsible for evaluation of the QA capabilities of suppliers of services and for providing the necessary QA functions to support procurement of services. The Safety, Safeguards and Quality Manager is also responsible for developing and implementing procedures which meet the requirements of this section.
The Production Support Manager provides support functions such as source verification or surveillance, receipt inspections, installation inspections, and review of procurement documents during receipt inspections. This manager is also responsible for developing and implementing procedures which meet the requirements of this section.
The Engineering Manager is responsible for evaluation of suppliers' technical capabilities and for determining the methods of acceptance to be applied to purchased services. The Engineering Manager is also responsible for the approval of dispositions and technical evaluations for supplier-generated nonconformances for services when required by purchasing documents. The Engineering Manager is also responsible for providing measures which ensure the proper selection, application, methods of acceptance, and use of items.
The Central Procurement Director is responsible for purchasing items and services in accordance with the technical requirements specified by engineering.
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2.7.3 Requirements AQ items that are procured in accordance with the requirements of this section. AQ services shall be in accordance with the requirements of Section 2.7 of the Q program.
2.7.3.1 Changes to Procurement Documents The requirements of Section 2.4.3.3 are followed when changes to procurement documents are
- made, j
2.7.3.2 Application, Use and Methods of Acceptance for Items Procedures are established which govern the application, use and acceptance of items. Engineering specifies the use, acceptance criteria and method of acceptance for procured items and is in accordance with the following:
- 1. Engineering specifies methods used to accept items. Methods include one or more of the following:
{
a.
Receipt inspection (done for all items) j b.
Post-installation test c.
Supplier survey (O) d.
Source verification j
e.
Acceptable supplier and item performance record f.
Certificate of Compliance g.
Special test I
- 2. The selection of the method or combination of methods in 1. above is based on the following:
l a.
Importance to safety and complexity of the item, b.
Selected critical characteristics,
]
c.
Available supplier information, j
d.
Quality history, e.
Degree of standardization j
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- 3. Alternate items are allowed provided the Engineering Manager provides verification that the I
alternate item will perform its intended AQ function.
- 4. Procurement documents are issued and controlled in accordance with the requirements of Section 2.4 of this Appendix.
l S. Receipt inspections determine that damage was not sustained during shipment, that the item J
received is the item ordered, and that inspection and testing are performed as required, to j
ensure conformance with manufacturer's published requirements; and to ensure that required documentation is received and is acceptable.
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l Quality Assurance Program - GDPs August 15,1998 Rev. 26 2.8 Identification and Control of Items 2.3.1 General A system is established for the identification and control of AQ items within the scope of the Appendix as described in Section 2.2 of this Appendix. The requirements for the identification and control of such items are in accordance with Basic Requirement 8 and Supplement 8S-1 of ASME NQA-1,1989. This system establishes the requirements for the identification and control of such items and associated materials, consumables, parts, spare parts, components, and sub-assemblies.
2.8.2 Responsibilities The Engineering Manager is responsible for specifying requirements for identification methods, traceability, shelf life, and operating lifc of items when required by codes, standards, or specifications.
Engineering specifies these requirements during the generation of specifications, drawings, procurement documents, or other documents appropriate to the circumstances.
Organization Managers are responsible for maintaining and implementing identification, traceability, shelf life and operating life requirements for items under their jurisdiction.
The Materials Management Manager is responsible for receipt, delivery, storage, identification, traceability, and control of materials.
2.8.3 Requirements 2.8.3.1 Identification ofItems Procedures are established to ensure that items are identified from initial receipt and fabrication of the items up to and including installation and use to assure that only correct and accepted items are used or installed. Where physical identification to control the item is either impractical or insufficient, physical separation, procedural controls, or other means are employed. When markings are used, measures are established to ensure that the markings are clear, legible and do not have a detrimental effect n.- the function or service life of the item. Markings are transferred to each part of an identified item when subdividing and are not to be obliterated or hidden by surface treatments or coatings unless other means of identification are provided.
2.8.3.2 Traceability of Items Procedures are established for the traceability of items, when specified by codes, standards or specifications.
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\\,J 2.8.3.3 Limited Life Items Procedures are established to ensure that items which have a limited operating life or shelf-life are identified and controlled to preclude use of items whose operating life or shelf-life has expired. These procedures also establish the requirements for the identification and control of items such as chemicals and reagents.
2.8.3.4 Maintaining Identification of Stored Items Procedures are established for the control of item identification consistent with the planned duration and conditions of storage such as (1) provisions for maintenance or replacement of markings and identification records due to damage during handling or aging, (2) protection of identifications on items subject to excessive deterioration due to environmental exposure, and (3) provision of updating existing plant records.
2.9 Control of Processes Sectica 2.9 " Control of Processes" of the Q program applies.
2.10 Inspection p
2.10.1 General O
A system for inspection is established for AQ items which is within the scope of this Appendix as identified in Section 2.2. The requirements for inspection are in with accordance with ASME NQA-1, 1989, Basic Requirement 10, and Supplement 10S-1. This system provides measures to ensure that maintenance, repair or modification work is completed satisfactorily.
2.10.2 Responsibilities The Production Support Manager is responsible for inspection planning, for ensuring inspections are performed when required by documents or procedures, and for utilizing qualified and certified inspection personnel.
I Organization / Group Managers, responsible for the activity being inspected, are responsible for j
specifying hold and witness points in applicable work control documents and ensuring work quality is in accordance with inspection procedures, plans, and checklists as appropriate. Work control documents are developed from approved design documents, which specify the criteria for acceptance of
]
the work.
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2.10.3 Requirements Procedures for the inspection of AQ items and activities ensure the following:
- 1. Inspection for acceptance shall 'oe performed by persons other than those who performed or directly supervised the work or activity being inspected.
- 2. Inspection for acceptance following maintenance or repair is accomplished by Post Maintenance Testing and/or Functional Testing as a minimum. Engineering specifies additional inspection requirements taking into consideration the importance to safety, and applicable codes, standards, and other commitments.
- 3. Personnel performing Post Maintenance Testing and/or Functional Testing are qualified to perform the specific operation or maintenance tasks, based on knowledge of the specific operation or maintenance requirements. Quality control personnel performing inspection are trained and qualified in accordance with Section 2.2.
- 4. Inspection hold points are established to ensure that work does not bypass required inspections.
These hold points are established in work control documents. Work shall not proceed beyond an inspection hold point without specific consent of the designated inspection representative.
Consent to waive hold points is recorded prior to continuation of work beyond the designated hold point.
- 5. Inspection activities are performed to verify the quality and conformance of the item to specified requirements.
- 6. The identification of inspection activities, including inservice inspection, and attributes are based on the importance to safety and the cornplexity of the item or activity to be inspected; on mandatory inspections required by codes, standards, regulatory requirements, and commitments; and on inspection requirements established by the Engineering Manager. The depth and extent of inspections are determined by the importance to safety and complexity of the item or activity.
7.
Final inspection consist of Post Maintenance Testing and/or Functional Testing for the specific item involved. Where necessary, engineering identifies additional final inspection requirements.
- 8. Repairs, replacements, and modifications performed subsequent to final inspection require reinspection or retest, as appropriate, to verify acceptability.
- 9. Inspection and test requirements are identified in either maintenance procedures or work control documents and include acceptance criteria specified by engineering.
Inspections are documented. The documentation identifies the acceptance criteria, and provides for the recording of the objective evidence of the inspection results.
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Quality Assurance Program - GDPs August 15, 1998 Rev.26
- 10. Where a sample is used to verify acceptability of a group of items, the sampling procedure is documented and clearly identifies the sampling basis (typically based on recognized standard / practices).
I1. Work control documents specify the minimum documentation requirements for inspection as follows:
a.
item inspected b,
date of inspection c.
inspector d.
type of observation e.
results or acceptability f.
reference to information on action taken in connection with nonconformances 2.11 Test Control Section 2.11 " Test Control" of the Q program applies.
2.12 Control of Measuring and Test Equipment Section 2.12 " Control of Measuring and Test Equipment" of the Q program applies.
,m()
2.13 Handling Storage and Shipping 2.13.1 General A system is established for the handling, shipping, and storage of AQ items identified as within the scope of this Appendix as described in Section 2.2.
This system is in accordance with Basic Requirement 13 and Supplement 13S-1 of ASME NQA-1,1989. This system provides the requirements for item handling, storage, and shipping, to prevent damage, loss, or deterioration.
2.13.2 Responsibilities The Engineering Manager is responsible for specifying the requirements for handling, storage, shipping, cleaning, packaging, and on site movement of items in specifications, drawings, instmetions, procedures, procurement documents, and/or other appropriate documents, in accordance with requirements of this section of the Appendix.
Organization / Group Managers have the responsibility for the proper handling and on-site movement of items under their cognizance from the point of issuance through installation and use. These activities are accomplished in accordance with procedures consistent with the requirements of this section of the l
Appendix.
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The Materials Management Manager has the responsibility for the proper handling, storage, and on-site movement of items under his/her cognizance (i.e., upon receipt, during storage, and to the point of issuance). These activities are accomplished according to procedures consistent with the requirements of this section of the Appendix.
2.13.3 Requirements 1.
Procedures identify requirements for the handling, storage, cleaning, packaging, shipping, and preservation of items. These requirements are established during the generation of procurement, design, and shipping documents to prevent damage, loss, or deterioration. Periodic inspections are provided to verify compliance with storage requirements and to prevent deterioration.
2.
Procedures document the training and experience requirements for operators of special handling and lifting equipment.
3.
Procedures provide measures for the identification, control, use, and qualification of special handling equipment. These pmcedures also include inspection and testing requirements, with specified time intervals, to assure adequate maintenance of special handling tools and equipment.
4.
Procedures designate the methods of controlling stored items.
5.
Procedures or procurement documents specify cleaning operations that must be performed prior to preservation, packaging, storing, or installing items.
6.
Procedures and procurement documents specify the requirements for marking, and labeling of items to identify, maintain, and preserve the item, including indication of the presence of special environments or the need for special controls.
2.14 Inspection, Test, and Operating Status Section 2.14 " Inspection, Test, and Operating Status" of the Q program applies.
2.15 Nonconformance Control 2.15.1 General A system is established for the control of nonconforming AQ items and related activities and services within the scope of this Appendix as described in Section 2.2. This system is in accordance with Basic Requirement 15 and Supplement 15S-1 of ASME NQA-1,1989. The system establishes the requirements for identification, segregation, disposition, prevention of inadvertent installation or use, documentation, and notification to affected organizations for items which do not conform to specified requirements.
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Quality Assurance Program - GDPs August 15,1998 O).
Rev. 26 2.15.2 Responsibilities i
Personnel participating in AQ quality affecting activities within the scope of this Appendix are responsible for reporting and documenting nonconforming items or related activities and services.
The Materials Management Manager is responsible for development and maintenance of the i'
nonconformance control system for materials which meet the requirements of this section of the QAP l
until the materials are issued for installation or use.
The Engineering Manager is responsible for providing documented technical justification for the.
acceptability of nonconforming items dispositioned use-as-is or repair.
This manager is also responsible for applying the design control measures of Section 2.3 to those nonconformances to design i
requirements that are dispositioned "use-as-is" or " repair," and for ensuring'that as-built records reflect the accepted deviation.
The Plant Shift Superintendents (PSS) are responsible for evaluating identified and reported nonconformances for impact on system operability and deportability to the NRC.
l 2.15.3 ' Requirements Procedures are established to provide measures for the control of AQ items and related activities and services that do not conform to specified requirements. These measures ensure the following:
s
)
i
!~
1.
Nonconforming items are identified in a manner that does not adversely affect the end use of the item, by markings, tagging, and other appropriate methods. When identification of the item is not practical, the container, package, or segregated storage area is identified.
2.
Nonconforming items are segregated, when pra tical, by placing them in a clearly identified and designated area until properly dispositioned. When segregation is impractical or impossible due to physical conditions such as size, weight, or access limitations, other measures are employed to preclude inadvertent use of the item.
' 3.
Nonconforming characteristics are reviewed and dispositions are recommended.
Further processing, delivery, installation or use of the nonconforming item is controlled pending an evaluation and approved disposition by authorized personnel, and notification to affected organizations is provided.
4.
Nonconforming items or services identified by suppliers are reviewed to determine applicability and
- to initiate corrective action if required.
5.
The responsibility and authority for the evaluation and disposition of nonconforming items is defined. The personnel performing evaluations to determine the disposition have demonstrated competence in the specific area they are evaluating, have an adequate understanding of the requirements, and have access to pertinent background information.
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Quality Assurance Program - GDPs August 15, 1998 Rev. 26 6.
The disposition of nonconforming items is identified and documented. Technical justification for the acceptability of nonconforming items dispositioned " repair" or "use-as-is" are also documented.
7.
Nonconformances to design requirements dispositioned "use-as-is" or " repair" are subject to design control measures as described in Section 2.3. The as-built records, if such records are required, reflect the accepted deviation. This as-built requirement applies only to those as-built conditions captured after the effective date of this Appendix.
8.
Repaired or reworked items are reexamined in accordance with applicable procedures and with the original acceptance criteria unless the nonconforming item disposition has established alternate acceptance criteria.
2.16 Corrective Action Section 2.16 " Corrective Actions" of the Q program applies.
2.17 Quality Assurance Records Section 2.17 " Quality Assurance Records" of the Q program applies.
2.18 Audits 2.18.1 General An audit system is established for AQ items and activities and services within the scope of this Appendix as described in Section 2.2. The audit system is in accordance with Basic Requirement 18 and Supplement 18S-1 of NQA-1,1989. This system establishes planned and periodic audits to verify the compliance and the effectiveness of this Appendix in meeting quality requirements. Audits are executed in accordance with established procedures and are performed by personnel having no direct responsibilities in the areas being audited.
Internal audits of selected aspects of operational activities are performed with a frequency commensurate with their safety significance and in such a manner as to assure that audits of activities within the scope of this Appendix, as described in Section 2.2, are completed within specified time periods.
Required external audits of suppliers of services are performed to verify compliance with applicable quality assurance requirements and procurement document requirements. External audits of suppliers of items is not required.
2.18.2 Responsibilities The Safety, Safeguards and Quality Manager is responsible for the development, maintenance, scheduling and performance of internal and external audits consistent with the requirements of this section.
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Audited organizations are responsible for providing assistance as required during the planning and performance of audits, for providing access to facilities, personnel, documents, and records, as required, and for ensuring that requests for corrective action are promptly answered and that actions taken to correct any discrepancy are adequate and timely.
2.18.3 Requirements l
2.18.3.1 Training and Qualification
)
I 1.
Procedures are established to ensure that audit personnel are provided with appropriate training such
{
that they are competent to perform the required audits; and 2.
Procedures also require that auditors and lead auditors meet the training and experience requirements as described in Section 2.2.4. Technical specialists may participate as audit team members provided they receive the required indoctrination and guidance during the audit.
)
)
2.18.3.2 Scheduling 1.
Procedures are established to ensure internal and external audits are scheduled in a manner to provide coverage and coordination with ongoing QAP activities, at a frequency commensurate with the status and importance to safety of the activity. The audit schedule is reviewed periodically and g3 revised as necessary to assure coverage is maintained current; 2.
The frequency for regularly scheduled internal and external audits is based upon evaluation of all applicable and active elements of this Appendix. These evaluations include an assessment of the effectiveness of the applicable and active elements of the program based upon such information as the following:
a.
importance to safety, b.
previous audit results and corrective action, c.
nonconformance reports.
l d.
independent information (e.g., from sources such as generic industry experience, ASME, peer inspections, regulanng bodies, etc.);
3.
Internal audits are regularl.s scheduled and performed such that the requirements of Section 2 of this Appendix are audned a: least once every three years. To form the basis for determining audit cycles longer than one year. the Independent Assessment group performs a documented evaluation of performance history of the audit area. This evaluation and assessment will be performed annually for those areas with audit cycles longer than one year. The evaluation of performance history will include review of such information, as applicable or available, as: event reports, problem reports, nonconfonnance reports, QA surveillance reports, self-assessment reports, NRC inspection and observation reports, trend reports, management assessments, or other management reports as applicable or available in addition to the criteria of 2 above;
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External audits of suppliers of services are scheduled and performed at least once every three years from the date of initial acceptable supplier evaluation. The following alternatives apply:
a.
Suppliers of services, if used infrequently, do not require reaudit every three years. However they shall be audited prior to use if their QAP approval has lapsed.
b.
Suppliers of services do not require external audit if they perform work on site using the USEC QAP and procedures under direct USEC supervision. Otherwise, external audit will be required for suppliers of service; 5.
Regularly scheduled audits are supplemented by additional unschduled audits or surveillance for one or more of the following conditions:
a.
When significant changes are made in functional areas of the QAP such as significant reorganization or procedure revisions.
b.
When it is suspect that safety, performance, or reliability may be in jeopardy due to deficiencies in the QAP or an approved supplier's QA Program.
c.
When a systematic independent assessment of program effectiveness or item quality or both is considered necessary.
d.
When it is necessary to verify implementation of required corrective actions.
2.18.3.3 Audit Plan Procedures are established to ensure that the auditing organization develops and documents an audit plan for each audit. The plan is required to identify the audit scope, requirements, audit personnel, activities to be audited, organizations to be notified, applicable documents, schedule, and applicable written procedures and approved checklists, of questions covering the items to be audited.
2.18.3.4 Personnel and Selection of Audit Team 1.
Procedures are established which provide measures for the selection of the audit team, and audit team familiarization. These measures ensure consideration is given to special abilities, specialized technical training, prior experience, personal characteristics, and education when personnel are selected as audit team members; 2.
Procedures also require that the selected auditors be independent of any direct responsibility for performance of the activities which they will audit and, in the case of internal audits, personnel having direct responsibility for performing the activities being audited are not involved in the selection of the audit team; l
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Procedures also require that an audit team be identified prior to the beginning of each audit. The team contains one or more auditors and shall have an individual appointed to lead the team who l
organizes and directs the audit, coordinates the preparation and issuance of the audit report, and evaluates the responses; and 4.
These procedures also establish' measures for audit team preparation prior to initiation of the audit, particularly that pertinent information including policies, procedures, standards, instructions, codes, regulatory requirements, and prior audit reports, is available for review by the auditors for formulation of the checidist and the conduct of the audit.
2.18.3.5 Audit Performance 1
Procedures are established for governing the activities associated with audit performance. These procedures establish requirements for audit perfomlance which are in accordance with performance-based principles and satisfy the requirements of Supplement 18S-1, Section 4 of ASME NQA-1,1989.
2.18.3.6 Reporting Procedures establish measures fer the preparation and issuance of an audit report within 30 days of the post-audit conference. The audit report is distributed to the responsible management of both the auditing and the audited organizations. These procedures ensure that the minimum information of ASME NQA-1,1989, Supplement IN-1, SecJon 5 is included in the audit report which is prepared, S
signed, and issued by the audit team leader.
t
'2.18.3.7. Response and Follow-Up Action 1.
Procedures require that the management of the audited organization or activity investigate adverse audit findings, identify and schedule corrective action, identify and schedule measures to prevent recurrence, and notify the appropriate organization in writing of the actions taken or planned. The l
adequacy of the written audit responses is evaluated by or for the auditing organization; and l
2.
Procedures require follow-up actions to be taken to verify that corrective actions are completed as scheduled.
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2.18.3.8 Records
- Audit records include audit plari, audit replies, written reports, and record of completion of corrective action.
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Quality Assurance Program - GDPs August 15, 1998 Rev. 26 Appendix A Section 3 AQ Structures Important to Safety The following requirements apply for AQ structures important to safety identified in SAR Section 3.15 (Paducah) and SAR Section 3.8 (Portsmouth).
3.1 Responsibilities The Engineering Manager is responsible for inspection and evaluation of structures important to safety.
3.2 Requirements 3.2.1 Modifications or changes to structures require evaluation in accordance with SAR Section 6.3.
3.2.2 Engineering will inspect and evaluate the physical condition of structures on a five year cycle. The structural inspection will determine if structural degradation has occurred that will affect the building's structural capacity as described and analyzed in the SAR.
3.2.3 The building inspection will include the following items:
- 1. Foundations Visible portions of the foundations for signs of settlement, anchorage integrity, cracking, spalling or other detrimental effects.
- 2. Building frames - Beam and column components for deformation and deflection.
- 3. Bracing - Bracing for trueness and deformation.
4.
Connections - Connections for bolting and weld integrity.
- 5. Corrosion - Corrosion, such as paint degradation, rust, water damage, etc., found on the structural components for significance and potential repair.
3.2.4 As found condnions identified will be evaluated in accordance with SAR Section 6.3.
3.2.5 Modifications to structures will be conducted in accordance with Appendix A, Section 2.3.
3.2.6 Repairs to stmetures will be conducted by using the maintenance control system (maintenance service requests). Engineering will review work package instructions to ensure that no change to the building structural capacity has occurred. Repairs will be "like-for-like" or be evaluated as modifications.
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Appendix B 1.0 PADUCAH AND PORTSMOUTH ITEMS ADDRESSED BY CO51PLIANCE PLAN This program is implemented as described with exception (s) as listed below. The listing of the exception (s) also contains a brief description of what is currently in place at the plant. The Compliance Plan provides a description of the exceptions (noncompliance), a justification for continued operation, a description of the actions to be taken to achieve compliance and the schedule fo completion of those actions.
l.
Except as described below, non-compliances associated with procedures, equipment, and training needed for implementation of Q requirements (described in Sections 2.2 through 2.17 of the QAP),
and AQ requirements (described in Sections 2.2 through 2.17 of Appendix A of the QAP), are addressed in the respective sections of the SAR related to the implementation of those requirements.
(e.g., Records Management non-compliances are addressed in SAR Section 6.10 and PORTS Compliance Plan Issue 29 and PGDP Compliance Plan Issue 26). Refer to the SAR and associated '
Compliance Plan Issues for a description of these non-compliances, JCOs. and corrective action plans.
2.
Section deleted.
3.
Section deleted.
.4.
Section deleted.
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l Quality Assurance Program - GDPs August 15,1998 I
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Quality Assurance Program - GDPs August 15, 1998
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Rev.26 Appendix C TECHNICAL JUSTIFICATIONS FOR EXCEPTTONS TO THE QAP
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Exception for the Paducah Records Storage Vault The following is the technicaljustification for an exception to the requirements of NQA-1,1989 for the records storage vault. An exposed fire protection sprinkler pipe passes through the records storage vault as well as two roof drain lines and there are no floor drains. The following explanation and technical justification provides reasonable assurance of the integrity of the stored records in the unlikely event of a pipe failure.
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Quality Assurance Program - GDPs August 15, 1998 Rev.26
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' Quality Assurance Program - GDPs August 15,1998 Rev.26
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ENGINEERING EVALUATION O
i C-100 RECORDS STORAGE VAULT July 24,1995 1.
Summary Statements EXISTING CONDITIONS (A)
The fire protection of the C-100 Records Storage Vault consists of pressurized water-filled sprinkler lines.
(B)
The C-100 Records Storage Vault does not conform to the NOA-1 (1989) requirements, Section 4.4.1 Part (b), which states:
" Floor... with drainage control."
There are no floor drains.
(C)
The C-100 Records Storage Vault does not conform to the NOA-1 (1989) requirements, Section 4.4.1 Part (i), which states:
LD
,V "Only those penetrations used exclusively for fire protection, communication, lighting, or temperature /
humidity control are allowed.. "
There are two roof drain lines which pentrate the records storage vault.
ENGINEERING EVALUATION The engineering evaluation was to assess the risk of water damage to records stored
{
in the vault due to the existing conditions. Two case conditions were considered l
independently: (1) A roof drain instantaneous guillotine failure releasing its entire j
capacity into the vault for a 100 year flood over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period; and (2) j Inadvertent activation of three sprinkler heads simultaneously releasing 135 gal / min flow for a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period. The evaluation determined the worst case to be an accumulation of 5 inches of water on the vault floor.
i The records will be stored in the vault on a mobile shelving system that has a clearance of 6.125 inches from the floor to the bottom shelf. Any other storage cabinets or shelving that is used in the vault is/will be placed on a base that will give a minimum of 6 inches of clearance to the bottom of the first shelf or drawer. Also, any discharge, from either the sprinkler heads or drain pipe, causing water to be sprayed onto stored records would be negligible due to the covered design of the
[
mobile shelving system.
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Quality Assurance Program - GDPs August 15, 1998 Rcy. 26 Drawing B1-3 A specifies a certified 4-hour fire door, to be provided by the manufacturer, for the vault door. However, this door is not watertight at the g
threshold and any accumulation of water would be noticeable in the hallway outside the door. When the door is opened, any collection of water will be drained through the 57 inch vault doonvay whose threshold is level with the vault floor. The vault door was conservatively assumed to be closed and watertight in the evaluation calculations.
CONCLUSION The use of the vault to store records with the current fire protection sprinklers and roof drains is acceptable. Thev do not present an unacceptable risk in terms of notential water damage to records stored in the vault.
2.
Engineering Evaluation Assumptions
- The vault door is closed and watertight.
- The two case..apable of causing water to accumulate are the failure of a roof drain and the activation of 3 sprinkler heads.
- The discharge of a roof drain is half of a 100 yr flood discharge over the area of the vault roof for a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
- The discharge of a single sprinkler head is 44.9 GPM over a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
h 71. Naudd4' 1
Date: M44/W Prepared by:
Stacey M. Marinelli Checked by:
I[
Date: 7/.26/ 95-Charles E. Floyd Date: 7ds k Approved by:
M/ft2 J4fAv. Oakley #
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Emergency. Plan - PGDP January 19,1996 A
Rev. 2 U
- 1. FACILITY DESCRIPTION USEC leases portions of Paducah DOE reservation from the Department of Energy (DOE) and conducts uranium enrichment activities at the plant. These uranium enrichment activities are regulated by the NRC. DOE and DOE contractors also conduct activities and operate other facilities at the site, which are not regulated by the NRC.
1.1 DESCRIPTION
OF NRC-REGULATED ACTIVITIES The primary mission of the plant is the enrichment of uranium viith the isotope necessary to produce fuel for nuclear reactors (*U) using the gaseous diffusion process. A basic summary of this process follows.
Uranium hexafluoride is received from the conversion plant operated by Allied Signal Corporation in Metropolis, Illinois, and other conversion facilities. The material is shipped to PGDP by truck and rail in cylinders containing 10 or 14 tons of UF in accordance with Department of Transportation (DOT) 6 regulations.
j When UF is received, it is assayed and weighed in the toll cylinder facility and stored. When 6
needed, the assayed cylinder is moved to a feed facility, heated, and evacuated to the gaseous diffusion (3
enrichment process.
q)
Uranium hexafluoride is a white crystalline solid at ambient pressures and temperature and a gas at process conditions. The enrichment method increases the concentration of"U by the physical process of diffusion. The UF gas is not physically altered nor are its chemical properties changed.
6 The gaseous diffusion enrichment process employs a series of compressors and converters to enrich UF in S U. The fundamental building block of the process consists of a compressor, a converter, and 6
a motor that form a stage. Stages are grouped together to form cells. The cells are then interconnected to provide what is known as a cascade. The compressors, which are driven by electric motors, are used
(
to circulate the process gas and main:ain flow through the cascade. The converters contain porous tubes I
and barriers through which the process gas is diffused. In each converter, a portion of the process gas diffuses through the t arrier and is fed to the next higher stage with the undiffused gas being recycled to the next lower stage. The diffused stream is slightly enriched in the 235 isotope while the undiffused portion is slightly depleted in the 235 isotope to the same degree. Each stage also contains a gas cooler
)
to remove the heat of compression from the process gas and a control valve for process control. The
{
process is repeated through numerous cells until the desired enrichment level is reached.
Upon completion of the enrichment process, the enriched portion of the process stream is extracted I
in the product withdrawal facility and placed in 2%- or 10-ton product cylinders. The product cylinders are shipped by rail or truck, in accordance with DOT and state requirements, to the Portsmouth Gaseous l
Diffusion Plant (PORTS) for further enrichment or to a licensed or DOE-operated facility for conversion to uranium metal.
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Emergency Plan - PGDP August 15, 1998 Rev. 26 The depleted portion of the process stream is extracted in the tails withdrawal facility in 10- or 14-ton cylinders. The depleted uranium cylinders are moved to the cylinder storage yards located within the fence of PGDP, where they are currently being stored.
PGDP is designed to operate at a capacity of 11.3 million separative work unit (SWU) annually at its rated power level of 3.040 MW.
Source material, special nuclear material (SNM), and byproduct material are primarily handled in the buildings and storage yards listed in Table 1-1 and 1-2, respectively. The possession limits for source material, byproduct mslerial, and SNM are shown in Table 1-3 of the Safety Analysis Report.
l Uranium hexafluoride (UF)is a radioactive, poisonous material, which is found at PGDP as a gas 6
liquid and solid. Additionally, UF. reacts with water to fonn hydrogen fluoride (HF) and uranyl fluoride (UO:F ). UF and UO F: are chemical topological hazards due to the heavy metal properties of uranium.
2 6
2 The organs primarily affected are the kidneys. HF is an acid and may cause effects from irritation of skin, eyes, mucous membranes, and lungs to chemical burns causing deep tissue destruction. The radictoxological effects of uranium at the assays encountered at PGDP are not significant when compared to the chemical topological effects.
Numerous substances associated with the enrichment process could pose hazards if they were released to the envirorunent. Only a few of these substances are highly toxic and present in large quantities at the plant. Based upon the hazards and consequence analyses that have been conducted, USEC has concluded that any nonradiological hazardous release would most likely involve one or more of the following:
Chlorine trifluoride (CIF ) is a poisonous gas, oxidizer, and corrosive. Additionally, Clli reacts 3
with water to form hydrogen fluoride and chlorine. CIF is used as a drying agent in the cascade 3
and is purchased and delivered in 160-lb cylinders. Cylinders are stored in the northwest corner of the C-745-B cylinder yard and are transferred as needed to the C-350 drying agent storage building. The CIF is vaporized into the C-350 CIF storage drum, which is used for the controlled 3
3 flow of CIF to the distribution piping. This permits the controlled flow of C)F to the C-310 3
building and to the C-331 and C-335 bulidings' metering station for cell treatment on an as-needed basis. The inventories are controlled so that no more than 1,000 lbs of ClF are available for 3
release from a single credible accident.
Nitric acid (HNO ) is a volatile, corrosive liquid. HNO up to 70% concentration is delivered by 3
3 truck and is stored in an 11,000 gal tank located outside the southwest corner of building C-400.
Prior to use, the acid is transferred to and stored in a 500-gal day tank inside the building. HNO3 is used primarily in a solution with water to decontaminate uranium-contaminated metal surfaces.
It is also used for other miscellaneous chemical operations. The maximum inventory of HNO at 3
PGDP is limited by the capacity of the storage tanks.
Hydrochloric acid (hcl) is a volatile, corrosive liquid. hcl is delivered by truck and is stored in a 17,000 gallon, two-section tank each containing 8,500 gallons, inside building C-400. Prior to use, the acid is diluted to less than 30% to form a " pickling" solution to be used as part of the j
cleaning process after degreasing, j
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Emergency Plan - PGDP August 15, 1998 Rev. 26 O
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Emergency Plan - PGDP August 15, 1998 Rev. 26 Table 1-3 Deleted.
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Emergency Plan. PGDP September 15,1995 Rev.I 9
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Emergency Plan - PGDP December 15, 1997
_Rev.21
- 4. RESPONSIBILITIES USEC is responsible for overall direction and control of NRC-regulated activities at PGDP. USEC l
is also required to provide site-wide emergency response services to DOE pursuant to Appendix F of the i
Lease Agreement.
i 4.1 NORMAL FACILITY ORGANIZATION I
i While the Executive Vice President of Operations is ultimately responsible for the safe operation of the plant, the General Manager is responsible for the day-to-day management and operation of the plant, including the program of emergency response services. An organizational chart showing the functional levels and reporting responsibilities is provided in the Safety Analysis Report, Section 6.1.
The l
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administrative and technical support personnel staffing the plant organization are normally on-site daily, l
Monday through Friday, holidays excluded. Plant operational personnel are on duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
Descriptions of the key managers at the plant and their responsibilities are provided below.
4.1.1 General Manager The General Manage. has direct responsibility for operation of the plant in a safe, reliable, and efficient manner. The Gerwal Manager is responsible for and is authorized to declare an emergency and to initiate the appropriate response.
4.1.2 Enrichment Plant Manager The Enrichment Manager provides assistance and support to the General Manager in providing for safe operation of the plant and is assigned specific areas of oversight for day-to-day production operations, maintenance, and emergency management.
4.1.3 Operations Manager The Operations Manager is responsible for the operations of the enrichment cascade. This includes such activities as ensuring the correct and safe operations of the plant utility and chemical services, UF.
j processes, proper handling of UF., and the periodic testing of equipment to ensure safe and efficient operation.
4.1.4 Production Support Manager The Production Support Manager is responsible for establishing and implementing the radiation protection program, laboratory operations, and waste management program.
4-1 l
Emergency _ Plan - PGDP August 15,1998 Rev. 26 4.1.5 Maintenance Manager The Maintenance Manager is responsible for directing and supervising the implementation of the enriclunent maintenance program for electrical, mechanical, and instrumentation and control systems and equipment.
4.1.6 Enviromnental Safety and Health Manager The Environmental Safety and Health manager is responsible for establishing and implementing the environmental monitoring program, the site environmental protection program, and industrial and chemical safety programs at the facility. This includes activities associated with environmental compliance, occupational safety and health, industrial safety, chemical safety, and industrial hygiene.
4.1.7 Site and Facilities Support Manager The Site and Facilities Support Manager is responsible for emergency management, plant fire and police services, security, and nonproduction facility maintenance.
4.1.8 Engineering Manager The Engineering Manager is responsible for engineering activities in support of operations including design, fabrication, and construction of plant modifications or additions; the configuration management program, and nuclear safety. Responsibilities also include project management, construction, and coordination of large project plant modifications or additions.
4.1.9 Administrative Support Manager The Administrative Support Manager is responsible for human resources, information services, and l
documents and records.
4.1.10 Nuclear Regulatory Affairs Manager The Nuclear Regulatory Affairs manager is responsible for the day-to-day interface with NRC representatives on matters of regulatory compliance. As delegated by the Nuclear Regulatory Assurance and Policy Manager, the Nuclear Regulatory Affairs Manager has responsibility for coordinating certification related and certificate renew 21-related activities.
4.1.11 Shift Operations Manager l
The Shift Operations Manager oversees the activities of the PSSs and has the responsibility and l
authority to make decisions to assure safe operation of the plant.
4-2
Emergency Elan - PGDP August 15, 1998 Rev.26 p)
G 4.1.12 Safety, Safeguards and Quality Manager -
1 The Safety, Safeguards and Quality Manager is responsible for implementing and directing independent assessments, quality systems, nuclear material control and accountability, and nuclear safety
]
assurance.
l 4.1.13 Emergency Management Manager The Emergency Management Manager is responsible for developing, maintaining, and updating the plan and for ensuring that the emergency management program is designed to comply with federal, state, and local regulations.
4.1.14 On-Duty PSS j
As the senior manager on shift, the on<luty PSS represents the General Manager and managers and has the authority and responsibility to make decisions as necessary to ensure safe operation, including stopping work and placing the plant in a safe condition.
The on-duty PSS is responsible for making proper notification in regard to abnormal plant conditions, determining the severity of the event, declaring an emergency, and initiating appropriate response. The on-duty PSS may respond to an incident scene as the on-scene incident commander or dispatch the APSS or other qualified individual in this capacity. The on-duty PSS is the crisis manager until relieved by a member of management designated in the emergency line of executive succession.
k 4.1.15 Assistant Plant Shift Superintendent (APSS)
The APSS responsibilities include operational, technical, and/or environmental, safety and health support functions to the plant shift operating staff. The on-duty APSS reports directly to the on-duty PSS and may be dispatched to an incident scene as the incident commander.
4.1.16 Materials Management Manager The Materials Management manager is responsible for managing the projects, programs, and the activities related to packaging and transportation, material control, stores, shipping and receiving, and property disposition.
4.1.17 Commitment Management Manager The Commitment Management Manager is responsible for providing plant management with data to assure the plant's corrective actions and commitments are properly addressed and managed to facilitate compliance with the implementing policies and procedures, including the Certification Application. The Commitment Management manager is responsible for the administration of the problem reporting system.
4.1.18 Deleted l
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V 4-3
Emergency _ Plan - PGDP August 23,1997 Rev.14 4.2 ON-SITE EMERGENCY RESPONSE ORGANIZATION The Emergency Response Organization (ERO) is responsible for taking immediate mitigative and corrective actions to minimize the consequences of an incident to workers, public health and safety, and the environment. The ERO is staffed with trained personnel who respond to events and are required to participate in formal training, drills, and exercises. The incident type and severity dictate the level of ERO activation.
The ERO has the following specitic functions and responsibilities, depending on the incident and level of response needed to mitigate the problem: event categorization, determination of emergency class, notification, protective action recommendations, management and decision making, control of on-site emergency activities, consequence assessment, protective actions, medical support, public information, activation and coordination of on-site response resources, security, communications, administrative support, and coordi; ion and liaison with off-site support and response organizations.
The ERO is divided into functional groups as follows:
1.
Plant Emergency Squad, 2.
EOC cadre, and 3.
Joint Public k.fvanation Center (JPIC).
Members of these groups are assigned to on-scene response locations and emergency response centers, such as the EOC. Emergency assignments correspond as closely as possible to daily duties.
Primary and alternate personnel are assigned to the ERO positions. Assignments are updated periodically.
Management ERO positions in each group provide oversight and final authority in the group's deci; ion-making process.
4.2.1 Direction and Coordination The initial ERO consists of the plant emergency squad with the PSS, APSS, or other qualified individual as incident commander (IC) at the scene. Upon classification of the emergency as an Alert or SAE, the PSS becomes the CM and maintains overall control of the plant during the emergency until relieved. When the EOC is operational, a manager. designated in the emergency line of executive succession relieves the PSS as CM and the overall control of the emergency shifts from the PSS to the CM.
The PSS conducts transition and turnover of command and control authority and responsibility of I
the CM function in a formal manner by use of specially developed procedural checklists and, if possible, face-to-face briefings. A primary and alternates are identified for the CM.
The order of succession for the CM position is identified in an EPIP and includes the following:
l 1.
PSS 2.
General Manager 3.
Enrichment Plant Manager j
4.
Others as designated by the General Manager and trained and qualified as CM l
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7 Emergency _ Plan - PGDP December 15,1997 n
Rev.21 STU-Ills provide secure voice conununications to on-site and off-site users of other STU-III telephones. It can operate as a normal telephone a the " clear" mode.
I Cellular telephone service is available from the plant site. The PSS and assistant PSS response vehicles are equipped with cellular telephones. This system also provides backup for the plant telephone system.
6.2.1.2 PA System A PA system is in place with the capability to cover most occupied site buildings. During emergencies, the system is not used for routine traffic. The system is tested daily. Two-way radios and runners are used to conununicate with individuals that are not covered by the PA system.
6.2.1.3 Radio Systems The four two-way racio networks support normal plant operations and, therefore, are effectively utilized daily. The PSS and assistant PSS response vehicles are equipped with two-way radios. The PSS, assistant PSS, and fire service response vehicles, including the plant ambulances, each have the capability of communicating with responding units on the county emergency response frequency.
6.2.1.4 Pager System
(
Key EOC personnel have pagers which provide access from any tone-type telephone and can relay v
return telephone numbers or coded responses to the holder of the unit. EOC cadre pager drills are conducted at least quarterly. Pagers are used frequently for nonemergency us:s, which enhances the regular testing program.
6.2.1.S Facsimile Machines The facsimile machines located in the EOC are used to communicate with USEC and federal, state, and local agencies.
6.2.2 Off-Site Communications The plant uses the commercial telephone system for off-site emergency communications. Cellular telephones can be used as a backup to the commercial telephone system. The PSS, assistant PSS, and fire service response vehicles, including the plant ambulances, each have the capability of communicating on the county emergency response frequency.
The Public Warning System, consisting of outdoor warning sirens and emergency alert system l
announcements, is used to provide emergency notification. Operations testing of the Public Warning System sirens is conducted monthly.
l (O) 6-5
Emergency Plan - PGDP August 15, 1998 Rev. 26 6.3 ON-SITE MEDICAL FACILITIES The plant maintains medical coverage consistent with the acti"ities being conducted on-site. In an emergency, off-duty medical personnel are notified and directed to required locations as needed. The PSS notifications include alerting appropriate occupational health services and medical personnel in the event of emergencies ranging from industrial accidents to toxic or radiological releases. Letters of Agreement are maintained with area hospitals. These off-site hospitals also have facilities, equipment, and supplies for the treatment of contaminated individuals. A summary of the medical resources follows.
A plant medical facility is maintained on-site during the day shift (Monday through Friday). This facility has the supplies, equipment, and personnel to treat most injuries. This includes capabilities for the treatment of contaminated individuals including a shower for contaminated ambulatory patients, radiation survey instruments, and decontamination supplies. Medical personnel assess patient condition, provide necessary emergency care, and determine appropriate supplemental treatment.
Doctors and nurses provide medical services during the day shift (Monday through Friday); plant fire fighters provide emergency medical coverage the remainder of the time.
Emergency medical technicians provide and staff ambulance service. Additional ambulance support is available from off-site.
6.4 EMERGENCY MONITORING EQUIPMENT The plant maintains various radiation detection equipment on-site for normal and emergency response use. Criticality accident alarms have been placed in those areas and in facilities containing fissile material as f.escribed in Section 5.2 of the SAR. The criticality accident alarm system provides for radiation detection and an alarm system to alert plant personnel.
Persons requiring radiation exposure monitoring wear beta-gamma-sensitive dosimeters (TLDs),
which are processed and evaluated by a processor holding current accreditation from the National Voluntary Laboratory Accreditation Program of the National Institute of Standards and Technology.
These personnel exposure monitoring dosimeters are exchanged and analyzed in accordance with Section 5.3 of the SAR. As appropriate, other types of dosimeters, (e.g., finger rings, direct-reading dosimeters, and neutron dosimeters) are used.
Radiation dose rate and contamination survey instruments used are appropriate to measure the types and energies of radiation encountered at GDPs. Instruments capable of supporting radiography operations are also maintained in inventory.
Instrumentation includes alpha / beta count rate and scaler instrumentation as well as ion chambers used to evaluate personnel exposure.
Designated plant emergency vehicles responding to the scene will contain necessary emergency equipment and supplies and ensure that radiological monitoring equipment is readily available to emergency personnel. Radiological monitoring equipment is also stored in Building C-300 for designated field monitoring personnel. Emergency equipment and its storage locations are identified in appropriate EPIPs.
6-6
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TSR-PGDP August 15, 1998 Rev.26
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SECTION 2.2 SPECIFIC TSRs FOR UF FEED FACILITIES (C-333-A AND C-337-A) 2.2.4 GENERAL LDilTLNG CONDITIONS FOR OPERATION 2.2.4.1 UF RELEASE DETECTION SYSTEM - AUTOCLAVE HEATED HOUSINGS, PIPING TRENCH, JET STATION, WEST WALL DETECTORS (C-337-A ONLY)
LCO 2.2.4.1: UF release detection system shall be operable.
6 APPLICABILITY: Modes: 4, 5 ACTIONS:
Condition Required Action Completion Time l
A.
The UF release detection A.1 Perform UF smoke Initiate within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 6
6 system is inoperable.
watch on area continuously thereafter affected by PGLD until operability restored.
detection head inoperability. TSR 1.6.2.2(d) is not I
applicable.
B.
Action item A not B.1 Place the area Immediately satisfactorily affected by the accomplished, outage.in the following mode as i
applicable: mode 2 or 3 for autoclaves and mode 6 for piping.
SURVEILLANCE REQUIRE.\\1ENTS:
Surveillance Frequency SR 2.2.4.1-1 Test each UF release detection head to Quanerly verify it will detect " smoke."
BASIS:
1 The reaction of UF. and water (free atmospheric humidity) in the case of a Up release produces uranyl fluoride (UO F:) as particulate and hydrogen fluoride (HF) as a gas which will hydrate.
2 The UO F and HF*x(H O) are highly visible as " smoke." This system detects the presence of 22 2
('
operating personnel to initiate corrective / mitigative action. [SAR 4.3.1.1.1]
this " smoke" and alarms in the local autoclave area, the OMR, and the associated ACR to alert l
2.2-12
.