GE Hitachi Nuclear Enercv HITACHIJerald G. HeadJoaq•1 BlSenior Vice President, Global Suppl• Date UNCONTROLLED WHEN PRINTED OR TRANSMITTED ELECTRONICALLY (ti)HITACHI __• NEDE-31

GE Hitachi Nuclear EnercvHITACHIJerald G. Head

SeirVice President, Regulatory Affairs

3901 Castle Hayne RoadP0 Box 780 M/C A-i18Wilmington, NC 28402-0780USA

T 910 819 5692F 910 362 5692jerald~head @Oge~com

MFN 15-085 Docket number: 72-1

October 9, 2015

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskDirector, Division of Spent Fuel ManagementOffice of Nuclear Material Safety and SafeguardsWashington, DC 20555-0001

Subject: Revised Version of the GE Hitachi Nuclear Energy, Morris Operation, TopicalReport NEDE-31 559, Entitled "GE Hitachi Nuclear Energy Quality AssurancePlan - Morris Operation," Revision 3

References:

1. Letter from GE to USNRC, Subject: Quality Assurance Plan for Morris Operations,

NEDE-31559, Revision 02, May 27, 1998.

2. Letter from USNRC to E. W. Secko, GE, Subject: Quality Assurance Plan for Morris

Operation, Revision 02 (TAC No. L22635), August 8, 2000.

GEH submitted the Morris Operation Quality Assurance Plan for your review and approval inMay 1998 (Reference 1) and received the Office of Nuclear Material Safety and SafeguardsSafety Evaluation Report on August 8, 2000 (Reference 2.)

Please find GEH's proposed revision to the Morris Operation Quality Assurance Plan for yourreview and approval. Enclosure 1 contains the revised plan.

If you have any questions concerning this letter, please contact Richard Augi at 910-819-6366.

Nh, 552QoD'-

I declare under penalty of perjury that the foregoing information is true and correct to the best ofmy knowledge, information, and belief.

Sincerely,

Jerald G. HeadSenior Vice President, Regulatory Affairs

Commitments: No additional commitments are made in this response.

Enclosure:

1. GE Hitachi Nuclear Energy, Quality Assurance Plan, Morris Operation, NEDE-31559,

Revision 3

Cc: Mark Lombard, USNRC NMSSAnthony McFadden, GEHFranklin Partney, GEHJon Ball, GEHPeter Yandow, GEHTammy Orr, GEHJerry Head, GEHMark Elliot, GEH003N1259

Enclosure 1

MFN 15-085

GE Hitachi Nuclear EnergyQuality Assurance Plan, Morris Operation

NEDE-31 559, Revision 3

IMPORTANT NOTICE REGARDING CONTENTS OF THIS DOCUMENTPlease Read Carefully

The information contained in this document is furnished solely for the purpose(s) statedin the transmittal letter. The only undertakings of GEH with respect to information in thisdocument are contained in the contracts between GEH and its customers orparticipating utilities, and nothing contained in this document shall be construed aschanging that contract. The use of this information by anyone for any purpose otherthan that for which it is intended is not authorized; and with respect to any unauthorizeduse, GEH makes no representation or warranty, and assumes no liability as to thecompleteness, accuracy, or usefulness of the information contained in this document.

HITACHI GE Hitachi Nuclear Energy

GE-Hitachi Nuclear Energy Americas LLC7555 East Collings RoadMorris, IL 60450

NEDE-31 559REVISION 3September, 2015

Class I (Public)

Quality Assurance Topical Report

GE Hitachi Nuclear Energy

Quality Assurance Plan

Morris Operation

Approved By:

Approved By:

'MCFADDEN, MANAGER, MORRIS OPERATION

Copyright 1998, 2015 GE-Hitachi Nuclear Energy AmericasLILC

UNCONTROLLED WHEN PRINTED OR TRANSMITTED ELECTRONICALLY

(• NEDE-31559HITACHI Revision: 3Disclaimer

GEH Quality Assurance Plan. Morris Oneration Page 2 of 37

DISCLAIMER

This document was prepared by GE-Hitachi Nuclear Energy Americas LLC (GEH) and isfurnished solely for the purpose or purposes stated in the transmittal letter. No other use, direcior indirect, of the document or the information it contains is authorized. Neither GEH nor any 01the contributors to this document:

* Makes any representation or warranty (express or implied) as to the completeness,accuracy or usefulness of the information contained in this document or that such use ofany information may not infringe privately owned rights; or

* Assumes any responsibility for liability or damage of any kind that may result from anyuse of such information.


HITACHI

GEH Quality Assurance Plan. Morris Oneration

NEDE-31559Revision: 3

Revision HistoryPage 3 of 37

Revision History

3 ~~~Reformatted document, updated organization, removed7/125 R.Ag3 ~~~obsolete references and standards.7/125 R.Ag

Added reference to NEDO-1 1209-A for support provided to___________GEH Morris by other GEH locations.______


~NEDEo31559HITACHFI Revision: 3Policy Statement

£FH Ouai~tv Assurant•e Plan. Monrris Oaeration Page 4 ofr37

POLICY STATEMENT

This Quality Assurance Plan is the top-level policy document that establishes the manner inwhich quality is to be achieved and presents GEH Morris' overall philosophy regardingachievement and assurance of quality. Implementing procedures assign more detailedresponsibilities and requirements, and define the organizational interfaces involved in conductingactivities within the scope of the Quality Assurance Program. Compliance with the QAP andimplementing procedures is mandatory for personnel associated with implementation of the GEHMorris Quality Assurance Program. These activities shall be performed in compliance with therequirements of the Code of Federal Regulations (CFR), the applicable Nuclear RegulatoryCommission (NRC) Facility Operating Licenses, regulatory guidance documents and applicablelaws and regfthe state and local governments.

7 u/a-i/-so-

Joaq•1 BlSenior Vice President, Global Suppl• Date


__• NEDE-31 559(ti)HITACHI Revision: 3Table of Contents


TABLE OF CONTENTS

DISCLAIMER ............................................................................................. 2

REVISION HISTORY ..................................................................................... 3

POLICY STATEMENT................................................................................... 4

TABLE OF CONTENTS ................................................................................. 5

ACRONYMS ......................................................................................... i..... 6

1.0 ORGANIZATION......................................... ........................................ 7

2.0 QUALITY ASSURANCE PROGRAM ......................................................... 10

3.0 DESIGN CONTROL............................................................................ 12

4.0 PROCUREMENT DOCUMENT CONTROL.................................................. 13

5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS...................................... 15

6.0 DOCUMENT CONTROL....................................................................... 16

7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES .............. 18

8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS .. 19

9.0 CONTROL OF SPECIAL PROCESSES ..................................................... 21

10.0 INSPECTION ................................................................................... 23

11.0 TEST CONTROL ............................................................................... 25

12.0 CONTROL OF MEASURING AND TEST EQUIPMENT.................................... 27

13.0 HANDLING, STORAGE, AND SHIPPING ................................................. .. 29

14.0 INSPECTION, TEST, AND OPERATING STATUS ......................................... 31

15.0 NONCONFORMING MATERIAL OR COMPONENTS...:................................... 33

16.0 CORRECTIVE ACTION PROGRAM ......................................................... 35

17.0 QUALITY ASSURANCE RECORDS ......................................................... 36

18.0 AUDITS.......................................................................................... 37


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Acronyms and AbbreviationsPage 6 of 37

ACRONYMS

AcronymDefinitionCFR Code of Federal RegulationsEHS Environmental Health and SafetyEHSPAEnvironmental Health and Safety Procurement AdministratorGEH GE Hitachi Nuclear EnergyM&TE Measuring and Test Equipment

MO GEH Morris OperationN IR Nonconforming Item RecordOMC Operations and Maintenance Coordinator

US NRC United States Nuclear Regulatory CommissionQA Quality AssuranceQAP Quality Assurance PlanQAPD Quality Assurance Program DescriptionSCAQ Significant Condition Adverse to Quality


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1.0 ORGANIZATION

1.1 Purpose

To establish the GEH Morris Operation (MO) organization structure and functional responsibilities forthe Quality Assurance Program. Persons and organizations assigned quality-related responsibilitieshave sufficient authority and organizational freedom to: identify, evaluate, and recommend solutionsto quality and safety-related problems; verify implementation of corrective action; and stopunsatisfactory work and control further processing, delivery, installation or utilization ofnonconforming items until proper disposition has been established.

1.2 Delegation and Performance of Duties

Each Manager or Supervisor may assign performance of his duties to those qualified to performsuch duties. However, responsibility for those duties cannot be assigned or delegated. Managersand Supervisors, if qualified, may perform the work.

1.3 General

1.3.1 The program is implemented by or at the direction of MO. The MO organization structureas described in this section is intended to clearly establish responsibility and authority ofpersonnel performing quality related functions.

1.3.2 Responsibility and authority is generically defined in this section and specifically by activityin other sections of this Quality Assurance Plan (QAP). An abbreviated organization chartshowing those components concerned with implementing this program is presented inFigure 1.

1.3.3 The Vice President of GEH Global Supply Chain is responsible for establishing the QualityAssurance (QA) policies, goals, and objectives. In order to assure compliance with thosepolicies, the Manager, MO has been delegated the overall responsibility and authority forestablishment and execution of this QA program.

1.3.4 Responsibility assignments within the organization are intended to achieve required qualityby those responsible for performing activities and provide verification of quality by othersnot having direct responsibility.

1.3.5 MO personnel responsible for defining, reporting and measuring overall QA programeffectiveness are independent from production and have direct access to responsiblemanagement.

1.4 Organization and Responsibilities

1.4.1 The Manager, MO has overall responsibility for routine operations of the Morris facility. TheManager MO is responsible for:

* Activities performed at MO,* Establishing policy and direction,* Licensing and Regulatory Compliance,


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•Radiation Safety which includes radiation safety, safety, security and radioactivematerial shipping and receiving.

1.4.2 The Environmental Health and Safety and Procurement Administrator (EHSPA) isresponsible for compliance to all applicable OSHA and internal EHS standards.

1.4.3 The Operations and Maintenance Coordinator (OMC) is responsible for operations andmaintenance overview, projects, contracts, and site engineering. The 0MC is alsoresponsible for operator certification, operations plans, and schedules.

1.4.4 Quality is responsible for establishing overall quality programs and for assuring that quality-related activities are performed in accordance with these programs. Quality isorganizationally independent of the operating functions and has been delegated authorityand responsibility to identify and evaluate quality problems; to recommend and assureimplementation of corrective actions; and to stop work and control further processing,delivery, installation or utilization of nonconforming items until proper disposition isestablished.

1.4.5 Certain activities are delegated to GEH Wilmington QA, Sourcing, and Engineering. Theseactivities are conducted per the applicable requirements of the NRC approved GEH QualityAssurance Program Description NEDO-1 1209-A. The delegated activities are summarizedas follows:

(a) Qualification of suppliers(b) Supplier evaluation and audits(c) Procurement document review and issuance(d) Source inspection(e) Engineering calculations(f) Engineering activity verification(g) Administration and maintenance of quality-related software(h) Internal audits(i) 10 CER Part 71 activities (if required)

1.4.6 Personnel can perform functions that they are qualified for, but are outside their primaryarea of responsibility. When this occurs, they shall report to the manager or supervisorresponsible for the function; i.e., when personnel perform quality control activities theyreport to Quality.


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FIGURE 1: MORRIS OPERATION ORGANIZATION(Operations below dotted line are represented at GEH Morris)


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2.0 QUALITY ASSURANCE PROGRAM

2.1 Purpose

To establish requirements to plan, manage, control and implement this QAP.

2.2 General

2,2.1 MO's QAP complies with the Code of Federal Regulations, Title 10, Part 72, LicensingRequirements for the Storage of Spent Fuel in an Independent Spent Fuel StorageInstallation (ISFSI) and 10 CFR Part 21.

2,2.2 MO's Quality Program is implemented with written methods established in MO proceduresor instructions.

2,2.3 The MO Quality Program described in this document shall apply to the following structures,systems and components that are determined to be important to safety per 10 CR 72.122:

* Fuel storage basin-concrete walls, floors, and expansion gate,• Fuel storage basin-stainless steel liner,* Fuel storage system, including baskets and supporting grids,* Unloading pit doorway guard,* Filter cell structure,* Fuel Storage Basin building,* Fuel Basket Grapple,* Fuel Grapple,* Fuel Basin Crane,* Fuel Handling Crane,* Cask Crane,* Spent Fuel Cladding.

Other items are normally excluded from the scope of this document, but may be included tomeet specific project requirements. Depending on project scope or service, this QAP maybe applied in its entirety, or any portion thereof may be applied, as determined by Quality.

2.2.4 Activities affecting quality are documented and accomplished under controlled conditions.

2.3 Responsibilities

2.3.1 The Global Supply Chain Leader is responsible for providing the organization structurefor the implementation of this QAP.

2.3.2 The Manager, MO is responsible for implementing activities in accordance with therequirements of this QAP, including program documentation, maintenance, andenforcement.

2.3.3 GEH Quality is responsible for conducting an audit program of activities affecting quality.


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2.3.4 Quality shall report to the Manager, MO on program status and adequacy on a yearly basisor sooner if significant events adverse to quality arise.

2.4 Indoctrination and Training

2.4.1 Managers are responsible to assure adequate personnel training and identify minimumrequired training for assigned individuals.

2.4.2 MO personnel indoctrination and training is commensurate with the scope, complexity, andimportance of the activities; and with the education, experience, and proficiency of thepersonnel performing the activity.

2.4.3 Training shall be provided to achieve initial proficiency, maintain proficiency, and adapt tochanges in technology, methods, or job responsibilities.

2.4.4 On-the-job training shall be used if direct hands-on applications or experience is needed toachieve and maintain proficiency.

2.4.5 Personnel performing or managing activities affecting quality receive indoctrination andtraining in their job responsibilities and authority, that includes general criteria, technicalobjectives, requirements of applicable codes and standards, regulatory commitments,company procedures, and quality requirements.

2.4.6 Records of indoctrination and training include the employee's name, topic covered anddate of completion.

2.4.7 Training and certification program for inspection and test personnel is controlled in animplementing procedure.

2.5 Plan Control and Revisions

2.5.1 This QAP and all MO procedures are electronically maintained.

2.5.2 All individuals at the MO facility shall acknowledge they have reviewed the QAP throughtheir individual Training Records. This process should be followed for all subsequentrevisions of the QAP.

2.5.3 Revisions to the QAP shall be prepared, approved and issued in the same manner as theinitial issue.


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3.0 DESIGN CONTROL

3.1 General

3.1.1 Engineering activities including engineering calculations, verification activities andadministration and maintenance of quality-related software are to be performed under theGEH QAPD NEDO-11209-A.

3.1.2 Engineering activities on structures, systems and components as described in Section2.2.3 will be treated as safety related per NEDO-11209-A.


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4.0 PROCUREMENT DO.CUMENT CONTROL

4.1 Purpose

To describe measures to assure applicable regulatory requirements, design bases and otherrequirements necessary to assure quality are included in procurement documents.

4.2 General

4.2.1 The Materials and Service Request (MSR) is classified to reflect the quality level of theprocurement.

4.2.2 The MSR, drawings, specifications and other accompanying documents are reviewed forquality requirements by Quality. These requirements may include:

* Standard or Specification, as appropriate.* Supplier on Approved Supplier List.* Regulatory Requirements (i.e. 10CFR21, 100FR72 Subpart G).* Provisions for Source Inspection.* Documentation Requirements.* Quality or Non-Quality designation.* Where the MSR is for a structure, system or component as defined in Section 2.2.3, the

supplier shall certify the material was furnished under a quality program approved byGE-Hitachi Nuclear Energy (GEH) and shall record their quality manual identificationand revision number on their certification documentation. The supplier shall be requiredto incorporate appropriate QA Program requirements in subtier procurementdocuments.

* Personnel and procedure qualification records.* Specific quality clauses.* Other quality-related records.

4.2.3 To the extent necessary, procurement documents require vendors to provide a QAprogram consistent with requirements of this QAP.

4.2.4 Revisions to MSRs shall list requirements that have been changed and shall be subject tothe same preparation, review, approval and other processing required for the initialdocument. Specific non-quality related revisions, such as price changes or cancellationmay be processed by Sourcing. Sourcing personnel cannot add, alter or delete technical orquality requirements after review and approval of the MSR.

4.2.5 Purchase Orders (POs) issued by an approved MSR can only be revised by issuing arevised MSR.

4.2.6 On POs which specify source inspection, the supplier is required to grant MO and/or thecustomer the right of access to the supplier's shop to inspect products, processes, testingand quality records related to the P0.


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4.3.1 Quality is responsible for MSR review to ascertain applicable quality requirements havebeen incorporated.

4.3.2 GEH Sourcing is responsible for submitting the Request for Quote (RFQ) package toprospective bidders.

4.3.3 The OMC is responsible for initiation of MSR's for Instrumentation and Test Equipment.

4.3.4 GEH Engineering or OMC is responsible for initiation of MSR's for structures, systems andcomponents as described in Section 2.2.3 and Plant Modifications.


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5.0 INSTRUCTIONS, PROCEDURES, AND. DRAWINGS

5.1 Purpose

To describe measures to ensure activities affecting quality are described in instructions, proceduresor drawings of a type appropriate to work being performed and work is accomplished in accordancewith required instructions, procedures and drawings.


5.2.1 Organizations preparing instructions, procedures, specifications and drawings are

responsible to assure these documents adequately describe activities affecting quality.

5.2.2 Quality is responsible to:

* Review and approve instructions, procedures and drawings that affect quality.* Perform verification of instructions, procedures, drawings and specifications

compliance with requirements. ,

5.3 Documents Affecting Quality

5.3.1 Instructions, procedures and drawings are prepared as required and as applicable.

5.3.2 Inspection acceptance criteria shall be included within appropriate procedures, drawings orspecifications for the specific activity.

5.3.3 Review and approval as required shall be performed prior to release for use of aninstruction, procedure or drawing.

5.3.4 -Revisions to documents are prepared, reviewed, approved and distributed in the samemanner as the original issue.



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6.0 DOCUMENT CONTROL

6.1 Purpose

To describe measures to ensure documents related to quality activities, such as instructions,procedures and drawings are controlled for issue and distribution.

6.2 General

MO has established the necessary measures and governing procedures to control the preparationof, issuance of, and changes to documents that specify quality requirements or prescribe howactivities affecting quality, including organizational interfaces, are controlled to ensure that correctdocuments are being employed.

6.2.1 The operation and use of the document control system (including electronic systems usedto make documents available at points of use) is documented and provides for thefollowing:

Identification of internal and external documents to be controlled* Identification of the correct document (including revision) to be used and control of

superseded documents* Distribution for use at the appropriate location* Identification of assignment of responsibility for preparing, reviewing, approving, and

issuing documents* Review of documents for adequacy, completeness, legibility and correctness prior to

approval and issuance* A method for providing feedback from users to continually improve procedures and

work instructions* Coordinating and controlling interface documents and procedures

6.2.2 The types of documents to be controlled include, but are not limited to:

* Drawings such as design, construction, installation, and as-built drawings* Engineering calculations* Design specifications* Purchase orders and related documents* Vendor-supplied documents- Audit, surveillance, and quality verification/inspection procedures* Inspection and test reports* Instructions and procedures for activities covered by this QAP* Technical requirements* Nonconformance reports

6.3 Review and Approval of Documents

6.3.1 Individuals other than the preparer review documents for adequacy, accuracy, andcompleteness.

6.3.2 Prior to issuance or use, the reviewed documents are approved. This review process isapplied to all subsequent revisions.


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6.3.3. A listing of all controlled documents identifying the cu~rrent approved revision, or date ofapproval, is maintained so personnel can readily determine the appropriate document for

use.

6.4 Changes to Documents

6.4.1 Changes to documents, other than those defined in implementing procedures as minorchanges, are reviewed and approved by the same organizations that performed the originalreview and approval unless other organizations are specifically designated.

6.4.2 The reviewing organization is given access to pertinent background data or informationupon which to base their approval.

6.4.3 Minor changes to documents, such as inconsequential editorial corrections, do not requirethat the revised documents receive the same review and approval as the originaldocuments.

6.4.4 To avoid a possible omission of a required review, the type of minor changes that do notrequire such a review and approval and the persons who can authorize such aclassification will be clearly delineated in implementing procedures.


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7.0 CONTRO.L OF PURCHASED MATERIAL, EQUIPMENT AND SER.VICES

7.1 General

7.1.1 Procurement activities including qualification of suppliers, supplier evaluations and audits,source inspections and procurement document review and issuance are to be performedunder the GEH QAPD NEDO-1 1209-A.

7.1.2 Activities for structures, systems and components as described in Section 2.2.3 will betreated as safety related per NEDO-1 1209-A.

7.2 Receiving Inspection

7.2.1 Receiving inspection is the responsibility of Quality and provides assurance that:

* Supplier-furnished documents meet specified requirements.* Material, component, or equipment is identified properly and corresponds with the

identification on receiving documentation.* Inspection records or certificates of conformance attesting to the acceptance of

material, components, and equipment are available at MO prior to installation or use.- Items accepted and released are identified as to their inspection status prior to

forwarding them to a controlled storage area or releasing them for installation, use, orfurther work.

7.2.2 Receiving inspection may be performed using an Incoming Material Report (IMR). The IMRdefines inspections to be performed. The IMR, certifications, test reports and other quality-related records are maintained in the in accordance with Section 17.0



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8.0 IDENTIFICATION .AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS

8.1 Purpose

To describe methods to control material, parts and components. This identification and controlverifies that only specified items accepted by Quality are used in construction, maintenance,production or laboratory operations.

8.2 General

8.2.1 Identification of items is maintained by heat number, part number, serial number or otherappropriate means, either on an item or on records traceable to an item throughoutfabrication, erection, installation and use.

8.2.2 Identification is maintained on non-permanent items until they are consumed or otherwiseutilized. If identification is destroyed prior to use, the organization responsible for usereidentifies the item utilizing procurement, fabrication, operation or quality records.


8.3.1 MO organizations are responsible to maintain identification and control of items while theitems are in their control.

8.3.2 Suppliers are responsible to maintain identification and control of items (materials, parts orcomponents) while the items are in their control and prior to final acceptance.

8.4 Implementation

8.4.1 Received material or items shall be checked against PO requirements by Quality anddocumented on an Incoming Material Report (IMR) per Section 10.0 of this QAP.

8.4.2 Identification of material shall be traceable to applicable Certificates of Compliance orCertified Material Test Reports. Physical identification shall not be detrimental to material oritem function.

8.4.3 Before operations that remove identification marks are performed or material is cut orparted, either transfer the identification marks to another area of the part or a temporarymethod of identification shall be established on the item, drawing, or work package andused to prevent loss of traceability. As soon as practical, permanent identification shall bereestablished on the material and verified by Quality.

8.4.4 Small products or those items which are not feasible to label need not be individuallyidentified unless required by specification. Such products shall be kept in suitable packagesor containers that are identified until installation.

8.4.5 Status of material or items shall be maintained by tagging in accordance with Section 14.0of this QAP.


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8.4.6 Material and items without proper identification shall be considered unacceptable and shallrnot be used. Quality shall resolve the status of material and items in this category. If statuscannot be satisfactorily established, they shall be evaluated as nonconforming material peiSection 15.0 of this QAP.

8.4.7 Marking, tagging and control of inspected items and material is addressed in Sections 10.0,14.0 and 15.0.



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9.0 CONTROL OF SPECIA.L PROCESSES

9.1 Purpose

To describe requirements for assuring special processes such as welding, brazing, heat treat, andcleaning are controlled and accomplished by qualified personnel using qualified procedures inaccordance with applicable codes, standards, specifications, criteria and other special requirements.MO does not perform any NDE processes. If NDE processes are required, they will be appropriatelypurchased per Section 4 of this QAP.


9.2.1 The Operations and Maintenance Coordinator (OMC) is responsible to:

* Establish and/or identify special processes to be used to fabricate procuredequipment. Requirements may be established in the form of criteria, specifications,instructions, and procedures as appropriate.

* Develop special processes, whenever appropriate in accordance with national codesand standards or other recognized data.

9.2.2 Quality (for MO personnel performing Special Process work) or GEH Sourcing (for vendorsand contractors performing Special Process work) are responsible to:

* Review special process and personnel qualifications to assure special processes andpersonnel can achieve stated quality requirements for a specific task.

* Review personnel qualification data prior to utilization of any special process.• Approve special process procedures prior to use.

9.3 Special Process Procedures

9.3.1 Special process requirements are specified on drawings or other design documents.Required information includes the standard to which the procedure must be qualified.

9.3.2 Each special process is qualified using written procedures according to requirements ofapplicable national standards or codes in specifications incorporating the requirements.

9.3.3 Applicable special process procedures are utilized at the work location.

9.3.4 The use and storage of special process materials is controlled by procedures.

9.3.5 Equipment controlling special processes (such as heat controls, electrical controls andrecording equipment) are calibrated on a planned frequency and results documented.

9.3.6 All records reflecting the quality of a process or procedure such as heat treat furnacecertification, furnace charts, and welding records are maintained as process records.

9.3.7 GEH Quality performs a review of fabrication or test processes, controls processqualification samples, reviews process parameters and test result documentation and in-process inspection for assuring special process quality.


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9.4 Special Process Personnel*

9.4.1 Each special process is performed by a qualified/certified person according to requirementsof the applicable specification.

9.4.2 Requalification of personnel is performed according to requirements of the applicableprocess.

9.5 Records

9.5.1 Quality maintains a list of qualified procedures and records to substantiate QC personnelqualifications for all special process operations performed at MO on structures, systemsand components as described in Section 2.2.3. Records include name, type of certification,education and experience background as well as examination results.

9.5.2 Contractor or supplier process procedures and records are reviewed and approved asapplicable by GEH Supplier Quality prior to initiating work at contractor or supplierlocations.



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10.0 INSPECTION

10.1 Purpose

To describe requirements to control inspection activities affecting quality to assure items, materialand processes are in compliance with applicable requirements. This section also establishesrequirements for qualification and certification of examination, inspection and test personnel.

10.2 General

10.2.1 Inspection procedures may be prepared from drawings and specifications by GEH Qualityprior to performing inspections.

10.2.2 Examination, measurement or test of materials, components or products are performedwhen required.

10.2.3 Inspection activities are performed in a manner so the value of a characteristic is verified.After measurement, results of inspections are certified by the inspectors' symbol (stamp,name, etc.) which is traceable to each inspector.

10.2.4 Inspection activities are performed by personnel other than those who performed the actualwork.

10.2.5 Inspection personnel are certified in accordance with this QAP and implementingprocedures on qualification and certification of inspection personnel.

10.2.6 Inspector qualification/certification is maintained by Quality.


10.3.1 The Operations and Maintenance Coordinator (OMC) is responsible to makerecommendations regarding classification of equipment and identification of significantquality characteristics.


- Review equipment classification as described in Section 2.2.3 to ensure the level ofquality.

* Plan and establish frequency and methods of inspection used to verify required qualitylevels.

* Verify that inspectors (both MO and supplier personnel working at MO) are qualifiedand certified to the applicable requirements per Section 2.0 to perform quality relatedinspections.

* Assure appropriate requirements for process monitoring are established andinspection process(es) meet the requirements.


~j) HITACHI NEDE-31559Revision 03


10.4 Implementation

10.4.1 Final inspection of completed items is performed by Quality personnel to verify specifiedrequirements.

10.4.2 Process monitoring is used where applicable to control quality related activities if aninspection is not possible. When appropriate, integrated program or process monitoringand inspection is used.

10.4.3 Nonconformances detected during performance of quality-related inspections or processmonitoring are documented and processed as described in Section 15.0.



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11.0 TEST CONTROL

11.1 Purpose

To describe requirements to control testing in accordance with material or design specifications,

regulatory or license requirements.

11.2 Applicability

Test control is applicable to all MO or supplier organizations required to perform tests in conjunctionwith work activities as specified in design documents, contract or material codes.

11.3 General

11.3.1 Test programs can include manufacturing tests prior to installation, installation tests,equipment verification tests, compliance and operational tests and developmentalengineering tests.

11.3.2 Tests are conducted by qualified personnel in accordance with approved procedures.

11.3.3 Testing shall be performed with a written test procedure which shall include requirementsfor the following, as appropriate:

* Prerequisites such as system line up or isolation and circuit isolation.* Safety requirements.• Equipment requirements.• Calibrated instrument requirements.* Special environmental conditions.• Personnel training requirements.* Data to be acquired.* Acceptance criteria.* Actions to be taken if test results are unacceptable.

11.3.4 Test results are documented on test reports and evaluated by a knowledgeable individualto assure test requirements have been satisfied. Test reports will include, but are notlimited to, the following as required by the test procedure:

* Item tested.• Date of test.* Test or data recording equipment.• Person recording test data.* Type of observation.* Results of test.* Action taken on any noted deviations.- Person evaluating results.* Procedure and revision number.• Quality acceptance.

11.3.5 Items not passing required tests are identified as nonconforming and processed inaccordance with Section 15.0 of this QAP.


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11.4 Respons~ibilities

11.4.1 GEH Engineering is responsible to:

- Incorporate test requirements and acceptance limits in applicable design/testdocuments.

* Prepare basic test instructions and/or procedures.* Plan and schedule tests related to design, construction, operation and analytical

activities.* Review and approve applicable test procedures including test status and results.* Direct activities related to performing applicable tests.* Review technical qualifications of outside test facilities to perform the required test, if

testing cannot be done by MO.


* Witness and verify test data and other pertinent items during testing, when required.Witnessing tests at approved test agencies is at the discretion of Quality.

* Review and approve applicable test procedures and results to assure activitiesaffecting quality are controlled and in compliance with applicable design documents.


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12.0 CONTROL OF MEASURING AND TEST EQUIPMENT

12.1 Purpose

To describe requirements to provide, calibrate and control devices used in quality related inspection,measuring and test activities.

12.2 General

12.2.1 Measuring and test equipment (M&TE) is adjusted and calibrated at prescribed intervalsusing certified equipment having a valid relationship to nationally recognized standards. Ifno national standard exists, the basis for calibration is documented.

12.2.2 Each organization provides an area for storage of calibrated M&TE. Environmentalconditions of storage areas are appropriate to the type of M&TE.

12.2.3 Use of out-of-calibration items is precluded by controlled access or administrative controlas appropriate.

12.2.4 Personnel responsible for calibrations are trained to perform these duties. Overall directionis assigned to a responsible management individual with authority to issue and recall.


12.3.1 The Operations and Maintenance Coordinator (OMC) and Instrumentation &Communications Specialist (ICS) are responsible to control and calibrate M&TE used forfabrication, construction, operation or maintenance work; or for inspections.

12.3.2 The OMC and ICS have responsibility to ensure M&TrE in their organizations are controlledand calibrated, that calibration is recorded, have current calibration stickers attached andare recalled for calibration.

12.3.3 Users of M&TE are responsible for returning instruments for recalibration if damage ormalfunction is suspected.

12.3.4 The OMO and ICS are responsible to ensure personnel using M&TE are trained asrequired to checkout, install, use and understand data readouts used to record data.


- Resolve nonconformances resulting from M&TE discovered to be out-of-calibration.- Ascertain that appropriate nonconformance corrective action is accomplished.- Ascertain that suppliers' calibration programs comply with requirements.

12.4 Control System

12.4.1 Instruments (standards) used to calibrate production instruments and other tools requiringcalibration have an uncertainty (error) of no more than 1/4 of the tolerance of the



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equipment being calibrate~d. Greater tolerances may be allowed based on the function ofthe equipment, but must be approved by GEH Quality. These standards are calibrated bythe National Institute of Standards and Technology (NI1ST) or a certified source havingtraceability to NIST, if available. The standards are checked and calibrated at specifiedintervals.

12.4.2 M&TE are tagged with a "Calibration" label and calibrated to specific schedules.

12.4.3 Personnel using a calibrated device shall use it only within the indicated calibration periodand calibrated range and report any inaccuracies or malfunction to the Manager, MO, theOMC, or the EHSPA. Out of Tolerance Gage Reports should be generated as needed.

12.4.4 Recalibration of any device may be requested by anyone at any time should damage occuror variations be observed that would indicate recalibration is necessary.

12.4.5 Calibration service suppliers shall perform their calibration against measurement standardswith an established relationship to national standards or other recognized standards wheresuch standards exist.

12.4.6 Approved calibration service suppliers shall include in their report or calibration certificationthe standard(s) used for calibration, the "as-found" condition prior to adjustment when the"as-found" condition is out of specification, adjustments made as well as identification ofthe device calibrated.

12.4.7 Out of calibration devices are tagged and segregated from calibrated instruments. Theresponsible manager or supervisor then performs an evaluation to determine validity ofprevious inspections, tests or operations and acceptability of items involved. Results of thisevaluation shall be documented and reviewed by Quality. If necessary, a NonconformingItem Record (NIR) listing uses of the device by item and identification shall be initiated andprocessed in accordance with Section 15.0.

12.4.8 Periodic checks of calibrated tools to validate devices are within tolerance may beperformed. Standards for performing these checks will be maintained by Quality.


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13.0 HANDLING, STORAGE, AND SHIPPING

13.1 Purpose

To describe measures used to control handling, storage, and shipping of nuclear and non-nuclearmaterial in compliance with license requirements and instructions, procedures, specifications ordrawings to prevent damage, deterioration or loss.

13.2 Applicability

This section applies to all organizations that participate in packaging, shipping, storage and handlingof items to be incorporated or used in construction, maintenance or operations. These items include,but are not limited to, irradiated nuclear fuel, construction materials, fabricated assemblies and parts.

13.3 General

13.3.1 Nuclear Materials

Nuclear safety is of prime concern in storing nuclear material. Use of approvedcontainers or equipment, placing in authorized storage areas, use of approvedprocedures for fuel identification, storage operations and monitoring to assurecompliance are required. Primary storage features include:

-Storing irradiated fuel assemblies in baskets or racks designed for criticality,thermal and structural safety within fuel storage pools.

-Verifying nuclear safety of stored nuclear materials by using instruments and/orpersonnel observations.

-Maintaining and testing fuel handling equipment.

13.3.2 Non-Nuclear Materials (for structures, systems and components as described in Section2.2.3)

-Handling, shipping and packaging is performed in accordance with requirementsspecified in specifications, drawings and special instructions to prevent damage ordegradation of quality.

* Identification (and status) of items during handling (including division or joining in thefabrication process), packaging and shipping are described in Section 8.0 and Section14.0.

* Storage activities include identification, inspection status (Section 14.0) through tags,marking, distribution control, preservation of the item from environmental deteriorationand protection from unauthorized access or modification.


13.4.1 GEH MO is responsible to perform handling, storage and shipping activities as part ofroutine fuel storage operation and facility maintenance as well as equipment maintenancein accordance with license requirements.

13.4.2 Quality is responsible to review handling, storage and shipping procedures.



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13.5 Implementation

13.5.1 Requirements for cleaning, marking, packaging, preservation, shipping, storage andhandling are incorporated in Operations and Maintenance documents. These requirementsare reviewed and approved by appropriate management.

13.5.2 Operations and Maintenance implements these tasks by development and/or use ofdetailed procedures.

13.5.3 Specific procedures for irradiated fuel handling and storage are developed in accordancewith the QAP.

13.5.4 Any activities related to 10 CFR Part 71 shall be performed per the GEH QAPD NEDO-11209-A.


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14.0 INSPECTION, TEST, AND OPERATING ST.ATUS

14.1 Purpose

14.1.1 To describe measures used to indicate status of inspection and test of structures, systemsand components as described in Section 2.2.3 related equipment during fabrication andassembly. Such measures are designed to preclude use of nonconforming items.

14.1.2 This section also describes measures to indicate operational status of structures, systemsand components to prevent inadvertent operation while these structures, systems andcomponents are not in conformance with license requirements.

14.2 General

14.2.1 Inspection and test status of individual items is indicated by stamps, tags, labels, routingcards or other documentation. The using organization verifies equipment status is indicatedby this type device prior to use.

14.2.2 Such documentation provides for identification of items which have satisfactorily passedrequired inspections and tests.

14.2.3 Operational status of the plant, which is dependent on the operational status of structures,systems and components, is indicated by tagged valves and switches, lockouts, etc., inconjunction with log book entries that document status to prevent unauthorized adjustmentor operation.


14.3.1 The Manager, MO and OMC are responsible to assure MO systems and equipment are notused while in nonconforming status.

14.4 Implementation

14.4.1 Inspection, test and operating status of incoming irradiated fuel is covered in Section 13.0.

14.4.2 Inspection, test and operating status of incoming and in-process maintenance andconstruction items are covered in Sections 7.0 and 13.0. Structures, systems andcomponents as described in Section 2.2.3 are identified by a readily recognized identitysuch as a heat number or serial number.

14.4.3 Nonconforming material and items are handled in accordance with Section 15.0.

14.4.4 The operating status of all systems is controlled by Lock and Tag Out procedures toprevent inadvertent operation of a system undergoing maintenance or repair. Basic "Lock-out" tags used are:



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•DANGER - DO NOT OPERATE tags are placed on equipment not in service due tomaintenance or processing and if operated could result in a hazardous condition topersonnel and/or equipment.

•CAUTION or status tags placed on valves, switches or controls that indicate conditionof applicable systems. Instructions on the tag specify steps that must be taken insequence to operate the equipment in question.

14.4.5 Quality verifies inspection, test and operating status by surveillance of fabrication,receiving, test and inspection processes and/or process audits, documentation producedand equipment utilized in design, fabrication, inspection and test.



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15.0 NONC.ONFORMING MATERIAL OR COMPONENTS

15.1 Purpose

To describe requirements to identify and control material or items as nonconforming and to preventinadvertent use of nonconforming material or items not in conformance with applicable design orproject specifications.


15.2.1 All MO personnel are responsible to identify and report nonconforming material, items orprocesses.

15.2.2 Quality is responsible to verify validity of the nonconformance and close out the NIR uponverification that disposition is accomplished.

15.2.3 MO personnel in conjunction with Quality are responsible to develop nonconformancedisposition and follow up to assure the approved disposition is accomplished.

15.2.4 The OMC is responsible for review of NIRs and periodic quality trend reports.

15.3 Requirements

15.3.1 Operations, Maintenance or Quality personnel shall report material or items determined tobe nonconforming to the OMC or Manager, MO.

15.3.2 The 0MC or Manager, MO verifies the nonconformance. If a nonconformance does exist,an NIR is initiated describing the condition.

15.3.3 A "Hold Tag" is attached to the material or item as necessary to ensure control of furtherwork activities. The NIR is entered on the NIR Index and forwarded to the appropriateManager or Supervisor for a proposed disposition. A copy of the NIR is maintained by MOpersonnel until the original is returned.

15.3.4 The responsible Manager or Supervisor shall determine the disposition of materials oritems using the following:

* Meets Specification - A disposition for a nonconformance when the previouslyestablished acceptance criteria and compliance have been fully met.

• Use-As-Is - A disposition permitted for a nonconforming item when it has beenestablished that the item is satisfactory for its intended use.

* Repair - The process of restoring a nonconforming characteristic to a condition suchthat the capability of an item to function reliably and safely is unimpaired even thoughthat item still may not conform to the original requirement.

* Rework - Process by which a nonconforming item is made to conform to prior specifiedrequirements by completion or correction.

* Reject - The item is unsuitable for use and is to be designated as scrap or returned tothe vendor.


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•Othe~r (if not material or item) - Disposition applied to documentation correction orreevaluation of processes.

15.3.5 If a nonconformance disposition is use-as-is or repair, or if requested by involved parties,the nonconformance is referred to the Material Review Board (MRB) for disposition. TheMRB is comprised of Quality and GEH Engineering. Operations, Maintenance, Sourcing orother groups as determined by Quality are included as appropriate.

15.3.6 Technical justification for the acceptability of items with a disposition of "use-as-is" or"repair" must be documented.

15.3.7 Disposition to "use as is" or "repair" that does not adversely affect function, fit-up, safety, orbasic design requirements of the manufacturing plan, supporting documents, designdocuments or contractual agreements may be made without customer notification, unlessrequired by the customer contract.

15.3.8 Quality reviews the selected disposition for concurrence with the requirements and signifiesapproval by signing that section of the NIR.

15.3.9 Quality and the responsible manager or supervisor shall process the NIR and submit it forfurther processing and approval.

15.3.10 If there is a concern that a nonconformance could result in a substantial safety hazard, asafety evaluation is requested in accordance with the Corrective Action Program forReporting of Defects and Noncompliance Under 10 CFR Part 21.

15.3.11 Upon satisfactory completion of work required by disposition of the NIR, the item will be

reinspected and if acceptable to Quality, the Hold Tag will be removed and the NIR closed.

15.4 Summary of Nonconforming Item Records

15.4.1 Quality closes nonconformance records when all appropriate actions are taken.

15.4.2 A periodic summary of applicable open and closed nonconformance records is provided tothe Manager, MO.


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16.0 CORRECTIVE ACTION. PROGRAM

16.1 General

16.1.1 The Corrective Action Program is controlled under the GEH QAPD NEDO-1 1209-A.

16.1.2 If there is a concern that a condition adverse to quality could result in a substantial safetyhazard, a safety evaluation is requested in accordance with the Corrective Action Programfor Reporting of Defects and Noncompliance Under 10 CFR Part 21


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17.0 QUALITY ASSURANCE RECORDS

17.1 Purpose

To describe measures to ensure sufficient records are generated and maintained to furnish evidencethat activities affecting quality are properly performed, and such records are stored, maintained andsafeguarded for an adequate period utilizing a systematic means of retrieval.

17.2 Applicability

This section is applicable to all quality related activities in design, fabrication, construction andoperation.

17.3 General Requirements

17.3.1 In-process control of documents that furnish evidence of quality and provide informationrelating to activities affecting quality is maintained by the originating organization untilcompletion of a task or project, then transferred to document control.

17.3.2 Records pertaining to quality of items or activities are retained in accordance withregulatory requirements and MO instructions.

17.3.3 A document index system assures all records are readily identifiable and retrievable. EachOrganization that generates quality records is responsible to identify and index suchrecords with appropriate cross references in accordance with document control procedurespresented in Section 6.0.

17.3.4 Records shall be legible (in original or reproduced form), accurate, complete and readilyidentifiable to item or activity involved.


17.4.1 Originating organizations are responsible to provide control of documents in accordancewith written procedures, instructions or other documentation.

17.5 Records Handling Procedure

17.5.1 Records are maintained in an offsite vault or in a Record Center. Lifetime records aremaintained for the lifetime of the item or facility to which they pertain.

17.5.2 Storage is accomplished by retention of complete (hard copy) documentation, microfilm orother reproductions. Items such as radiographs are not reproduced, but retained asoriginals.

17.5.3 An index system is established for all records stored by MO. The index system includesrecord location within the system.


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18.0 AUDITS

18.1 General

The audit program, including internal audits, is controlled per the GEH QAPD NEDO-11209-A.
