ML23272A030

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PGE-8010, Revision 31, Trojan ISFSI Quality Assurance Program Manual
ML23272A030
Person / Time
Site: Trojan, 07100327
Issue date: 09/14/2023
From:
Portland General Electric Co
To:
Office of Nuclear Material Safety and Safeguards
References
VPN-008-2023 PGE-8010, Rev 31
Download: ML23272A030 (1)
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Text

Trojan ISFSI Quality Assurance Program Manual PGE-8010 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program Approval Page Approved by:

Quality Assurance Manager Signature: Date:

Approved by:

ISFSI Manager Signature: Date:

Concurrence:

Corporate Executive Responsible for Signature: Date:

Trojan PGE-8010 Page 2 of36 Proposed Revision 31

Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program TABLE OF CONTENTS POLICY STATEMENT ................................................................................................................ 5 INTRODUCTION .......................................................................................................................... 6 QUALITY ASSURANCE PROGRAM DETAILS ..................................................................... 8 1.0 ORGANIZATION ............................................................................................................... 8 1.1 Corporate Executive Responsible for Trojan ................................................................. 8 1.2 Independent Management Assessments ........................................................................ 8 1.3 Additional PGE Senior Management Oversight.. .......................................................... 9 1.4 ISFSI Organization ........................................................................................................ 9 1.4.1 ISFSI Manager ......................................................................................................... 9 1.4.2 ISFSI Staff ............................................................................................................... 9 1.4.3 QA Manager ............................................................................................................. 9 1.5 Corporate Executives Responsible for Support Organizations .................................... 10 1.6 Delegation of Work ...................................................................................................... 10

1. 7 Interface Contro I .......................................................................................................... 10 1.8 Storage Cask and Transportation Package Designer .................................................. .10 1.9 Other Engineering Services ......................................................................................... 11
1. 10 Authority to Stop Work ............................................................................................... 11 2.0 QUALITY ASSURANCE PROGRAM ............................................................................ 12 2.1 Responsibilities ............................................................................................................ 12 2.2 Program Summary ....................................................................................................... 12 2.3 QA Program Change Control. ...................................................................................... 13 2.4 Important to Safety Activities ...................................................................................... 13 2.5 Periodic Review of the Quality Assurance Program ................................................... 14 2.6 Applicability of 10 CFR 2 l .......................................................................................... 14 2.7 Personnel Indoctrination and Training ........................................................................ .14
2. 7.1 Qualification Requirements ................................................................................... 14 2.7.2 Training Records .................................................................................................... 15 3.0 DESIGN CONTROL ......................................................................................................... 16 3.1 General ......................................................................................................................... 16 4.0 PROCUREMENT DOCUMENT CONTROL ................................................................. .17 4.1 General ......................................................................................................................... 17 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS ................................................ .18 5.1 Quality Assurance Program Procedures ...................................................................... 18 5 .2 QA Review and Concurrence ...................................................................................... 18 6.0 DOCUMENT CONTROL ................................................................................................. 19 6.1 Controlled Documents ................................................................................................. 19 6.2 Control of Electronic Documents ................................................................................ 20 7 .0 CONTROL OF PURCHASED ITEMS AND SERVICES ............................................... 21 7 .1 General ......................................................................................................................... 21 7 .2 Acceptance of Item or Service ..................................................................................... 21 PGE-8010 Page 3 of36 Proposed Revision 31

Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS ................................................................................................................ 23 9.0 CONTROL OF SPECIAL PROCESSES ......................................................................... .24 10.0 INSPECTION .................................................................................................................... 25 10.1 Inspector Qualification ................................................................................................. 25 11.0 TEST CONTROL .............................................................................................................. 26 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT ............................................ .27 12.1 Calibration Control ...................................................................................................... 27 12.2 Out-Of-Calibration Equipment ................................................................................... .27 13.0 HANDLING, STORAGE, AND SHIPPING .................................................................... 28 14.0 INSPECTION, TEST, AND OPERATING STATUS ...................................................... 29 15.0 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS .............................. 30 16.0 CORRECTIVE ACTION .................................................................................................. 31 17.0 QUALITY ASSURANCE RECORDS ............................................................................. .32 18.0 AUDITS ............................................................................................................................. 33 18.1 Audit Program .............................................................................................................. 33 18.2 Audit Personnel ............................................................................................................ 33 APPENDIX A- TROJAN ISFSI FUNCTIONAL ORGANIZATION CHART ................................... 34 APPENDIX B -TROJAN ISFSI REGULATORY REQUIREMENTS AND COMMI1MENTS .......... 35 APPENDIX C - ADMINIS TRATIVE CONTROLS .......................................................................... 36 PGE-8010 Page 4 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program POLICY STATEMENT

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Portland General Electric (PGE) shall operate the Trojan Independent Spent Fuel Storage Installation (ISFSI) and prepare radioactive material shipping packages in a manner that will ensure the health and safety of the public and workers. These activities shall be performed in compliance with the requirements of the Code of Federal Regulations (CFR), the applicable Nuclear Regulatory Commission (NRC) licenses, and applicable laws and regulations of the state of Oregon and any other entities having legal jurisdiction.

The PGE Trojan ISFSI Quality Assurance (QA) Program description provided in this document summarizes how the Trojan ISFSI QA Program complies with the regulations in 10 CFR 72, Subpart G and 10 CFR 71, Subpart H. The QA Program is implemented via procedures that align with the commitments included in this QA Program. Together, they provide for control of activities conducted at the Trojan ISFSI that affect the quality of important-to-safety (ITS) structures, systems, and components (SSCs) and include all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily in service.

This QA Program governs ITS activities pertaining to 1) operation of the Trojan ISFSI under the IO CPR 72 specific license and 2) the preparation and use of radioactive material shipment packages at the Trojan ISFSI that are conducted under the Trojan 10 CFR 71 general license granted pursuant to 10 CFR 71.17. Regulatory-related programs, such as those listed in Appendix C shall be implemented via written procedures.

This QA Program is the top-level policy document that establishes the manner in which quality is to be achieved and presents PGE's overall philosophy regarding achievement and assurance of quality.

Implementing procedures assign more detailed responsibilities and requirements and define the organizational interfaces involved in conducting activities within the scope of the QA Program. The PGE Corporate Executive Responsible for Trojan establishes overall expectations for effective implementation of the QA Program and is ultimately responsible for obtaining the desired end result.

Compliance with the Trojan ISFSI QA Program and procedures is mandatory for PGE employees, contractors, and others who may directly or indirectly be associated with implementation of the QA Program. PGE management expects all personnel to perform their duties in full compliance with PGE's corporate policies governing business ethics and expectations for procedure compliance. In implementing the requirements of this QA Program, PGE employees, contractors, and others are further expected to behave in a manner that reflects a strong nuclear safety culture by using conservative decision-making and continuously reinforcing the philosophy of a safety-conscious work environment.

Corporate Executive Responsible for Trojan Portland General Electric Company PGE-8010 Page 5 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program INTRODUCTION GENERAL This Trojan ISFSI QA Program is the top-level policy document that establishes the PGE QA policy and assigns major functional responsibilities for impo1iant-to-safety (ITS) activities involving: 1) operation and maintenance of the Trojan ISFSI and 2) the preparation and use of radioactive material shipment packages that are conducted at the Trojan ISFSI. This includes activities conducted by PGE employees or for PGE by contractors. This QA Program describes the methods and establishes QA and administrative control requirements that meet 10 CFR 72, Subpart G and 10 CFR 71, Subpart H. The QA Program is implemented in a graded approach, consistent with the applicable guidance for licensees provided in NRC Regulatory Guide (RG) 7.10, "Establishing Quality Assurance Programs for Packaging Used in Transport of Radioactive Material," Revision 3.

The Trojan ISFSI QA Program is defined by this NRC-approved regulatory document that describes the applicable QA elements for both 10 CFR 72 and 10 CFR 71 ITS activities conducted at the Trojan ISFSI site. Written site procedures or instructions are used to provide detailed implementing requirements for the Trojan ISFSI staff and contractors that are consistent with this QA Program. Certain elements of Trojan ISFSI QA functions (i.e., records management and purchasing) are implemented by PGE corporate organizations outside the Trojan ISFSI organization, as described later in this document. Such functions are required to conduct assigned activities in accordance with procedures that are consistent with the requirements of this QA Program.

SCOPE/APPLICABILITY 1 PGE is a licensee of the NRC under a 10 CFR 72 specific license (SNM-2509) that governs the interim storage of spent nuclear fuel at the Trojan ISFSI. This license also grants PGE a general license under 10 CFR 71.17 to "transport, or to deliver to a carrier for transport, licensed material in a package for which a license, Certificate of Compliance (CoC), or other approval has been issued by the NRC." Conditions of both licenses require PGE to establish, maintain, and implement a QA Program that has been reviewed and approved by the NRC.

This QA Program applies to ITS activities conducted in support of ISFSI operations governed by 10 CFR 72 and activities conducted to support the preparation and use of radioactive material transportation packages governed by 10 CFR 71.

This QA Program applies to Trojan ISFSI activities governed by 10 CFR 72 affecting the quality and performance of ITS SSCs including, but not limited to operations, maintenance, procurement, inspections, and testing. However, PGE chooses not to perform ce1iain activities in-house, such as design control and special processes. ITS activities that are not performed in-house are delegated to and performed by a qualified contractor as authorized by the POE 1 For simplicity, throughout this document "Trojan ISFSI activities" includes activities governed by both 10 CFR 72 and IO CFR 71 unless otherwise stated.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program procurement process and vendor selection described herein. While certain activities may be

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delegated for implementation, PGE as the licensee maintains ultimate responsibility for compliance with this QA Program.

Because radioactive material transportation packages are designed, certified, and fabricated by the package CoC holder, ITS activities conducted by PGE pertaining to radioactive material packages under 10 CFR 71 are limited to repair, procurement, maintenance, and use consistent with the guidance in RG 7.10.

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Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program QUALITY ASSURANCE PROGRAM DETAILS 1.0 ORGANIZATION The purpose of this chapter is to delineate the authorities, responsibilities, and interfaces of persons and organizations performing activities in support of spent fuel storage and radioactive material transport at the Trojan ISFSI that affect the functions of SSCs that are important-to-safety.

Appendix A provides an organization chart that illustrates the functional authorities, responsibilities, and organizational interfaces that are used to effectively implement the Trojan ISFSI QA Program. The functional responsibilities indicated in Appendix A are further described in the sections that follow.

1.1 Corporate Executive Responsible for Trojan The Corporate Executive Responsible for Trojan has overall authority and responsibility for nuclear safety at the ISFSI facility and is responsible for promulgating PGE's corporate policies as well as QA policies; maintaining a continuing awareness of QA matters; maintaining management controls for effectively implementing applicable QA Program elements; and resolving certain disagreements between Trojan ISFSI organizational elements that may arise related to ITS activities. The Corporate Executive Responsible for Trojan has direct access to the QA Manager and the ability to inquire about any matter involving nuclear safety. The Corporate Executive Responsible for Trojan also uses the Independent Management Assessment (IMA) function to perform periodic, externally led assessments to provide feedback on particular issues of interest or on the status and adequacy of overall ISFSI operations, as circumstances dictate.

1.2 Independent Management Assessments The Trojan ISFSI uses an Independent Management Assessment (IMA) process to seek outside reviews and consultation on matters related to nuclear safety and efficient, effective ISFSI operation. The Corporate Executive Responsible for Trojan shall periodically have an IMA performed to evaluate the effectiveness of the Trojan QA Program and its implementation. These IMAs are performed by individual(s) designated by the Corporate Executive Responsible for Trojan who are independent of Trojan ISFSI operations and QA Program implementation and have the appropriate level of expertise in the activities being assessed.

IMAs are led and conducted by individuals who have the appropriate level of expertise in the activities being assessed. These periodic IMAs shall be performed no less frequently than every 24 months with a 90-day grace period. Use of all, or part of the grace period does not impact the established 24-month cycle for the assessment. The IMA results are communicated via a written report in a timely manner to the Corporate Executive Responsible for Trojan to ensure effective corrective actions are implemented, as necessary, on a timeframe commensurate with their safety significance. In addition, these results are reported to the PGE President through the Corporate Executive Responsible for Trojan. The Corporate Executive Responsible for Trojan may have an PGE-8010 Page 8 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program IMA performed for a specific or general issue of concern at any time, separate from the required 24-month periodic assessments.

1.3 Additional PGE Senior Management Oversight The ISFSI Manager and QA Manager report to the Corporate Executive Responsible for Trojan.

However, one or more temporary or permanent senior management positions may be appointed between the ISFSI Manager and/or the QA Manager and the Corporate Executive Responsible for Trojan to provide additional management oversight as circumstances demand. In this case, the Corporate Executive Responsible for Trojan retains the responsibility as the highest-level PGE responsible manager for the implementation of this QA Program.

1.4 ISFSI Organization 1.4.1 ISFSI Manager The ISFSI Manager reports to the Corporate Executive Responsible for Trojan and is responsible for the day-to-day implementation of the QA Program. Reporting to the ISFSI Manager are the ISFSI Staff line organizations that implement the tasks required to operate the ISFSI in a safe, secure, and efficient manner.

1.4.2 ISFSI Staff The ISFSI Staff reports to the ISFSI Manager. Responsibilities, qualifications, and training required for ISFSI staff personnel performing ITS activities are detailed in the Trojan ISFSI FSAR and associated implementing procedures. ISFSI Staff personnel shall not be used to perform audits of ISFSI ITS activities as provided for under this program. Appendix A provides the Trojan ISFSI functional organization chart depicting the groups that comprise the ISFSI staff.

1.4.3 QA Manager The QA Manager reports to the Corporate Executive Responsible for Trojan and is responsible

  • for independent oversight of the implementation of the Trojan ISFSI QA Program. The QA Manager also has an indirect reporting responsibility to the ISFSI Manager for ensuring efficient day-to-day implementation of the QA Program by the line organization. If disagreements are
  • identified that cannot be resolved between the QA Manager and the ISFSI Manager, then these are referred to the Corporate Executive Responsible for Trojan for resolution.

Although the QA Manager reports indirectly to the ISFSI Manager in the context of day-to-day ISFSI operations, the QA Manager does not execute line organization work. Rather, the QA Manager acts in an advisory capacity to others in the line organization to ensure compliance with this QA Program. In the oversight role, the QA Manager is responsible for implementing independent QA functions including, but not limited to, quality control (QC) inspections, surveillances, audits, and advising the Corporate Executive Responsible for Trojan on the scope ofIMA assessments. In the oversight role, the QA Manager has the authority, direct access to responsible levels of management, organizational freedom, and access to work to perform these PGE-8010 Page 9 of36 Proposed Revision 31

Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program duties, including independence from cost and schedule considerations when opposed to safety function considerations.

1.5 Corporate Executives Responsible for Support Organizations Corporate executives with responsibility for nuclear support activities shall assure that their assigned managers implement the QA Program, as applicable. Managers of nuclear support organizations that implement elements of the QA Program, such as records management and procurement services, are responsible for ensuring that procedures that implement the applicable portions of the QA Program are established, implemented, and maintained.

At least biennially, the PGE corporate managers of nuclear support organizations shall review and document the status and adequacy of the parts of the QA Program they are executing and submit it to the ISFSI Manager, QA Manager, and Corporate Executive Responsible for Trojan.

1.6 Delegation of Work PGE retains and exercises the responsibility for the scope and implementation of this QA Program. Positions identified in this QA Program may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for compliance with program requirements. Decisions affecting safety are made at the level appropriate based upon their nature and effect, with technical advice or review as appropriate.

The responsibility for implementing certain elements of the QA Program may be delegated to other organizations duly qualified to perform such activities. However, the ultimate responsibility for compliance with, and effective implementation of the requirements of this QA Program in those areas remains with PGE via the acceptance process for procured items and services.

1. 7 Interface Control Where more than one organization is involved in the execution of activities, the responsibilities, interfaces, and authority of each organization shall be clearly defined and documented. The external interfaces between organization and the internal interfaces between organizational units, and changes thereto, shall be documented.

1.8 Storage Cask and Transportation Package Designer The designers of storage cask design used at the Trojan ISFSI and the transportation package design used to ship the canistered spent nuclear fuel, provide engineering services for the cask/package designs. The storage cask designer may provide engineering support for POE ISFSI operations (e.g., license change requests for the ISFSI and evaluations of aging management inspection findings). The transportation cask designer holds the Part 71 CoC and controls the design and licensing of the packaging that will be used for shipping the spent nuclear fuel from the Trojan ISFSI. If these engineering services affect ITS SSCs, they are performed PGE-8010 Page 10 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program under the respective companies' NRC-approved QA programs, which are reviewed and approved by PGE as part of the procurement and supplier qualification processes for those services.

1.9 Other Engineering Services

  • One or more engineering firms may provide engineering services for the Trojan ISFSI. These engineering services include engineering, analysis, and design activities on an as-needed basis. If these engineering services affect ITS SSCs, they are performed under the respective companies' QA programs, which are reviewed and approved by PGE as part of the procurement and supplier qualification processes for those services.

1.10 Authority to Stop Work QA and QC inspection personnel have the authority, and the responsibility, to stop work in progress which is not being done in accordance with approved procedures or this QA Program.

This authority extends to off-site work performed by suppliers that furnish ITS items and services to the Trojan ISFSI.

All employees at the Trojan ISFSI are empowered with the authority to stop work where unsatisfactory work or unsafe conditions exist that pose an immediate threat to the health and safety of the public, workers, or the environment. Any of these conditions are to be immediately reported to the work supervisor, ISFSI Manager, and/or QA Manager for investigation and evaluation. Work that has been stopped is approved for restart commensurate with the complexity and significance of the conditions preceding the stopped work.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 2.0 QUALITY ASSURANCE PROGRAM PGE has established the necessary measures and governing procedures to implement this QA Program. This QA Program includes monitoring activities against acceptance criteria in a manner sufficient to provide assurance that ITS ISFSI activities are performed satisfactorily.

Further, PGE ensures through the systematic process described herein that its suppliers ofITS equipment or services meet the applicable requirements of 10 CFR 72, Subpart G and 10 CFR 71, Subpart H, as applicable. Senior PGE management is regularly apprised of the adequacy of implementation of the QA Program through the audit functions described in Chapter 18.

The objective of the QA Program is to assure that the Trojan ISFSI is operated and maintained, and radioactive material transportation packages prepared and used in accordance with governing regulations and license requirements. This QA Program is based on the guidance applicable to licensees in NRC Regulatory Guide (RG) 7.10, Revision 3, applied in a graded approach as suggested in Appendix A to the RG and NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety." This guidance has been appropriately applied for an ISFSI that is no longer transferring spent fuel into the storage facility. PGE is temporarily storing the spent fuel awaiting its shipment to a suitable offsite facility in the future.

Delegated responsibilities may be performed under a supplier's or principal contractor's QA Program, provided that the supplier or principal contractor has been approved as a supplier in accordance with the PGE QA Program. Periodic audits and assessments of supplier QA programs are performed to assure compliance with the requirements and commitments in those programs and implementing procedures.

2.1 Responsibilities The PGE Trojan ISFSI Manager is responsible for day-to-day implementation of this QA Program. ISFSI staff and other personnel who work directly or indirectly for PGE are responsible for achieving acceptable quality in the work covered by this QA Program. PGE QA and QC personnel performing independent verification activities are responsible for verifying the achievement of acceptable quality. Activities governed by the QA Program are performed as directed by documented instructions, procedures, and drawings that are of a detail appropriate for the activity's complexity and effect on safety. Instructions, procedures and drawings specify quantitative or qualitative acceptance criteria as applicable or appropriate for the activity, and verification is against these criteria. Provisions are established to designate or identify the proper documents to be used in an activity, and to ascertain that such documents are being used. The QA Manager is responsible for independently verifying ,hat processes and procedures comply with the QA Program and other applicable requirements, that such processes or procedures are implemented, and that management appropriately ensures compliance.

2.2 Program Summary For ISFSI operations, as provided for in 10 CFR 72.140(d), PGE has chosen to apply the Trojan QA Program previously approved under 10 CFR 71, Subpart H to satisfy the requirements of 10 CFR 72, Subpart G. As such, this QA Program also must meet the additional recordkeeping PGE-8010 Page 12 of36 Proposed Revision 31

Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program requirements of 10 CFR 72.174. Thus, this Part 71 QA Program fulfills the role of "previously approved program" as specified in 10 CFR 72.140(d).

For ITS activities governed by 10 CFR 72, the requirements of this QA Program apply to the design, fabrication, construction, testing, operation, modification, and decommissioning of the SSCs of the ISFSI, and to the managerial and administrative controls used to ensure safe operation of the ISFSI.

For ITS activities governed by 10 CFR 71, the requirements of this QA Program apply to the procurement, maintenance, repair, and use of radioactive material packaging for transport. Other 10 CFR 71 activities (i.e., design, fabrication, assembly, testing, and modification of important-to-safety radioactive material packaging) are not performed by PGE, but are the responsibility of the package CoC holder and fabricator. PGE obtains certifications from the Part 71 CoC holder that these activities are conducted in accordance with an NRC-approved QA Program as part of the procurement process.

2.3 QA Program Change Control This QA Program is maintained, and proposed changes evaluated pursuant to 10 CFR 71.106(b).

Proposed changes to this QA Program are evaluated by written procedure to determine if one or more of the changes involves a reduction in commitment as described in §71.106(b). Proposed changes that involve a reduction in commitment will be submitted to the NRC for review and approval before they are implemented at the Trojan ISFSI. Changes to the QA Program that do not reduce the commitments shall be submitted to the NRC no less frequently than every 24 months.

Revisions to the Part 71 QA Program that are approved (either with or without prior NRC approval based on the reduction-in-commitment determination) also apply to ITS activities governed by 10 CFR 72. Such changes will be made effective for use under Part 71 and/or 72, as applicable, when the ISFSI Manager determines the necessary implementing controls for the changes (e.g., procedures, training, etc.) are approved for use.

2.4 Important to Safety Activities In general, activities governed by 10 CFR 72 that are deemed ITS meet the definition of ITS found in 10 CFR 72.3. Likewise, activities governed by 10 CFR 71 that are deemed ITS meet the definition of ITS found in RG 7.10. Safety classifications for SSCs associated with Trojan ISFSI operations or radioactive material shipments are generally found in one or more of the following sources:

1. The Trojan ISFSI Final Safety Analysis Report (FSAR),
2. The Safety Analysis Report (SAR) for the transportation package, and/or
3. The associated design documents (e.g., drawings and specifications).

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program These classifications typically also include recognition of the graded approach to QA by classifying ITS items as Category A, B, or C consistent with the guidance in RG 7.10 and NUREG/CR-6407. For SSCs, SSC subcomponents, items, and services not uniquely classified in the storage FSAR or transportation SAR, PGE uses a documented procedural process for determining and documenting the safety classification and category of the item or service based on the above regulations and guidance.

2.5 Periodic Review of the Quality Assurance Program Management of those organizations implementing this QA Program, or portions thereof, shall assess the adequacy of that part of the program for which they are responsible to assure its effective implementation at least once every two years. Such assessment shall be in the form of written reports to the ISFSI Manager.

2.6 Applicabiiity of 10 CFR 21 PGE maintains a written program for identifying and reporting potential defects in accordance with 10 CFR 21. PGE requires suppliers of ITS-A items and services working under their own QA programs that have been approved by PGE to assume the responsibility for reporting potential defects pursuant to 10CFR 21 in accordance with a written procedure.

2.7 Personnel Indoctrination and Training The ISFSI Manager is responsible for establishing and implementing a program for indoctrination and training of personnel performing activities affecting quality as necessary to ensure that suitability proficiency is achieved and maintained. The indoctrination and training shall be commensurate with scope, complexity, importance of the activities, and the education, experience, and proficiency of the person.

2.7.1 Qualification Requirements Personnel performing or managing activities affecting quality shall receive indoctrination into their job responsibilities and authority, general criteria, technical objectives, requirements of applicable codes and standards, regulatory commitments, company procedures, and QA Program requirements.

The need for a formal training program for personnel performing or managing activities affecting quality shall be determined. Training shall be provided, if needed, to achieve initial proficiency, maintain proficiency, and adapt to changes in technology, methods, or job responsibilities. On-the-job (OJT) training shall be used if direct hands-on applications or experience is needed to achieve and maintain proficiency.

Individual managers of ISFSI functional areas are responsible for ensuring that personnel working under their cognizance are provided with the necessary indoctrination training and resources to accomplish assigned activities which fall under the scope of the QA Program.

Individual managers are also responsible for ensuring training and qualification documentation is complete and correct before an individual performs an ITS task.

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Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program Members of the Trojan ISFS staff (including audit and inspection personnel) shall have the appropriate qualifications necessary to perform their assigned duties defined in implementing procedures. These implementing procedures provide the criteria used to determine and assess appropriate staff qualifications.

Training programs are established and implemented to ensure that personnel achieve and maintain suitable proficiency. Personnel training and qualification records are maintained in accordance with approved procedures.

QA Lead Auditors are qualified and certified by the QA Manager in accordance with approved procedures. Training methods, minimum experience requirements, and certification practices are in accordance with established procedures and based on criteria set forth in QA Program implementing procedures. Proficiency evaluations are performed and documented as defined in approved procedures.

2.7.2 Training Records Records of the implementation for indoctrination and training may take the form of attendance sheets, training logs, or personnel training records. Records of qualification, including requalification, for Auditors and Lead Auditors and for inspection and test personnel shall be established and maintained by PGE.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 3.0 DESIGN CONTROL

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3.1 General PGE does not perform design work affecting Trojan ISFSI SSCs classified as ITS or design work affecting radioactive material packaging. Rather, ITS ISFSI design work, including engineering calculations, design change packages, and independent design verification, is performed by a qualified contracted design/engineering company. Such companies perform design work under their own approved QA Program that has been reviewed and approved by PGE as part of the procurement process. Storage cask and transportation packaging design work is performed by the storage cask design authority and the transportation package 10 CFR 71 CoC holder, respectively, under their NRC-approved QA Programs.

Pursuant to Trojan ISFSI Technical Specifications, design changes affecting ITS systems or equipment governed by 10 CFR 72 shall be approved by the ISFSI Manager prior to implementation. Procedural measures are established to assure that proposM design changes received from contracted suppliers are evaluated to determine if a change to the ISFSI license is required, and that appropriate personnel are notified of design modifications that may affect the performance of their duties.

Although design control implementation is delegated to other organizations, PGE retains overall responsibility for the quality of work via the process for acceptance of ITS items and services described elsewhere in this QA Program.

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Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program 4.0 PROCUREMENT DOCUMENT CONTROL 4.1 General Applicable procurement requirements for ITS items and services are specified or referenced in procurement documents. Measures are established to assure that, to the extent necessary, contractors or subcontractors provide a QA Program consistent with the applicable provisions of 10 CFR 72. In addition, measures are established to assure that the applicable requirements of 10 CFR 71 are included or referenced in documents for procurement ofradioactive material packaging and/or associated services, and that packages and procedures for use of these packages have been authorized by the NRC and documented in the NRC Certificate of Compliance.

Procurement requisitions and supplements thereto are reviewed for adequacy by personnel other than those that originated the requisition and/or supplements, and who are knowledgeable of QA practices and concepts. Procurement documents for ITS items and services shall state the scope of work to be performed and include all applicable design basis technical requirements (or references thereto), regulatory requirements, material and component identification requirements, drawings, specifications, codes and standards, special process instructions and test and inspection requirements to assure adequate quality. -

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 5.1 Quality Assurance Program Procedures Activities affecting quality shall be accomplished in accordance with approved and documented instructions, procedures, or drawings. Instructions, procedures, and drawings include the necessary limits and tolerances on material, equipment, processes, and specifications for activities associated with ITS items and services. Instructions, procedures, and drawings also prescribe special controls, processes, test equipment, tools, and skills to attain the required quality, and requirements for documentation and/or verification of quality by inspection and test.

PGE shall establish measures to ensure that the following requirements are fulfilled:

  • ITS activities are prescribed and accomplished in accordance with current documented instructions, procedures, or drawings that have been approved by appropriate levels of management.
  • Instructions, procedures, and drawings specify the methods for complying with each of the applicable sections of Subpart g of 10 CFR Part 72 and Subpart H of 10 CFR Part 71.
  • All work activities are coordinated with QA personnel to ensure that the work-controlling documents incorporate appropriate inspection and hold points to verify that initial work, planned work, effective repairs, or rework have been performed satisfactorily.
  • Instructions, procedures, and drawings include quantitative acceptance criteria (e.g.,

dimensions, tolerances, and operating limits) and qualitative acceptance criteria (e.g.,

workmanship samples) to verify that activities important to safety have been accomplished satisfactorily.

  • Written procedures address the use, management, storage, and protection of electronic records and data. PGE maintains information on the specific software applications and storage or computing hardware, if required.
  • All instructions, procedures, and drawings governing ITS work activities shall be followed by Trojan ISFSI personnel and contractors.

5.2 QA Review and Concurrence PGE shall establish measures to ensure that the QA organization reviews and concurs in inspection plans involving ITS SSCs in accordance with a graded approach; test, calibration, and special process procedures; and specifications as well as any changes thereto. Before fabrication of an item, the QA organization should review and concur in the related manufacturing plans, as they relate to scheduled witness and hold points during fabrication.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 6.0 DOCUMENT CONTROL Written procedures are available which provide for the preparation, review, and approval of documents requiring control. These procedures identify the appropriate qualified individuals or groups responsible for determining that appropriate quantitative and qualitative criteria are included in documents describing ITS activities and for verifying that these criteria have been satisfactorily met. Procedures also require that documents are approved for implementation by appropriate levels of management and changes to the documents are reviewed and approved by the same organizations as the original unless another responsible organization is designated by the governing procedure. Approved changes are included in controlled documents prior to implementation of the change.

Procedures shall ensure that documents are distributed in a timely manner to appropriate locations and are available for use by personnel performing prescribed activities. Master lists or equivalent document control systems are established to identify the current revision of controlled documents. These lists are available for use by cognizant personnel to preclude the use of superseded documents.

Procedures, including contractor procedures to be used onsite for ITS work, are reviewed by personnel other than those that prepared the procedure or procedure revision, and who are knowledgeable of QA practices and concepts. The level of detail in procedures is developed based on the graded approach to QA with the highest level of detail used for procedures governing ITS-A activities.

Temporary changes to documents affecting ITS SSCs may be made and implemented if a procedural method has been established to control the review and approval of the temporary changes.

6.1 Controlled Documents PGE shall maintain control of each of the documents of the QA Program to reflect the current version status. As a minimum, PGE exercises control over the following as they relate to ITS SSCs:

  • Design documents
  • Procurement documents
  • Operating and maintenance procedures
  • Inspection and test procedures
  • Corrective action reports PGE-8010 Page 19 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program 6.2 Control of Electronic Documents If the documents are stored electronically, PGE shall establish controls over access to the documents to ensure that the latest versions are available and initial versions and changes thereafter are properly authenticated, signed/authorized, and implemented. The software and hardware systems used to store electronic information shall be validated to be secure to avoid alteration or corruption of the information.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 7.0 CONTROL OF PURCHASED ITEMS AND SERVICES PGE has established the necessary measures and governing procedures to control purchased items and services to assure conformance with specified requirements. Such control provides for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services.

7.1 General PGE purchase orders/contracts for ITS items or services are placed with contractors, suppliers, and service organizations who have been evaluated by PGE for supply of the applicable ITS item or service. Procedures govern the selection of procurement sources. The effectiveness of the control of quality by contractors and suppliers shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service.

ITS items and services procured from a contractor, supplier, or service organization for which a QA program is required but has not been reviewed or accepted may be utilized by PGE when additional compensatory controls such as source inspection, special receipt instructions, and/or testing are imposed. These additional controls shall be documented and approved by the ISFSI Manager.

The QA Manager is responsible for developing and maintaining an Approved Supplier's List (ASL). Each supplier on the ASL will have a QA program equivalent to the PGE QA Program as determined by audit or other evaluation (e.g., review of supplier QA program manual and select implementing procedures). Acceptance of a supplier's QA program by PGE shall be commensurate with the importance to safety of the item or service being provided, based on the graded approach to quality.

7.2 Acceptance of Item or Service PGE establishes and implements measures to assess the quality of purchased items and services, whether purchased directly or through contractors, at intervals and to a depth consistent with the item or service importance to safety, complexity, quantity, and the frequency of procurement.

Verification actions include testing, as appropriate, during fabrication activities. Verifications occur at the appropriate phases of the procurement process, including, as necessary, verification of activities of suppliers below the first tier.

Measures to assure the quality of purchased items and services include the following, as applicable:

  • Items are inspected, identified, and stored to protect against damage, deterioration, or misuse.
  • Prospective ITS items and service suppliers are evaluated to assure only qualified suppliers are used, consistent with the quality category of the ITS item or service.

Qualified suppliers are audited no less frequently than on a triennial basis. In addition, if a subsequent contract or a contract modification significantly changes the scope, PGE-8010 Page 21 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program methods, or controls performed by a supplier, an audit ofthe changes is performed, thus starting a new triennial period.

  • PGE may utilize audits conducted by outside organizations for supplier qualification provided that the scope and adequacy of the audits meet PGE req~irements. Documented annual evaluations are performed for qualified suppliers to assure they continue to provide acceptable products and services. Industry programs, such as those applied by ASME, Nuclear Procurement Issues Corporation (NUPIC), or other established utility groups, are used as input or the basis for supplier qualification whenever appropriate. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). In addition, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action.
  • Provisions are made for accepting purchased items and services, such as source verification, receipt inspection, pre- and post-installation tests, certificates of conformance, and document reviews (including Certified Material Test Report/Certificate). Acceptance actions/documents should be established by the Purchaser with appropriate input from the Supplier and be completed to ensure that procurement, inspection, and test requirements, as applicable, have been satisfied before relying on the item to perform its intended safety function.
  • If there is insufficient evidence of implementation of a QA program, the initial evaluation is of the existence of a QA program addressing the scope of services to be provided. The initial audit may be performed after the supplier has completed sufficient work to demonstrate that its organization is implementing a QA program.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS ITS items and subassemblies are identified (on the item or on records traceable to the item) in such a manner as to allow traceability to the appropriate quality documentation. The location and method of identification are selected to prevent affecting the function or quality of the item.

When an item is subdivided, required identification markings will be transferred to each part or reflected in the records.

When several parts are joined in fabrication, a list of parts and corresponding identification documents will accompany the assembly, as necessary. This documentation will include, as applicable, heat, lot, serial or part numbers, material certifications, weld or braze qualifications, test reports, NDE records, fabrication travelers, and other documentation to provide the bases for determining the acceptability of the assembly and its component parts.

Proper identification of materials, parts, and components is verified and documented.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 9.0 CONTROL OF SPECIAL PROCESSES POE personnel do not perform special processes involving Trojan ISFSI ITS SSCs. Rather, all ITS special processes are performed by a qualified contracted company under its own approved QA Program and procured in accordance with approved procedures and Chapters 4 and 7 of this QA Program.

Although special process services are delegated to other organizations, POE retains overall responsibility for the quality of work via the process for acceptance oflTS items and services described elsewhere in this QA Program.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 10.0 INSPECTION Inspections are performed in accordance with written, approved inspection plans and/or inspection procedures, to verify that ITS items and processes conform to documented instructions, procedures, and drawings for accomplishing the activity.

Inspection programs are implemented through procedures which provide for preparation, review, and approval of inspection plans and procedures and provide for establishing mandatory hold points for witness by inspection. Inspection plans are approved by the ISFSI Manager or designee. Inspections shall be performed by QA resources other than those who performed or directly supervised the activity being inspected.

If direct inspection of items is impossible or disadvantageous, indirect control by monitoring processing methods, equipment, and personnel shall be provided. Both inspection and process monitoring shall be provided when control is inadequate without both.

10.1 Inspector Qualification PGE has established qualification programs for personnel performing quality inspections. The qualification program requirements are described in implementing procedures. These qualification programs are applied to individuals performing quality inspections regardless of the functional group to which they are assigned.

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Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program 11.0 TEST CONTROL Tests within the scope of this criterion include but are not limited to tests required by modifications and/or maintenance of SSCs classified as important to safety. These tests are performed to verify that an item will perform satisfactorily in service. The work package for maintenance or modifications to ITS SSCs identifies those tests necessary to demonstrate satisfactory performance of the affected equipment.

Measures are established to assure that test procedures incorporate the applicable requirements of 10 CPR 72 or 10 CPR 71 and the acceptance limits contained in the ISPSI license. Each test procedure is prepared and reviewed in accordance with applicable design documents, codes, and specifications.

The procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. Test results are documented, evaluated, and their acceptability determined by qualified personnel.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 Calibration Control PGE does not perform calibration of Trojan ISFSI installed instrumentation and/or portable M&TE. Rather, calibration of instrumentation used in ITS activities is performed by qualified contracted calibration facility(ies) as described below. M&TE is calibrated at intervals consistent with the manufacturer's guaranteed repeatability and PGE's experience.

Calibration services for portable M&TE may be procured from a commercial-grade supplier and shall meet the guidance set forth in NEI 14-05-A "Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement.of Laboratory Calibration and Test Services," Revision 1, as applicable to the Trojan ISFSI. This includes any applicable limitations in the NRC's Safety Evaluation Report endorsing the NEI guidance. Calibration services for installed, ITS M&TE shall be procured as an ITS service.

The control of portable M&TE and installed instrumentation is implemented by specific procedures or instructions that describe calibration control and recall frequency requirements.

Instruments, tools, gages, and fixtures used in quantitative measurement are uniquely identified, indicate calibration status, appear on a controlled list, are traceable to the national standards or natural constants, and are included in the calibration program.

12.2 Out-of-Tolerance Equipment When M&TE is found to be out of tolerance or beyond its calibration due date, PGE shall take measures to validate previous inspection and test results up to the time of previous calibration. In addition, PGE shall repair or replace any measuring equipment that is consistently out of tolerance.

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Tro;an Independent Spent Fuel Storage Installation Quality Assurance Program 13.0 HANDLING, STORAGE, AND SHIPPING On receipt of ITS items, compliance with special requirements for protective environments is verified and documented by qualified personnel responsible for ITS receipt inspection. Items are stored in a manner to protect against damage, degradation, or misuse. ITS items are handled, stored, preserved, or protected in accordance with codes and standards as specified in implementing procedures.

Procedures or instructions will be used to ensure that handling equipment, cranes, and rigging are examined and tested prior to performing critical lifts where the mishandling or drop of the lifted item can affect an ITS item.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 14.0 INSPECTION, TEST, AND OPERATING STATUS Procedures are established to indicate the status of inspections and tests involving ITS items.

ISFSI or other designated personnel are responsible for maintaining sufficient knowledge of tests or inspections in progress to control ISFSI and/or radioactive material transportation package activities.

The operating status of ITS SSCs that are found to have nonconformances is identified using tags, if appropriate, under the direction ofISFSI or other designated personnel to prevent inadvertent operation. Prior to the removal from service of ITS SSCs, ISFSI Manager permission to change status is given and documented in accordance with procedures to assure that the removal will not have an adverse effect on safe ISFSI operations.

  • PGE-8010 Page29 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program 15.0 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS Items that deviate from approved specifications, codes, drawings, or other applicable documents are considered as nonconforming. Procedures govern the use of nonconformance reports for identification, control, disposition of nonconforming items, and notification of affected organizations. The program shall include the following elements, at a minimum:

  • Proper identification,
  • Segregation of discrepant or nonconforming items,
  • Evaluation of the nonconforming items, and
  • Disposition of the nonconforming items.

Unless such controls are not feasible, nonconforming items are identified with appropriate tags and segregated to indicate their unacceptable status until the nonconformance is properly dispositioned. If this is not feasible, other methods are established to identify and control the nonconforming items.

A work package may be used in lieu of a nonconformance report in accordance with implementing procedures when nonconforming items are identified which can be restored to the original design requirements under a "rework" disposition.

Trojan ISFSI management reviews and approves nonconformance report dispositions. "Use as is" or "modify" dispositions require the review and approval of the responsible design organization. Tags associated with a nonconformance report are removed only by authorized personnel.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 16.0 CORRECTIVE ACTION Procedures govern the use of a documented process to assure that conditions adverse to quality are identified and corrected in a timely manner. Any individual has the authority and responsibility to report a condition adverse to quality to their manager or supervisor who will assure that it is or has been documented.

Significant conditions adverse to quality require determination of cause and corrective actions taken to preclude recurrence. Copies of corrective action program documents identifying significant conditions adverse to quality are distributed to appropriate levels of management for information and review.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 17.0 QUALITY ASSURANCE RECORDS The requirements under this criterion differ for 10 CFR 71, Subpart Hand 10 CFR 72, Subpart G. This is because each individual shipment of radioactive material from the Trojan ISFSI site will occur over a finite time frame. That is, once the material arrives and is accepted at a receipt facility, the recordkeeping requirements under the receiving facility's license apply.

For ISFSI operations under Part 72, the spent fuel is stored for extended time periods and records for the facility are required beyond the time of license termination. Thus, the retention requirements for maintaining quality records for transportation (10 CFR 71.135) are different than those for storage (10 CFR 72.174). This QA Program applies to activities performed under both 10 CFR 72 and 10 CFR 71. Thus, written procedures include the respective record retention requirements of Parts 72 and 71, as applicable, to spent fuel storage and transportation package preparation and use at the Trojan ISFSI. This meets the requirement in 10 CFR 72.140(d) for using a previously approved program to govern Part 72 activities.

The PGE Corporate Manager for record control services is responsible for ensuring that procedures that implement the applicable portions of the Trojan QA Program are established, implemented, and maintained.

In addition to the records required by this QA Program as defined in Trojan procedures, ISFSI records required by 10 CFR 72.30, 72.48, 72.72, and 72.80 shall be maintained. ISFSI records pertaining to the design, fabrication, erection, testing, maintenance, and use of SSCs important to safety shall be maintained by or under the control of PGE for the applicable durations specified in 10 CFR 72. Records shall also include changes to this QA Program as required by 10 CFR 71.106.

Records should be identifiable to specific systems, structures, and components, when applicable.

Documents which are designated as QA records shall be legible, accurate, and completed as appropriate for the work accomplished. Records are indexed, including as a minimum retention times and location of the records within the record system, to provide for retrieval without undue delay.

Prior to final transmittal of QA records to permanent storage, the originating organization shall be responsible for maintaining QA record controls.

The majority of ISFSI QA records are ultimately scanned and stored as electronic images on two redundant, electronic media storage systems housed at two separate locations. QA records in electronic format (e.g., .pdf format) may be directly filed and stored on the electronic media storage systems. Selected QA records on other media (e.g., paper hardcopies, microfilm, DVDs) are ultimately filed and maintained in a permanent records storage facility.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Program 18.0 AUDITS 18.1 Audit Program Audit schedules are established to meet applicable regulatory requirements and are based on the importance to safety of the activities to be audited. Audits shall be performed in accordance with written procedures using a check list or an annotated procedure which details the areas to be evaluated.

Audits shall be performed every 24 months with a 90-day grace period. Use of all, or part of the grace period does not impact the established 24-month cycle for the assessment. Audit results shall be documented. These results shall be reviewed by management having responsibility in the area audited. Follow-up action, including re-audit of deficient areas, shall be taken where indicated.

18.2 Audit Personnel Auditors are appropriately trained and qualified to assure competence for performing the required audits. The QA Manager has overall responsibility for performing planned and periodic audits ofISFSI activities. To ensure organizational independence, ISFSI Staff personnel shall not perform audits of ISFSI activities in which they are involved. External audits may be performed by either designated QA department resources or by properly qualified ISFSI staff personnel.

QA resources or appropriately trained and qualified ISFSI staff personnel may perform audits of Trojan ISFSI activities pursuant to this chapter. To ensure organizational independence in the performance of these audits, the audit team members ultimately report to the Corporate Executive Responsible for Trojan. Audit teams sl).all be comprised of individuals other than those that performed the IMA activity or conducted the internal audit(s) being audited PGE-8010 Page 33 of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program APPENDIX A Trojan ISFSI Functional Organization Corporate Independent Executive Management Responsible for Assessments Trojan Additional Senior Management I

I Corporate Support ISFSI (Records, Manager Purchasing)

Administrative Support I ISFSI I I I

Technical Support Quality Operations Security (Licensing, Assurance Training, RP, BP) and Maintenance PGE-8010 Page34of36 Proposed Revision 31

Troian Independent Spent Fuel Storage Installation Quality Assurance Program APPENDIXB Trojan ISFSI Regulatory Requirements and Commitments Regulatory Requirements:

1. 10 CFR 71, Subpart H, "Quality Assurance"
2. 10 CFR 72, Subpart G, "Quality Assurance"
3. 10 CFR 21, "Reporting of Defects" Regulatory Commitments:
1. Regulatory Guide 7.10, "Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material," Revision 3, with an exception to the annual audit frequency. The Trojan ISFSI is on a 24-month audit frequency in accordance with implementing plant procedures.
2. NUREG/CR-6407, "Classification of Transportation Packaging and Dry Fuel Storage System Components According to Important to Safety," February 1996.
3. NEI 14-05-A "Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services," Revision 1.

Regulatory Guidance:

1. NEI 11-04-A, "Nuclear Generation Quality Assurance Program Description," Revision 0.

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Troian Independent Spent Fuel Storage Installation Quality Assurance Prowam APPENDIXC Administrative Controls Regulatory-related programs, such as those listed below, are not within the scope of this QA program, but shall be implemented via written procedures:

  • Security Program
  • Instrument Calibration Program for non-ITS and portable M&TE
  • Emergency Response Program
  • Radiation Protection Program
  • Nuclear Training and Qualification Program
  • Independent Management Assessment Program
  • Independent Safety Review Program PGE-8010 Page36 of36 Proposed Revision 31
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