ML24022A152

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Us Dept. of Transportation, Maritime Admin, Decommissioning Quality Assurance Plan, STS-003-001, Revision 4
ML24022A152
Person / Time
Site: NS Savannah
Issue date: 01/18/2024
From:
Nuclear Ship Support Services
To:
Office of Nuclear Reactor Regulation
References
STS-003-001, Rev 4
Download: ML24022A152 (1)
v • d • e


Text

U.S. Department of Transportation Maritime Adtriinistration N.S. SAVANNAH DECOMMISSIONING QUALITY ASSURANCE PLAN Approved:K STS-003-001 Revision 4 Senior Technical Advisor Prepared by:

Nuclear Ship Support Services, LLC

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan RECORD OF REVISIONS Revision Summary of Revisions 0

This is the original version of the Decommissioning Quality Assurance Plan.

1 This revision includes items discussed with the NRC prior to the approval of Revision 0. The summary of issues are as follows:

  • Distinction ofresponsibility betweeri the Senior Technical Advisor (STA) and Manager, NS SAVANNAH Programs
  • Added para. 17.3 in Corrective Actions
  • Modified the Organization Chart to address responsibility issues.

2 This revision implements the commitment made to the NRC to update the QA plan to reflect the change from 'Review and Audit Committee' to 'Safety Review Committee.' Updated the Ship Name throughout applying Lloyds of London style for ship name. Changed cover page to reflect organization shift from the Office of Ship Operations. Corrected the Acronym used for Manager, N.S. SAVANNAH Programs for ~on~ist_ency \Vith other program documents.

3 This revision describes the organization for terminating the license of the NSS.

Section 2.0, Organization and Responsibilities is revised in its entirety.

4 This revision adds the Final Status Survey organization in Section 2.0, Organization and Responsibilities. The option of retrenchment as workload decreases is add(?d to Section 2.1 and 2._3.

Revision 3 2

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan r

    • ---~\*---*-- *,

(**t** II? --t-~~;f

  • r LIST OF EFFEGTIVE PAGES Page No.

Rev.No.

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    • Rev. No.

Page No.

Rev.No.

1 3

8 3

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2 3

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17

- 3 4

3 11 3

18 3

5 3

12 3

19 3

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Revision 3 3

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SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan Table of Contents 1.0 POLICY STATEMENT 5

2.0 ORGANIZATION AND RESPONSIBILITIES 5

3.0 DECOMMISSIONING QUALITY ASSURANCE PROGRAM 11 4.0 PROCEDURES AND DRAWINGS 13 5.0 DESIGN CONTROL 14 6.0 PROCUREMENT DOCUMENT CONTROL 14 7.0 DOCUMENT CONTROL 14 8.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 15 9.0 IDENTIFICATION AND CONTROL OF MATERIALS-PARTS & COMPONENTS 15 10.0 CONTROL OF SPECIAL PROCESSES 15 11.0 INSPECTION 16 12.0 TEST CONTROL 16 13.0 CONTROL OF MEASURING AND TEST EQUIPMENT 16 14.0 HANDLING, STORAGE AND SHIPPING 16

  • 15.0 - INSPECTION, TEST AND OP~RATIN(; STATUS 16 16.0 NONCONFORMING MATERIALS - PARTS & COMPONENTS 17 17.0 CORRECTIVE ACTION 17 18.0 QUALITY ASSURANCE RECORDS 17 19.0 AUDITS 18 20.0 CONTROL OF RADIOACTIVE WASTES OR MATERIALS 18 Revision 3 4

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan 1.0 POLICY STATEMENT The Maritime Administration (MARAD) Policy is to conduct nuclear plant activities within the scope of this Plan in such a manner as to ensure protection of the health and safety of the general public and project personnel. To implement this policy, MARAD will adhere to the Quality Assurance (QA) requirements established in this N.S. SAVANNAH (NSS) Decommissioning QA Plan and shall comply with and be responsive to, applicable federal, state and local requirements; 10 CFR (§) Parts 19, 20, 50 and 71.

MARAD is also committed to the applicable industry cod~s and standards and co}llmitments made tp tbe U.S. Nuclear Regulatory Commission.

Project procedures shall provide for compliance with appropriate regulatory, statutory, license and industry requirements. Specific quality assurance requirements and organizational responsibilities for implementation of these requirements shall be specified.

Compliance with this QA program and provisions of project procedures is mandatory for personnel with respect to decommissioning activities which may affect quality or the health and safety of the general public and project personnel. Personnel shall, therefore, be familiar with the requirements and responsibilities of the QA program that are applicable to their individual activities and interfaces.

2.0 ORGANIZATION AND RESPONSIBILITIES 2.1 General The U.S. Department of Transportation (DOT), acting by and through the Maritime Administration and its Senior Technical Advisor, N.S. SAVANNAH (STA), holds the NS-1 license. The Savannah Techni<;al Staff (STS) organizational unit is MARAD's licensee organization and is primarily made up of a combination of direct employees and contr..actors as described herein. In 2021, the STS wa*s realigned to report to the MARAD Office of Ship Operations (acting through the Director, Fleet Program Management), which has absorbed the functions of the Office of Ship Disposal Programs pending a formal reorganization. This primary organi?ation is depicted Figure 2_-l, MARAD Organization. The detailed STS organization is depicted in Figure 2-2, STS Organization Chart.

Revision 4 of the DQAP updates the MARAD organization and responsibilities following submittal of the License Termination Plan (LTP). In this context, it is useful to note that the STS is intended to cease functions and be disestablished in the period after license termination, once ship activities associated with decommissioning have been completed and service contracts have terminated. As noted herein, MARAD expects that as the workload decreases in the latter stages of decommissioning, there will be a gradual retrenchment of personnel among both its direct employees and contractors.

2.2 Responsibilities The STA has overall responsibility for safely performing licensed activities. In addition, the STA is responsible to administer the NS-1 license and will provide guidance and oversight to the Manager, N.S. SAVANNAH Programs (MSP). The MSP is responsible for the execution of all program activities including radiological protection and emergency response, ship husbandry and custody, decommissioning, and historic preservation. MARAD may assign a single incumbent to both positions.

2.3 Organization The NSS organization is comprised ofMARAD direct employees, contractors, and consultants.

The organization is structured on the basis that the objectives of the QA Manual will be met by those who manage, perform and support the activities within the scope of this plan. Those who Revision 3 5

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan perform work on quality related functions are directly responsible for meeting quality standards and reporting nonconformances or conditions adverse to quality. The requirements stipulated in the QA M~nual shall be imposed on all personnel and organizations, including contractors, who perform quality related decommissioning activities.

Meeting quality requirements and standards also relies on those who validate proper execution of activities and who have no direct responsibility for managing or performing the activity. For the NSS, these independent individuals will functionally report to the QA Manager.

Administratively, these independent individuals may report to others.

Specific QA requirements and organizational responsibilities for implementing of these requirements shall be specified in various procedures and other NSS Decommissioning project documents.

MARAD has procedurally defined and established lines of authority, responsibility, and communication. The relationships will be identified and updated, as appropriate, in organizational charts, functional responsibility and relationship descriptions, job descriptions for key personnel positions, or equivalent forms of documentation.

Three MARAD1 personnel fill STS positions and report to the MSP. They are procedurally responsible for assigned contractors_ and for providing dir~ction, coordination and inte_rf&cing communications. As the decommissioning workload decreases, a single incumbent may be assigned two positions. No single individual will perform more than two positions. The STS positions filled by MARAD employees include the following:

a.

The Decommissioning Program Manager (DPM) position is responsible for administration of all facility fun~tions, for direction of all licensed activities, and for assuring that the requirements of License No. NS-1, Technical Specifications and Emergency Port Operating Plaris are implemented. The DPM may be assigned as a Contracting Officer's Representative ( or Assistant COR) for NSS service contracts;

b.

The Facility Site Manager (FSM) is directly responsible for the physical reactor, nuclear systems, and radiologically controlled material, components, and equipment onboard the NSS. The FSM provides on-site management and oversight oflicensed activities, including direct oversight of the routine radiological monitoring and surveillance program. The FSM provides technical direction and guidance on overall ship husbanding and maintenance. The FSM may be assigned as a Contracting Officer's Representative

( or Assistant COR) for NSS service contracts; and,

c.

The Document Control Manager (DCM) is principally responsible for the management of document and records control to support licensed activities and the decommissioning program. The DCM is the lead for administrative support across all programmatic areas.

The DCM manages NSS property both on-site (i.e., onboard the ship) and in the staff office (i.e., at MARAD HQ). The DCM has major procedural responsibilities for site safety, medical coordination and emergency response. The DCM may be assigned as a Contracting Officer's Representative (or Assistant COR) for NSS service contracts.

The STS Organization includes the following committees:

a.

Executive Steering Committee (ESC) is composed of senior civilian officials of MARAD. The committee provides an official framework for agency management to provide guidance to and receive inputs from the STA regarding the conduct of licensed 1 MARAD may elect to fill a direct position with a contract employee as circumstances dictate. Any such contract employee will be independent of the primary integrated services contract described beginning on page 7.

Revision 3 6

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan activities, and to allow an integration of NSS activities into the broader efforts of the agency and Department of Transportation and vice versa; and,

  • t
b.

Safety Review Committee (SRC) provides independent review, oversight ap.d assessment of the licensed activities of the NSS facility as required by the Technical Specifications.

The SRC reports to the ST A.

The membership experience shall include an appropriate balance of both maritime and commercial nuclear ( operating and/or decommissioning) expertise.

The collective expertise of the SRC shall include, but not be limited to:

Quality Assurance.

Radiological Protection.

Environmental.

Occupational Safety and Health; Decommissioning; Marine Engineering and Vessel Husbandry; and, Management.

A significan! portion oft4e decolllmissioning project work is being perfonp.ed by contractors; In 2021, MARAD awarded an integrated services contract to Nuclear Ship Support Services (NSSSN), LLC, of Seabrook, New Hampshire. This contract is based on the prior integrated technical support contract that provided radiological protection and radiological emergency response; ship husbandry and custodial care; core nuclear competencies and proficiencies, and decommissioning services. No significant changes to existing key personnel descriptions or lines of authority were made as part of this contract award; however, some additional functions were added based on the increased scope of decommissioning and license termination activities. At the outset, each position described below is filled by an individual. As decommissioning activities progress and workload decreases in the latter phases of the project, certain positions may be consolidated under single incumbents. The STS positions filled by contractors include the following:

a.

The Quality Assurance Manager (QAM) is responsible for assuring implementation of the Decommissioning Quality Assurance Plan and its implementing procedures. This manual has been established to control the activities performed by the NSS Decommissioning Project and its contractors, within the scope of this Plan. The QAM will provide independent verification of contractors. On a case-by-case basis, the QAM will verify and approve the adequacy of a contractor's QA Manual (if applicable) prior to its use. The QAM is granted organizational freedom and authority to assure that an appropriate quality assurance program is established and effectively executed. The QAM's organizational freedom permits direct reporting to the ST A or MSP outside the Contractor's line management.

b.

The Project Manager (PM) is the major point of contact between the Contractor and MARAD. The PM is responsible for overall project management activities such as: task identification, tracking-and control; schedule development, monitoring and control; cost estimating and controlling; project risk identification, analysis, response planning, implementation and monitoring; and communications management. The PM is responsible for establishing and monitoring safety culture.

c.

The Business and Risk Manager (BRM) is responsible for the management of work processes on the NSS. The BRM coordinates the activities of work planners and monitors the performance of work activities and closeouts. The BRM is responsible for Revision 3 7

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan decommissioning planning; decommissioning oversight; subcontractor oversight; work control/ work planning technical support; management systems (including risk management); and s~rveUlance ancl maintenance inspections ~wei:sight al)d perfopnanc.<;:

monitoring.

d.

Following submittal of the LTP, the License Tennination Plan Manager is responsible for Final Status Survey (FSS) project coordination and direction.

e.

The Final Status Survey (FSS) Manager (FSSM) is responsible for management and onsite itriplement_ation of the final St~tus Survey (FSS) Plan.- The FS$M is responsible for supervising the conduct ofFSS activities; scheduling, planning, and implementing turnover surveys and survey area preparation prior to conducting an FSS; maintaining access controls for areas prior to, during and following the conduct of a field survey; and scheduling, planning, and implementing FSS activities.

f.

The License and Compliance Manager (LCM) is responsible for preparing regulatory correspondence and reports; coordinating facility inspections and public meetings; maintaining the licensing basis and basis documents; reviewing Federal Register rulemaking actions for applicability; preparing license amendments and exemption

_ requests as required; and, preparing and briefing senior MARAD management Ort NRC issues.

g.

The Project Control and Compliance Manager (PCCM) is responsible for cost and schedule control during decommissioning. The PCCM provides oversight and guidance on schedule development, formalization, and execution; reviews work authorizations /

work orders for cost and schedule impacts; and coordinates procurement activities with project cost and schedule programs.

- h.** The Nuclear Advisor (NA) is responsible for providing multi-disciplin~ry niicleai-skills

~d expertise to support the full range of on-site conduct of licensed activities. The NA provides this support to the MSP, DPM and FSM. The NA provides technical and peer review ofNSS pqlicie_s, programs; procedures and decommissiol}irig activities. The NA is the Engineering and Technical Support Manager which includes responsibility for nuclear safety, alarms and control systems, fire protection, mechanical/ electrical/

structural engineering, work order support, national historic landmark support, training, procedure development, and support to document control and records management.

i.

The Radiation Safety Officer (RSO) is responsible for the conduct and oversight of all radiation safety activities through implementation of the Health Physics Manual. All radiological controls personnel have stop work authority in matters relating to or impacting radiation safety.

j.

The Maintenance Manager (MM) is responsible for the identification, coordination and supervision of the broad range of ship management services necessary to satisfactorily husband and maintain the NSS.

k.

The Environmental Safety, Health & Security Manager (ESH&S) is responsible for safety management; occupational safety & health, industrial hygiene, security, environmental compliance and medical services.

Revision 3 8

I SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan FIGURE2-1 MARAD ORGANIZATION Savannah Technical Staff Organization Chart Revision 3 Nuclear Ship Savan_na/1 Decommissioning and License Termination

,\

Secretary ofTramporlatlon Maritime Admlnlltrator Deputy Maritime Administrator Esecutlve Director Assoclote Admlolstrator for

--~~eglc Seallft Deputy Associate Administrator for Federal SeaUft I

Director, Fleel Program Director, Ship 0 Management (DFPl\f) pcratlom (DSO)

Seolor Technlcol Advisor (STA) l\fanager, Savannah Programs (l\fSP)

Nuclear_Shlp SaVl!lln_ah Tec:hnlcal Staff 9

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan FIGURE 2-2 STS ORGANIZATION CHART Savannah Technical Staff Organization Chart,

-Nuclear Sl,ip Savanna/, Decommissionilig and License Termination U.S. Department of Transportation Maritime Administration Senlo~ Tedmlcal Ad,isor (STA)

Manager, Savannah Programs ~1SP)

I i

i i

I I

I I

I

executive Steering Committee (ESC)1 Deputy Chief Coonse, (l,£1.R-120.J)

(l,£1.R-J00)

  • Anoclate Admlnistntor for Ad~ahtratfoo,

Program E1ceDtoce ~n~ Quality Asmnnce Associate Admlnhtrator for Environment and I

Ad.-!,.,. (AfAR-6/IO.J2) i Compliance (l,£1.R-400)

Chief Flnandol om... (MAR-250)

Assotlate Administrator for stftteglc Seallft (A Safety Review Committee (SRC)

Dlnctor, Sblp Openflons (l,£1.R-6JU)

£1.R-600)'

)

DJredor, 1'1cct Prog. Management (MAR-610.I

  • Decommissioning Prognril Managtl' (DPM)

Qnallty Aunnlnre Manager (QAAI)

Facility Site Manager {FSM)

Lken,e CompJlnn,e l\lanqer (LCM) lbullaOon Safety Offirer (RSO) _

Nodl'III" AdliSOr {NA) i Decommissioning Program Manager FacWlySlte Docnmenl Control (DPl\1) l\lnnager (fSl\1) l\lonager (DCM)

Revision 3 I

I r---------- --------------------------- ---------- '-----------------. --------. ---*-----------------r------------*-----.------------

i Quollty Assuran~

i Contractors Project Manager i.---*-*-*

Mamger

  • -*-*-*-*-*-*-*-*-*-*-*-*.. --------------*-* i (PM)

(QAM) i I

'j i

, l

  • I I

I I i i i Business and '

Envlr. Safety,

'i I

Malntenam:e '

License Compllon<<

i Risk Manager Manager Manager Health & Seeurlty i

(BRM)

~M)

(LCM)

Manager (ESH&S) i I

I L. _______

I r,

r I

I i

I i

i License Final Stains Projeet Control i Termination Plan *-*-*

Survey Ml.nager ~

and C0mpllsnce

  • Nuclear Advisor Rodlallon Safety Manager (FSSM)

MDDllJll'r (PCCM):

(NA)

Offlcer(RSO)

I I

10

SAVANNAH Technic~l Staff STS-003-001, Decommissioning Quality Assurance Plan

    • -3;0 ** DEC0MMISSIONING QUALITY ASSURANC*E PROGRAM 3.1 General This Decommissioning QA Plan is the highest MARAD document which provides the generic and some specific requirements and methods to control activities. The term "QA Manual" as

. u~ed h.erein_include;:s thjs Plan_at1d.the _approv~d doqup1epts which. are used to implenient thi~..

Plan. This Plan lS.llllplemented through.such approved documents..

The NSS Decommissioning QA Manual has been established to control the activities performed by the NSS Decommissioning Project and its contractors, within the scope of this Plan. This control is exerted primarily through the provision of and compliance with, implementing documents and assurance that such documents are adequate and consistently used.

Adherence to the requirements of this Plan is mandatory for all MARAD ( and other Government) organizations and for all external organizations providing items, parts, materials

~r. c_o~dt1~t!Ilg acyviti~s w~ich ar'?_ wit~ ~h_e s~op~ o_(tliis P_l_aE*... _.....

this Plan sliail be 1ssued imder the authority of the St A, *ancf executed by the MSP. All changes.to the Plan shall be approved by the STA. Revisions to this plan will be submitted to the NRC; prior to the implementation of changes which involve a reduction in commitments

.. pr~vious_ly a_c~epted_ by the NRC and after implementation of chan$es havin~ no redu~tio1:1, in..

cgtµtpitl:p.ent.

~--... --.. - *. -

  • The s-cope of this*Pla:n includes radiological safety and implementation of the regulations as committed to in Section 1.0 of this Plan. To ensure consistency iii identifying those structures,*

systems and components.(SSCs), materials and activities within the scope of this Plan, a classification process shall be develC>ped and documented. This process relies on the use of the term "QA Plan Scope."

3.2.1 A Quality Classification process for items shall be developed. This classification process shall produce a Quality Classification List (QCL) which identifies the permanent plant structures, systems and components that are within the scope of this plan. New items to which this Plan applies shall be added to the Quality Classification List subsequent to their installation.

Revision 3 Since the NSS has been shutdown and defueled since November 8, 1971, the criteria i~ § ~9-2. defiajti_c;m of_basic CbJl!pon~rtt _is* n9~ applica_!jl~. This definition defmes safety-related (SR) SSCs as those relied on to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary; the capability to shut down the reactor and maintain it in a safe shutdown condition; or, the capability to prevent or mitigate the consequences of accidents that could result in potential off site exposure comparable to the. guidelines in..

§ 50.34(a)(l),-§ 50.67(b)(2) or§ 100.11. Therefore, only those permanently installed NSS structures, systems, and components whose intended function and/or operation is. directly related.to radiological safety, or whose failure.could result in unexpected and/or unacceptable radiological conditions (for example: the NSS Reactor Containment) shall be included on the QCL.

11

SA VANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan 3.2.2 Quality related activities within the scope of this Plan are those directly related to radiological safety and iinplementation of the regulations as corilrilitted to in Section 1.0 of this Plan. These activities are listed below:

Decommissioning activities within the scope of this Plan include the following:

Equipment control and status; Dismantling, fabricating, erecting, installing, maintaining, repairing and testing; Lifting and handling which could jeopardize functionality of QCL equipment or whose potential drop_ could have adverse radiological impact; Shipping and storage of dismantled items; Technical Specification surveillance testing (if any);

Functional testing (if any);

Fire protection; Radiological controls; Radiological environmental monitoring; and Compliance with the License, Technical Specifications and Port Operating Criteria and Plans.

Support activities within the scope of this Plan are System, component, part classification; Design; Procurement (including shipping, handling and storage of procured items);

Training; Security; Document control and records management; Housekeeping and cleaning; Welding; In-service inspection; and, Heat treatment.

Assurance activities within the scope of this Plan are Audit; Inspection; Nondestructive examination; Monitoring; Surveillance; and, Safety review.

Assurance activities are performed by individuals who are not directly responsible for managing or performing the work or activity. Assessment personnel, who are independent of the organization performing the work or activity, perform periodic assessments of the assurance activities to assure effectiveness and adequacy.

The above activities are controlled through the use of approved documents, which are, as a minimum, consistent with the requirements of this Plan. This Plan shall remain in effect throughout the decommissioning project.

Activities affecting quality shall be accomplished under suitable, controlled conditions.

Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness, iighting, climate control, etc.; and assurance that all prerequisites for the given activity have been satisfied.

3.3 Training Revision 3 12

SA VANN_AH Tectmical. Staff STS-003-001, Decommissioning Quality Assurance Plan 3.3.1 The program shall provide for indoctrination and training of personnel peiforining quality

  • related activities within* the scope oflhisPlaii':S-a:ctivities*fo a*ssure that suitable profici~ncy is ~cb.ieved 1,mcl m~mtaine_d. _Th~_ p:rogr~ l!_hall_ ta}{~ _into accoµnt the need for special controls, processes, test equipment, tools and skills to attain the required quality and the need for verification of satisfactory implementation.

3.3.2 Training programs shall be established for those personnel performing quality related activities within the scope ofthis Plan such that they are knowledgeable in the QA program-and proficient in implementing these-requirements. These training programs shall assure the following:

3.3.2.1 Personnel responsible for performing these activities are instructed as to the purpose, scope and implementation *of applicable procedures; 3.3.2.2 Personnel performing such activities are trained and qualified, as appropriate, in the principles and techniques of the activity being conducted; 3.3.2.3. The scope, objective and method of implementing the training are documented; and, 3.3.2.4 Methods are provided for documenting training sessions describing content,

-a:ttenda:nce; date. of*attendance :and the *results* of the training session; as-..

appropriate.

4~0 _ :PRO~EIJURES..A,ND ___ DRAWINGS

4. i Pr9ce_d!!!eS l!_llq drawings of a typ~ approl'_riate to _t4_e iircii!nsumces, ~h.all ~e -provide~ f9r the contr9l ~nd perfonnance of quality related activiti~s within th~ scope of this Plan which affect.

_. gu.ality, healtli Jilld safety of the publ_i9 or proj~ct p_efSQJ?.P:eLorregµ!a_tC>_ry req11ir~~ents.

4.2. Procedures arid drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

4.3 A procedure shall J,e implemented to control and delineate the requirements for the review an~

approval of documents implementing the requirements of this plan. These documents typically include, but are not limited to, those termed, called and/or labeled as: plans, procedures, instructions, drawings and specifications. This procedure shall include the review and approval requirements for the implementation of docmp.ents not specifically written for the ship decommissioning activities ( e.g., vendor documents, etc.). This review must consider the appropriateness of the document for work -at the ship and must ensure the document complies with higher tier ship documents.

4.3.1 The following typical procedures shall be provided as appropriate:

Revision 3 Calibration procedures; Radiation protection procedures; Special process procedures; Maintenance procedures; Dismantlement procedures; Audit procedures; Administrative control procedures; Emergency procedures;.

Rigging, lifting and handling; and, Inspection procedures.

13

SAVANNAH Technical Staff

-STS-003-001, Decommissioning Quality Assurance Plan

_ 5.0 DESIGN CONTROL.

5.1 When quality related activities within the scope of this Plan require design or modification of

- existing clesign, controls shall be appliecl commensurate witlithe poteriiiafimpact mi qualify or-*

health and safety of project personnel and the general public.

5.2 Appropriate provisions of design control shall include the specifying of design input, the correct translation of input in design documents, the verification of design by persons other thim th! otigin~tor and the;: as_suran_ce that changes_ tp th~ design pey911d gesign tole_ranc~ ar~

properlyreviewed and controiled:

6.0 PROCUREMENT DOCUMENT CONTROL 6.1 For quality related activities within the scope of this Plan, measures shall be established to assure that applicable regulatory requirements, design bases and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment and services, whether purchased by MARAD, the NSS Project or by its contractors or subcontractors. To the extent necessary, procurement documents shall require contractors or subcontractors to provide a QA program consistent with

-the_ contractor's potential impact on quality ot the_ health an:d:safety ofptoject petsonheLancl the:-: -

general public.

6.2 Procurement documents shali contain specific-tecluiical and quality requirements, as appropriate.

_ 6.3 _.. Procurement documents shall contain provisions.which establish the right of access to vendor.

facilities and records for source inspection-and audits,as appropriate. -

-- 6.4 Dociinieiits and changes thereto; initfatirif procuferiienfof-eqiiipinent, components or services

- shaH be appn:>Ved by appropriate management pei:sonnel and shall be subje_ct to a quality review to ensure applicable regulatory requirements, design bases, quality assurance and other requiren;ieii.t~ are adequately _sat1sfiec( pripr to re_le~se, -

7.0 DOCUMENT CONTROL 7.1 Measures shall be establishe<;l to control the issuance of documents, such as procedures and drawings, including changes thereto, which prescribe quality related activities within the scope of this Plan.

7.2 These measures shall assure that quality related documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used

_at the loc~tion where tl!e prescribed ac::tiyity is perfo1111ed, _

7.3 Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval or another designated responsible organization.

7.4 Procedures shall b*e controlled to assure that current copies are made available to personnel

__ performing the pres_cribed activities. __ These;; pro_c~d:ures shall.be r~viewed_ by a technicaUy _

_ _ competent person other than the preparer.and.shall be approved by a management member of.

the organization responsible for the prescribed activity.

  • 7.5 All procedure changes, except Non:.Substantive Changes;* shall be reviewed and approved in the same manner as the original.*

Revision 3 14

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan

. 8_.0. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 8.1 8.2 8.3 8.4 8.5 For quality related activities within the scope of this Plan, measures shall be established to assure that purchased material, equipment and services conform to the procurement documents.

These measures shall inciude provisions, as appropriate, for vendor evaluation and selection:

objective evidence of quality furnished by the vendor, inspection at the vendor source and

. _ _insp~c_tion of products on delivery:

the effectiveness of the controfof contractor services shall 1:ie assessed at intervals consistent with the importance of the service.

The adequacy of vendor's QA program speciffed in procurement documentation shall be verified prior to use when appropriate. Vendors' adherence to their QA program shall also be verified as appropriate.

Commensurate with potential adverse impacts on quality or health and safety, material and equipment shall be inspected on receipt at the NSS designated locations adjacent to the NSS work areas or other sites authorized by the MSP prior to use or storage to determine that

procureip.en! require~ents ar~*~at~sfied.-.

Measures shall be established for identifying nonconforming material, parts and components.

9.0 IDENTIFICATION AND CONTROL OF MATERIALS -

PARTS & COMPONENTS--

-~

~ -

9.1 For quality related activities within the scope of this Plan, measures shall be established for the*

contfoJ of materials, parts and coinporients-which_ are withip. tlie SG<;>pe of this l>lru,i.

9.2 These identification and control measures shall be designed to prevent the use of incorrect or *

  • defective material, parts and components.*

10.0 CONTROL OF SPECIAL PROCESSES 10.1 For quality related activities within the scope of this Plan, measures shall be established to assure that special processes, including welding, heat treating and nondestructive examination are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicabie codes; standards; specifications, criteria and other special requirements.

10.2 Welding of equipment within the scope of this Plan shall be performed in accordance with

  • . qualified procedures*. Such procedures shap be qualified in accordance with applicable codes and standards and shall be reviewed to assure their technical adequacy.

10.3 Measures shall be established that assure welding of equipment within the scope of this Plan is performed by qualified personnel.

  • 10.4 Nondestructive*examinations (NDE) ofequiprtrent within tlfe scope of this Plan shall be performed iii accordance with procedures form.ufated in ~ccordarice with applicable cocJes and standards and shall be reviewed to assure their technical adequacy.

10.5 Measures shall be established that assure NDE is performed by personnel qualified in accordance with applicable codes and standards.

Revision 3 15

SAVANNAH Technical Staff STS~003-001, Decommissioning Quality Ass~ranc,e Plan

_11.0 INSPECTION 11.1 For appropriate quality related activities within the scope of this Plan, measures shall be establishea to verify conformance witli the docunierited proceoui:-es arid oi:-awings for -

accomplishing the activity.

11.2

  • Ifmandatory inspection hold points, whlch require witnessing or inspection and beyond which work shall not proceed without prior consent are required, the specific hold points shall be indicated in ~ppr.9pri,at~ doc11ments, 'fbe d9c1Jllle~t containing the inspectio:n holq pQints §hall be reviewed prior to implementation by the organization requrred to perfonn the inspection.

11.3 Measures shall be established which assure that activities associated with technical services (such as surveillance testing,. instrument calibration, laboratory services, etc.) are reviewed, when determined appropriate, by qualified personnel.

11.4 Required inspections shall be performed in accordance with appropriate procedures. Such procedures shall contain a description of objectives, acceptance criteria and prerequisites for performing the inspections. These procedures shall also specify any special equipment or calibrations required to conduct the inspection.

1 L5 -Personnel performing required inspections-shall-be qualified.based on experience and training- -- -

hi inspecdon.meihods. -Reqiifred fo.spectioris shairriotbe perfomied by -indiv1duals who-performed the inspected activity or directly supervised the inspected activity.

  • -12~0 TEST CONTROL

-A documented test program shall he esfaolished fo *assure that all required testing is performed to-

      • --d~ionstrit~ -that the stru~tuie~: systeiii; o/c~in:poner{ts'~ithi~ the__scope of this -Pi~ will perform.
satisfactorily in *service: The* tests-shaff be peiforip:ed ih. ac.corda:ijc*e with ~written, approved arid conti9lled test procedµres or instructions ~hich incorporate or reference the requirements and l:!Cceptance stanclards contained in the applicable design documents. The extent of the testing shall be based on the complexity of the _modification, replace;:ment or r~p_air. Testfo.g shall fucl~de pr()oftests prior to instc1liation;_hydt:Q
  • testing, functional testing and pieoperational tests.

13.0 CONTROL OF MEASURING AND TEST EQUIPMENT Measures shall be established to assure that tools, gauges, instruments and other measuring and testing devices used in quality related activities within the scope of this Plan or important to the protection of health and safety are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within necessary limits.

- 14.0 HANDLING, STORAG*E AND SHIPPING Measures shall be established and documented to control handling, storage and shipping, including cleaning, packaging and preservation of items within the scope of this Plan in accordance with established instructions, proc~dures and drawings to prevent damage, deterioration or loss.

j 15.0 INSPECTION~ TEST AND OPERATING STATUS

. __ Inspection, test and_ operating status of eqµipme:nt al!d con;ipone11ts within the scope of this Phm shall be established based on the following criteria:

15.1. Inspection, test and operating status for equipment within the scope of this Plan shall be indicated and controlled by established procedures; Revision 3 16

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan 15.2. Status of such equipment shall be indicated by tag, label, marking or log entry; and, 15.3. Status of nonconforming parts, components or materials shall be positively maintained by established procedures.

16.0 NONCONFORMING MATERIALS - PARTS &

COMPONENTS 16J Measures shall be established to control materials, parts and components within-the-scope of--

. this Plan which do not confo:rni to requfreinents in order to prevent their inadvertent use.

These measures shall include, as appropriate, _procedures for identification, documentation, segregation, disposition and notification to affected organizations.

16.2 Nonconformance items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.

17.0 CORRECTIVE ACTION 17.1 Measures shall be established to assure that conditions adverse to quality, such as failures,

-malfunctions, di!;!cr_epancies; de~iations, ~d~fectjye J.l}aterial ~d _eqpipment and - _ *- -_ _ : _-: -

nonconformances are promptly identified and corrected.

i 7.2 The identification of tlie condition adverse to qu_ality, the cause of the condition and -the corre~tive ~ction taken shall l;>e documented and reported to appropriate !evels of manage~ent.

11.3 _ All Corrective Action Program recommended and supplementary actions, NRC inspection adverse findings and -MARAD-internal audit/ self~assessments and QA monitoring findings-and recommendations will be trackedin a computerized system thatassigns and tracks-the resolution of the-stated fmdmgs-and reco~endat1ons.

18.0 QUALITY AS~~RANCE ~~~OROS 18.1 Sufficient records shall be maintained to furnish evidence of quality related activities within the scope of this Plan ( e.g., inspection reports, receipt inspection documents, engineering evaluations, monitoring reports, final survey records, and survey instrument calibration records etc.). These records shall document, when applicable, the identification of the individual generating the document or the data recorder, the type of observation, the results, the acceptability and the action taken in connection with-any deficiencies noted.

18.2 Records shall be identifiable and retrievable.

18.3 Requirements shall be established concerning record retention, such as duration, location and assigned responsibility. Such requirements shall be consistent with the potential impact on quality, health and safety of the public, safety of project personnel and applicable regulations.

18.4 Measures shall be established which assure that qualification records of personnel performing special process activities, such as welding, NDE, inspection, etc., are retained.

18.5 Measures_shall be established which assure that qualityrelated procurementdocuments are retained.

18.6 Measures shall be established which assure that appropriaterecords pertaining to audits are retained.

18. 7 Measures shall be established which assure that records associated with personnel exposure control are retained.

Revision 3 17

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan 18.8 Measures shall be established wliich assure that records associated with personnel training are retained.

19.0 AUDITS 19.1 A program of internal assessment will be conducted. It will combine elements.of monitoring and auditing to assess the adequacy of performance for quality related activities within the

. scope of this Plan.

  • 19.2 Planned audits.shall be cc:iiducted to verify compliance with appropriate requirements ~£the QA Manual and to determine its effectiveness. The audits shall be performed in accordance with written procedures or checklists by appropriately qualified personnel not having direct responsibility in the areas being audited. Audit results shall be documented. Management, having responsibility in the area audited, shall review the documented results. Follow-up action, including re-audit of discrepant areas, shall be taken where indicated.

19.3 Reports of the results of each audit shall be prepared. These reports shall include a description of the area audited, identification of individuals responsible for implementation of the audited provisions and for performance of the audit, identification of discrepant areas and recommended corrective acti~n as appr(_)p~~te. ** *

.. = *_ =.-

19.4 Audit reports shall be distributed to the MSP and Safety Review Committee, and to those individuals responsible for implementation of audited provisions.

  • - 19,5 Measures shall be established which assure that discrepancies identified by audits or other m~~ms are re.so_lved_. th_ese.m~asuies._s~a_l! mclU:de riojifi(!atfon of th(;: m_an~ge:r-. responsible for *

. the discrepancy, recommended corrective action an_d verification ofsatisfactory resolution.

Pi~c:repan(?.ies sJ:!all be r~~olved 1:Jy the_pl~nagel!l.e.nt re_~ponsible (or the cliscn:pancy. qne.

management shouldtesolve disputed.discrepancies. lfliiie management is not capable of resolving disputed discrepancies, the resolution shall be escalated to the next level of management until the disputed discrepancy is resolved.

19.6 Moriitoring is used to establish aaequate confidence levels that activities within the scope of this Plan are being performed in accordance with the QA Manual requirements and project/ship administrative controls. Monitoring will be performed and the degree of monitoring performed shall be based typically on the status and safety significance of activities, extent of previous experience, thoroughness of overall coverage, uniqueness of the activity and trending data.

19.7 Monitors shall be qualified in accordance with a documented procedure that ensures Monitors are knowledgeable in the activities they are monitoring to the extent that they can readily verify compliance of the activity performed.

20.0 CONTROL OF RADIOACTIVE WASTES OR MATERIALS 20.1 General Revision 3 20: 1.1

.

  • Measures -~liafbe_e~tabli$l_led an<\ docWI1tint~d to assure ih.at the reqµire111enis of

§ 20, §. 71; and 49CFR, Parts 100 through 199 applicable to the packaging and transp()rting of r~dioa~tive ~astes ?.r materials.an~ satisfied.

20.1.2 Subpart H to § 71 identifies the QA criteria applicable to the control of packaging to be utilized to ship radioactive wastes or materials. The portions of this Plan that relate to the criteria in Subpart H to § 71 describe to a large extent the administrative controls 18

SAVANNAH Technical Staff STS-003-001, Decommissioning Quality Assurance Plan and quality requirements to be applied in the control, packaging and transportation of radioactive waste or material.

20.1.3 MARAD's policy, on the NSS Project, is to minimize the generation of -

radioactive waste in concert with the ALARA concept to minimize personnel exposures and environmental contamination.

20.1.4 10 CFR 20 requires that a quality control program be implemented to verify compliance with § 61.55 (Waste Classification) and§ 61.56 (Waste Characteristics).

This Plan will be implemented t9 the extentnecessary to as~ure compliance with those Parts of 10 CFR using a graded approach.

20.2 Requirements 20.2.1 Procedures and administrative controls shall be developed and implemented to cover the following:

20.2.1.2 Processing ofradioactive wastes including the collection, handling and preparation for shipment of radioactive liquids and solids. These procedures shall be consistent with the ALARA program and shall clearly identify the _administrative controls and 9rganizational :responsibilities. _

Revision 3 20.2.1.2 -Training and qualification of personnel operating radioactive waste processing equipment, health physics monitoring, packaging and shipping (which includes Waste Classification and establishment of Waste Characteristics) and other operations deemed appropriate by management.

20.2.1.3 Activities associated with the packaging of radioactive wastes or materials to include the-proper selection of the receptacles to be used for containing the waste materials, the selection of the shipping containers (structures used to contain and-support the receptacle and its contents); establishment of Waste Characteristics, Radiological control inspections of the packaging prior to release, proper markings on the outside of the package and the preparation of shipping papers and certificates. The ~ctivities shall be in accordance with§ 20, § 61, § 71 and 49CFR.

20.2.1.4 Movement of radioactive wastes or materials to assure personnel protection at all times.

20.2.1.5 Shipment of radioactive wastes or materials from the NSS to be in accordance with the regulations of the U.S. Department of Transportation (DOT) for the transportation of hazardous materials ( 49CFR) and of the NRC (§ 71 and § 20).

20.2.1.6 Design, fabrication, assembly, testing and modification of packaging used for transportation of radioactive waste or material which exceed the limits specified by§ 71 shall not be performed by MARAD. Such packaging shall be purchased from an outside supplier and shall comply with§ 71 and 49CFR. MARAD shall review and accept designs of packaging purchased from an outside supplier.

20.2.1.7 Packaging used for transp<>rting ofradioactive waste or materia!, which does not exceed the limits specified in§ 71.lQ, whether purchased from an outside supplier or designed by ( or for) MARAD, shall meet 49CFR.

20.2.1.8 Minimization of the generation ofradioactive wastes through trahting programs, prudent scheduling and use of equipment and personnel and good housekeeping practices.

20.2.2 The carriers to be used for transporting of radioactive waste or material shall be selected on the basis of their experience, knowledge of DOT regulations, control and 19

SAVANNAH Technical Staff

' ~t-~, -'3' j STS-003-001, Decommissioning Quality Assurance Plan maintenance of their equipment and the selection and control of their drivers. The carrier is.required to have or shall oe supplied documented procedures covering acceptance of radioactive waste or ]J1aterial from a shipper, certification requirements, placarding, storage control, reporting of incidents and security. The NSS Project shall review and accept carrier procedures specified by procurement documents covering the acceptance of radioactive waste or material for shipment 20.2.3 Operations involving radioactive waste processing or radioactive material shall be controlled to minimize personnel exposures or environmental contamination consistent with ALARA.

20.2.4 Operations procedures relating to radioactive waste or material shipping and Revision 3 packaging shall be reviewed by Quality Verification to establish any necessary inspection points.

20

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