DCL-21-056, Pacific Gas & Electric Co - Proposed Revision to the Pacific Gas and Electric Company Quality Assurance Program Approval Form for Radioactive Material Packages No. 0202

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Pacific Gas & Electric Co - Proposed Revision to the Pacific Gas and Electric Company Quality Assurance Program Approval Form for Radioactive Material Packages No. 0202
ML21243A570
Person / Time
Site: Diablo Canyon, Humboldt Bay, 07100202
Issue date: 08/31/2021
From: Zawalick M
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-21-056, DIL-21-006, HBL-21-015, HIL-21-003
Download: ML21243A570 (7)


Text

Pacific Gas and Elecmc Campany*

Maureen R. Zawalick Diablo Canyon Power Plant Vice President Mail code 104/6/608 Generation Business P.O. Box 56 and Technical Services Avila Beach, CA 93424 805.545.4242 Internal: 691.4242 PG&E Letter DCL-21-056 PG&E Letter DIL-21-006 PG&E Letter HBL-21-015 PG&E Letter HIL-21-003 ATTN: Document Control Desk 10 CFR 71 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant Docket No. 72-27, Materials License Number SNM-2514 Humboldt Bay Independent Spent Fuel Storage Installation Proposed Revision to the Pacific Gas and Electric Company Quality Assurance Program Approval Form for Radioactive Material Packages No. 0202

References:

1. NRC Letter Revised Quality Assurance Program Approval Form for Radioactive Material Packages No. 0202 Revision 8, dated August 13, 2015 (ML15231A222)
2. PG&E Letter HIL-19-010, Response to NRC Request for Supplemental Information for the Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan, dated September 3, 2019 (ML19247E271)
3. NRC Letter, Safety Evaluation Report for the Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0 (CAC NO. 001028), dated April 17, 2020 (ML20092L173)

Dear Commissioners and Staff:

In Reference 1, the U.S. Nuclear Regulatory Commission (NRC) issued a revised NRC Form 311, Quality Assurance (QA) Program Approval No. 71-0202, Revision 8 for Diablo Canyon and Humboldt Bay (HB). In accordance with 10 CFR 72.140(d),

A member of the STARS Alliance Callaway Diablo Canyon Palo Verde Wolf Creek

Document Control Desk PG&E Letter DCL-21-056 Page 2 PG&E Letter DIL-21-006 PG&E Letter HBL-21-015 PG&E Letter HIL-21-003 Pacific Gas and Electric Company (PG&E) notified the NRC of its plan to adopt the previously approved Humboldt Bay Power Plant (HBPP), 10 CFR Part 50, Appendix B QA Program for the HB Independent Spent Fuel Storage Installation (ISFSI) quality activities. HBPP decommissioning field activities are complete and PG&E plans to request termination of the HBPP 10 CFR Part 50 license and QA Program in 2021. As a result, PG&E submitted Revision 0 of an ISFSI-only HB QA Plan in Reference 2. The HB ISFSI QA Plan satisfies the requirements of 10 CFR Part 72, Subpart G and the requirements of 10 CFR Part 71, Subpart H for the procurement, maintenance, repair, and use of radioactive materials transport packages. In Reference 3, the NRC approved the HB ISFSI QA Plan.

Therefore, PG&E requests the following changes to the PG&E QA Program Approval for Radioactive Material Packages to reflect the transition from a HB, 10 CFR Part 50, Appendix B QA Program to an ISFSI-only 10 CFR Part 72, Subpart G QA Program concurrent with the termination of the HBPP 10 CFR Part 50 license.

1. NRC Form 311, QA Program Approval No. 71-0202, Revision 9
a. Revise Block 5 Item 4 to remove the reference to HBPP and reissue the NRC Form 311 to Diablo Canyon Power Plant only. This reference will no longer be applicable after termination of the HBPP Part 50 license.
b. Concurrent with the termination of the HBPP 10 CFR Part 50 License, terminate the HBPP 10 CFR Part 50 Appendix B QA Program approval.
2. NRC Form 311, QA Program Approval No. 71-new, Revision 0
a. Issue a new and separate NRC Form 311 QA Program Approval for Radioactive Material Packages for the HB ISFSI that references the NRC approved 10 CFR Part 72, Subpart G HB ISFSI QA Program. includes a proposed markup of the revision to NRC Form 311, QA Program Approval No. 71-0202. Enclosure 2 provides a proposed NRC Form 311, QA Program Approval to reflect the stand-alone HB ISFSI QA Plan.

NRC issuance of the revised Reference 1 and the new NRC Form 311 for the HB ISFSI are requested to become effective upon termination of the HBPP 10 CFR Part 50 License.

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

A member of the STARS Alliance Callaway Diablo Canyon Palo Verde Wolf Creek

Document Control Desk PG&E Letter DCL-21-056 Page 3 PG&E Letter DIL-21-006 PG&E Letter HBL-21-015 PG&E Letter HIL-21-003 If you have any questions or require additional information, please contact Jim Morris at 805-545-4609.

Sincerely, August 31, 2021 Maureen R. Zawalick _______________

Vice President, Generation Business and Technical Services Date Enclosures cc: Humboldt Distribution Diablo Distribution cc/enc: William C. Allen, NMSS Project Manager Ayesha Athar, NRC Acting Senior Resident Inspector Samson S. Lee, NRC Project Manager Scott A. Morris, NRC Region IV Administrator Gonzalo L. Perez, Branch Chief, California Dept of Public Health Amy M. Snyder, NRC Reactor Decommissioning Branch Project Manager A member of the STARS Alliance Callaway Diablo Canyon Palo Verde Wolf Creek

Enclosure 1 PG&E Letter DCL-21-056 PG&E Letter DIL-21-006 PG&E Letter HBL-21-015 PG&E Letter HIL-21-003 NRC Form 311 Quality Assurance Program Approval for Radioactive Material Packages 71-0202 Proposed Revisions (Mark Up)

NRC FORM 311 U. S. NUCLEAR REGULATORY COMMISSION 1. APPROVAL NUMBER (10-201907-2015)

-10 CFR 71 0202 QUALITY ASSURANCE PROGRAM APPROVAL REVISION NUMBER FOR RADIOACTIVE MATERIAL PACKAGES 9 Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and Title 10, Code of Federal Regulations, Chapter 1, Part 71, and in reliance on statements and representations heretofore made in Item 4 by the organization named in Item 2, the Quality Assurance Program identified in Item 4 is hereby approved. This approval is issued to satisfy the requirements of Section 71.101 of 10 CFR Part 71. This approval is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.

2. NAME Pacific Gas and Electric Company, Diablo Canyon STREET ADDRESS 77 Beale Street, Mail Code B32 CITY STATE ZIP CODE 3. DOCKET NUMBER San Francisco CA 94105 71-0202
4. QUALITY ASSURANCE PROGRAM APPLICATION DATE(S)

May 10,1994; May 28,1999; April 20, 2004;-and September 4, 2009, August 13, 2015

5. CONDITIONS
1. Activities conducted with regard to transportation packagings under applicable criteria of Appendix B to 10 CFR Part 50 authorized by this approval: procurement, maintenance, repair, and use. All other activities (i.e.,

design, fabrication, assembly, testing, and modification) shall be satisfied by obtaining certifications from packaging suppliers that these activities were conducted in accordance with an NRC-approved Quality Assurance Program. It shall remain the responsibility of the Quality Assurance Program holder that all transportation activities meet the requirements of 10 CFR 71.101.

2. Records shall be maintained in accordance with the provisions of 10 CFR Part 71. Specifically:
a. Records of each shipment of licensed material shall be maintained for 3 years after that shipment [10 CFR 71.91(a)].
b. Records providing evidence of packaging quality shall be maintained for 3 years after the life of the packaging [10 CFR 71.91(d)].
c. Records describing activities affecting packaging quality shall be maintained for 3 years after this Quality Assurance Program Approval is terminated [10 CFR 71.135].
3. Planned and periodic audits of all aspects of the Quality Assurance Program shall be conducted in accordance with written procedures or checklists, by appropriately trained personnel not having direct responsibility in the areas being audited, in accordance with 10 CFR 71.137.
4. This Quality Assurance Program Approval is applicable to packaging and transportation activities conducted

-by:

Diablo Canyon Power Plant and Humboldt Bay

4. This approval is effective upon termination of the Humboldt Bay Power Plant 10 CFR Part 50 License, DPR-7.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION I

SIGNATURE DATE LEIRA CUADRADO, PATRICIA SILVA, CHIEF INSPECTIONS AND OPERATIONS BRANCH DIVISION OF SPENT FUEL MANAGEMENT OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS NRC FORM 311 (10-201907-2015)

Enclosure 2 PG&E Letter DCL-21-056 PG&E Letter DIL-21-006 PG&E Letter HBL-21-015 PG&E Letter HIL-21-003 Proposed NRC Form 311 Quality Assurance Program Approval for Radioactive Material Packages Humboldt Bay ISFSI

NRC FORM 311 U. S. NUCLEAR REGULATORY COMMISSION 1. APPROVAL NUMBER (10-2019)

TBD QUALITY ASSURANCE PROGRAM APPROVAL REVISION NUMBER FOR RADIOACTIVE MATERIAL PACKAGES 0 Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and Title 10, Code of Federal Regulations, Chapter 1, Part 71, and in reliance on statements and representations heretofore made in Item 4 by the organization named in Item 2, the Quality Assurance Program identified in Item 4 is hereby approved. This approval is issued to satisfy the requirements of Section 71.101 of 10 CFR Part 71. This approval is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.

2. NAME Pacific Gas and Electric Company, Humboldt Bay ISFSI STREET ADDRESS 77 Beale Street, Mail Code B32 CITY STATE ZIP CODE 3. DOCKET NUMBER San Francisco CA 94105 TBD
4. QUALITY ASSURANCE PROGRAM APPLICATION DATE(S)

April 17, 2020

5. CONDITIONS
1. Activities conducted with regard to transportation packagings under applicable criteria of 10 CFR Part 72, Subpart G authorized by this approval: procurement, maintenance, repair, and use . All other activities (i.e.,

design, fabrication, assembly, testing, and modification) shall be satisfied by obtaining certifications from packaging suppliers that these activities were conducted in accordance with an NRC-approved Quality Assurance Program. It shall remain the responsibility of the Quality Assurance Program holder that all transportation activities meet the requirements of 10 CFR 71.101.

2. Records shall be maintained in accordance with the provisions of 10 CFR Part 71. Specifically:
a. Records of each shipment of licensed material shall be maintained for 3 years after that shipment [10 CFR 71.91(a)].
b. Records providing evidence of packaging quality shall be maintained for 3 years after the life of the packaging [10 CFR 71.91(d)].
c. Records describing activities affecting packaging quality shall be maintained for 3 years after this Quality Assurance Program Approval is terminated [10 CFR 71.135].
3. Planned and periodic audits of all aspects of the Quality Assurance Program shall be conducted in accordance with written procedures or checklists, by appropriately trained personnel not having direct responsibility in the areas being audited, in accordance with 10 CFR 71.137.
4. This approval is effective upon termination of the Humboldt Bay Power Plant 10 CFR Part 50 License, DPR-7.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION I

SIGNATURE DATE LEIRA CUADRADO, CHIEF INSPECTIONS AND OPERATIONS BRANCH DIVISION OF SPENT FUEL MANAGEMENT OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS NRC FORM 311 (10-2019)