DCL-25-086, Independent Spent Fuel Storage Installation - Proposed Revision to the Quality Assurance Program
| ML25309A160 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/05/2025 |
| From: | Tyman J Pacific Gas & Electric Co |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| DCL-25-086 | |
| Download: ML25309A160 (1) | |
Text
Pacific Gas and Electric,C'Ompany$
PG&E Letter DCL-25-086 Jordan P. Tyman Director Risk and Compliance Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.4423 Jordan.Tyman.@pge.com U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 10 CFR 50.54(a)(4)
Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Independent Spent Fuel Storage Installation Materials License No. SNM-2511, Docket No. 72-26 Proposed Revision to the Quality Assurance Program
References:
- 1. American National Standards Institute/American Nuclear Society (ANSI/ANS), ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," November 20, 2014
- 2. NRC Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 4, dated June 2019
[ADAMS Accession No. ML19101A395]
Dear Commissioners and Staff:
In accordance with the requirements of Title 10, U.S. Code of Federal Regulations (10 CFR) 50.54(a)(4), Pacific Gas and Electric Company (PG&E) hereby requests approval of a revision to the Diablo Canyon Quality Assurance Program Description (QAPD). Specifically, PG&E is proposing to revise the QAPD to reflect the education and work experience requirements for the Radiation Protection Manager position be consistent with current industry standards (References 1 and 2).
The enclosure provides a description and justification for the proposed change, and a basis for concluding the revised QAPD will continue to satisfy the criteria of 10 CFR Part 50 Appendix B. Attachments 1 and 2 to the Enclosure provide markup and retyped pages of the QAPD, respectively.
Per 10 CFR 50.54(a)(4)(iv), PG&E understands that this proposed change "shall be regarded as accepted by the Commission upon receipt of a letter to this effect from the appropriate reviewing office of the Commission or 60 days after submittal to the Commission, whichever occurs first."
Once accepted, PG&E will revise the QAPD within 180 days. In addition, the DCPP Updated Final Safety Analysis Report (UFSAR) will also be revised to reflect the proposed change.
A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk Page 2 PG&E Letter DCL-25-086 PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter. If you have any questions regarding this information, please contact Mr. James Morris, Manager, Regulatory Services, at (805) 545-4609.
Sincerely,
}Lf-Jordan P. Tyman 11/5/2025 Director, Risk and Compliance rntt/51120047-11 Enclosure cc:
cc/enc:
Diablo Distribution Kristina L. Banovac, NRC Project Manager Mahdi 0. Hayes, NRC Senior Resident Inspector Samson S. Lee, NRC Senior Project Manager John D. Monninger, NRC Region IV Administrator A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek Date
Request for NRC Approval of a Proposed Change to the Enclosure PG&E Letter DCL-25-086 Diablo Canyon Quality Assurance Program Description In Accordance with 10 CFR 50.54(a)(4)
Request for NRC Approval of a Proposed Change to the Enclosure PG&E Letter DCL-25-086 Diablo Canyon Quality Assurance Program Description In Accordance with 10 CFR 50.54(a)(4)
TABLE OF CONTENTS
- 1.
SUMMARY
DESCRIPTION................................................................................ 2
- 2.
DESCRIPTION OF THE CHANGE...................................................................... 2
- 3.
JUSTIFICATION FOR THE PROPOSED CHANGE............................................. 2
- 4.
CRITERIA IN 10 CFR 50 APPENDIX B............................................................... 3
- 5.
PRECEDENT...................................................................................................... 3
- 6.
CONCLUSION.................................................................................................... 3
- 7.
REFERENCES................................................................................................... 3 Page 1 of 3
Request for NRC Approval of a Proposed Change to the Enclosure PG&E Letter DCL-25-086 Diablo Canyon Quality Assurance Program Description In Accordance with 10 CFR 50.54(a)(4)
- 1.
SUMMARY
DESCRIPTION In accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) 50.54(a)(4), Pacific Gas and Electric Company (PG&E) hereby requests approval of a revision to the Diablo Canyon Quality Assurance Program Description (referenced as QAPD in this document). Specifically, PG&E is proposing to revise the QAPD to reflect the education and work experience requirements for the Radiation Protection Manager (RPM) position be consistent with current industry standards (References 1 and 2).
- 2.
DESCRIPTION OF THE CHANGE The proposed changes will revise the QAPD to reflect the education and work experience requirements for the RPM position to be consistent with the current industry standards (References 1 and 2). Specifically, Section 2.5, Selection and Training of Nuclear Power Plant Personnel, of the QAPD will be revised to reflect the revised qualification requirements, as shown below:
(a) The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 2, April 1987, Revision 4, June 2019, for radiation protection manager.
In addition, Appendix B, Current Regulatory Requirements and PG&E Commitments Pertaining to the Quality Assurance Program, of the QAPD will also be revised to reflect the revised qualification requirements. Attachment 1 provides the marked-up pages of QAPD showing the proposed changes, and Attachment 2 provides the retyped pages.
- 3.
JUSTIFICATION FOR THE PROPOSED CHANGE The proposed change to the qualification requirements for the RPM position will align Diablo Canyon Power Plant (DCPP) with the current industry standards that have been endorsed by the NRC. That is, DCPP will meet the qualification requirements for the RPM position in accordance with the American National Standards Institute/American Nuclear Society (ANSI/ANS), ANSI/ANS 3.1-2014 (Reference 1) as endorsed by Regulatory Guide 1.8, Revision 4 (Reference 2). Currently, DCPP meets the qualification requirements for the RPM position in accordance with ANSI/ANS 3.1-1981 (Reference 3) as endorsed by Regulatory Guide 1.8, Revision 2 (Reference 4).
Page 2 of 3
- 4.
CRITERIA IN 10 CFR 50 APPENDIX B Enclosure PG&E Letter DCL-25-086 The proposed changes continue to satisfy the criteria of 10 CFR 50 Appendix B.
Specifically, the RPM will meet or exceed the qualification requirements specified in ANSI/ANS-3.1-2014 (Reference 1) as endorsed by Regulatory Guide 1.8, Revision 4 (Reference 2). The RPM will remain the individual responsible for implementation of the radiological protection program. Adoption of Regulatory Guide 1.8, Revision 4 (Reference 2) relative to RPM qualification requirements will ensure the RPM continues to be fully qualified to perform this task. Therefore, the revised QAPD continues to satisfy the criteria of 10 CFR 50 Appendix B.
- 5.
PRECEDENT In January 2023, Entergy submitted a similar revision to the Entergy Quality Assurance Program Manual for NRC review and approval (ADAMS Accession No. ML23018A220). Specifically, Entergy requested NRC approval to revise the education and work experience requirements for Radiation Protection Technicians to be consistent with current industry standards. Entergy received NRC approval in May 2023 (ADAMS Accession No. ML23117A217).
- 6.
CONCLUSION The proposed change is compliant with, and continues to satisfy, the criteria of 10 CFR 50 Appendix B, as incorporated in the QAPD.
- 7.
REFERENCES
- 1. American National Standards Institute/American Nuclear Society (ANSI/ANS), ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," November 20, 2014.
- 2. Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 4, June 2019 [ADAMS Accession No. ML19101A395]
- 3. ANSI/ANS, ANSI/ANS-3.1-1981, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," December 17, 1981.
- 4. Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Revision 2, April 1987 [ADAMS Accession No. ML003739928]
Page 3 of 3
QAPD Page Markups Enclosure PG&E Letter DCL-25-086
Diablo Canyon Quality Assurance Program Description and authority provisions of this QA Program section. Copies shall be provided to the CNO, and to NSOC.
2.5 Selection and Training of Nuclear Power Plant Personnel Staffing, training, and qualification is the single most important variable which can be controlled to achieve the nuclear generation goals of maximizing plant safety, efficiency, and reliability. Therefore, it is the policy of nuclear generation that personnel at all levels shall be qualified for the positions they fill and receive the necessary training and retraining to enable them to perform at the highest level of efficiency. Nuclear generation personnel shall meet or exceed the minimum qualifications of ANSI/ANS 3.1 1978, for comparable positions, with the following exceptions [Reference 2]:
(a) The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 2, April 1987, Revision 4, June 2019, for radiation protection manager.
(b) The operations manager shall meet or exceed the minimum qualifications as specified in Technical Specification 5.2.2.e.
(c) The licensed Reactor Operators and Senior Reactor Operators shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3, May 2000 with the exceptions clarified in the current revision to the Operator Licensing Examination Standards for Power Reactors, NUREG-1021, Section ES-202 [Reference 1].
(d) For the purpose of 10 CFR 55.4, a licensed SRO and a licensed RO are those individuals who, in addition to meeting the requirements specified in (c), perform the functions described in 10 CFR 50.54(m).
(e) The radiation protection technicians shall meet or exceed the minimum qualification of ANSI/ANS 3.1-2014 as endorsed by Regulatory Guide 1.8, revision 4, June 2019.
NOTE: These exceptions are also listed in Appendix B, Current Regulatory Requirements and PG&E Commitments Pertaining to the Quality Assurance Program, where all pertinent commitments are captured.
24
Diablo Canyon Quality Assurance Program Description APPENDIX B CURRENT REGULATORY REQUIREMENTS AND PG&E COMMITMENTS PERTAINING TO THE QUALITY ASSURANCE PROGRAM The Quality Assurance Program for DCPP and the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) described in this document, program directives, and administrative procedures complies with the requirements set forth in the Code of Federal Regulations.
In addition, it complies with the regulatory documents and industry standards listed below.
Changes to this list are not made without the review and concurrence of the Director, Quality Verification (QV).
Date Reg. Guides (Rev)
Standard No.
Rev.
Title/Subject Exceptions 1.8 2/79 ANSI/ANS 3.1 (Pro-posed Rev. 2) 1978 Personnel Selection and Training 57 Except that for the Quality Verification Director, the one year of qualifying nuclear power plant experience in the overall implementation of the Quality Assurance program can be obtained outside the Quality Assurance organizations.
Except certain personnel are trained and qualified to the Institute of Nuclear Power Operations (INPO) criteria as described in Chapter 13.
Except that a retraining and replacement training program for the plant staff meets or exceeds the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and 10 CFR Part 55. This exception is based on the NRC letter to PG&E, dated July 19, 1989, issuing License Amendments No. 43 and 42.
Except that the Radiation Protection Manager's qualifications shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 2,
.Aipril 1987Revision 4, June 2019, for the Radiation Protection Manager.
QAPD Retyped Pages Enclosure PG&E Letter DCL-25-086
Diablo Canyon Quality Assurance Program Description and authority provisions of this QA Program section. Copies shall be provided to the CNO, and to NSOC.
2.5 Selection and Training of Nuclear Power Plant Personnel Staffing, training, and qualification is the single most important variable which can be controlled to achieve the nuclear generation goals of maximizing plant safety, efficiency, and reliability. Therefore, it is the policy of nuclear generation that personnel at all levels shall be qualified for the positions they fill and receive the necessary training and retraining to enable them to perform at the highest level of efficiency. Nuclear generation personnel shall meet or exceed the minimum qualifications of ANSI/ANS 3.1 1978, for comparable positions, with the following exceptions [Reference 2]:
(a) The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 4, June 2019, for radiation protection manager.
(b) The operations manager shall meet or exceed the minimum qualifications as specified in Technical Specification 5.2.2.e.
(c) The licensed Reactor Operators and Senior Reactor Operators shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1993 as endorsed by Regulatory Guide 1.8, Revision 3, May 2000 with the exceptions clarified in the current revision to the Operator Licensing Examination Standards for Power Reactors, NUREG-1021, Section ES-202 [Reference 1].
(d) For the purpose of 10 CFR 55.4, a licensed SRO and a licensed RO are those individuals who, in addition to meeting the requirements specified in (c), perform the functions described in 10 CFR 50.54(m).
(e) The radiation protection technicians shall meet or exceed the minimum qualification of ANSI/ANS 3.1-2014 as endorsed by Regulatory Guide 1.8, revision 4, June 2019.
NOTE: These exceptions are also listed in Appendix B, Current Regulatory Requirements and PG&E Commitments Pertaining to the Quality Assurance Program, where all pertinent commitments are captured.
24
Diablo Canyon Quality Assurance Program Description APPENDIX B CURRENT REGULATORY REQUIREMENTS AND PG&E COMMITMENTS PERTAINING TO THE QUALITY ASSURANCE PROGRAM The Quality Assurance Program for DCPP and the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) described in this document, program directives, and administrative procedures complies with the requirements set forth in the Code of Federal Regulations.
In addition, it complies with the regulatory documents and industry standards listed below.
Changes to this list are not made without the review and concurrence of the Director, Quality Verification (QV).
Date Reg. Guides (Rev)
Standard No.
Rev.
Title/Subject Exceptions 1.8 2/79 ANSI/ANS 3.1 (Pro-posed Rev. 2) 1978 Personnel Selection and Training 57 Except that for the Quality Verification Director, the one year of qualifying nuclear power plant experience in the overall implementation of the Quality Assurance program can be obtained outside the Quality Assurance organizations.
Except certain personnel are trained and qualified to the Institute of Nuclear Power Operations (INPO) criteria as described in Chapter 13.
Except that a retraining and replacement training program for the plant staff meets or exceeds the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and 10 CFR Part 55. This exception is based on the NRC letter to PG&E, dated July 19, 1989, issuing License Amendments No. 43 and 42.
Except that the Radiation Protection Manager's qualifications shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 4, June 2019, for the Radiation Protection Manager.