ML15083A455

San Onofre Nuclear Generating Station, Units 1, 2 and 3 - and Independent Spent Fuel Storage Installation - Request for Additional Information Decommissioning Quality Assurance Program Review (TAC Nos. MF5215, MF5216, and MF5217)

ML15083A455
Person / Time
Site:	San Onofre
Issue date:	03/27/2015
From:	Wengert T J Plant Licensing Branch IV
To:	Palmisano T J Southern California Edison Co
Wengert T J
References
TAC MF5215, TAC MF5216, TAC MF5217
Download: ML15083A455 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 27, 2015 Mr. Thomas J. Palmisano Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION-REQUEST FOR ADDITIONAL INFORMATION RE: DECOMMISSIONING QUALITY ASSURANCE PROGRAM REVIEW (TAC NOS. MF5215, MF5216, AND MF5217) Dear Mr. Palmisano: By letter dated November 13, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14322A 157), Southern California Edison (SCE) submitted a proposed revision of the Decommissioning Quality Assurance Program (DQAP) for San Onofre Nuclear Generating Station (SONGS), Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation for U.S. Nuclear Regulatory Commission (NRC) review and approval. In order to complete its review, the NRC staff requests additional information as specified in the Enclosure. The staff's request was clarified during a telephone conversation held with your staff on March 18, 2015. As discussed with your staff on March 24, 2015, please provide a response by April 20, 2015.

T. Palmisano -2 -If you have any questions, please contact me at (301) 415-4037 or via e-mail at Thomas.Wengert@nrc.gov. Docket Nos. 50-206, 50-361, 50-362, and 72-41 Enclosure: Request for Additional Information cc w/encl: Distribution via Listserv Sincerely, Thomas J. Wengert, Senior Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION REGARDING DECOMMISSIONING QUALITY ASSURANCE PROGRAM SOUTHERN CALIFORNIA EDISON SAN ONOFRE NUCLEAR GENERA TING STATION, UNITS 1, 2 AND 3 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. 50-206, 50-361. 50-362, AND 72-41 By letter dated November 13, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14322A157), Southern California Edison requested the Nuclear Regulatory Commission (NRC) staff to review and approve the Decommissioning Quality Assurance Program {DQAP) for San Onofre Nuclear Generating Station (SONGS), Units 1, 2 and 3, and the Independent Spent Fuel Storage Installation. The following additional information is necessary for the NRC staff to complete its review: 1. The requirements of 10 CFR Part 50, Appendix B, Criterion 11, "Quality Assurance Program," states in part, "The applicant shall regularly review the status and adequacy of the quality assurance program. Management of other organizations participating in the quality assurance program shall regularly review the status and adequacy of that part of the quality assurance program which they are executing." Clarify how the SONGS DQAP meets this requirement or provide justification on why it is not needed. 2. The requirements of 10 CFR Part 50, Appendix 8 address the quality assurance requirements for nuclear power plants and fuel cycle processing plants; the requirements of 10 CFR Part 72, Subpart G address the quality assurance requirements for independent storage of spent nuclear fuel; and the requirements of 10 CFR Part 71, Subpart H address the quality assurance requirements for packaging and transportation of radioactive material. The NRC staff has endorsed industry guidance as acceptable for complying with the above regulations. Specifically, Appendix E of the SONGS DQAP references the American Society of Mechanical Engineers (ASME) NQA-1-200812009 Addendum, "Quality Assurance Requirements for Nuclear Facility Applications"; Regulatory Guide1 .191, "Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown"; and NRC Regulatory Issue Summary (RIS) 2000-18, "Guidance on Managing Quality Assurance Records in Electronic Media." Clarify to what extent the DQAP commits to meeting the references listed in Appendix E. Clarify what codes and standards will be used to implement the DQAP at SONGS. Address how proposed reductions in commitments, alternatives or exceptions will be evaluatep or considered for review by the NRC staff. / Enclosure

-2 -3. The requirements of 10 CFR Part 50, Appendix 8, Criterion VII, "Control of Purchased Material, Equipment, and Services," states in part, that, "Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery." Section 7.0, "Control of Purchased Materials, Equipment and Services," of the SONGS DQAP states, in part, "A Supplier's QA Program that satisfies specified quality requirements shall be listed on the SONGS Evaluated Suppliers List." Clarify the process for evaluation of suppliers prior to being listed and maintained on the SONGS Evaluated Suppliers List. 4. The requirements of 10 CFR Part 50, Appendix 8, Criterion VII, states in part, that, "Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery." Section 7.0, of the SONGS DQAP states, "Suppliers of commercial grade calibration services may be qualified based on their accreditation by nationally-recognized accrediting body, as an alternative to qualification by supplier audit, commercial grade survey, or in-process surveillance." The NRC staff has approved a similar alternative outlined in the NRC staff's safety evaluation for Arizona Public Service Company in a letter dated September 28, 2005 (ADAMS Accession No. ML052710224). Clarify if SONGS will be committing to the conditions contained in the alternative outlined in the NRC staff's safety evaluation for Arizona Public Service Company. 5. The requirements of 10 CFR Part 50, Appendix 8, Criterion VII, states in part, "The effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services." Section 7 of the SONGS DQAP states, "Items important to safety SS Cs [structures, systems and components] and services from suppliers whose QA Program has not been reviewed or accepted may be used, provided additional controls such as source inspection, special receipt inspections, and/or testing are imposed. These additional controls shall be documented and approved by the appropriate level of management."

-3 -Clarify if this alternative is referring to the application of commercial grade dedication. Additionally, if commercial grade dedication will be implemented, what industry guidance will be utilized? 6. The requirements of 10 CFR Part 50, Appendix B, Criterion VII, states, in part, "Documentary evidence that material and equipment conform to the procurement requirements shall be available at the nuclear power plant or fuel reprocessing site prior to installation or use of such material and equipment. This documentary*evidence shall be retained at the nuclear power plant or fuel reprocessing plant site and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications, met by the purchased material and equipment." Clarify how the above requirements are addressed in the SONGS DQAP. 7. The requirements of 10 CFR Part 50, Appendix B, Criterion XVIII, "Audits," states, in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program ... " Section 18, "Audits," of the SONGS DQAP states, "Internal audits of the QA Program shall be on a bi-annual cycle with a 90 day grace period .... " Appendix B of the DQAP lists guidance and regulatory commitments. Regulatory Guide 7.10, "Establishing Quality Assurance Programs for Packaging Used in Transport of Radioactive Material," Revision 2, issued March 2005, is listed. The Regulatory Guide addresses an audit interval of annual. Clarify the frequency for internal audits. 8. Regarding personnel training and qualification, in Section 2 of the proposed SONGS DQAP, it states, in part: "Members of the SONGS staff (including audit and inspection personnel) shall have sufficient qualifications to perform their assigned duties. Implementing procedures provide the criteria utilized for determining and assessing appropriate staff qualifications." Please clarify what "sufficient qualifications" means in this section.

T. Palmisano -2 -If you have any questions, please contact me at (301) 415-4037 or via e-mail at Thomas.Wengert@nrc.gov. Docket Nos. 50-206, 50-361, 50-362, and 72-41 Enclosure: Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC LPL4-2 r/f RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr Resource RidsNrrDorllpl4-2 Resource RidsNrrLAPBlechman Resource RidsNrrPMSanOnofre Resource RidsRgn4MailCenter Resource KKavanagh, NRO AKeim, NRO PPrescott, NRO JTapp, NMSS MVaaler, NMSS Sincerely, IRA/ Thomas J. Wengert, Senior Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation ADAMS Accession No. ML 15083A455 *via memo OFFICE NRR/DORL/LPL4-2/PM NRR/DORL/LPL4-2/LA NRO/DCIP/QVIP/BC* NAME TWengert PBlechman KKavanagh DATE 3/26/15 3/25/15 2/23/15 OFFICE NRR/DORL/LPL4-2/BC NRR/DORL/LPL4-2/PM NAME MKhanna TWengert DATE 3/26/15 3/27/15 OFFICIAL RECORD COPY