HBL-16-001, Revision 11 to the Defueled Safety Analysis Report and Revision 33 to the Quality Assurance Plan

Revision 11 to the Defueled Safety Analysis Report and Revision 33 to the Quality Assurance Plan

ML16029A508
Person / Time
Site:	Humboldt Bay
Issue date:	01/29/2016
From:	Halpin E Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HBL-16-001
Download: ML16029A508 (82)

Text

Pacific Gas and Electric Company Edward D. Halpin Diablo Canyon Power Plant Senior Vice President P.O. Box 56 Avila Beach, CA 93424 Power Generation and Chief Nuclear Officer 805.545.4100 E-Mail: El H8@pge.com January 29, 2016 PG&E Letter HBL-16-001 U.S. Nuclear Regulatory Commission 10 CFR 50.71 ATTN: Document Control Desk 10 CFR 50.54 Washington, DC 20555-0001 Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit 3 Revision 11 to the Defueled Safety Analysis Report and Revision 33 to the Humboldt Bay Quality Assurance Plan

Dear Commissioners and Staff:

Pursuant to 10 CFR 50.71(e), Pacific Gas and Electric Company (PG&E) is submitting the Humboldt Bay Power Plant, Unit 3 Defueled Safety Analysis Report (DSAR), Revision 11, in accordance with 10 CFR 50.4(b)(6). The changes contained in Revision 11 of the DSAR include changes made under the provisions of 10 CFR 50.59 since DSAR, Revision 10, was submitted to the NRC in PG&E Letter HBL-14-003, dated February 4, 2014, and reflect the current plant configuration and organization through November 20, 2015. contains the DSAR, Revision 11, which replaces Revision 10 in its entirety. Revision bars are shown in the margins with an identifying revision change number.

PG&E is also submitting Revision 33 of the Humboldt Bay Quality Assurance Plan (QAP) in accordance with 10 CFR 50.54(a)(3). Enclosure 2 contains Revision 33 to the Humboldt Bay QAP in its entirety. Revision 31 was submitted to the NRC in PG&E Letter HBL-14-003, dated February 4, 2014, with DSAR Revision 10. Revision bars shown in the margins of QAP Revision 33 indicate changes made between QAP Revisions 32 and 33. Enclosure 3 contains QAP Revision 32 in its entirety. Revision bars shown in the margins of QAP Revision 32 indicate changes made between QAP Revisions 31 and 32.

PG&E makes no new or revised regulatory commitments (as defined in NEI 99-

04) in this letter.

If you have any questions regarding this submittal, please contact Mr. Hossein Hamzehee at (805) 545-4720.

Document Control Desk PG&E Letter HBL-16-001 January 29, 2016 Page 2 I state under penalty of perjury that the foregoing is true and correct.

Executed on January 29, 2016.

Sincerely,

?J£?~

Edward D. Halpin Senior Vice President - Power Generation and Chief Nuclear Officer Enclosures cc: Marc L. Dapas, NRC Region IV Administrator John B. Hickman, NRC Project Manager HBPP Humboldt Distribution

Enclosure 1 PG&E Letter HBL-16-001 HUMBOLDT BAY POWER PLANT (HBPP) UNIT 3 DEFUELED SAFETY ANAYLSIS REPORT, REVISION 11

DE FUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section CHAPTER 1. INTRODUCTION AND

1.1 INTRODUCTION

1-1 1.2 SITE CHARACTERISTICS 1-2 1.3 QUALITY STANDARDS 1-2 1.4 FIRE PROTECTION 1-2 1.5 CONTROL OF RELEASES OF RADIOACTIVE MATERIALS 1-2 1.6 PERSONNEL SELECTION AND TRAINING 1-3 1.7 REPORTING OF OPERATING INFORMATION 1-3 1.8 MEASURING AND REPORT OF EFFLUENTS FROM NUCLEAR POWER PLANTS 1-3 1.9 IDENTIFICATION OF AGENTS AND CONTRACTORS 1-4 1.10 CONCLUSIONS 1-4 CHAPTER 2. SITE AND ENVIRONMENT 2.1

SUMMARY

2-1 2.2 SITE AND ADJACENT AREAS 2-1 2.3 METEOROLOGY 2-1 2.4 HYDROLOGY 2-1 2.5 ENVIRONMENTAL MONITORING PROGRAM 2-2 CHAPTER3. STRUCTURES 3.1 REFUELING BUILDING 3-1 3.2 RADWASTE TREATMENT FACILITIES 3-1 REVISION 11

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section Title Page CHAPTER 4. AUXILIARY SYSTEMS 4.1 GENERAL 4-1 4.2 VENTILATION SYSTEMS 4-1 4.3 WASTE DISPOSAL SYSTEMS 4-1 4.4 FIRE PROTECTION PROGRAM 4-1 I CR 11-02 CHAPTER 5. RADIOACTIVE WASTE AND RADIATION PROTECTION 5.1 RADIONUCLIDE INVENTORY 5-1 5.2 LIQUID WASTE TREATMENT SYSTEMS 5-1 5.3 GASEOUS WASTE MANAGEMENT 5-1 5.4 SOLID WASTE MANAGEMENT 5-1 5.5 OFF-SITE DOSE CALCULATION MANUAL 5-1 5.5.1 Liquid Discharge Pathway 5-1 5.5.2 Gaseous Discharge Pathway 5-2 5.6 RADIATION PROTECTION PROGRAM 5-2 5.6.1 Organization 5-2 5.6.2 Equipment and Instrumentation 5-2 5.6.3 Radiation Protection Procedures 5-2 5.6.4 Personnel Exposure Reporting 5-2 CHAPTER 6. CONDUCT OF OPERATIONS 6.1 PLANT ORGANIZATION 6-1 6.2 PERSONNEL TRAINING 6-1 6.3 EMERGENCY PLAN 6-1 REVISION 11

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section 6.4 PLANT PROCEDURES 6-1 6.5 RECORDS 6-1 CHAPTER 7. SAFETY ANALYSIS 7.1 DECOMMISSIONING ACCIDENT ANALYSIS 7-1 CR 11-02 iii REVISION 11

DSAR CHAPTER INTRODUCTION AND

1.1 INTRODUCTION

In 1984 PG&E submitted the Humboldt Bay Power Plant, Unit 3 (referred to as either HBPP, Unit 3, or the Humboldt Bay nuclear facility) SAFSTOR Decommissioning Plan (SOP) in support of the application to amend the HBPP Operating License to a Possession-Only License. As a result of the 1996 NRC decommissioning rule, the SOP was considered to be a Post-Shutdown Decommissioning Activities Report (PSDAR) because it contained information related to decommissioning activities . It was also considered to be a Final Safety Analysis Report (FSAR) because it contained information such as plant description, site characterization and accident analysis. In compliance with the 1996 NRC decommissioning rule, PG&E submitted a PSDAR in February 1998 to provide a general overview of proposed decommissioning activities. As a result, the SOP will focus on providing the type of information contained in an FSAR and will contain less information related to decommissioning activities. Thus, the SOP has been more appropriately renamed the Defueled Safety Analysis Report (DSAR) .

In addition to the DSAR and PSDAR, PG&E has submitted other documents to the NRC in accordance with 10 CFR 50 that constitute the licensing basis for H BPP. These other documents include: (1) License Amendments, (2) revised Technical Specifications, (3)

CR License Termination Plan. 11 -02 This DSAR reflects the changes made following Humboldt Bay's(HB's) decision to decommission Unit 3 in June 1983, as well as License Condition 2.8.1 that allow Pacific Gas and Electric Company (PG&E) "... to take actions necessary to decommission and decontaminate this facility." PG&E will update the DSAR in accordance with the methodology specified in 10 CFR 50.59 and 10 CFR 50.71 (e), submitting updates at least every two years. Revisions to the DSAR are numbered, starting with Revision 1.

The purpose of the DSAR is to provide a Safety Analysis Report that provides assurance that based on the decommissioning activities and the administrative controls and programs in place during decommissioning, no undue risk to the public health and safety will occur during normal operation and postulated accident conditions.

The following provides a history of major plant operation and licensing-related actions :

1. Unit 3 achieved initial criticality on February 16, 1963, and began commercial operation in August 1963.

2. On July 2, 1976, Unit 3 was shut down for annual refueling and to conduct seismic modifications. Seismic and geologic studies were in progress.

3 In December 1980 it became apparent that the cost of completing required backfits might have made it uneconomical to restart the unit. Work was suspended at that time awaiting further guidance regarding backfitting requirements.

1-1 REVISION 11

4 In 1983, updated economic analyses indicated that restarting Unit 3 would probably not be economical, and in June 1983 PG&E announced its intention to decommission the unit.

5 On December 11, 2008, PG&E completed the transfer of spent fuel from the spent fuel pool into the ISFSI.

1.2 SITE CHARACTERISTICS The Humboldt Bay nuclear facility is located about four miles true southwest of the city of Eureka, Humboldt County, California, and consists of 142.9 acres of land.

Since there are no design basis accidents that could approach 10 CFR 100 limits, no Safety Features are necessary to keep public exposures below the 10 CFR 100 dose limits under worst case postulated accident conditions.

1.3 QUALITY STANDARDS The Humboldt Bay Quality Assurance Plan (HBQAP) describes the 10 CFR 50, Appendix B quality assurance program for important-to-safety SSCs and activities. Management and CR administrative program requirements that apply to Unit 3 are subject to administrative 11-01 controls which demonstrate compliance with regulatory requirements.

1.4 FIRE PROTECTION The Fire Prevention Program describes the overall fire protection program in place at HB.

DSAR Chapter 4 also discusses the fire protection system.

1.5 CONTROL OF RELEASES OF RADIOACTIVE MATERIALS The radiological administrative control programs at Humboldt Bay effectively control the collection, segregation, processing, packaging, and discharge or disposal of radioactive solids and liquids. These systems and programs function to control releases to as low as is reasonably achievable levels and are designed to give reasonable assurance that the numerical guidelines defined in 10 CFR 50.34a, 50.36a, and 10 CFR 50, Appendix I, and contained in the Off-site Dose Calculation Manual (ODCM) will be met.

Modular HEPA ventilation system(s) are used for interim airborne radioactivity control, if CR required. HEPA filter loading is administratively controlled to limit the potential offsite 11-02 exposure.

Interim storage buildings are provided for packaged low-level radioactive waste. Potential release pathways of radionuclides in particulate form are controlled and monitored in accordance with the ODCM.

1-2 REVISION 11

Liquid and solid wastes are normally processed in batches for off-site disposal. Gaseous effluents (particulates and tritium) could be released during dismantlement activities. During this time, samples will be taken from temporary monitored release points in accordance with the ODCM.

1.6 PERSONNEL SELECTION AND TRAINING Plant personnel meet the minimum education and experience standards specified in ANSI N18.1-1971, "Standard for Selection and Training of Personnel for Nuclear Power Plants."

Retraining and replacement training meets or exceeds the requirements and Manager shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2, April 1987.

DSAR Chapter 6 discusses training programs for staff personnel. Records of the CR 11-02 qualifications, training, and retraining of each member of the plant organization are maintained in accordance with established programs.

In accordance with 10 CFR Part 19, personnel are provided radiological training commensurate with the hazards to which they may be exposed while working at HBPP.

1.7 REPORTING OF OPERATING INFORMATION The Humboldt Bay Quality Assurance Plan specifies the annual routine reporting requirements.

Personnel radiation exposure and monitoring procedures have been established and reports CR are submitted, as required. 11 -02 Reporting abnormal events in Licensee Event Reports and Special Reports is performed by site staff in accordance with established procedures and applicable regulatory requirements.

Established procedures ensure significant events are quickly brought to the attention of management and acted upon within the allowed reporting period.

1.8 MEASURING AND REPORT OF EFFLUENT FROM NUCLEAR POWER PLANTS The measuring and reporting of radiological effluents from Humboldt Bay complies with the requirements of Regulatory Guide 1.21 and the ODCM.

Annual reports summarizing the quantity of radionuclides released from the site are submitted to the NRC in accordance with 10 CFR 50.36a(a)(2). This summary data is comprised of radioactive release information collected in accordance with the ODCM.

1-3 REVISION 11

1.9 IDENTIFICATION OF AGENTS AND CONTRACTORS PG&E is responsible for control of agents and contractors used during the decommissioning the Humboldt Bay facility.

1.10 CONCLUSIONS The personnel assembled to decommission Humboldt Bay facility are capable of performing their required project function. The health and safety of the public and plant personnel are among the primary concerns during decommissioning.

The Humboldt Bay facility can be decommissioned in a safe manner and PG&E is qualified to decommission this nuclear facility in accordance with all applicable laws and regulations and in a manner satisfactory to the NRC, the public, and itself.

1-4 REVISION 11

DSAR CHAPTER 2 -SITE AND ENVIRONMENT 2.1

SUMMARY

The Humboldt Bay nuclear facility lies in the Northern California Coast Ranges geomorphic province. This province consists of a system of longitudinal mountain ranges (2000 to 4000 foot elevations with occasional 6000 feet peaks) and valleys with a trend of N 30 degrees to 40 degrees W. Terrain of the site varies from submerged and low tidal land, protected by dikes and tide gates, to a high precipitous bluff along the southwestern boundary.

Elevations range from approximately -3 feet to +75 feet based on a datum of the mean lower low water (MLLW) level.

Soils in the immediate vicinity of the site consist of sand and alluvial soil and strata of the Hookton and Carlotta sedimentary formations. These formations are primarily consolidated sands, gravels, and clays and conglomerates with good engineering properties.

Figure 2-1 shows the general location of the Humboldt Bay site. Figure 2-2 provides a more specific layout of the PG&E-owned land and a general layout of the site.

2.2 SITE AND ADJACENT AREAS The land in the general vicinity around the Humboldt Bay site is presently low density rural housing and is used primarily as grazing areas.

Within a 15-mile radius of the site there are five cities or communities (Eureka, Fortuna, Arcata, King Salmon, and Fields Landing). Activities in the area immediately surrounding the site are not expected to change extensively.

King Salmon Avenue runs along the west side of the site boundary and connects with US Highway 101 which runs along the southern boundary of the site. The Southern Pacific Railroad runs roughly parallel to Highway 101 but is out of service.

PG&E is operating Humboldt Bay Generating Station (HBGS), a new dual fueled (natural gas and diesel) power plant, on the Humboldt Bay site adjacent to the south side of the facility.

The Humboldt Bay ISFSI is located on site approximately 600 feet northwest of the HBGS.

2.3 METEROLOGY The Humboldt Bay facility uses conservative default atmospheric dispersion and deposition factors in its evaluations of off-site gaseous releases to calculate the doses that result from normal gaseous effluent and abnormal or accident release conditions.

2.4 HYDROLOGY The surface runoff from the site is directed into drains eventually discharging into Humboldt Bay. Outside the area served by the plant drain system, surface runoff drains into Buhne Slough, the natural drainage for the area, which drains into Humboldt Bay.

The nearest streams to the site are Salmon Creek and Elk River, which are within a mile south and north of the site, respectively, and which discharge into Humboldt Bay. These streams are used for watering livestock, but are not used as a potable water supply.

2-1 REVISION 11

The Mad River flows west approximately 13 -15 miles northeast of the site. The Ruth reservoir, the source of the city's water supply, is located on this river.

To the south, the Eel River discharges to the Pacific Ocean 8-10 miles from HB. This river is not used for potable water within 25 miles of HB.

Groundwater elevation in the area near the bay is similar to sea level and may be somewhat affected by tidal action. This elevation is approximately 12 feet below the plant floor elevation.

2.5 ENVIRONMENTAL MONITORING PROGRAM The environmental monitoring of the environment during decommissioning is delineated in the Off-site Dose Calculation Manual.

Results of the Humboldt Bay environmental monitoring are available to the State of California and federal agencies that have a direct interest and concern in these matters.

2-2 REVISION 11

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Figure 2-2 REVISION 11

DSAR CHAPTER 3 -STRUCTURES 3.1 REFUELING BUILDING Once the majority of radioactivity is removed from within the Refueling Building, the structure will be removed.

3.2 RADWASTE TREATMENT FACILITIES Temporary liquid radioactive waste processing capability is available. Temporary buildings CR 11-02 are used to store low level radwaste packages awaiting shipment. As decommissioning progresses, these structures, systems and components will be removed from service and removed.

3-1 REVISION 11

DSAR CHAPTER 4 -AUXILIARY SYSTEMS 4.1 GENERAL The systems considered in this DSAR Chapter are:

1. Ventilation Systems

2. Waste Disposal Systems

3. Fire Protection Systems Design changes, modifications, and additions to existing systems and components are reviewed for compliance with the requirements of 10 CFR 50.59 "Changes, Tests, and Experiments."

4.2 VENTILATION SYSTEMS Modular HEPA ventilation systems are used, as required, to monitor gaseous effluents CR (particulate). Gaseous effluent is sampled for radioactivity in accordance with the Offsite 11-02 Dose Calculation Manual (ODCM).

4.3 WASTE DISPOSAL SYSTEMS CR Temporary waste disposal systems are used to support the remaining decommissioning 11-02 activities.

4.4 FIRE PROTECTION PROGRAM CR 11-02 The fire protection program describes the organizational requirements, design features, operational requirements, compensatory measures, testing requirements, and off-site fire fighting assistance coordination requirements that collectively define Unit 3's fire protection program. Fire loading, ignition sources, and combustible materials are significantly reduced and the possibility for a major fire is greatly diminished from the unit's operational phase. As decommissioning progresses, the requirements for fire suppression, detection and alarm systems will be removed.

Offsite firefighting capability is provided by the local fire department.

4-1 REVISION 11

DSAR CHAPTER 5- RADIOACTIVE WASTE AND RADIATION PROTECTION 5.1 RADIONUCLIDE INVENTORY The remaining radioactive source term at the defueled Unit 3 reactor site has been greatly cR reduced by radioactive decay and spent fuel removal. Administrative and engineering 11-02 controls are utilized to limit airborne radioactivity exposure to the workers and general public during decontamination and dismantlement.

5.2 LIQUID WASTE TREATMENT SYSTEMS A temporary wastewater disposal system, such as tanks, pumps, piping, and processing CR equipment are used, as required, to process waste water prior to release or shipment off 11-02 site.

5.3 GASEOUS WASTE MANAGEMENT Modular ventilation systems are used, as required, to monitor gaseous effluents (particulate). CR 11-02 5.4 SOLID WASTE MANAGEMENT Solid radioactive wastes are collected and processed on or off site and shipped to a licensed and/or permitted burial site for disposal. Off-site secondary processors may be used for volume reduction or further processing prior to disposal. Solid wastes are packaged in containers which conform to Department of Transportation (DOT) requirements (49 CFR) for transport to a licensed disposal facility.

The total curie content and major radionuclide composition by waste type are reported in the Radioactive Effluent Release Report required pursuant to 10 CFR 50.36a.

5.5 OFF-SITE DOSE CALCULATION MANUAL The ODCM provides the information and methodologies used to evaluate the impact of radiological liquid and gaseous effluent discharged from the plant.

The ODCM is used to demonstrate that the plant complies with the requirements of 40 CFR 190 and 10 CFR 20, and the dose guidelines of 10 CFR 50, Appendix I. Calculations for continuous airborne releases use default atmospheric diffusion coefficients and gaseous effluent flow rates. Exposures due to plant decommissioning are estimated by calculation methods specified in the ODCM.

5.5.1 Liquid Discharge Pathway Discharge of processed radioactive effluents to Humboldt Bay was terminated . Process water and liquids that exceed 10 times 10 CFR 20, Appendix B, Table 2, Column 2 are CR manifested and disposed of at a licensed disposal site. Storm water and ground water during 11-02 decommissioning is treated and released using the Ground Water Treatment System (GWTS) in accordance with the Storm Water Pollution Prevention Plan and the associated NPDES permit.

5-1 REVISION 11

5.5.2 Gaseous Discharge Pathway Release pathways have been and are expected to continue to be very small; well within the 10 CFR 50, Appendix I dose guidelines and 10 CFR 20 concentration limits. Modular HEPA CR 11-02 ventilation systems are used, as required, to monitor gaseous effluents during decommissioning.

5.6 RADIATION PROTECTION PROGRAM 5.6.1 Organization The HB Director has the overall responsibility for radiological protection for all onsite activities, including assurance that ALARA policies are carried out at the facility. The Radiation Protection Manager is responsible for specifying radiation protection requirements for work activities. The HBPP organization and reporting chain are specified in administrative CR 11-01 procedures.

5.6.2 Equipment and Instrumentation Personnel Protective Equipment Anti-contamination clothing is furnished and worn as necessary to protect personnel against CR contact with radioactive contamination. Respiratory protective equipment is available for the 11-02 protection of personnel against airborne radioactive contamination.

Radiation Protection Instrumentation A variety of instruments are used to cover the entire spectrum of radiation measurements at Humboldt Bay.

5.6.3 Radiation Protection Procedures The radiation protection program is organized to meet the requirements of 10 CFR 20. CR 11-02 5.6.4 Personnel Exposure Reporting An annual exposure monitoring report for individuals is submitted in accordance with 10 CFR 20.2206(b).

5-2 REVISION 11

DSAR CHAPTER 6 - CONDUCT OF OPERATIONS 6.1 PLANT ORGANIZATION The details of the PG&E organization that oversees the activities at the Humboldt Bay CR nuclear facility are discussed in administrative procedures. The HB Director heads the on- 11-01 site Humboldt Bay facility organization and directs the activities of the functional on-site departments.

6.2 PERSONNEL TRAINING Plant personnel are selected and trained for their assigned duties, with each department head being responsible for conducting department training that meets the applicable requirements and standards.

Radiological training is provided to all personnel commensurate to the hazards to which an individual will be exposed. Training is conducted and documented in accordance with the training program.

6.3 EMERGENCY PLAN CR Radiological source terms which may result in declaration of a radiological emergency are 11-02 eliminated or administratively controlled to limit potential exposure beyond the site boundary.

6.4 PLANT PROCEDURES The HB Administrative Procedures (HBAPs) define and implement administrative requirements or activities involving inter-departmental processes and administrative responsibilities. Procedure hierarchy, preparation, review, approval, revision, and control are established in accordance with the applicable HBAPs. CR 11-01 6.5 RECORDS CR Records are maintained as described in administrative procedures. 11-01 6-1 REVISION 11

DSAR CHAPTER 7 - SAFETY ANALYSIS 7.1 DECOMMISSIONING ACCIDENT ANALYSIS There are no postulated decommissioning accidents with potential radiological impacts to CR the environment. The remaining radioactive source terms at the defueled Unit 3 reactor site 11-02 have been eliminated or are administratively controlled to mitigate the postulated event precursors.

7-1 REVISION 11

Enclosure 2 PG&E Letter HBL-16-001 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

VOLUME 4, REVISION 33

Nuclear Power Generation NUMBER L-4 VOLUME 4 Humboldt Bay REVISION 33 EFFEC DATE 11-20-15 Power Plant PAGE 1 ofl TITLE APPROVED BY HUMBOLDT BAY QUALITY ORIGINAL SIGNED 10-9-15 ASSURANCE PLAN (HBQAP)

DIRECTOR/PLANT MANAGER I DATE HB NUCLEAR (Procedure Classification - Quality Related)

1.0 DESCRIPTION

This document describes the Quality Assurance Pian to be applied to Humboldt Bay Power Plant Unit 3 during decommissioning, and includes Humboldt Bay Independent Spent Fuel Storage Installation (HB ISFSI) activHies. The HBQAP satisfies the requirements of 10 CFR 50 Appendix B, and 10 CFR 72 Subpatt G. In addition, NRC Approval No. 202, Revision 8 "Quality Assurance Program for Radioactive Material Packages" has approved the HBQAP as satisfying the provisions of 10 CFR 71 subpart H for the procurement, maintenance, repair and use of radioactive materials transpmt packages.

2.0 ATIACHMENTS 2.1 Humboldt Bay Quality Assurance Plan (HBQAP), Revision 33.

3.0 RESPONSIBLE ORGANIZATION Director, Quality

L-4 Attachment 2.1 Rev.33 Page 1 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

TABLE OF CONTENTS Section Title Page INTRODUCTION 2 1.0 ORGANIZATION 3 2.0 QUALITY ASSURANCE PROGRAM 9 3.0 DESIGN CONTROL 11 4.0 PROCUREMENT DOCUMENT CONTROL 12 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 13 6.0 DOCUMENT CONTROL 14 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 15 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND CO:MPONENTS 16 9.0 SPECIAL PROCESSES 17 10.0 INSPECTION 18 11.0 TEST CONTROL 19 12.0 CONTROL OF :MEASURING AND TEST EQUJPMENT 20 13.0 HANDLING, STORAGE, AND SHIPPING

• 21 14.0 INSPECTION, TEST, AND OPERATING STATUS 22 15.0 CONTROL OF NONCONFORMING CONDITIONS 23 16.0 CORRECTIVE ACTION 24 17.0 QUALITY ASSURANCE RECORDS 25 18.0 AUDITS 26 APPENDIX A APPLICABLE STRUCTURES, SYSTEMS, AND COMPONENTS 27 B ADMINISTRATIVE CONTROLS 28

L-4 Attachment 2.1 Rev. 33 Page 2 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

INTRODUCTION Pacific Gas and Electric (PG&E) has established and is implementing a comprehensive Quality Assurance Progmm for Humboldt Bay Power Plant Unit 3 (HBPP Unit 3) and Humboldt Bay _

Independent Spent Fuel Storage Installation (HB ISFSI) to assure compliance with established regulatory requirements set forth by the Nuclear Regulatozy Commission (NRC). The Quality Assurance Program is described in this Humboldt Bay Quality Assurance Plan (HBQAP).

The Humboldt Bay QA Program consists of the HBQAP and implementing procedures and instructions. The HBQAP describes the responsibilities for implementing quality requirements; establishing and maintaining the QA Program; and assessing the performance of activities subject to theHBQAP.

The HBQAP is a comprehensive statement of the quality assurance controls governing the Important to Safety (ITS) Stntctures Systems and Components (SSC). The HBQAP describes the organizational structure, functional responsibilities, levels of authority, line of communication, and inte1faces. The HBQAP satisfies the requirements oflO CFR50 Appendix B> 10 CFR 71 SubpartH and 10 CFR 72 Subpart G. The requirements for management and administrative controls are described in appendix B of this HBQAP.

The requirements and commitments contained in the HBQAP are mandatmy and must be implemented, enforced, and adhered to by all individuals and organizations petfonning activities affecting quality. Workers are encouraged to actively participate in the continued improvement and implementation of the HBQAP. Any necessaty ch~ges should be pr01nptly communicated and implemented.

The implementation of the requirements of the HBQAP is perfonned in a graded approach commensurate with any items or activities importance to safety. This graded approach is applicable to ITS SSCs and is responsive to NRC Regulatmy Guide 7.1 0.

TI1e HBQAP is implemented through the use of approved procedures (i.e. policies, procedures, manuals, instructions, or other documents) that provide written guidance for the control of ITS items and activities. The HBQAP also provides for development of documentation to demonstrate objective .

evidence of compliance with the stated requirements.

L-4 Attachment 2.1 Rev. 33 Page 3 of29 1.0 ORGANIZATION PG&E~s efforts are to assure the quality and safety of the decommissioning of the HBPP Unit 3, packaging and transportation of radioactive material and the operation and maintenance of the HB ISFSI utilizing the HBQAP. The progratn is organized in a structured manner with clearly defined levels of authority, assignments of responsibility and lines of communication.

Assignment of the responsibility for an item or activity includes responsibility for its quality. The Quality Organization provides independent oversight of quality activities and maintains lines of communication with Senior Management.

PG&E has assumed full responsibility for the establishment and execution of the HBQAP prescribed herein, programs and administrative procedm*es. The work of executing selected portions of the HBQAP may be delegated to organizations externa1 to PG&E; however, in all such instances, PG&E retains overall responsibility.

Specific responsibilities pertaining to quality assurance matters are assigned by the HBQAP and its implementing procedures *and instructions to various individuals throughout PG&E. Jn each instance, the assignment of a responsibility to an individual includes with it a commensurate delegation of sufficient authority that the person can, in fact, fulfill that responsibility. Unless otherwise specifically prohibited, it is understood that the functions, tasks and activities necessary to carry out a responsibility may be delegated to and perfmmed by other qualified individuals.

All delegations offtmctions, tasks, activities and authority shall be documented. Individuals Inay fulflll more than one function unless prevented by the need to maintain independence as specified

• in the HBQAP.

Figures land 2 illustrate the organizational structure, ftmctional responsibilities, levels of authority, line of communication, and inte1faces of persons and organizations performing activities governed by the. HBQAP.

The functional responsibilities shown in Figures 1 and 2 are further described below. Generic titles are used for the functions and responsibilities. Differences (if any) between actual titles used in the organization are traceable to the HBQAP titles by the use of administrative procedures.

The SENIOR VICE PRESIDENT- CHIEF NUCLEAR OFFICER (CNO) is responsible for overall 1-IBPP Unit 3 decommissioning, and HB ISFSI activities, safety and for taking measures needed to ensure acceptable performance of the HB ISFSI staff in designing, fabricating, constructing, testing, operating, 1nodifying, decommissioning, and providing technical suppmi to the HB ISFSI and during HBPP Unit 3 decommissioning.

L-4 Attachment 2.1 Rev. 33 Page 4 of29

• The CNO, or designee, as specified in administrative procedures, approves and signs official company correspondence to the U.S. Nuclear Regulatory Commission (NRC) or its representatives. The CNO approves revisions to the QA Program as described herein that constitute a reduction in a commitment made to the NRC. The CNO is responsible for designating individual(s) to perfonn an Independent Manage~nent Review to periodically assess the effectiveness of the HB QA Program.

The DIRECTOR- QUALITY (Quality Director) is responsible for assuring that the HBQAP and implementing procedures are effectively implemented and complied with by all involved organizations, both internal and external to PG&E. The Quality Director has the organizational freedom and requisite authority to assess, review, inspect> audit, and monitor the conduct of quality activities to assure compliance with the HBQAP and other regulatory requirements. The Quality Director reports to the CNO, and has access to the President, HB Director, and appropriate managers for any significant quality problem or deficiency.

The Quality Director is responsible for maintaining and submitting for approval changes to the 1-IBQAP. The Quality Director is responsible for the review of all regulatory submittals as they pertain to the HBQAP and his/her concunence is required prior to subrnittal.

Reporting to the Quality Director are the quality assurance, supplier quality and independent quality control inspection functions. These i.J).dividuals or groups do not have direct responsibility for petfonning the work being verified; are trained and qualified in QA concepts and practices; are independent of the organization respo~sible for performing the task and have direct access to management levels. The Quality Organization is sufficiently free from direct pressures for cost and schedule that assures the ability to: (a) identify quality problems; (b) initiate, recommend, or provide solutions through designated channels; and_(c) verify implementation of solutions.

Individuals within the Quality Organization have the authority to stop unsatisfactory. work and control further processing, delivery, or installation of nonconforming material. Organizational positions with stop work authority are identified in the implementing procedures.

The DIRECTOR-NUCLEAR SECURITY and EMERGENCY SERVICES (HB ISFSI Director) is responsible for the conduct of activities related to the HB ISFSI. This includes responsibility for operation, maintenance, training, security and emergency preparedness. The day-to-day responsibilities are delegated to and executed by the HB ISFSI management team. Specific responsibilities are described in administi*ative procedures.

The HB ISFSI Director is also responsible for the development of, programs, procedures, and instructions required for HB ISFSI within the requirements and/or limits established in the HBQAP; HB ISFSI Technical Specifications; and administrative guidelines established in the HB ISFSI Final Safety Analysis Report (FSAR).

The HB ISFSI Director shall delegate these responsibilities to other members of the HB ISFSI management team during his/her absence.

The ISFSI MANAGER is responsible for the operation and maintenance of the HB JSFSI, maintenance of the Physical Security Plan and interfacing with outside agencies.

L-4 Attachment 2.1 Rev. 33 Page 5 of29 The Diablo Canyon Power Plant (DCPP) RADIATION PROTECTION MANAGER is responsible for implementing the HB ISFSI radiation protection program for the protection of the workers and members of the public.

An INDEPENDENT MANAGEMENT REVIEW is periodically performed to assess the effectiveness of the HB QA Program, including audit program. Results of the Independent Management Review are provided to the CNO for cmTective action, as necessary. Individual(s) that perform the Independent Management Review are appointed by the CNO. The Independent Management Review includes oversight of the HBQAP implementation and matters relating to safe storage of spent nuclear fuel, as directed by the CNO.

The DIRECTOR- HUMBOLDT BAY (H8 Director) is responsible for the conduct of activities related to the HBPP Unit 3 decommissioning. This includes responsibility for operation, maintenance, engineering, radiation protection, training, radioactive material packaging, and transport for decommissioning activities. The day-to-day responsibilities are delegated to and executed by the HB decolll111issioning management team that direCtly reports to the HB Director.

Specific responsibilities are described in administrative procedures.

The HB Director is also responsible for the development of, programs~ procedures, and instructions required for HBPP Unit 3 within the requirements and/or limits established in the HBQAP; HBPP Unit 3 Technical Specifications; and administrative guidelines established in the HBPP Unit 3 Defueled Safety Analysis Report (DSAR). The HB Director is the Design Authority for the HBPP Unit 3 and HB ISFSI. .

The HB Director shall delegate these responsibilities to other members of the HB management team during his/her absence.

The HBPP ENGINEERING MANAGER is responsible for technical aspects of the engineering and design ofHBPP Unit 3 and HB ISFSI SSCs including, performance of modifications; configuration control and design bases defense and management; quality classification of SSCs; and the specification of technical and quality requirements for the purchase of services, materials and equipment.

• The HBPP RADIATION PROTECTION MANAGER is responsible for implementing the decommissioning radiation protection program for the protection of the workers and members of the public.

INDEPENDENT SAFETY REVIEWER(S) (ISR) performs independent safety reviews of proposed changes, tests and experiments to SSCs, activities, program documents and procedures that are subject to the HBQAP requirements. ISRs shall be individuals without direct responsibility for the performance of these activities under review, and shall be competent and knowledgeable in the subject area being reviewed. ISRs are designated by the HB Director for decommissioning activities or the HB ISFSI Director for ISFSI activities.

CORPORATE SUPPORT for ITS activities includes, but is not limited to, procurement, recor~s, employee concerns, and licensing. Each organization documents and maintains a written description of its internal organization.

L-4 Attachment 2.1 Rev. 33 Page 6 of29 SUPPLIERS that provide ITS SSCs or services are required to comply with the HBQAP or to a QA Prograw approved by PG&E. Supplier QA Programs are required to comply with the applicable portions of 10 CFR 50, Appendix B; 10 CFR 71, Subpart H; or 10 CFR 72, Subpart G.

The Quality Program reqLLirements are defined in the contract or similar procurement document.

Suppliers to PG&E are required to document their internal organization, to the extent necessa1y for PG&E, to assure the supplier is capable of effectively managing, directing, and executing the requirements of the procurement documents.

Staff Qualifications Except as specified in other portions of the HBQAP, each member of the staff shall meet or exceed the following minimum qualifications:

For HB Unit3, the minimum qualifications of ANSI Nl8.1 (1971) for comparable positions are applicable.

For the HB ISFSI; the minimum qualifications are described in the ISFSI FSAR The following reqtdrements and clarifications apply to the positions listed below, and are applicable to both HBPP Unit 3 and the HB ISFSI; RADIATION PROTECTION MANAGERS shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2~ Aprill987.

The QUALITY DIRECTOR shall have knowledge of QA regulations, policies, practices, and standards; and experience working in QA, nuclear power plant, fuel storage facility, or in a similar highly technological industry. At the time of assignment to the active position, the Quality Director shall have six years of experience in implementing Quality Assurance.

At least one year of these six years of experience shall be nuclear power plant or fuel storage facility experience in the overall implementation of a Quality Assurance Program (QAP). A minimum ofone year of this six-year experience requirement shall be related technical or academic training. A maximum of four years of this six-year experience requirement may be fulfilled by related technical or academic training.

The one year of qualifying nuclear power plant or fuel storage facility experience in the overall implementation of the Quality Assurance program can be obtained outside the Quality Assurance organizations.

L-4 Attachment 2.1 Rev. 33 Page 7 of29 Figure 1 HB ISFSI Organization Chart Senior Vice President ChiefNuc]ear Officer Director Independent Quality Management Review Director Nuclear DCPP or Contract Supp01t Security and Emergency

• Records Services

• Licensii1g I I

• Procurement HBPP Engineering ---------------* ~---------------

• Employee Concerns

• Radiation Protection

• Other (as required)

I I HB ISFSI Independent Safety HB ISFSI Manager Reviewers

L-4 Attachment 2.1 Rev. 33 Page 8 of29 Figurc2 HB Decommissioning Organization Chart Senior Vice President ChiefNuclear Officer DCPP or Contract Suppmt

• Records Director

• Licensing Quality

• Procurement

• Employee Concerns

• Other (as require d)

I I

Director I I

I Humboldt Bay I I

I I

I I

~-------------------------~------1 HBPP HBPP Radiation HBPP Independent Engineering Protection Safety Reviewers Manager Manager

L-4 Attachment 2.1 Rev. 33 Page 9 of29 2.0 QUALITY ASSURANCE PROGRAM 2.1 PROGRAMAPPLICABILITY The HBQAP Tequirements~ apply to SSCs designated as ITS in Appendix A.

The quality requirements for the management and administrative program~ in Appendix B that support ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP.

The quality requirements for the management and administrative programs that suppmt HBPP Unit 3 are designated in administrative programs and procedures.

A graded approach is used to define the controls applied to quality activities commensurate with the activity,simportance to safety. The graded approach also applies to the level of quality oversight for quality activities.

Activities that require review and concutTence by Quality persmmel are delineated in administrative procedures and are based on the activity's impmtance to safety.

The effectiveness of the imple1nentation of the HBQAP shall be assured through Quality Related programs, procedures and drawings. ,

2.2 PROGRAM CONTROL The status and adequacy of the HBQAP shall be regularly monitored and it shall be revised as necessary to improve its effectiveness or to reflect changing conditions.

The HBQAP, including*any changes~ supplements, or appendices are issued and maintained as controlled documents. Changes to the HBQAP requirements shall be made in accordance with 10 CFR 50.54.

Changes to the HBQAP that do not reduce commitments shall be included in tl1e periodic updates required by 10 CPR 50. 71. Prior to issuance for use, proposed changes to the HBQAP that reduce commitments are reviewed and concurred with in writing by the Quality Director and are approved by the CNO, or designee~ prior to being submitted to and approved by the NRC in accordance with 10 CFR 50.54.

Implementation of the HBQAP is accomplished through separately issued procedures~ instructions, and drawings. Each organization is responsible for the establishment and implementation of detailed procedures and instructions prescribing the quality activities for which they are responsible. Such documents are derived from the requirements and reflect the responsibilities specified in the HBQAP.

Questions or disputes involving interpretations ofHBQAP requirements and commitments are referred to the Quality Director for resolution. Questions or disputes involving the responsibilities defined in the HBQAP are referred to the CNO.

Questions or disputes involving other quality matters are resolved by refel1'ing the matter, in a timely manner, to successively higher levels of 1nanagement until, if necessary, the matter reaches the management level which has direct authority ove1; all contesting patties.

L-4 Attachment 2.1 Rev. 33 Page 10 of29 2.3 INDOCTRINATION AND TRAINING Indoctrination and training for personnel implementing ITS activities are conducted to assure suitable proficiency is achieved and maintained. The extent of indoctrination and training is commensurate with the scope~ complexity and importance to safety of the assigned task; in conjunction with the education and experience of the individual. Personnel involved in implementing the activities within the scope of the HBQAP shall be responsible for the quality of their work. At a minimum, these personnel shall receive:

• Indoctrination in the Tequirements of the HBQAP;

• Indoctrination in their organization's implementing procedures; and

• Training and qualification in tasks requiring special skills or knowledge, as required.

Indoctrination, training, qualification, andre-qualification (when applicable) shal1 be prescribed and performed in accordance with written procedures; and applicable codes, standards and regulatory requirements; which specify the 1nanagement responsibilities; training areas; frequency of training; method of qualification and requalification; and documentation requirements.

Training and qualification records are maintained in accordance with implementing procedures.

2.4 REGULATORY COMMITMENTS Regulatory commitments, where applicable, are specified in the Unit 3 DSAR, ISFSI FSAR, Technical Specifications or Licenses.

L-4 Attachment 2.1 Rev.33 Page 11 of29 3.0 DESIGN CONTROL Design Control' applies to the 10 CPR 72 ~SCs designated as ITS in Appendix A. Design activities shall be controlled to assure that design, technical, and quality requirements are conectly translated into desi!,rn documents and that changes to design and design documents are properly controlled. Design control procedures shall address responsibilities for:

( 1) Interface control (2) Design input (3) Design performance (4) Design verification (5) Design change Systematic methods shall be established and documented for cormnuuicating needed design infonnation across the external and internal design interfaces, including changes to the design information, as work progresses. Document control1neasures shall be established for design documents that reflect commitments in applicable design basis documents (e.g., specifications, calculations, computer programs, system descriptions, drawings).Provisions for design input shall deflne the technical objectives for SSCs being designed or analyzed. Design inputs shaH be documented, reviewed and approved and translated to design docmnents. Required design analyses (such as stress, thermal, hydraulic and accident analysis; material compatibility; maintenance and repair and ALARA considerations) shall be performed in a planned, controlled, and correct manner. PG&E procedures shall identify the review and approval responsibilities for design analyses.

PG&E shall provide for reviewing, confirming, or substantiating the design to assure that the design meets the specified design inputs. Design verification shall be petformed by competent individuals or groups other than those who performed the original design, but who may be from the same department.

The results -o f the design verification effmis shall be documented with the identification of the verifier clearly provided. The design verification shall be completed prior to relying upon the component system or structure to pe1form its function. Procedures shall assure that verified computer codes are certified for use and that their applicability is specified.

Changes or modifications to the designated SSCs in Appendix A shall be approved by the Design Authority, or designee, as specified in administrative procedures, prior to implementation. Procedures for implementing design changes, inclttding field changes, shall assure that the impact of the change is carefully considered, required actions documented, and information concerning the change transmitted to affected persons and organizations. These changes shall be subjected to design control measures commensmate with those applied to the original design.

Nonconforming activities such as, deviations, errors or deficiencies in approved design documents, including design methods (such as computer codes), shall be controlled as described in Sections 15.0 and 16.0.

L-4 Attachment 2.1 Rev. 33 Page 12 of29 4.0 PROCUREMENT DOCUMENT CONTROL Procurement Document Control applies to SSCs designated as lTS in Appendix A. Procurement documents shall include those requirements necessary to assure that the items and services to be provided will be of the desired quality.

Procedures that implement procurement document control shall describe the organizational responsibilities for procurement planning~ preparation, review, approva~ and control of procure1nent documents; supplier selection; bid evaluations; identification of replacement parts, where applicable; and review and evaluation of the supplier's QA Program prior to initiation of activities affected by the program.

Procedures shall be established to review the adequacy of the technical and* QA requirements stated in procurement documents; determine that requirements are correctly stated, inspectable, and controllable; assure adequate acceptance and rejection criteda; and provide for the preparation, review, and approval of procurement documents in accordance with applicable requirements. The review and documented concurrence of the adequacy of technical, and QA requirements stated in procurement documents shall be performed by independent personnel trained and qualified in applicable QA practices and concepts.

Changes to procurement documents shall be subject to the same controls as the original document.

L-4 Attachment 2.1 Rev. 33 Page 13 of29 5.0 INSTRUCTIONS, PROCEDURES. AND DRAWINGS Controls for Instructions> Procedures, and Drawings apply to SSCs designated as ITS in Appendix A.

Activities, other than skill of the craft, shall be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings. These documents shall include quantitative or qualitative acceptance criteria for verifying that an activity was satisfactorily accomplished, where applicable (i.e., verification activities for procurement, inspection tests).

Procedures prescribing a preplanned method of conducting activities required by the HBQAP shall be established in accordance with the applicable regulation, codes, standards, and specifications.

Changes to or deviations from established instructions, procedures, or drawings require the same review and approval as the original document. Instructions, procedures, or drawings, including changes and deviations, subject to the HBQAP shall be maintained.

Administrative controls shall be established that provide the methods by which temporary changes can be made to approved procedures, including the designation of persons authorized to approve such changes.

Temporary changes that clearly do not change the intent of the approved procedure from the standpoint of nuclear safety may be approved by two members of the HBPP/ISFSI management team. Such changes shall be documented and, if appropriate, incorporated into the next revision of the affected procedure.

Administrative controls for approval and timely notification or training of personnel affected by the temporary change shall be implemented.

Procedures subject to the HBQAP shall be periodically reviewed as described in administrative procedures.

L-4 Attachment 2.1 Rev. 33 Page 14 of29 6.0 DOCUMENT CONTROL Document Control applies to SSCs designated as ITS in Appendix A, and the administrative programs described in Appendix B. Documents and changes to documents that prescribe or verify activities affecting quality shall be controlled in a 1nanner that precludes the use of inappropriate or outdated documents. *

• A document control system sha11 be established to identify the current revision of instructions, procedures, specifications, drawings, and procurement documents. Written procedures shall identify those responsible for preparing, reviewing, approving, and issuing documents.

Procedures and instructions shall assure that documents, including changes, are prepared; reviewed by a qualified jndividual other than the person who generated the document; approved for release by authorized personnel; distributed to the location where the activity is petfonned prior to commencing work; and used in performing the activity.

Procedures, instructions and other documents that implement HBQAP requirements shall be reviewed and concurred with by the Quality Organization. Revisions to procedures, instructions and other docun1ents shall also be reviewed and concmTed with by the Quality Organization, as specified in administrative procedures.

• L-4 Attachment 2.1 Rev. 33 Page 15 of29 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Control of Purchased Material, Equipment, and Services applies to SSCs and associated activities that are designated as ITS in Appendix A. Supplier activities that provide purchased material, equipment, and services shall be 1nonitored as necessary to assure such items and services meet procurement document requirements.

Procedures shall describe-each organization's responsibilities for the control of purchased material, equipment, and services, .including the interfaces between all affected organizations.

All materials, equipment, and services shall meet the specified technical and quality requirements.

Verification that a supplier can meet the specified technical and quality requirements shall be documented.

A Supplier~s QA Program that satisfies specified quality requirements shall be listed on the PG&E Qualified Suppliers List. The PG&E Qualified Suppliers List shall be controlled.

Suppliers of commercial grade calibration services may be qualified based on their accreditation by a nationally-recognized accrediting body, as an alternative to qualification by supplier audit, commercial grade survey, or in-process surveillance.

The effectiveness of contractors and supplier's quality controls shall be assessed at intervals consistent with the impoliance, complexity, and quantity of the product or service. Supplier performance and compliance with procurement documents are monitored by source verification, receipt inspection, or a combination of the two.

Source verification and/or receipt inspection activities are performed to assure that the requirements of the procurement documents have been met. Accepted items are appropriately marked, removed from the inspection area, and located in a controlled storage area until use.

ITS SSCs and services from a supplier whose QA Program has not been reviewed or accepted may be used provided additional controls such as source inspection, special receipt instructions, and/or testing are imposed. These additional controls shall be docmnented and approved by the appropriate level of management.

Spare and replacement patis are procured such that their performance and quality are at least equivalent to those of the patts that will be replaced. Commercial grade items are controlled by written procedure.

Designated Quality personnel or other personnel with appropriate qualifications are responsible for assuring source inspections, surveys, or audits of suppliers are performed as necessary.

Documentation of acceptance shall be available prior to installation or acceptance for use.

L-4 Attachment 2.1 Rev. 33 Page 16 of29 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS The Identification and Control of Materials, Parts and Components apply to SSCs designated as ITS in Appendix A. Materials, parts, and components shall be identified and controlled in a matmer to preclude the use of incorrect or defective items.

Implementing procedures shall describe the organizational responsibilities and controls to ensure that only correct and accepted items are used.

Materials, parts, and components, including partially fabricated subassemblies, batches, lots, and consumables, shall be identified in a manner that each can be traceable to its applicab]e drawing, specification, or other technic~l documentation at any stage from initial receipt through fabrication, installation, repair, modification or use of an item. When required by code, standard, or specification; traceability of materials, parts, or components to specific inspection or test records shall be provided for and verified.

Items having limited shelf or operating life are controlled to preclude use after the shelf life or operating life has expired.

Identification marking, where employed, shall be clear, unambiguous, and indelible and its application shall not impair the function of the identified item or any other item. When an item is subdivided, the identifying marking shall be transferred to each resulting pa1t. Markings shall not be rendered illegible by treatment, process, assembly, installation, or coating unless other means of identification and determining acceptability are provided.

L-4 Attachment 2.1 Rev. 33 Page 17 of29 9.0 SPECIAL PROCESSES Special Processes apply to SSCs designated as ITS in Appendix A. Special processes shall be controlled and perfotmed by qualified personnel using written procedures or instructions in accordance with applicable codes, standards, specifications, criteda, or other special requirements.

A special process is an activity, in which the quality of the result is highly dependent upon either process variables or the skill and performance of the person doing the work, and the specified quality is difficult to verify by inspection and test after the process is completed.

Special processes include, but are not limited to: welding, heat treating, nondestructive examination, and chemical cleaning.

Equipment used for special processes shall be qualified, maintained, stored, issued in accordance applicable procedures and operated by qualified personneL The implementing instructions shall contain the criteria for assuring proper process control and compliance with applicable codes, standards, QA p1'ocedures, and design specifications. Records of qualifications and controls shall be maintained.

L-4 Attachment 2.1 Rev. 33 Page 18 of29 10.0 INSPECTION Inspection activities apply to SSCs designated as lTS in Appendix A. A comprehensive program of inspection of items and activities affecting quality shall be conducted to verify conformance with established requirements. Procedures shall describe the organizational responsibilities necessary to carry out the inspection program.

Inspections shal1 be planned in accordance with approved procedures, and based on drawings_,

specifications, and other controlled documents. Inspections shall be performed in accordance with written and approved inspection plans and/or inspection procedures to verify that the quality of items and activities conform to applicable and documented instructions, procedures, and drawings. Acceptance/rejection criteria and mandatmy quality control inspection hold points shall be identified, where applicable. Work shall not proceed beyond such hold points without the appropriate documented concmTence by Quality personnel or assigned and authorized personnel.

The inspection results, including acceptance/rejection criteria_, shall be documented and evaluated.

Unacceptable inspection results shall be evaluated and resolved in accordance with procedures. Where applicable~ modifications, repairs and replacements; are re-inspected to the same standard or method to verify acceptability. Inspection records shall be maintained.

Inspections shall be performed by qualified individuals other than those who performed or directly supervised the activity being inspected.

L~4 Attachment 2.1 Rev. 33 Page 19 of29 11.0 TEST CONTROL Test Control applies to the 10 CFR 72 SSCs designated as ITS in Appendix A.

A prograu1 of testing shall be conducted, as necessaty~ to demonstrate that SSCs will pe1form satisfactorily in service. This program shall ensure that the necessary testing is identified and performed at the appropriate time in accordance with written test procedures that incorporate or reference the requirements and acceptance limits contained in the applicable design documents.

The procedures that implement testing shall specify the appropriate prerequisites for the test (e.g.

environmental conditions~ specification of instrumentation, and completeness of tested item), sufficient instruction for the pmforniance of the test, witness or hold points, acceptance/rejection criteria and limits, and the 1'equired test documentation. The procedures shall provide for evaluation and documentation of the test results; data; and their acceptability as detennined by a qualified person or group. Test results that do not meet the acceptance criteria shalJ be documented and evaluated to determine the appropriate corrective action. Where applicable, modifications, repairs, and replacements; are re-tested to verify acceptability. Test records shall be maintained.

L-4 Attachment 2.1 Rev. 33 Page 20 of29 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT The Control of Measuring and Test Equipment applies to SSCs designated as ITS in Appendix A.

Organizational responsibilities shall be delineated for establishing, implementing, and assuring the effectiveness of the calibration program for measuring and test equipment (M&TE).

M&TE, including reference standards, used to determine the acceptability of items or activities shall be maintained within prescribed accuracy limits, suitable range, type, and accuracy to verify conformance with requirements.

Procedures for control ofM&TE shall provide for the identification (labeling, codes, or alternate documented control syste1n), recall, and calibration (including documented pre-calibration checks) of the M&TE. The calibration procedures shall delineate special controls, where applicable, for usage, handling, and storage required for environmental conditions such as temperature, humidity, cleanliness, or radiation to maintain accuracy or operating characteristics of the M&TE.

Calibrations standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shaH be documented. Special calibration' and control measures are not required when normal commercjal practices provide adequate accuracy Instruments shall be calibrated prior to use. The calibration intervals, whether calendar- or usage-based, shall be predetermined and to the extent practical, consistent with the instrument manufacturer's guaranteed repeatability and/or the user's experience. Indication of expiration, if feasible, will be displayed on or with the M&TE. Special calibration shall be required whenever the accuracy of the equipment is suspect M&TE or instrumentation found to be out of calibration shall be evaluated and documented.

Records of M&TE usage shall be 1naintained, such that measures may be taken to determine the validity of previous inspections performed and the acceptability of items inspected or tested since the previous calibration when the M&TE is suspect.

L-4 Attachment 2.1 Rev. 33 Page21 of29 13.0 HANDLING, STORAGE, AND SHIPPING Handling, Storage and Shipping requirements apply to SSCs designated as ITS in Appendix A. Material and equipment shall be handled, stored, and shipped in accordance with design and .procurement requirements in a manner that will prevent damage, deterioration, or loss.

Special coverings, equipment, and protective environments shall be specified and' provided where necessmy for the protection of items from damage or deterioration. When such. special protective features are required, their existence shall be verified and monitored as necessary to assure they continue to serve their intended function.

Special handling tools and equipment shall be provided where necessary to ensure items can be handled safely and without damage.

Markings or labeling shall be used to indicate the .p resence of special environments or the need for special controls. Provisions shall be described for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials.

Special handling, preservation, storage, cleaning, packaging, and shipping requirements are established and accomplished by suitably trained individuals in accordance with predetermined work and inspection instructions.

L-4 Attachment 2.1 Rev. 33 Page 22 of29 14.0 INSPECTION, TEST, AND OPERATING STATUS Inspection, Test and Operating Status requirements apply to SSCs designated as ITS in Appendix A. The inspection, test, and/or operating status of material, equipment, and operating systems shaH be readily apparent and verifiable.

The procedures used to indicate status shall provide means for assuring that required inspections and tests are performed in the prescribed sequence; and acceptability is indicated; to prevent inadvertent use or operation. Items accepted and released are identified to indicate their inspection status prior to forwarding them to a controUed storage area or *r eleasing them for installation or further work. Deviations :fi.*mn the prescribed sequence shall be subject to the same level of control as the generation of the original sequence to prevent the bypassing or omission of a required test or inspection.

The operating status of nonconforming, inoperable or malfunctioning ITS SSCs shall be identified and documented to prevent inadvertent operation. Identification of status may be by such means as, but not limited to, tags, stamps, maddngs, labels, oi* travelers. In some instances, records traceable to the item may be used.

The procedures implementing control of inspection, test, and operating status shall clearly delineate authority for the application, change, or removal of a status identifier.

L-4 Attachment 2.1 Rev. 33 Page 23 of29 15.0 CONTROL OF NONCONFORMING CONDITIONS The Control of Nonconforming Conditions applies to SSCs designated as ITS in Appendix A. Items and activities that do not conform to requirements shall be controlled in a manner that will prevent their inadvertent use or installation. Nonconforming conditions are documented, reviewed and accepted, rejected, repaired or reworked in accordaJ!ce with quality procedures. Organizations affected by nonconform-ing conditions shall be notified of such conditions.

Measures shall be established to identify, label and segregate nonconforming items to indicate their unacceptable status and to prevent inadvertent use or installation until the nonconformance is properly dispositioned. Labels associated with a nonconforming item shall only be removed by authorized personnel.

The acceptability of nonconforming items shall be verified and documented prior to use. Documentation shall include a description of the change, waiver, or deviation that has been accepted.

In cases where required documentary evidence that items have passed required inspections and tests is not available, tl1e associated materials or equipment shall be considered nonconforming. Until suitable documenta1y evidence is available to show that the material or equipment is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fu1fi11 their intended safety :fu.llctions.

Nonconfonning conditions shall be processed as conditions adverse to quality in accordance with Section 16.0.

L-4 Attachment 2.1 Rev. 33 Page24 of29 16.0 CORRECTIVE ACTION Corrective Action applies to SSCs designated as ITS in Appendix A. Conditions adverse to quality shall be identified, controlled, reviewed, and evaluated to determine remedial action and corrective action and implement those actions as soon as practicable.

A systematic review and evaluation of conditions adverse to quality shall be conducted and documented.

Conditions adverse to quality shall include, but not be limited to: engineering, design, and drafting errors; equipment failures and malfunctions; abnormal occurrences; deficiencies; deviations; and defective material, equipment, and services. The evaluation and corrective action taken should be based on safety significance.

Findings and actual or recomtnended conecti~e actions shall be reported to management for review and

~ssessment. Corrective actions shall be accmnplished in a timely manner commensurate with the safety significance.

Significant conditions adverse to quality shall be evaluated for reportability to the NRC. Significant conditions adverse to quality_, the cause of the condition, and the corrective action taken to preclude recurrence shall be documented and reported to management. Follow-up reviews shall be conducted to verify that the corrective action was properly implemented and effective in correcting the identified condition.

L-4 Attachment 2.1 Rev. 33 Page 25 of29 17.0 QUALITY ASSURANCERECORDS The requirements for Quality Assurance Records apply to those SSCs that are designated as ITS described in Appendix A.

Sufficient records shall be 1naintained to furnish evidence of both the quality of items and activities affecting quality and to meet applicable code, standard, regulatory, and license requirements. The records include ali documents referred to, or described in the HBQAP as records or required by quality procedures.

At a n1inimum quality records include operating logs, maintenance and modification procedures, related inspection results_, and reportable occurrences and other records as required by the applicable license, Technical Specifications and Code of Federal Regulations. Additionally, records required by the HBQAP, and furnished by vendors, suppliers, subcontractors, and contractors that perfonn or supply quality-related activities or SSCs that are ITS are also QA Records and shall be maintained.

A management control system for the collection, storage, and maintenance of completed quality assurance

. (QA) rec_ords shall be maintained. This records management program shall be designed and implemented to assure that the QA records are complete, i*eadily retrievable when needed, and protected from damage or destruction during storage by fire, flooding, theft, enviromnental conditions, or other causes.

QA records stored electronically will follow the guidance for electronic records management given in the Nuclear Information and Records Management Association (NIRMA) technical guidelines, TG 11-1998, "Authentication of Records;" TG 15-1998, "Management ofElectronic Records;" TG 16-1998, "Software Configuration Management and Quality Assurance;') and TG 21-1998, "Electronic Records Protection and Restoration." QA records will be stored on electronic media (that is, optical disk, magnetic tape, network array, etc.) meeting the requirements of the NIRMA guidelines. Altmnately_, records stored on optical

• disks may meet the requirements of Generic Letter 88-18, "Plant Record Storage on Optical Disk," dated October 20, 1988. Information Systems will determine the appropriate electronic media. Regardless of the electronic media selected, the process must be capable of producing legible, accurate, and complete records during the required retention period.

Electronic QA records, including backup copies, are stored in two redundant electronic media storage systems at physically-independent electronic locations. QA records in electrmiic format (e.g., pdf fmmat) 1nay be filed and stored on the electronic media storage systems. Selected QA records on other media (e.g.>

paper hardcopies, microfilm, DVDs) are maintained in a Permanent Records Storage Facility.

Detailed records for items or activities shall be specified by instmctions, procedures, drawings, or specification or other documents that prescribe the item or activity and shall be generated by the organization responsible for the item or activity including PG&E and non-PG&E organizations.

L-4 Attachment 2.1 Rev. 33 Page 26 of29 18.0 AUDITS The requirements for Audits app]y to SSCs designated as ITS in Appendix A. Measures shall establish a comprehensive system of planned and periodic audits. These assess, monitor and verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the HBQAP and implementing activities.

Internal and supplier audits are petfonned in accordance with written procedures and/or check lists.

Audits are perfo1med by qualified personnel not having direct responsibility in the areas audited.

Auditors shall have experience, training or qualifications commensurate with the scope and complexity of their audit responsibility.

Scheduling, preparation, personnel selection, performance, reporting, response, follow-up action, and records management are performed in accordance with written procedures. Audit scopes and schedules are established to meet applicable regulatory require1nents and are based on the status and safety significance of the activities to be audited.

. Detailed audit schedules are documented in accordance with Quality procedures. At a minimum, the conformance of decommissioning activities and ISFSI operations to applicable regulatmy requirements is audited at least once every 24 months or more frequently as performance dictates.

External audits of suppliers providing ITS materials, parts, equipment or services are ,scheduled and performed based on the importance of an sse or activity to confirm implementation of their Quality Program requirements, but not less than every 3 years.

Audits that are not mandated by regulation have a grace period of up to 90 days, when the urgency of other priorities makes meeting the specified schedule dates impracticaL For audit activities deferred using a grace period, the next scheduled due date shall be based on the originally scheduled due date, but may not exceed the original due date plus 90 days.

Audit reports shall be prepared, issued to and reviewed by responsible management ofboth the audited and auditing organizations. Audit records shall .be generated and retained. Follow-up action~ including re-audit of deficient areas, shall be taken, where applicable.

L-4 Attachment 2.1 Rev. 33 Page 27 of29 APPENDIX A IMPORTANT-TO-SAFETY STRUCTURES, SYSTEMS AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart Hand 10 CFR 72 Subpatt G will be applied, as a minimum, to quality activities affecting th~ ITS SSCs associated with spent fuel storage and transportation package that are listed below. The quality categ01y is based on the guidance in NUREG/CR-6407. In addition, the HB ISFSI FSAR, Holtec International ill-STORM Safety Analysis Repmt (SAR), Holtec lntemational Ill~STAR SAR and associated specifications include additional classification infonnation.

NOTE There are no HBPP safety related SSCs remaining at the site.

The quality classification of NRC Licensed HB ISFSI Dry Fuel Storage Components and Transportation Packages is made by the NRC Certificate Holder. The Certificate Holder is responsible for design and licensing controls for these components u_nder their NRC approved Quality Assurance Program. PG&E utilizes these types of components and packages under the provisions of a NRC General License for Radioactive Material Transportation Packages (10 CFR 71) and Spent Fuel and GTCC Storage ( 10 CFR 72).

IMPORTANT TO SAFETY AS DEFINED BY 10 CFR 71 AND 10 CFR 72 A. Dry Spent Fuel and GTCC Storage (10 CFR 72) sse Quality Category Desi~n/Liceuse Responsible Multi-Purpose Canister A PG&E Fuel Basket and Basket Spacers A PG&E Damaged Fuel Container A PG&E Hi -Star 100 HB Overpack A PG&E Transporter Lift Links A PG&E GTCC Waste Container A PG&E Hi-Star HB GTCC Overpack A PG&E HB ISFSI Storage Vault B PG&E Fuel Spacers B PG&E Transporter Connector Pins B PG&E Helium Fill Gas B PG&E

• Lid Retention Device B PG&E Cask Transp01ter B PG&E Process Waste Container B PG&E B. Transport of Spent Fuel and GTCC Waste (10 CFR 71) sse Quality Category D esi2n!License Responsible Multi-Purpose Canister A Holtec International Fuel Basket and Basket Spacers A Holtec International Damaged Fuel Container A Holtec International Hi-Star 100 HB Overpack A Holtec International GTCC Waste Container A Holtec International Hi-Star HB GTCC Overpack A Holtec International Fuel Spacers B Holtec International Helium Fi11 Gas B Holtec International

L-4 Attachment 2.1 Rev. 33 Page 28 of29 APPENDIXB ADMINISTRATIVE CONTROLS 1.0 PROGRAMS AND PROCEDURES The program and procedures listed below shall be established and controlled to support HBPP Unit 3 and/or HB ISFSI.

1.1 HBPP U1iit 3 a) Radiation Protection Program b) Radiological Environmental Monitoring Program c) Radioactive Effluent Control Program 1.2 HB ISFSI a) Radiation Protection Program b) Emergency PIan c) Radiological Environmental Monitoring Program d) Security Program (as defined in security license bases documents) 1.3 Management and Administrative Programs The management and administrative programs quality requirements applicable to ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP as described in administrative procedures. Applicable regulatory and quality requirements for the management and administrative programs in Appendix B are designated in administrative programs and procedures.

2.0 RADIOLOGICAL MONITORING Administrative controls for radiological monitoring of gaseous effluents and the environment shall be controlled and implemented to ensure conformance with USNRC Regulatory Guide 4.15 (December 1977).

• 3.0 TECHNICAL SPECIFICATION ACTIVITffiS In addition to the applicable quality assurance requirements specified in the HBQAP, Technical Specification activities shall be controlled in accordance with the Limiting Conditions for Operations (LCO) and Surveillance Requirements (SR).

4.0 OFFSITE DOSE CALCULATION MANUAL The Offsite Dose Calculation Manual (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, and conduct of the radiological environmental monitoring program. The ODCM shall also contain the radioactive effluent controls and radiological enviromnental monitoring activities *and descriptions of the information that should be included in the Annual Radiological Environmental Monitoring Repmt, and Annual Radioactive Effluent Release Report.

Licensee initiated changes to the ODCM: .

1. Sha11 be documented and records of reviews performed shall be retained. This documentation sha11 contain:

i) sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s ), and

L-4 Attachment 2.1 Rev. 33 Page 29 of29 ii) a determination that the change(s) will maintain the level of radioactive effluent control required by 10CFR 20.1302, 40CFR Part 190, IOCFR 50.36a and Appendix Ito 10CFR 50, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

2. . Shall beco1ne effective after review and approval of the HB Director; and

3. Shall be submitted to the Cmmnission in the form of a complete, legible copy of the entire ODCM as a part of or concunent with the Radioactive Effluent Release Rep01t for the period of the rep~tt in which any change in the ODCM was made. Each change shall be identified by marlcings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.0 RADIOACTIVE EFFLUENT CONTROLS PROGRAM This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable (A LARA). The program ( 1) shall be contained in the ODCM, (2) shall be implemented by written procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded.

6.0 REPORTING REQUIREMENTS The following reports shall be submitted in accordance with 10 CFR 50.4.

6.1 Occupational Radiation Exposure Report An annual rep01t shall be made of personnel exposure, in accordance with the requirements of 10 CFR Part 20.2206. The repmt shall be submitted by April 30 of each year.

6.2 Annual Radiological Envil*onmental Monitoring Report The Annual Radiological Environmental Monitoring Report covering the operation of the unit during the previous calendar year shall be sub1nitted by May 1 of each year. The report shaH include summaries, interpretations, and analyses of trends of the resuJts of the Radiological Environmental Monitoring Program for the repmting period. The material provided shall be consistent with the objectives outlined in the ODCM, and in 10 CFR 50, Appendix I> Sections IV.B.2, N.B.3, and IV.C.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of radiological environmental samples and of environmental radiation 1neasurements taken during the period pursuant to the quality related locations specified in the table and figures in the ODCM, as well as summarized *and tabulated results of these analyses and measurements. In the ~vent that some individual results are not available for inclusion with the report, the repmt shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual rep01t.

6,3 Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Repmt covering the activities of the unit in the previous year shall be submitted prior to April I of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released frmn the unit. The material provided shall be consistent with the objectives outlined in the ODCM and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section N.B.l.

Enclosure 3 PG&E Letter HBL-16-001 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

VOLUME 4, REVISION 32

Nuclear Power Generation NUMBER L-4 VOLUME 4 Humboldt Bay REVISION 32 EFFEC DATE 9-4-14 Power Plant PAGE 1 of1 TITLE APPROVED BY ORIGINAL SIGNED 9-4-14 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

DIRECTOR/PLANT MANAGER I DATE HB NUCLEAR (Procedure Classification- Quality Related)

1.0 DESCRIPTION

This document describes the Quality Assurance Plan to be applied to Humboldt Bay Power Plant Unit 3 during decommissioning, and includes Humboldt Bay Independent Spent Fuel Storage Installation (HB ISFSI) activities. The HBQAP satisfies the requirements of 10 CFR 50 Appendix B, and 10 CFR 72 Subpart G. In addition, NRC Approval No. 202, Revision 8 "Quality Assurance Program for Radioactive Material Packages" has approved the HBQAP as satisfying the provisions of 10 CFR 71 subpart H for the procurement, maintenance, repair and use of radioactive materials transport packages.

2.0 ATTACHMENTS 2.1 Humboldt Bay Quality Assurance Plan (HBQAP), Revision 32.

3.0 RESPONSIBLE ORGANIZATION Director, Quality

L-4 Attachment 2.1 Rev. 32 Page 1 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

TABLE OF CONTENTS Section Title Page INTRODUCTION 2 1.0 ORGANIZATION 3 2.0 QUALITY ASSURANCE PROGRAM 8 3.0 DESIGN CONTROL 10 4.0 PROCUREMENT DOCUMENT CONTROL 11 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 12 6.0 DOCUMENT CONTROL 13 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 14 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 15 9.0 SPECIAL PROCESSES 16 10.0 INSPECTION 17 11.0 TEST CONTROL 18 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 19 13.0 HANDLING, STORAGE, AND SHIPPING 20 14.0 INSPECTION, TEST, AND OPERATING STATUS 21 15.0 CONTROL OF NONCONFORMING CONDITIONS 22 16.0 CORRECTIVE ACTION 23 17.0 QUALITY ASSURANCE RECORDS 24 18.0 AUDITS 25 APPENDIX A APPLICABLE STRUCTURES, SYSTEMS, AND COMPONENTS 26 B ADMINISTRATIVE CONTROLS 28

L-4 Attachment 2.1 Rev. 32 Page 2 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

INTRODUCTION Pacific Gas and Electric (PG&E) has established and is implementing a comprehensive Quality Assurance Program for Humboldt Bay Power Plant Unit 3 (HBPP Unit 3) and Humboldt Bay Independent Spent Fuel Storage Installation (HB ISFSI) to assure compliance with established regulatory requirements set forth by the Nuclear Regulatory Commission (NRC). This Quality Assurance Program is described in the Humboldt Bay Quality Assurance Plan (HBQAP).

The Humboldt Bay QA Program consists of the HBQAP and implementing procedures and instructions. The HBQAP describes the responsibilities for implementing quality requirements; establishing and maintaining the QA Program; and assessing the performance of activities subject to theHBQAP.

The HBQAP is a comprehensive statement of the quality assurance controls governing the Important to Safety (ITS) Structures Systems and Components (SSC). The HBQAP describes the organizational structure, functional responsibilities, levels of authority, line of communication, and interfaces. The HBQAP satisfies the requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart Hand 10 CFR 72 Subpart G. The requirements for management and administrative controls are described in appendix B of this HBQAP.

The requirements and commitments contained in the HBQAP are mandatory and must be implemented, enforced, and adhered to by all individuals and organizations performing activities affecting quality. Workers are encouraged to actively participate in the continued improvement and implementation of the HBQAP. Any necessary changes should be promptly communicated and implemented.

The implementation of the requirements of the HBQAP is performed in a graded approach commensurate with any items or activities importance to safety. This graded approach is applicable to ITS SSCs and is responsive to NRC Regulatory Guide 7.10.

The HBQAP is implemented through the use of approved procedures (i.e. policies, procedures, manuals, instructions, or other documents) that provide written guidance for the control of ITS items and activities. The HBQAP also provides for development of documentation to demonstrate objective evidence of compliance with the stated requirements.

L-4 Attachment 2.1 Rev. 32 Page 3 of29 1.0 ORGANIZATION PG&E's efforts are to assure the quality and safety of the decommissioning of the HBPP Unit 3, packaging and transportation of radioactive material and the operation and maintenance of the HB ISFSI utilizing the HBQAP. The program is organized in a structured manner with clearly defined levels of authority, assignments of responsibility and lines of communication.

Assignment of the responsibility for an item or activity includes responsibility for its quality. The Quality Organization provides independent oversight of quality activities and maintains lines of communication with Senior Management.

PG&E has assumed full responsibility for the establishment and execution of the HBQAP prescribed herein, programs and administrative procedures. The work of executing selected portions of the HBQAP may be delegated to organizations external to PG&E; however, in all such instances, PG&E retains overall responsibility.

Specific responsibilities pertaining to quality assurance matters are assigned by the HBQAP and its implementing procedures and instructions to various individuals throughout PG&E. In each instance, the assignment of a responsibility to an individual includes with it a commensurate delegation of sufficient authority that the person can, in fact, fulfill that responsibility. Unless otherwise specifically prohibited, it is understood that the functions, tasks and activities necessary a

to carry out responsibility may be delegated to and performed by other qualified individuals.

All delegations of functions, tasks, activities and authority shall be documented. Individuals may fulfill more than one function unless_prevented by the need to maintain independence as specified in the HBQAP. .

Figure 1 illustrates the organizational structure, functional responsibilities, levels of authority, line of communication, and interfaces of persons and organizations performing activities governed by the HBQAP.

The functional responsibilities shown in Figure 1 are further described below. Generic titles are used for the functions and responsibilities. Differences (if any) between actual titles used in the organization are traceable to the HBQAP titles by the use of administrative procedures.

The PRESIDENT establishes the corporate policies, goals, and objectives related to all ofPG&E's activities and operations.

The SENIOR VICE PRESIDENT -ENERGY SUPPLY reports to the President and oversees PG&E's energy procurement and power generation assets, including nuclear, fossil and hydroelectric, cogeneration and renewable sources, with a focus on planning for and delivering reliable, affordable and clean electricity and gas for distribution to PG&E's customers.

The SENIOR VICE PRESIDENT - CHIEF NUCLEAR OFFICER (CNO) is responsible for overall HBPP Unit 3 decommissioning, and HB ISFSI activities, safety and for taking measures needed to ensure acceptable performance ofthe HB ISFSI staff in designing, fabricating, constructing, testing, operating, modifying, decommissioning, and providing technical support to the HB ISFSI and during HBPP Unit 3 decommissioning.

L-4 Attachment 2.1 Rev. 32 Page 4 of29 The CNO, or designee, as specified in administrative procedures, approves and signs official company correspondence to the U.S. Nuclear Regulatory Commission (NRC) or its representatives. The CNO approves revisions to the QA Program as described herein that constitute a reduction in a commitment made to the NRC. The CNO is responsible for designating individual(s) to perform an Independent Management Review to periodically assess the effectiveness of the HB QA Program.

The DIRECTOR- QUALITY (Quality Director) is responsible for assuring that the HBQAP and implementing procedures are effectively implemented and complied with by all involved organizations, both internal and external to PG&E. The Quality Director has the organizational freedom and requisite authority to assess, review, inspect, audit, and monitor the conduct of quality activities to assure compliance with the HBQAP and other regulatory requirements. The Quality Director reports to the CNO, and has access to the President, HB Director, and appropriate managers for any significant quality problem or deficiency.

The Quality Director is responsible for maintaining and submitting for approval changes to the HBQAP. The Quality Director is responsible for the review of all regulatory submittals as they pertain to the HBQAP and his/her concurrence is required prior to submittal.

Reporting to the Quality Director are the quality assurance, supplier quality and independent quality control inspection functions. These individuals or groups do not have direct responsibility for performing the work being verified; are trained and qualified in QA concepts and practices; are independent of the organization responsible for performing the task and have direct access to management levels. The Quality Organization is sufficiently free from direct pressures for cost and schedule that assures the ability to: (a) identify quality problems; (b) initiate, recommend, or provide solutions through designated channels; and (c) verify implementation of solutions.

Individuals within the Quality Organization have the authority to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming material. Organizational positions with stop work authority are identified in the implementing procedures.

The DIRECTOR- HUMBOLDT BAY (HB Director) is responsible for the conduct of activities related to the HBPP Unit 3 and the HB ISFSI. This includes responsibility for operation, maintenance, engineering, radiation protection, training, security, radioactive material packaging, transport and decommissioning. The day-to-day responsibilities are delegated to and executed by the HB management team that directly reports to the HB Director. Specific responsibilities are described in administrative procedures.

The HB Director is responsible for the Independent Safety Reviewer process. The HB Director is also responsible for the development of, programs, procedures, and instructions required for HBPP Unit 3 and HB ISFSI within the requirements and/or limits established in the HBQAP; HBPP Unit 3 and HB ISFSI Technical Specifications; and administrative guidelines established in the HBPP Unit 3 Defueled Safety Analysis Report (DSAR) and HB ISFSI Final Safety Analysis Report (FSAR). The HB Director is the Design Authority for the HBPP Unit 3 and HB ISFSI.

L-4 Attachment 2.1 Rev. 32 Page 5 of29 The HB Director shall delegate these responsibilities to other members of the HB management team during his/her absence.

The ENGINEERING MANAGER is responsible for technical aspects of the engineering and design of HBPP Unit 3 and HB ISFSI SSCs established for monitoring system performance and trends; performance of modifications to the HB ISFSI; configuration control and design bases defense and management; quality classification of SSCs; and the specification of technical and quality requirements for the purchase of services, materials and equipment.

The ISFSI MANAGER is responsible for the operation and maintenance of the HB ISFSI.

The RADIATION PROTECTION MANAGER is responsible for implementing the radiation protection program for the protection of the workers and members of the public.

An INDEPENDENT MANAGEMENT REVIEW is periodically performed to assess the effectiveness of the HB QA Program, including audit program. Results of the Independent Management Review are provided to the CNO for corrective action, as necessary. Individual(s) that perform the Independent Management Review are appointed by the CNO. In addition, the Independent Management Review includes oversight of the HBQAP implementation and matters relating to decommissioning activities and safe storage of spent nuclear fuel, as directed by the CNO.

INDEPENDENT SAFETY REVIEWER(S) (ISR) perfonns independent safety reviews of proposed changes, tests and experiments to SSCs, activities, program documents and procedures that are subject to the HBQAP requirements. ISRs shall be individuals without direct responsibility for the performance of these activities under review, and shall be competent and knowledgeable in the subject area being reviewed. ISRrs are designated by the HB Director.

CORPORATE SUPPORT for ITS activities includes, but is not limited to, procurement, records, employee concerns, and licensing. Each organization documents and maintains a written description of its internal organization.

SUPPLIERS that provide ITS SSCs or services are required to comply with the HBQAP or to a QA Program approved by PG&E. Supplier QA Programs are required to comply with the applicable portions of 10 CFR 50, Appendix B; 10 CFR 71, Subpart H; or 10 CFR 72, Subpart G.

The Quality Program requirements are defined in the contract or similar procurement document.

Suppliers to PG&E are required to document their internal organization, to the extent necessary for PG&E, to assure the supplier is capable of effectively managing, directing, and executing the requirements of the procurement documents.

L-4 Attachment 2.1 Rev. 32 Page 6 of29 Staff Qualifications Except as specified in other portions of the HBQAP, each member of the staff shall meet or exceed the following minimum qualifications:

For HB Unit 3, the minimum qualifications of ANSI N18.1 (1971) for comparable positions are applicable.

For the HB ISFSI, the minimum qualifications are described in the ISFSI FSAR.

The following requirements and clarifications apply to the positions listed below, and are applicable to both HBPP Unit 3 and the HB ISFSI; The RADIATION PROTECTION MANAGER shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2, April, 1987.

The QUALITY DIRECTOR shall have knowledge of QA regulations, policies, practices, and standards; and experience working in QA, nuclear power plant, fuel storage facility, or in a similar highly technological industry. At the time of assignment to the active position, the Quality Director shall have six years of experience in implementing Quality Assurance.

At least one year of these six years of experience shall be nuclear power plant or fuel storage facility experience in the overall implementation of a Quality Assurance Program (QAP). A minimum of one year of this six-year experience requirement shall be related technical or academic training. A maximum of four years of this six-year experience requirement may be fulfilled by related technical or academic training.

The one year of qualifying nuclear power plant or fuel storage facility experience in the overall implementation of the Quality Assurance program can be obtained outside the Quality Assurance organizations.

L-4 Attachment 2.1 Rev. 32 Page 7 of29 Figure 1 Organization Chart President PG&E Senior Vice President Energy Supply Corporate or Contract Support

• Records

• Licensing ---,

• Procurement Senior Vice President

• Employee Concerns ChiefNuclear Officer

• Other (as required)

I I Director Director Independent Quality Humboldt Bay Management Review I

L----------------------------------------------

I I I Engineering ISFSI Radiation Protection Independent Safety Manager Manager Manager Reviewers

L-4 Attachment 2.1 Rev. 32 Page 8 of29 2.0 QUALITY ASSURANCE PROGRAM 2.1 PROGRAM APPLICABILITY The HBQAP requirements, apply to SSCs designated as ITS in Appendix A.

The quality requirements for the management and administrative programs in Appendix B that support ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP.

The quality requirements for the management and administrative programs that support HBPP Unit 3 are designated in administrative programs and procedures.

A graded approach is used to define the controls applied to quality activities commensurate with the activity's impmiance to safety. The graded approach also applies to the level of quality oversight for quality activities.

Activities that require review and concurrence by Quality personnel are delineated in administrative procedures and are based on the activity's importance to safety.

The effectiveness of the implementation of the HBQAP shall be assured through Quality Related programs, procedures and drawings.

2.2 PROGRAM CONTROL The status and adequacy of the HBQAP shall be regularly monitored and it shall be revised as necessary to improve its effectiveness or to reflect changing conditions.

The HBQAP, including any changes, supplements, or appendices are issued and maintained as controlled documents. Changes to the HBQAP requirements shall be made in accordance with 10 CPR 50.54.

Changes to the HBQAP that do not reduce commitments shall be included in the periodic updates required

• by 10 CFR 50.71. Prior to issuance for use, proposed changes to the HBQAP that reduce commitments are reviewed and concurred with in writing by the Quality Director and are approved by the CNO, or designee, prior to being submitted to and approved by the NRC in accordance with 10 CPR 50.54.

Implementation of the HBQAP is accomplished through separately issued procedures, instructions, and drawings. Each organization is responsible for the establishment and implementation of detailed procedures and instructions prescribing the quality activities for which they are responsible. Such documents are derived from the requirements and reflect the responsibilities specified in the HBQAP.

Questions or disputes involving interpretations of HBQAP requirements and commitments are referred to the Quality Director for resolution. Questions or disputes involving the responsibilities defined in the HBQAP are referred to the CNO.

Questions or disputes involving other quality matters are resolved by referring the matter, in a timely manner, to successively higher levels of management until, if necessary, the matter reaches the management level which has direct authority over all contesting parties.

L-4 Attachment 2.1 Rev. 32 Page 9 of29 2.3 INDOCTRINATION AND TRAINING Indoctrination and training for personnel implementing ITS activities are conducted to assure suitable proficiency is achieved and maintained. The extent of indoctrination and training is commensurate with the scope, complexity and importance to safety of the assigned task; in conjunction with the education and experience of the individual. Personnel involved in implementing the activities within the scope of the HBQAP shall be responsible for the quality of their work. At a minimum, these personnel shall receive:

• Indoctrination in the requirements of the HBQAP;

• Indoctrination in their organization's implementing procedures; and

• Training and quaJification in tasks requiring special skills or knowledge, as required.

Indoctrination, training, qualification, andre-qualification (when applicable) shall be prescribed and performed in accordance with written procedures; and applicable codes, standards and regulatory requirements; which specify the management responsibilities; training areas; frequency of training; method of qualification and requalification; and documentation requirements.

Training and qualification records are maintained in accordance with implementing procedures.

2.4 REGULATORY COMMITMENTS Regulatory commitments, where applicable, are specified in the Unit 3 DSAR, ISFSI FSAR, Technical Specifications or Licenses.

L-4 Attachment 2.1 Rev. 32 Page 10 of29 3.0 DESIGN CONTROL Design Control applies to the 10 CFR 72 SSCs designated as ITS in Appendix A. Design activities shall be controlled to assure that design, technical, and quality requirements are correctly translated into design documents and that changes to design and design documents are properly controlled. Design control procedures shall address responsibilities for:

( 1) Interface contro 1 (2) Design input (3) Design performance (4) Design verification (5) Design change Systematic methods shall be established and documented for communicating needed design information across the external and internal design interfaces, including changes to the design information, as work progresses. Document control measures shall be established for design documents that reflect commitments in applicable design basis documents (e.g., specifications, calculations, computer programs, system descriptions, drawings).Provisions for design input shall defme the technical objectives for SSCs being designed or analyzed. Design inputs shall be documented, reviewed and approved and translated to design documents. Required design analyses (such as stress, thermal, hydraulic and accident analysis; material compatibility; maintenance and repair and ALARA considerations) shall be performed in a planned, controlled, and correct manner. PG&E procedures shall identify the review and approval responsibilities for design analyses.

PG&E shall provide for reviewing, confrrming, or substantiating the design to assure that the design meets the specified design inputs. Design verification shall be performed by competent individuals or groups other than those who performed the original design, but who may be from the same department.

The results of the design verification efforts shall be documented with the identification of the verifier clearly provided. The design verification shall be completed prior to relying upon the component system or structure to perform its function. Procedures shall assure that verified computer codes are certified for use and that their applicability is specified.

Changes or modifications to the designated SSCs in Appendix A shall be approved by the Design Authority, or designee, as specified in administrative procedures, prior to implementation. Procedures for implementing design changes, including field changes, shall assure that the impact of the change is carefully considered, required actions documented, and information concerning the change transmitted to affected persons and organizations. These changes shall be subjected to design control measures commensurate with those applied to the original design.

Nonconforming activities such as, deviations, errors or deficiencies in approved design documents, including design methods (such as computer codes), shall be controlled as described in Sections 15.0 and 16.0.

L-4 Attachment 2.1 Rev. 32 Page 11 of29 4.0 PROCUREMENT DOCUMENT CONTROL Procurement Document Control applies to SSCs designated as ITS in Appendix A. Procurement documents shall include those requirements necessary to assure that the items and services to be provided will be of the desired quality.

Procedures that implement procurement document control shall describe the organizational responsibilities for procurement planning; preparation, review, approval and control of procurement documents; supplier selection; bid evaluations; identification of replacement parts, where applicable; and review and evaluation of the supplier's QA Program prior to initiation of activities affected by the program.

Procedures shall be established to review the adequacy of the technical and QA requirements stated in procurement documents; determine that requirements are correctly stated, inspectable, and controllable; assure adequate acceptance and rejection criteria; and provide for the preparation, review, and approval of procurement documents in accordance with applicable requirements. The review and documented concurrence of the adequacy of technical, and QA requirements stated in procurement documents shall be performed by independent personnel trained and qualified in applicable QA practices and concepts.

Changes to procurement documents shall be subject to the same controls as the original document.

L-4 Attachment 2.1 Rev. 32 Page 12 of29 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Controls for Instructions, Procedures, and Drawings apply to SSCs designated as ITS in Appendix A.

Activities, other than skill of the craft, shall be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings. These documents shall include quantitative or qualitative acceptance criteria for verifying that an activity was satisfactorily accomplished, where applicable (i.e., verification activities for procurement, inspection tests).

Procedures prescribing a preplanned method of conducting activities required by the HBQAP shall be established in accordance with the applicable regulation, codes, standards, and specifications.

Changes to or deviations from established instructions, procedures, or drawings require the same review and approval as the original document. Instructions, procedures, or drawings, including changes and deviations, subject to the HBQAP shall be maintained.

Administrative controls shall be established that provide the methods by which temporary changes can be made to approved procedures, including the designation of persons authorized to approve such changes.

Temporary changes that clearly do not change the intent of the approved procedure from the standpoint of nuclear safety may be approved by two members of the HBPP/ISFSI management team. Such changes shall be documented and, if appropriate, incorporated into the next revision of the affected procedure.

Administrative controls for approval and timely notification or training of personnel affected by the temporary change shall be implemented.

Procedures subject to the HBQAP shall be periodically reviewed as described in administrative procedures.

L-4 Attachment 2.1 Rev.32 Page 13 of29 6.0 DOCUMENT CONTROL Document Control applies to SSCs designated as ITS in Appendix A, and the administrative programs described in Appendix B. Documents and changes to documents that prescribe or verify activities affecting quality shall be controlled in a manner that precludes the use of inappropriate or outdated documents.

A document control system shall be established to identify the current revision of instructions, procedures, specifications, drawings, and procurement documents. Written procedures shall identify those responsible for preparing, reviewing, approving, and issuing documents.

Procedures and instructions shall assure that documents, including changes, are prepared; reviewed by a qualified individual other than the person who generated the document; approved for release by authorized personnel; distributed to the location where the activity is performed prior to commencing work; and used in performing the activity.

Procedures, instructions and other documents that implement HBQAP requirements shall be reviewed and concurred with by the Quality Organization. Revisions to procedures, instructions and other documents shall also be reviewed and concurred with by the Quality Organization, as specified in administrative procedures.

L-4 Attachment 2.1 Rev. 32 Page 14 of29 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Control of Purchased Material, Equipment, and Services applies to SSCs and associated activities that are designated as ITS in Appendix A. Supplier activities that provide purchased material, equipment, and services shall be monitored as necessary to assure such items and services meet procurement document requirements.

Procedures shall describe each organization's responsibilities for the control of purchased material, equipment, and services, including the interfaces between all affected organizations.

All materials, equipment, and services shall meet the specified technical and quality requirements.

Verification that a supplier can meet the specified technical and quality requirements shall be documented.

A Supplier's QA Program that satisfies specified quality requirements shall be listed on the PG&E Qualified Suppliers List. The PG&E Qualified Suppliers List shall be controlled.

Suppliers of commercial grade calibration services may be qualified based on their accreditation by a nationally-recognized accrediting body, as an alternative to qualification by supplier audit, commercial grade survey, or in-process surveillance.

The effectiveness of contractors and supplier's quality controls shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service. Supplier performance and compliance with procurement documents are monitored by source verification, receipt inspection, or a combination of the two.

Source verification and/or receipt inspection activities are performed to assure that the requirements of the procurement documents have been met. Accepted items are appropriately marked, removed from the inspection area, and located in a controlled storage area until use.

ITS SSCs and services from a supplier whose QA Program has not been reviewed or accepted may be used provided additional controls such as source inspection, special receipt instructions, and/or testing are imposed. These additional controls shall be documented and approved by the appropriate level of management.

Spare and replacement parts are procured such that their performance and quality are at least equivalent to those of the parts that will be replaced. Commercial grade items are controlled by written procedure.

Designated Quality personnel or other personnel with appropriate qualifications are responsible for assuring source inspections, surveys, or audits of suppliers are performed as necessary.

Documentation of acceptance shall be available prior to installation or acceptance for use.

L-4 Attachment 2.1 Rev. 32 Page 15 of29 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS The Identification and Control of Materials, Parts and Components apply to SSCs designated as ITS in Appendix A. Materials, parts, and components shall be identified and controlled in a manner to preclude the use of incorrect or defective items.

Implementing procedures shall describe the organizational responsibilities and controls to ensure that only correct and accepted items are used.

Materials, parts, and components, including partially fabricated subassemblies, batches, lots, and consumables, shall be identified in a manner that each can be traceable to its applicable drawing, specification, or other technical documentation at any stage from initial receipt through fabrication, installation, repair, modification or use of an item. When required by code, standard, or specification; traceability of materials, parts, or components to specific inspection or test records shall be provided for and verified.

Items having limited shelf or operating life are controlled to preclude use after the shelf life or operating life has expired.

Identification marking, where employed, shall be clear, unambiguous, and indelible and its application shall not impair the function of the identified item or any other item. When an item is subdivided, the identifying marking shall be transferred to each resulting part. Markings shall not be rendered illegible by treatment, process, assembly, installation, or coating unless other means of identification and determining acceptability are provided.

L-4 Attachment 2.1 Rev. 32 Page 16 of29 9.0 SPECIAL PROCESSES Special Processes apply to SSCs designated as ITS in Appendix A. Special processes shall be controlled and performed by qualified personnel using written procedures or instructions in accordance with applicable codes, standards, specifications, criteria, or other special requirements.

A special process is an activity, in which the quality of the result is highly dependent upon either process variables or the skill and performance of the person doing the work, and the specified quality is difficult to verify by inspection and test after the process is completed.

Special processes include, but are not limited to: welding, heat treating, nondestructive examination, and chemical cleaning.

Equipment used for special processes shall be qualified, maintained, stored, issued in accordance applicable procedures and operated by qualified personnel.

The implementing instructions shall contain the criteria for assuring proper process control and compliance with applicable codes, standards, QA procedures, and design specifications. Records of qualifications and controls shall be maintained.

L-4 Attachment 2.1 Rev. 32 Page 17 of29 10.0 INSPECTION Inspection activities apply to SSCs designated as ITS in Appendix A. A comprehensive program of inspection of items and activities affecting quality shall be conducted to verify conformance with established requirements. Procedures shall describe the organizational responsibilities necessary to carry out the inspection program.

Inspections shall be planned in accordance with approved procedures, and based on drawings, specifications, and other controlled documents. Inspections shall be performed in accordance with written and approved inspection plans and/or inspection procedures to verify that the quality of items and activities conform to applicable and documented instructions, procedures, and drawings. Acceptance/rejection criteria and mandatory quality control inspection hold points shall be identified, where applicable. Work shall not proceed beyond such hold points without the appropriate documented concurrence by Quality personnel or assigned and authorized personnel.

The inspection results, including acceptance/rejection criteria, shall be documented and evaluated.

Unacceptable inspection results shall be evaluated and resolved in accordance with procedures. Where applicable, modifications, repairs and replacements; are re-inspected to the same standard or method to verify acceptability. Inspection records shall be maintained.

Inspections shall be performed by qualified individuals other than those who performed or directly supervised the activity being inspected.

L-4 Attachment 2.1 Rev.32 Page 18 of29 11.0 TEST CONTROL Test Control applies to the 10 CFR 72 SSCs designated as ITS in Appendix A.

A program of testing shall be conducted, as necessary, to demonstrate that SSCs will perform satisfactorily in service. This program shall ensure that the necessary testing is identified and performed at the appropriate time in accordance with written test procedures that incorporate or reference the requirements and acceptance limits contained in the applicable design documents.

The procedures that implement testing shall specify the appropriate prerequisites for the test (e.g.

environmental conditions, specification of instrumentation, and completeness of tested item), sufficient instruction for the performance of the test, witness or hold points, acceptance/rejection criteria and limits, and the required test documentation. The procedures shall provide for evaluation and documentation of the test results; data; and their acceptability as determined by a qualified person or group. Test results that do not meet the acceptance criteria shall be documented and evaluated to determine the appropriate corrective action. Where applicable, modifications, repairs, and replacements; are re-tested to verify acceptability. Test records shall be maintained.

L-4 Attachment 2.1 Rev. 32 Page 19 of29 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT The Control of Measuring and Test Equipment applies to SSCs designated as ITS in Appendix A.

Organizational responsibilities shall be delineated for establishing, implementing, and assuring the effectiveness of the calibration program for measuring and test equipment (M&TE).

M&TE, including reference standards, used to determine the acceptability of items or activities shall be maintained within prescribed accuracy limits, suitable range, type, and accuracy to verify conformance with requirements.

Procedures for control of M&TE shall provide for the identification (labeling, codes, or alternate documented control system), recall, and calibration (including documented pre-calibration checks) of the M&TE. The calibration procedures shall delineate special controls, where applicable, for usage, handling, and storage required for environmental conditions such as temperature, humidity, cleanliness, or radiation to maintain accuracy or operating characteristics of the M&TE.

Calibrations standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shall be ~

documented. Special calibration and control measures are not required when normal commercial practices provide adequate accuracy Instruments shall be calibrated prior to use. The calibration intervals, whether calendar- or usage-based, shall be predetermined and to the extent practical, consistent with the instrument manufacturer's guaranteed repeatability and/or the user's experience. Indication of expiration, if feasible, will be displayed on or with the M&TE. Special calibration shall be required whenever the accuracy of the equipment is suspect. M&TE or instrumentation found to be out of calibration shall be evaluated and documented.

Records of M&TE usage shall be maintained, such that measures may be taken to determine the validity of previous inspections performed and the acceptability of items inspected or tested since the previous calibration when the M&TE is suspect.

L-4 Attachment 2.1 Rev. 32 Page 20 of29 13.0 HANDLING, STORAGE, AND SHIPPING Handling, Storage and Shipping requirements apply to SSCs designated as ITS in Appendix A. Material .

and equipment shall be handled, stored, and shipped in accordance with design and procurement requirements in a manner that will prevent damage, deterioration, or loss.

Special coverings, equipment, and protective environments shall be specified and provided where necessary for the protection of items from damage or deterioration. When such special protective features are required, their existence shall be verified and monitored as necessary to assure they continue to serve their intended function.

Special handling tools and equipment shall be provided where necessary to ensure items can be handled safely and without damage.

Markings or labeling shall be used to indicate the presence of special environments or the need for special controls. Provisions shall be described for the storage of chemicals, reagents (including control of shelf life); lubricants, and other consumable materials.

Special handling, preservation, storage, cleaning, packaging, and shipping requirements are established and accomplished by suitably trained individuals in accordance with predetermined work and inspection instructions.

L-4 Attachment 2.1 Rev. 32 Page 21 of29 14.0 INSPECTION, TEST, AND OPERATING STATUS Inspection, Test and Operating Status requirements apply to SSCs designated as ITS in Appendix A. The inspection, test, and/or operating status of material, equipment, and operating systems shall be readily apparent and verifiable.

The procedures used to indicate status shall provide means for assuring that required inspections and tests are performed in the prescribed sequence; and acceptability is indicated; to prevent inadvertent use or operation. Items accepted and released are identified to indicate their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work. Deviations from the prescribed sequence shall be subject to the same level of control as the generation of the original sequence to prevent the bypassing or omission of a required test or inspection.

The operating status of nonconforming, inoperable or malfunctioning ITS SSCs shall be identified and documented to prevent inadvertent operation. Identification of status may be by such means as, but not limited to, tags, stamps, markings, labels, or travelers. In some instances, records traceable to the item may be used.

The procedures implementing control of inspection, test, and operating status shall clearly delineate authority for the application, change, or removal of a status identifier.

L-4 Attachment 2.1 Rev. 32 Page 22 of29 15.0 CONTROL OF NONCONFORMING CONDITIONS The Control of Nonconforming Conditions applies to SSCs designated as ITS in Appendix A. Items and activities that do not conform to requirements shall be controlled in a manner that will prevent their inadvertent use or installation. Nonconforming conditions are documented, reviewed and accepted, rejected, repaired or reworked in accordance with quality procedures. Organizations affected by nonconforming conditions shall be notified of such conditions.

Measures shall be established to identify, label and segregate nonconforming items to indicate their unacceptable status and to prevent inadvertent use or installation until the nonconformance is properly dispositioned. Labels associated with a nonconforming item shall only be removed by authorized personnel.

The acceptability of nonconforming items shall be verified and documented prior to use. Documentation shall include a description of the change, waiver, or deviation that has been accepted.

In cases where required documentary evidence that items have passed required inspections and tests is not available, the associated materials or equipment shall be considered nonconforming. Until suitable documentary evidence is available to show that the material or equipment is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.

Nonconforming conditions shall be processed as conditions adverse to quality in accordance with Section 16.0.

L-4 Attachment 2.1 Rev. 32 Page 23 of29 16.0 CORRECTIVE ACTION Corrective Action applies to SSCs designated as ITS in Appendix A. Conditions adverse to quality shall be identified, controlled, reviewed, and evaluated to determine remedial action and corrective action and implement those actions as soon as practicable.

A systematic review and evaluation of conditions adverse to quality shall be conducted and documented.

Conditions adverse to quality shall include, but not be limited to: engineering, design, and drafting errors; equipment failures and malfunctions; abnormal occurrences; deficiencies; deviations; and defective material, equipment, and services. The evaluation and corrective action taken should be based on safety significance.

Findings and actual or recommended corrective actions shall be reported to management for review and assessment. Corrective actions shall be accomplished in a timely manner commensurate with the safety significance.

Significant conditions adverse to quality shall be evaluated for reportability to the NRC. Significant conditions adverse to quality, the cause of the condition, and the corrective action taken to preclude recurrence shall be documented and reported to management. Follow-up reviews shall be conducted to verify that the corrective action was properly implemented and effective in correcting the identified condition.

L-4 Attachment 2.1 Rev. 32 Page 24 of29 17.0 QUALITY ASSURANCE RECORDS The requirements for Quality Assurance Records apply to those SSCs that are designated as ITS described in Appendix A.

Sufficient records shall be maintained to furnish evidence of both the quality of items and activities affecting quality and to meet applicable code, standard, regulatory, and license requirements. The records include all documents referred to, or described in the HBQAP as records or required by quality procedures.

At a minimum quality records include operating logs, maintenance and modification procedures, related inspection results, and reportable occurrences and other records as required by the applicable license, Technical Specifications and Code of Federal Regulations. Additionally, records required by the HBQAP, and furnished by vendors, suppliers, subcontractors, and contractors that perform or supply quality-related activities or SSCs that ITS are also QA Records and shall be maintained.

A management control system for the collection, storage, and maintenance of completed quality assurance (QA) records shall be maintained. This records management program shall be designed and implemented to assure that the QA records are complete, readily retrievable when needed, and protected from damage or destruction during storage by fire, flooding, theft, environmental conditions, or other causes.

QA records stored electronically will follow the guidance for electronic records management given in the Nuclear Information and Records Management Association (NIRMA) technical guidelines, TG 11-1998, "Authentication of Records;" TG 15-1998, "Management of Electronic Records;" TG 16-1998, "Software Configuration Management and Quality Assurance;" and TG 21-1998, "Electronic Records Protection and Restoration." QA records will be stored on electronic media (that is, optical disk, magnetic tape, network array, etc.) meeting the requirements of the NIRMA guidelines. Alternately, records stored on optical disks may meet the requirements of Generic Letter 88-18, "Plant Record Storage on Optical Disk," dated October 20, 1988. Information Systems will determine the appropriate electronic media. Regardless of the electronic media selected, the process must be capable of producing legible, accurate, and complete records during the required retention period.

Electronic QA records, including backup copies, are stored in two redundant electronic media storage systems at physically-independent electronic locations. QA records in electronic format (e.g., pdf format) may be filed and stored on the electronic media storage systems. Selected QA records on other media (e.g.,

paper hardcopies, microfilm, DVDs) are maintained in a Permanent Records Storage Facility.

Detailed records for items or activities shall be specified by instructions, procedures, drawings, or specification or other documents that prescribe the item or activity and shall be generated by the organization responsible for the item or activity including PG&E and non-PG&E organizations.

L-4 Attachment 2.1 Rev. 32 Page 25 of 29

• 18.0 AUDITS The requirements for Audits apply to SSCs designated as ITS in Appendix A. Measures shall establish a comprehensive system of planned and periodic audits. These assess, monitor and verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the HBQAP and implementing activities.

Internal and supplier audits are performed in accordance with written procedures and/or check lists.

Audits are performed by qualified personnel not having direct responsibility in the areas audited.

Auditors shall have experience, training or qualifications commensurate with the scope and complexity of their audit responsibility.

Scheduling, preparation, personnel selection, performance, reporting, response, follow-up action, and records management are performed in accordance with written procedures. Audit scopes and schedules are established to meet applicable regulatory requirements and are based on the status and safety significance of the activities to be audited.

Detailed audit schedules are documented in accordance with Quality procedures. At a minimum, the conformance of decommissioning activities and ISFSI operations to applicable regulatory requirements is audited at least once every 24 months or more frequently as performance dictates.

External audits of suppliers providing ITS materials, parts, equipment or services are scheduled and performed based on the importance of an sse or activity to confirm implementation of their Quality Program requirements, but not less than every 3 years.

Audits that are not mandated by regulation have a grace period of up to 90 days, when the urgency of other priorities makes meeting the specified schedule dates impractical. For audit activities deferred using a grace period, the next scheduled due date shall be based on the originally scheduled due date, but may not exceed the original due date plus 90 days.

Audit reports shall be prepared, issued to and reviewed by responsible management of both the audited and auditing organizations. Audit records shall be generated and retained. Follow-up action, including re-audit of deficient areas, shall be taken, where applicable.

L-4 Attachment 2.1 Rev. 32 Page 26 of29 APPENDIX A IMPORTANT-TO-SAFETY STRUCTURES, SYSTEMS AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart Hand 10 CFR 72 Subpart G will be applied, as a minimum, to quality activities affecting the ITS SSCs associated with spent fuel storage and transportation package that are listed below. The quality category is based on the guidance in NUREG/CR-6407. In addition, the HB ISFSI FSAR, Holtec International HI-STORM Safety Analysis Report (SAR), Holtec International HI-STAR SAR and associated specifications include additional classification information.

NOTE There are no HBPP safety related SSCs remaining at the site.

The quality classification ofNRC Licensed HB ISFSI Dry Fuel Storage Components and Transportation Packages is made by the NRC Certificate Holder. The Certificate Holder is responsible for design and licensing controls for these components under their NRC approved Quality Assurance Program. PG&E utilizes these types of components and packages under the provisions of a NRC General License for Radioactive Material Transportation Packages (10 CFR 71) and Spent Fuel and GTCC Storage (1 0 CFR 72).

IMPORTANT TO SAFETY AS DEFINED BY 10 CFR 71 AND 10 CFR 72 A D*ry S;pen t F ueI an d GTCC Storage (10 CFR 72) sse Quality Category Design/License Responsible Multi-Purpose Canister

• A PG&E Fuel Basket and Basket Spacers A PG&E Damaged Fuel Container A PG&E Hi-Star 100 HB Overpack A PG&E Transporter Lift Links A PG&E GTCC Waste Container A PG&E Hi-Star HB GTCC Overpack A PG&E HB ISFSI Storage Vault B PG&E Fuel Spacers B PG&E Transporter Connector Pins B PG&E Helium Fill Gas B PG&E Lid Retention Device B PG&E Cask Transporter B PG&E Process Waste Container B PG&E B. Transport of Spent Fuel and GTCC Waste (10 CFR 71) sse Quality Category Design/License Responsible Multi-Purpose Canister A Holtec International Fuel Basket and Basket Spacers A Holtec International Damaged Fuel Container A Holtec International Hi-Star 100 HB Overpack A Holtec International GTCC Waste Container A Holtec International Hi-Star HB GTCC Overpack A Holtec International Fuel Spacers B Holtec International Helium Fill Gas B Holtec International

L-4 Attachment 2.1 Rev. 32 Page 27 of29 C. Radioactive Material Transport Packages- Greater than Type A Shipments 10 CFR 71)

NRC Certificate Holder*

• Radioactive Material Transport Packages subject to the provisions of 10 CFR 71, Subpart C, "General Licenses" are "Important-to-Safety" and subject to the applicable requirements of the HBQAP. SSC and Quality Category are as determined by the NRC Certificate Holder for the cask chosen for the shipment.

L-4 Attachment 2.1 Rev. 32 Page 28 of29 APPENDIXB ADMINISTRATIVE CONTROLS 1.0 PROGRAMS AND PROCEDURES The program and procedures listed below shall be established and controlled to support HBPP Unit 3 and/or HB ISFSI.

a) Radiation Protection Program b) Emergency Plan c) Radioactive Effluent Control Program d) Security Program (as defined in security license bases documents) e) Radiological Environmental Monitoring Program f) Fire Protection Program The management and administrative programs quality requirements applicable to ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP as described in administrative procedures. To assure compliance with applicable regulatory and quality requirements for the management and administrative programs that support HBPP Unit 3 are designated in administrative programs and procedures.

2.0 RADIOLOGICAL MONITORING Administrative controls for radiological monitoring of gaseous effluents and the environment shall be controlled and implemented to ensure conformance with USNRC Regulatory Guide 4.15 (December 1977).

3.0 TECHNICAL SPECIFICATION ACTIVITIES In addition to the applicable quality assurance requirements specified in the HBQAP, Technical Specification activities shall be controlled in accordance with the Limiting Conditions for Operations (LCO) and Surveillance Requirements (SR).

4.0 OFFSITE DOSE CALCULATION MANUAL The Offsite Dose Calculation Manual (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, calculation of gaseous effluent monitoring alarm and trip setpoints, and conduct of the radiological environmental monitoring program. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities and descriptions of the information that should be included in the Annual Radiological Environmental Monitoring Report, and Annual Radioactive Effluent Release Report.

Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

i) sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change( s), and ii) a determination that the change( s) will maintain the level of radioactive effluent control required by 10CFR 20.1302, 40CFR Part 190, 10CFR 50.36a and Appendix I to 10CFR 50, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

L-4 Attachment 2.1 Rev. 32 Page 29 of29

2. Shall become effective after review and approval of the Plant Manager; and

3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented 5.0 RADIOACTIVE EFFLUENT CONTROLS PROGRAM This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable (ALARA). The program (1) shall be contained in the ODCM, (2) shall be implemented by written procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded.

6.0 REPORTING REQUIREMENTS The following reports shall be submitted in accordance with 10 CPR 50.4.

6.1 Occupational Radiation Exposure Report An annual report shall be made of personnel exposure, in accordance with the requirements of 10 CFR Part 20.2206. The report shall be submitted by April30 of each year.

6.2 Annual Radiological Environmental Monitoring Report The Annual Radiological Environmental Monitoring Report covering the operation of the unit during the previous calendar year shall be submitted by May 1 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the ODCM, and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of radiological environmental samples and of environmental radiation measurements taken during the period pursuant to the quality related locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual report.

6.3 Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Report covering the activities of the unit in the previous year shall be submitted prior to April 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary ofthe quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.l.

Pacific Gas and Electric Company Edward D. Halpin Diablo Canyon Power Plant Senior Vice President P.O. Box 56 Avila Beach, CA 93424 Power Generation and Chief Nuclear Officer 805.545.4100 E-Mail: El H8@pge.com January 29, 2016 PG&E Letter HBL-16-001 U.S. Nuclear Regulatory Commission 10 CFR 50.71 ATTN: Document Control Desk 10 CFR 50.54 Washington, DC 20555-0001 Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit 3 Revision 11 to the Defueled Safety Analysis Report and Revision 33 to the Humboldt Bay Quality Assurance Plan

Dear Commissioners and Staff:

Pursuant to 10 CFR 50.71(e), Pacific Gas and Electric Company (PG&E) is submitting the Humboldt Bay Power Plant, Unit 3 Defueled Safety Analysis Report (DSAR), Revision 11, in accordance with 10 CFR 50.4(b)(6). The changes contained in Revision 11 of the DSAR include changes made under the provisions of 10 CFR 50.59 since DSAR, Revision 10, was submitted to the NRC in PG&E Letter HBL-14-003, dated February 4, 2014, and reflect the current plant configuration and organization through November 20, 2015. contains the DSAR, Revision 11, which replaces Revision 10 in its entirety. Revision bars are shown in the margins with an identifying revision change number.

PG&E is also submitting Revision 33 of the Humboldt Bay Quality Assurance Plan (QAP) in accordance with 10 CFR 50.54(a)(3). Enclosure 2 contains Revision 33 to the Humboldt Bay QAP in its entirety. Revision 31 was submitted to the NRC in PG&E Letter HBL-14-003, dated February 4, 2014, with DSAR Revision 10. Revision bars shown in the margins of QAP Revision 33 indicate changes made between QAP Revisions 32 and 33. Enclosure 3 contains QAP Revision 32 in its entirety. Revision bars shown in the margins of QAP Revision 32 indicate changes made between QAP Revisions 31 and 32.

PG&E makes no new or revised regulatory commitments (as defined in NEI 99-

04) in this letter.

If you have any questions regarding this submittal, please contact Mr. Hossein Hamzehee at (805) 545-4720.

Document Control Desk PG&E Letter HBL-16-001 January 29, 2016 Page 2 I state under penalty of perjury that the foregoing is true and correct.

Executed on January 29, 2016.

Sincerely,

?J£?~

Edward D. Halpin Senior Vice President - Power Generation and Chief Nuclear Officer Enclosures cc: Marc L. Dapas, NRC Region IV Administrator John B. Hickman, NRC Project Manager HBPP Humboldt Distribution

Enclosure 1 PG&E Letter HBL-16-001 HUMBOLDT BAY POWER PLANT (HBPP) UNIT 3 DEFUELED SAFETY ANAYLSIS REPORT, REVISION 11

DE FUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section CHAPTER 1. INTRODUCTION AND

1.1 INTRODUCTION

1-1 1.2 SITE CHARACTERISTICS 1-2 1.3 QUALITY STANDARDS 1-2 1.4 FIRE PROTECTION 1-2 1.5 CONTROL OF RELEASES OF RADIOACTIVE MATERIALS 1-2 1.6 PERSONNEL SELECTION AND TRAINING 1-3 1.7 REPORTING OF OPERATING INFORMATION 1-3 1.8 MEASURING AND REPORT OF EFFLUENTS FROM NUCLEAR POWER PLANTS 1-3 1.9 IDENTIFICATION OF AGENTS AND CONTRACTORS 1-4 1.10 CONCLUSIONS 1-4 CHAPTER 2. SITE AND ENVIRONMENT 2.1

SUMMARY

2-1 2.2 SITE AND ADJACENT AREAS 2-1 2.3 METEOROLOGY 2-1 2.4 HYDROLOGY 2-1 2.5 ENVIRONMENTAL MONITORING PROGRAM 2-2 CHAPTER3. STRUCTURES 3.1 REFUELING BUILDING 3-1 3.2 RADWASTE TREATMENT FACILITIES 3-1 REVISION 11

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section Title Page CHAPTER 4. AUXILIARY SYSTEMS 4.1 GENERAL 4-1 4.2 VENTILATION SYSTEMS 4-1 4.3 WASTE DISPOSAL SYSTEMS 4-1 4.4 FIRE PROTECTION PROGRAM 4-1 I CR 11-02 CHAPTER 5. RADIOACTIVE WASTE AND RADIATION PROTECTION 5.1 RADIONUCLIDE INVENTORY 5-1 5.2 LIQUID WASTE TREATMENT SYSTEMS 5-1 5.3 GASEOUS WASTE MANAGEMENT 5-1 5.4 SOLID WASTE MANAGEMENT 5-1 5.5 OFF-SITE DOSE CALCULATION MANUAL 5-1 5.5.1 Liquid Discharge Pathway 5-1 5.5.2 Gaseous Discharge Pathway 5-2 5.6 RADIATION PROTECTION PROGRAM 5-2 5.6.1 Organization 5-2 5.6.2 Equipment and Instrumentation 5-2 5.6.3 Radiation Protection Procedures 5-2 5.6.4 Personnel Exposure Reporting 5-2 CHAPTER 6. CONDUCT OF OPERATIONS 6.1 PLANT ORGANIZATION 6-1 6.2 PERSONNEL TRAINING 6-1 6.3 EMERGENCY PLAN 6-1 REVISION 11

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section 6.4 PLANT PROCEDURES 6-1 6.5 RECORDS 6-1 CHAPTER 7. SAFETY ANALYSIS 7.1 DECOMMISSIONING ACCIDENT ANALYSIS 7-1 CR 11-02 iii REVISION 11

DSAR CHAPTER INTRODUCTION AND

1.1 INTRODUCTION

In 1984 PG&E submitted the Humboldt Bay Power Plant, Unit 3 (referred to as either HBPP, Unit 3, or the Humboldt Bay nuclear facility) SAFSTOR Decommissioning Plan (SOP) in support of the application to amend the HBPP Operating License to a Possession-Only License. As a result of the 1996 NRC decommissioning rule, the SOP was considered to be a Post-Shutdown Decommissioning Activities Report (PSDAR) because it contained information related to decommissioning activities . It was also considered to be a Final Safety Analysis Report (FSAR) because it contained information such as plant description, site characterization and accident analysis. In compliance with the 1996 NRC decommissioning rule, PG&E submitted a PSDAR in February 1998 to provide a general overview of proposed decommissioning activities. As a result, the SOP will focus on providing the type of information contained in an FSAR and will contain less information related to decommissioning activities. Thus, the SOP has been more appropriately renamed the Defueled Safety Analysis Report (DSAR) .

In addition to the DSAR and PSDAR, PG&E has submitted other documents to the NRC in accordance with 10 CFR 50 that constitute the licensing basis for H BPP. These other documents include: (1) License Amendments, (2) revised Technical Specifications, (3)

CR License Termination Plan. 11 -02 This DSAR reflects the changes made following Humboldt Bay's(HB's) decision to decommission Unit 3 in June 1983, as well as License Condition 2.8.1 that allow Pacific Gas and Electric Company (PG&E) "... to take actions necessary to decommission and decontaminate this facility." PG&E will update the DSAR in accordance with the methodology specified in 10 CFR 50.59 and 10 CFR 50.71 (e), submitting updates at least every two years. Revisions to the DSAR are numbered, starting with Revision 1.

The purpose of the DSAR is to provide a Safety Analysis Report that provides assurance that based on the decommissioning activities and the administrative controls and programs in place during decommissioning, no undue risk to the public health and safety will occur during normal operation and postulated accident conditions.

The following provides a history of major plant operation and licensing-related actions :

1. Unit 3 achieved initial criticality on February 16, 1963, and began commercial operation in August 1963.

2. On July 2, 1976, Unit 3 was shut down for annual refueling and to conduct seismic modifications. Seismic and geologic studies were in progress.

3 In December 1980 it became apparent that the cost of completing required backfits might have made it uneconomical to restart the unit. Work was suspended at that time awaiting further guidance regarding backfitting requirements.

1-1 REVISION 11

4 In 1983, updated economic analyses indicated that restarting Unit 3 would probably not be economical, and in June 1983 PG&E announced its intention to decommission the unit.

5 On December 11, 2008, PG&E completed the transfer of spent fuel from the spent fuel pool into the ISFSI.

1.2 SITE CHARACTERISTICS The Humboldt Bay nuclear facility is located about four miles true southwest of the city of Eureka, Humboldt County, California, and consists of 142.9 acres of land.

Since there are no design basis accidents that could approach 10 CFR 100 limits, no Safety Features are necessary to keep public exposures below the 10 CFR 100 dose limits under worst case postulated accident conditions.

1.3 QUALITY STANDARDS The Humboldt Bay Quality Assurance Plan (HBQAP) describes the 10 CFR 50, Appendix B quality assurance program for important-to-safety SSCs and activities. Management and CR administrative program requirements that apply to Unit 3 are subject to administrative 11-01 controls which demonstrate compliance with regulatory requirements.

1.4 FIRE PROTECTION The Fire Prevention Program describes the overall fire protection program in place at HB.

DSAR Chapter 4 also discusses the fire protection system.

1.5 CONTROL OF RELEASES OF RADIOACTIVE MATERIALS The radiological administrative control programs at Humboldt Bay effectively control the collection, segregation, processing, packaging, and discharge or disposal of radioactive solids and liquids. These systems and programs function to control releases to as low as is reasonably achievable levels and are designed to give reasonable assurance that the numerical guidelines defined in 10 CFR 50.34a, 50.36a, and 10 CFR 50, Appendix I, and contained in the Off-site Dose Calculation Manual (ODCM) will be met.

Modular HEPA ventilation system(s) are used for interim airborne radioactivity control, if CR required. HEPA filter loading is administratively controlled to limit the potential offsite 11-02 exposure.

Interim storage buildings are provided for packaged low-level radioactive waste. Potential release pathways of radionuclides in particulate form are controlled and monitored in accordance with the ODCM.

1-2 REVISION 11

Liquid and solid wastes are normally processed in batches for off-site disposal. Gaseous effluents (particulates and tritium) could be released during dismantlement activities. During this time, samples will be taken from temporary monitored release points in accordance with the ODCM.

1.6 PERSONNEL SELECTION AND TRAINING Plant personnel meet the minimum education and experience standards specified in ANSI N18.1-1971, "Standard for Selection and Training of Personnel for Nuclear Power Plants."

Retraining and replacement training meets or exceeds the requirements and Manager shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2, April 1987.

DSAR Chapter 6 discusses training programs for staff personnel. Records of the CR 11-02 qualifications, training, and retraining of each member of the plant organization are maintained in accordance with established programs.

In accordance with 10 CFR Part 19, personnel are provided radiological training commensurate with the hazards to which they may be exposed while working at HBPP.

1.7 REPORTING OF OPERATING INFORMATION The Humboldt Bay Quality Assurance Plan specifies the annual routine reporting requirements.

Personnel radiation exposure and monitoring procedures have been established and reports CR are submitted, as required. 11 -02 Reporting abnormal events in Licensee Event Reports and Special Reports is performed by site staff in accordance with established procedures and applicable regulatory requirements.

Established procedures ensure significant events are quickly brought to the attention of management and acted upon within the allowed reporting period.

1.8 MEASURING AND REPORT OF EFFLUENT FROM NUCLEAR POWER PLANTS The measuring and reporting of radiological effluents from Humboldt Bay complies with the requirements of Regulatory Guide 1.21 and the ODCM.

Annual reports summarizing the quantity of radionuclides released from the site are submitted to the NRC in accordance with 10 CFR 50.36a(a)(2). This summary data is comprised of radioactive release information collected in accordance with the ODCM.

1-3 REVISION 11

1.9 IDENTIFICATION OF AGENTS AND CONTRACTORS PG&E is responsible for control of agents and contractors used during the decommissioning the Humboldt Bay facility.

1.10 CONCLUSIONS The personnel assembled to decommission Humboldt Bay facility are capable of performing their required project function. The health and safety of the public and plant personnel are among the primary concerns during decommissioning.

The Humboldt Bay facility can be decommissioned in a safe manner and PG&E is qualified to decommission this nuclear facility in accordance with all applicable laws and regulations and in a manner satisfactory to the NRC, the public, and itself.

1-4 REVISION 11

DSAR CHAPTER 2 -SITE AND ENVIRONMENT 2.1

SUMMARY

The Humboldt Bay nuclear facility lies in the Northern California Coast Ranges geomorphic province. This province consists of a system of longitudinal mountain ranges (2000 to 4000 foot elevations with occasional 6000 feet peaks) and valleys with a trend of N 30 degrees to 40 degrees W. Terrain of the site varies from submerged and low tidal land, protected by dikes and tide gates, to a high precipitous bluff along the southwestern boundary.

Elevations range from approximately -3 feet to +75 feet based on a datum of the mean lower low water (MLLW) level.

Soils in the immediate vicinity of the site consist of sand and alluvial soil and strata of the Hookton and Carlotta sedimentary formations. These formations are primarily consolidated sands, gravels, and clays and conglomerates with good engineering properties.

Figure 2-1 shows the general location of the Humboldt Bay site. Figure 2-2 provides a more specific layout of the PG&E-owned land and a general layout of the site.

2.2 SITE AND ADJACENT AREAS The land in the general vicinity around the Humboldt Bay site is presently low density rural housing and is used primarily as grazing areas.

Within a 15-mile radius of the site there are five cities or communities (Eureka, Fortuna, Arcata, King Salmon, and Fields Landing). Activities in the area immediately surrounding the site are not expected to change extensively.

King Salmon Avenue runs along the west side of the site boundary and connects with US Highway 101 which runs along the southern boundary of the site. The Southern Pacific Railroad runs roughly parallel to Highway 101 but is out of service.

PG&E is operating Humboldt Bay Generating Station (HBGS), a new dual fueled (natural gas and diesel) power plant, on the Humboldt Bay site adjacent to the south side of the facility.

The Humboldt Bay ISFSI is located on site approximately 600 feet northwest of the HBGS.

2.3 METEROLOGY The Humboldt Bay facility uses conservative default atmospheric dispersion and deposition factors in its evaluations of off-site gaseous releases to calculate the doses that result from normal gaseous effluent and abnormal or accident release conditions.

2.4 HYDROLOGY The surface runoff from the site is directed into drains eventually discharging into Humboldt Bay. Outside the area served by the plant drain system, surface runoff drains into Buhne Slough, the natural drainage for the area, which drains into Humboldt Bay.

The nearest streams to the site are Salmon Creek and Elk River, which are within a mile south and north of the site, respectively, and which discharge into Humboldt Bay. These streams are used for watering livestock, but are not used as a potable water supply.

2-1 REVISION 11

The Mad River flows west approximately 13 -15 miles northeast of the site. The Ruth reservoir, the source of the city's water supply, is located on this river.

To the south, the Eel River discharges to the Pacific Ocean 8-10 miles from HB. This river is not used for potable water within 25 miles of HB.

Groundwater elevation in the area near the bay is similar to sea level and may be somewhat affected by tidal action. This elevation is approximately 12 feet below the plant floor elevation.

2.5 ENVIRONMENTAL MONITORING PROGRAM The environmental monitoring of the environment during decommissioning is delineated in the Off-site Dose Calculation Manual.

Results of the Humboldt Bay environmental monitoring are available to the State of California and federal agencies that have a direct interest and concern in these matters.

2-2 REVISION 11

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Figure 2-2 REVISION 11

DSAR CHAPTER 3 -STRUCTURES 3.1 REFUELING BUILDING Once the majority of radioactivity is removed from within the Refueling Building, the structure will be removed.

3.2 RADWASTE TREATMENT FACILITIES Temporary liquid radioactive waste processing capability is available. Temporary buildings CR 11-02 are used to store low level radwaste packages awaiting shipment. As decommissioning progresses, these structures, systems and components will be removed from service and removed.

3-1 REVISION 11

DSAR CHAPTER 4 -AUXILIARY SYSTEMS 4.1 GENERAL The systems considered in this DSAR Chapter are:

1. Ventilation Systems

2. Waste Disposal Systems

3. Fire Protection Systems Design changes, modifications, and additions to existing systems and components are reviewed for compliance with the requirements of 10 CFR 50.59 "Changes, Tests, and Experiments."

4.2 VENTILATION SYSTEMS Modular HEPA ventilation systems are used, as required, to monitor gaseous effluents CR (particulate). Gaseous effluent is sampled for radioactivity in accordance with the Offsite 11-02 Dose Calculation Manual (ODCM).

4.3 WASTE DISPOSAL SYSTEMS CR Temporary waste disposal systems are used to support the remaining decommissioning 11-02 activities.

4.4 FIRE PROTECTION PROGRAM CR 11-02 The fire protection program describes the organizational requirements, design features, operational requirements, compensatory measures, testing requirements, and off-site fire fighting assistance coordination requirements that collectively define Unit 3's fire protection program. Fire loading, ignition sources, and combustible materials are significantly reduced and the possibility for a major fire is greatly diminished from the unit's operational phase. As decommissioning progresses, the requirements for fire suppression, detection and alarm systems will be removed.

Offsite firefighting capability is provided by the local fire department.

4-1 REVISION 11

DSAR CHAPTER 5- RADIOACTIVE WASTE AND RADIATION PROTECTION 5.1 RADIONUCLIDE INVENTORY The remaining radioactive source term at the defueled Unit 3 reactor site has been greatly cR reduced by radioactive decay and spent fuel removal. Administrative and engineering 11-02 controls are utilized to limit airborne radioactivity exposure to the workers and general public during decontamination and dismantlement.

5.2 LIQUID WASTE TREATMENT SYSTEMS A temporary wastewater disposal system, such as tanks, pumps, piping, and processing CR equipment are used, as required, to process waste water prior to release or shipment off 11-02 site.

5.3 GASEOUS WASTE MANAGEMENT Modular ventilation systems are used, as required, to monitor gaseous effluents (particulate). CR 11-02 5.4 SOLID WASTE MANAGEMENT Solid radioactive wastes are collected and processed on or off site and shipped to a licensed and/or permitted burial site for disposal. Off-site secondary processors may be used for volume reduction or further processing prior to disposal. Solid wastes are packaged in containers which conform to Department of Transportation (DOT) requirements (49 CFR) for transport to a licensed disposal facility.

The total curie content and major radionuclide composition by waste type are reported in the Radioactive Effluent Release Report required pursuant to 10 CFR 50.36a.

5.5 OFF-SITE DOSE CALCULATION MANUAL The ODCM provides the information and methodologies used to evaluate the impact of radiological liquid and gaseous effluent discharged from the plant.

The ODCM is used to demonstrate that the plant complies with the requirements of 40 CFR 190 and 10 CFR 20, and the dose guidelines of 10 CFR 50, Appendix I. Calculations for continuous airborne releases use default atmospheric diffusion coefficients and gaseous effluent flow rates. Exposures due to plant decommissioning are estimated by calculation methods specified in the ODCM.

5.5.1 Liquid Discharge Pathway Discharge of processed radioactive effluents to Humboldt Bay was terminated . Process water and liquids that exceed 10 times 10 CFR 20, Appendix B, Table 2, Column 2 are CR manifested and disposed of at a licensed disposal site. Storm water and ground water during 11-02 decommissioning is treated and released using the Ground Water Treatment System (GWTS) in accordance with the Storm Water Pollution Prevention Plan and the associated NPDES permit.

5-1 REVISION 11

5.5.2 Gaseous Discharge Pathway Release pathways have been and are expected to continue to be very small; well within the 10 CFR 50, Appendix I dose guidelines and 10 CFR 20 concentration limits. Modular HEPA CR 11-02 ventilation systems are used, as required, to monitor gaseous effluents during decommissioning.

5.6 RADIATION PROTECTION PROGRAM 5.6.1 Organization The HB Director has the overall responsibility for radiological protection for all onsite activities, including assurance that ALARA policies are carried out at the facility. The Radiation Protection Manager is responsible for specifying radiation protection requirements for work activities. The HBPP organization and reporting chain are specified in administrative CR 11-01 procedures.

5.6.2 Equipment and Instrumentation Personnel Protective Equipment Anti-contamination clothing is furnished and worn as necessary to protect personnel against CR contact with radioactive contamination. Respiratory protective equipment is available for the 11-02 protection of personnel against airborne radioactive contamination.

Radiation Protection Instrumentation A variety of instruments are used to cover the entire spectrum of radiation measurements at Humboldt Bay.

5.6.3 Radiation Protection Procedures The radiation protection program is organized to meet the requirements of 10 CFR 20. CR 11-02 5.6.4 Personnel Exposure Reporting An annual exposure monitoring report for individuals is submitted in accordance with 10 CFR 20.2206(b).

5-2 REVISION 11

DSAR CHAPTER 6 - CONDUCT OF OPERATIONS 6.1 PLANT ORGANIZATION The details of the PG&E organization that oversees the activities at the Humboldt Bay CR nuclear facility are discussed in administrative procedures. The HB Director heads the on- 11-01 site Humboldt Bay facility organization and directs the activities of the functional on-site departments.

6.2 PERSONNEL TRAINING Plant personnel are selected and trained for their assigned duties, with each department head being responsible for conducting department training that meets the applicable requirements and standards.

Radiological training is provided to all personnel commensurate to the hazards to which an individual will be exposed. Training is conducted and documented in accordance with the training program.

6.3 EMERGENCY PLAN CR Radiological source terms which may result in declaration of a radiological emergency are 11-02 eliminated or administratively controlled to limit potential exposure beyond the site boundary.

6.4 PLANT PROCEDURES The HB Administrative Procedures (HBAPs) define and implement administrative requirements or activities involving inter-departmental processes and administrative responsibilities. Procedure hierarchy, preparation, review, approval, revision, and control are established in accordance with the applicable HBAPs. CR 11-01 6.5 RECORDS CR Records are maintained as described in administrative procedures. 11-01 6-1 REVISION 11

DSAR CHAPTER 7 - SAFETY ANALYSIS 7.1 DECOMMISSIONING ACCIDENT ANALYSIS There are no postulated decommissioning accidents with potential radiological impacts to CR the environment. The remaining radioactive source terms at the defueled Unit 3 reactor site 11-02 have been eliminated or are administratively controlled to mitigate the postulated event precursors.

7-1 REVISION 11

Enclosure 2 PG&E Letter HBL-16-001 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

VOLUME 4, REVISION 33

Nuclear Power Generation NUMBER L-4 VOLUME 4 Humboldt Bay REVISION 33 EFFEC DATE 11-20-15 Power Plant PAGE 1 ofl TITLE APPROVED BY HUMBOLDT BAY QUALITY ORIGINAL SIGNED 10-9-15 ASSURANCE PLAN (HBQAP)

DIRECTOR/PLANT MANAGER I DATE HB NUCLEAR (Procedure Classification - Quality Related)

1.0 DESCRIPTION

This document describes the Quality Assurance Pian to be applied to Humboldt Bay Power Plant Unit 3 during decommissioning, and includes Humboldt Bay Independent Spent Fuel Storage Installation (HB ISFSI) activHies. The HBQAP satisfies the requirements of 10 CFR 50 Appendix B, and 10 CFR 72 Subpatt G. In addition, NRC Approval No. 202, Revision 8 "Quality Assurance Program for Radioactive Material Packages" has approved the HBQAP as satisfying the provisions of 10 CFR 71 subpart H for the procurement, maintenance, repair and use of radioactive materials transpmt packages.

2.0 ATIACHMENTS 2.1 Humboldt Bay Quality Assurance Plan (HBQAP), Revision 33.

3.0 RESPONSIBLE ORGANIZATION Director, Quality

L-4 Attachment 2.1 Rev.33 Page 1 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

TABLE OF CONTENTS Section Title Page INTRODUCTION 2 1.0 ORGANIZATION 3 2.0 QUALITY ASSURANCE PROGRAM 9 3.0 DESIGN CONTROL 11 4.0 PROCUREMENT DOCUMENT CONTROL 12 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 13 6.0 DOCUMENT CONTROL 14 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 15 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND CO:MPONENTS 16 9.0 SPECIAL PROCESSES 17 10.0 INSPECTION 18 11.0 TEST CONTROL 19 12.0 CONTROL OF :MEASURING AND TEST EQUJPMENT 20 13.0 HANDLING, STORAGE, AND SHIPPING

• 21 14.0 INSPECTION, TEST, AND OPERATING STATUS 22 15.0 CONTROL OF NONCONFORMING CONDITIONS 23 16.0 CORRECTIVE ACTION 24 17.0 QUALITY ASSURANCE RECORDS 25 18.0 AUDITS 26 APPENDIX A APPLICABLE STRUCTURES, SYSTEMS, AND COMPONENTS 27 B ADMINISTRATIVE CONTROLS 28

L-4 Attachment 2.1 Rev. 33 Page 2 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

INTRODUCTION Pacific Gas and Electric (PG&E) has established and is implementing a comprehensive Quality Assurance Progmm for Humboldt Bay Power Plant Unit 3 (HBPP Unit 3) and Humboldt Bay _

Independent Spent Fuel Storage Installation (HB ISFSI) to assure compliance with established regulatory requirements set forth by the Nuclear Regulatozy Commission (NRC). The Quality Assurance Program is described in this Humboldt Bay Quality Assurance Plan (HBQAP).

The Humboldt Bay QA Program consists of the HBQAP and implementing procedures and instructions. The HBQAP describes the responsibilities for implementing quality requirements; establishing and maintaining the QA Program; and assessing the performance of activities subject to theHBQAP.

The HBQAP is a comprehensive statement of the quality assurance controls governing the Important to Safety (ITS) Stntctures Systems and Components (SSC). The HBQAP describes the organizational structure, functional responsibilities, levels of authority, line of communication, and inte1faces. The HBQAP satisfies the requirements oflO CFR50 Appendix B> 10 CFR 71 SubpartH and 10 CFR 72 Subpart G. The requirements for management and administrative controls are described in appendix B of this HBQAP.

The requirements and commitments contained in the HBQAP are mandatmy and must be implemented, enforced, and adhered to by all individuals and organizations petfonning activities affecting quality. Workers are encouraged to actively participate in the continued improvement and implementation of the HBQAP. Any necessaty ch~ges should be pr01nptly communicated and implemented.

The implementation of the requirements of the HBQAP is perfonned in a graded approach commensurate with any items or activities importance to safety. This graded approach is applicable to ITS SSCs and is responsive to NRC Regulatmy Guide 7.1 0.

TI1e HBQAP is implemented through the use of approved procedures (i.e. policies, procedures, manuals, instructions, or other documents) that provide written guidance for the control of ITS items and activities. The HBQAP also provides for development of documentation to demonstrate objective .

evidence of compliance with the stated requirements.

L-4 Attachment 2.1 Rev. 33 Page 3 of29 1.0 ORGANIZATION PG&E~s efforts are to assure the quality and safety of the decommissioning of the HBPP Unit 3, packaging and transportation of radioactive material and the operation and maintenance of the HB ISFSI utilizing the HBQAP. The progratn is organized in a structured manner with clearly defined levels of authority, assignments of responsibility and lines of communication.

Assignment of the responsibility for an item or activity includes responsibility for its quality. The Quality Organization provides independent oversight of quality activities and maintains lines of communication with Senior Management.

PG&E has assumed full responsibility for the establishment and execution of the HBQAP prescribed herein, programs and administrative procedm*es. The work of executing selected portions of the HBQAP may be delegated to organizations externa1 to PG&E; however, in all such instances, PG&E retains overall responsibility.

Specific responsibilities pertaining to quality assurance matters are assigned by the HBQAP and its implementing procedures *and instructions to various individuals throughout PG&E. Jn each instance, the assignment of a responsibility to an individual includes with it a commensurate delegation of sufficient authority that the person can, in fact, fulfill that responsibility. Unless otherwise specifically prohibited, it is understood that the functions, tasks and activities necessary to carry out a responsibility may be delegated to and perfmmed by other qualified individuals.

All delegations offtmctions, tasks, activities and authority shall be documented. Individuals Inay fulflll more than one function unless prevented by the need to maintain independence as specified

• in the HBQAP.

Figures land 2 illustrate the organizational structure, ftmctional responsibilities, levels of authority, line of communication, and inte1faces of persons and organizations performing activities governed by the. HBQAP.

The functional responsibilities shown in Figures 1 and 2 are further described below. Generic titles are used for the functions and responsibilities. Differences (if any) between actual titles used in the organization are traceable to the HBQAP titles by the use of administrative procedures.

The SENIOR VICE PRESIDENT- CHIEF NUCLEAR OFFICER (CNO) is responsible for overall 1-IBPP Unit 3 decommissioning, and HB ISFSI activities, safety and for taking measures needed to ensure acceptable performance of the HB ISFSI staff in designing, fabricating, constructing, testing, operating, 1nodifying, decommissioning, and providing technical suppmi to the HB ISFSI and during HBPP Unit 3 decommissioning.

L-4 Attachment 2.1 Rev. 33 Page 4 of29

• The CNO, or designee, as specified in administrative procedures, approves and signs official company correspondence to the U.S. Nuclear Regulatory Commission (NRC) or its representatives. The CNO approves revisions to the QA Program as described herein that constitute a reduction in a commitment made to the NRC. The CNO is responsible for designating individual(s) to perfonn an Independent Manage~nent Review to periodically assess the effectiveness of the HB QA Program.

The DIRECTOR- QUALITY (Quality Director) is responsible for assuring that the HBQAP and implementing procedures are effectively implemented and complied with by all involved organizations, both internal and external to PG&E. The Quality Director has the organizational freedom and requisite authority to assess, review, inspect> audit, and monitor the conduct of quality activities to assure compliance with the HBQAP and other regulatory requirements. The Quality Director reports to the CNO, and has access to the President, HB Director, and appropriate managers for any significant quality problem or deficiency.

The Quality Director is responsible for maintaining and submitting for approval changes to the 1-IBQAP. The Quality Director is responsible for the review of all regulatory submittals as they pertain to the HBQAP and his/her concunence is required prior to subrnittal.

Reporting to the Quality Director are the quality assurance, supplier quality and independent quality control inspection functions. These i.J).dividuals or groups do not have direct responsibility for petfonning the work being verified; are trained and qualified in QA concepts and practices; are independent of the organization respo~sible for performing the task and have direct access to management levels. The Quality Organization is sufficiently free from direct pressures for cost and schedule that assures the ability to: (a) identify quality problems; (b) initiate, recommend, or provide solutions through designated channels; and_(c) verify implementation of solutions.

Individuals within the Quality Organization have the authority to stop unsatisfactory. work and control further processing, delivery, or installation of nonconforming material. Organizational positions with stop work authority are identified in the implementing procedures.

The DIRECTOR-NUCLEAR SECURITY and EMERGENCY SERVICES (HB ISFSI Director) is responsible for the conduct of activities related to the HB ISFSI. This includes responsibility for operation, maintenance, training, security and emergency preparedness. The day-to-day responsibilities are delegated to and executed by the HB ISFSI management team. Specific responsibilities are described in administi*ative procedures.

The HB ISFSI Director is also responsible for the development of, programs, procedures, and instructions required for HB ISFSI within the requirements and/or limits established in the HBQAP; HB ISFSI Technical Specifications; and administrative guidelines established in the HB ISFSI Final Safety Analysis Report (FSAR).

The HB ISFSI Director shall delegate these responsibilities to other members of the HB ISFSI management team during his/her absence.

The ISFSI MANAGER is responsible for the operation and maintenance of the HB JSFSI, maintenance of the Physical Security Plan and interfacing with outside agencies.

L-4 Attachment 2.1 Rev. 33 Page 5 of29 The Diablo Canyon Power Plant (DCPP) RADIATION PROTECTION MANAGER is responsible for implementing the HB ISFSI radiation protection program for the protection of the workers and members of the public.

An INDEPENDENT MANAGEMENT REVIEW is periodically performed to assess the effectiveness of the HB QA Program, including audit program. Results of the Independent Management Review are provided to the CNO for cmTective action, as necessary. Individual(s) that perform the Independent Management Review are appointed by the CNO. The Independent Management Review includes oversight of the HBQAP implementation and matters relating to safe storage of spent nuclear fuel, as directed by the CNO.

The DIRECTOR- HUMBOLDT BAY (H8 Director) is responsible for the conduct of activities related to the HBPP Unit 3 decommissioning. This includes responsibility for operation, maintenance, engineering, radiation protection, training, radioactive material packaging, and transport for decommissioning activities. The day-to-day responsibilities are delegated to and executed by the HB decolll111issioning management team that direCtly reports to the HB Director.

Specific responsibilities are described in administrative procedures.

The HB Director is also responsible for the development of, programs~ procedures, and instructions required for HBPP Unit 3 within the requirements and/or limits established in the HBQAP; HBPP Unit 3 Technical Specifications; and administrative guidelines established in the HBPP Unit 3 Defueled Safety Analysis Report (DSAR). The HB Director is the Design Authority for the HBPP Unit 3 and HB ISFSI. .

The HB Director shall delegate these responsibilities to other members of the HB management team during his/her absence.

The HBPP ENGINEERING MANAGER is responsible for technical aspects of the engineering and design ofHBPP Unit 3 and HB ISFSI SSCs including, performance of modifications; configuration control and design bases defense and management; quality classification of SSCs; and the specification of technical and quality requirements for the purchase of services, materials and equipment.

• The HBPP RADIATION PROTECTION MANAGER is responsible for implementing the decommissioning radiation protection program for the protection of the workers and members of the public.

INDEPENDENT SAFETY REVIEWER(S) (ISR) performs independent safety reviews of proposed changes, tests and experiments to SSCs, activities, program documents and procedures that are subject to the HBQAP requirements. ISRs shall be individuals without direct responsibility for the performance of these activities under review, and shall be competent and knowledgeable in the subject area being reviewed. ISRs are designated by the HB Director for decommissioning activities or the HB ISFSI Director for ISFSI activities.

CORPORATE SUPPORT for ITS activities includes, but is not limited to, procurement, recor~s, employee concerns, and licensing. Each organization documents and maintains a written description of its internal organization.

L-4 Attachment 2.1 Rev. 33 Page 6 of29 SUPPLIERS that provide ITS SSCs or services are required to comply with the HBQAP or to a QA Prograw approved by PG&E. Supplier QA Programs are required to comply with the applicable portions of 10 CFR 50, Appendix B; 10 CFR 71, Subpart H; or 10 CFR 72, Subpart G.

The Quality Program reqLLirements are defined in the contract or similar procurement document.

Suppliers to PG&E are required to document their internal organization, to the extent necessa1y for PG&E, to assure the supplier is capable of effectively managing, directing, and executing the requirements of the procurement documents.

Staff Qualifications Except as specified in other portions of the HBQAP, each member of the staff shall meet or exceed the following minimum qualifications:

For HB Unit3, the minimum qualifications of ANSI Nl8.1 (1971) for comparable positions are applicable.

For the HB ISFSI; the minimum qualifications are described in the ISFSI FSAR The following reqtdrements and clarifications apply to the positions listed below, and are applicable to both HBPP Unit 3 and the HB ISFSI; RADIATION PROTECTION MANAGERS shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2~ Aprill987.

The QUALITY DIRECTOR shall have knowledge of QA regulations, policies, practices, and standards; and experience working in QA, nuclear power plant, fuel storage facility, or in a similar highly technological industry. At the time of assignment to the active position, the Quality Director shall have six years of experience in implementing Quality Assurance.

At least one year of these six years of experience shall be nuclear power plant or fuel storage facility experience in the overall implementation of a Quality Assurance Program (QAP). A minimum ofone year of this six-year experience requirement shall be related technical or academic training. A maximum of four years of this six-year experience requirement may be fulfilled by related technical or academic training.

The one year of qualifying nuclear power plant or fuel storage facility experience in the overall implementation of the Quality Assurance program can be obtained outside the Quality Assurance organizations.

L-4 Attachment 2.1 Rev. 33 Page 7 of29 Figure 1 HB ISFSI Organization Chart Senior Vice President ChiefNuc]ear Officer Director Independent Quality Management Review Director Nuclear DCPP or Contract Supp01t Security and Emergency

• Records Services

• Licensii1g I I

• Procurement HBPP Engineering ---------------* ~---------------

• Employee Concerns

• Radiation Protection

• Other (as required)

I I HB ISFSI Independent Safety HB ISFSI Manager Reviewers

L-4 Attachment 2.1 Rev. 33 Page 8 of29 Figurc2 HB Decommissioning Organization Chart Senior Vice President ChiefNuclear Officer DCPP or Contract Suppmt

• Records Director

• Licensing Quality

• Procurement

• Employee Concerns

• Other (as require d)

I I

Director I I

I Humboldt Bay I I

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~-------------------------~------1 HBPP HBPP Radiation HBPP Independent Engineering Protection Safety Reviewers Manager Manager

L-4 Attachment 2.1 Rev. 33 Page 9 of29 2.0 QUALITY ASSURANCE PROGRAM 2.1 PROGRAMAPPLICABILITY The HBQAP Tequirements~ apply to SSCs designated as ITS in Appendix A.

The quality requirements for the management and administrative program~ in Appendix B that support ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP.

The quality requirements for the management and administrative programs that suppmt HBPP Unit 3 are designated in administrative programs and procedures.

A graded approach is used to define the controls applied to quality activities commensurate with the activity,simportance to safety. The graded approach also applies to the level of quality oversight for quality activities.

Activities that require review and concutTence by Quality persmmel are delineated in administrative procedures and are based on the activity's impmtance to safety.

The effectiveness of the imple1nentation of the HBQAP shall be assured through Quality Related programs, procedures and drawings. ,

2.2 PROGRAM CONTROL The status and adequacy of the HBQAP shall be regularly monitored and it shall be revised as necessary to improve its effectiveness or to reflect changing conditions.

The HBQAP, including*any changes~ supplements, or appendices are issued and maintained as controlled documents. Changes to the HBQAP requirements shall be made in accordance with 10 CFR 50.54.

Changes to the HBQAP that do not reduce commitments shall be included in tl1e periodic updates required by 10 CPR 50. 71. Prior to issuance for use, proposed changes to the HBQAP that reduce commitments are reviewed and concurred with in writing by the Quality Director and are approved by the CNO, or designee~ prior to being submitted to and approved by the NRC in accordance with 10 CFR 50.54.

Implementation of the HBQAP is accomplished through separately issued procedures~ instructions, and drawings. Each organization is responsible for the establishment and implementation of detailed procedures and instructions prescribing the quality activities for which they are responsible. Such documents are derived from the requirements and reflect the responsibilities specified in the HBQAP.

Questions or disputes involving interpretations ofHBQAP requirements and commitments are referred to the Quality Director for resolution. Questions or disputes involving the responsibilities defined in the HBQAP are referred to the CNO.

Questions or disputes involving other quality matters are resolved by refel1'ing the matter, in a timely manner, to successively higher levels of 1nanagement until, if necessary, the matter reaches the management level which has direct authority ove1; all contesting patties.

L-4 Attachment 2.1 Rev. 33 Page 10 of29 2.3 INDOCTRINATION AND TRAINING Indoctrination and training for personnel implementing ITS activities are conducted to assure suitable proficiency is achieved and maintained. The extent of indoctrination and training is commensurate with the scope~ complexity and importance to safety of the assigned task; in conjunction with the education and experience of the individual. Personnel involved in implementing the activities within the scope of the HBQAP shall be responsible for the quality of their work. At a minimum, these personnel shall receive:

• Indoctrination in the Tequirements of the HBQAP;

• Indoctrination in their organization's implementing procedures; and

• Training and qualification in tasks requiring special skills or knowledge, as required.

Indoctrination, training, qualification, andre-qualification (when applicable) shal1 be prescribed and performed in accordance with written procedures; and applicable codes, standards and regulatory requirements; which specify the 1nanagement responsibilities; training areas; frequency of training; method of qualification and requalification; and documentation requirements.

Training and qualification records are maintained in accordance with implementing procedures.

2.4 REGULATORY COMMITMENTS Regulatory commitments, where applicable, are specified in the Unit 3 DSAR, ISFSI FSAR, Technical Specifications or Licenses.

L-4 Attachment 2.1 Rev.33 Page 11 of29 3.0 DESIGN CONTROL Design Control' applies to the 10 CPR 72 ~SCs designated as ITS in Appendix A. Design activities shall be controlled to assure that design, technical, and quality requirements are conectly translated into desi!,rn documents and that changes to design and design documents are properly controlled. Design control procedures shall address responsibilities for:

( 1) Interface control (2) Design input (3) Design performance (4) Design verification (5) Design change Systematic methods shall be established and documented for cormnuuicating needed design infonnation across the external and internal design interfaces, including changes to the design information, as work progresses. Document control1neasures shall be established for design documents that reflect commitments in applicable design basis documents (e.g., specifications, calculations, computer programs, system descriptions, drawings).Provisions for design input shall deflne the technical objectives for SSCs being designed or analyzed. Design inputs shaH be documented, reviewed and approved and translated to design docmnents. Required design analyses (such as stress, thermal, hydraulic and accident analysis; material compatibility; maintenance and repair and ALARA considerations) shall be performed in a planned, controlled, and correct manner. PG&E procedures shall identify the review and approval responsibilities for design analyses.

PG&E shall provide for reviewing, confirming, or substantiating the design to assure that the design meets the specified design inputs. Design verification shall be petformed by competent individuals or groups other than those who performed the original design, but who may be from the same department.

The results -o f the design verification effmis shall be documented with the identification of the verifier clearly provided. The design verification shall be completed prior to relying upon the component system or structure to pe1form its function. Procedures shall assure that verified computer codes are certified for use and that their applicability is specified.

Changes or modifications to the designated SSCs in Appendix A shall be approved by the Design Authority, or designee, as specified in administrative procedures, prior to implementation. Procedures for implementing design changes, inclttding field changes, shall assure that the impact of the change is carefully considered, required actions documented, and information concerning the change transmitted to affected persons and organizations. These changes shall be subjected to design control measures commensmate with those applied to the original design.

Nonconforming activities such as, deviations, errors or deficiencies in approved design documents, including design methods (such as computer codes), shall be controlled as described in Sections 15.0 and 16.0.

L-4 Attachment 2.1 Rev. 33 Page 12 of29 4.0 PROCUREMENT DOCUMENT CONTROL Procurement Document Control applies to SSCs designated as lTS in Appendix A. Procurement documents shall include those requirements necessary to assure that the items and services to be provided will be of the desired quality.

Procedures that implement procurement document control shall describe the organizational responsibilities for procurement planning~ preparation, review, approva~ and control of procure1nent documents; supplier selection; bid evaluations; identification of replacement parts, where applicable; and review and evaluation of the supplier's QA Program prior to initiation of activities affected by the program.

Procedures shall be established to review the adequacy of the technical and* QA requirements stated in procurement documents; determine that requirements are correctly stated, inspectable, and controllable; assure adequate acceptance and rejection criteda; and provide for the preparation, review, and approval of procurement documents in accordance with applicable requirements. The review and documented concurrence of the adequacy of technical, and QA requirements stated in procurement documents shall be performed by independent personnel trained and qualified in applicable QA practices and concepts.

Changes to procurement documents shall be subject to the same controls as the original document.

L-4 Attachment 2.1 Rev. 33 Page 13 of29 5.0 INSTRUCTIONS, PROCEDURES. AND DRAWINGS Controls for Instructions> Procedures, and Drawings apply to SSCs designated as ITS in Appendix A.

Activities, other than skill of the craft, shall be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings. These documents shall include quantitative or qualitative acceptance criteria for verifying that an activity was satisfactorily accomplished, where applicable (i.e., verification activities for procurement, inspection tests).

Procedures prescribing a preplanned method of conducting activities required by the HBQAP shall be established in accordance with the applicable regulation, codes, standards, and specifications.

Changes to or deviations from established instructions, procedures, or drawings require the same review and approval as the original document. Instructions, procedures, or drawings, including changes and deviations, subject to the HBQAP shall be maintained.

Administrative controls shall be established that provide the methods by which temporary changes can be made to approved procedures, including the designation of persons authorized to approve such changes.

Temporary changes that clearly do not change the intent of the approved procedure from the standpoint of nuclear safety may be approved by two members of the HBPP/ISFSI management team. Such changes shall be documented and, if appropriate, incorporated into the next revision of the affected procedure.

Administrative controls for approval and timely notification or training of personnel affected by the temporary change shall be implemented.

Procedures subject to the HBQAP shall be periodically reviewed as described in administrative procedures.

L-4 Attachment 2.1 Rev. 33 Page 14 of29 6.0 DOCUMENT CONTROL Document Control applies to SSCs designated as ITS in Appendix A, and the administrative programs described in Appendix B. Documents and changes to documents that prescribe or verify activities affecting quality shall be controlled in a 1nanner that precludes the use of inappropriate or outdated documents. *

• A document control system sha11 be established to identify the current revision of instructions, procedures, specifications, drawings, and procurement documents. Written procedures shall identify those responsible for preparing, reviewing, approving, and issuing documents.

Procedures and instructions shall assure that documents, including changes, are prepared; reviewed by a qualified jndividual other than the person who generated the document; approved for release by authorized personnel; distributed to the location where the activity is petfonned prior to commencing work; and used in performing the activity.

Procedures, instructions and other documents that implement HBQAP requirements shall be reviewed and concurred with by the Quality Organization. Revisions to procedures, instructions and other docun1ents shall also be reviewed and concmTed with by the Quality Organization, as specified in administrative procedures.

• L-4 Attachment 2.1 Rev. 33 Page 15 of29 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Control of Purchased Material, Equipment, and Services applies to SSCs and associated activities that are designated as ITS in Appendix A. Supplier activities that provide purchased material, equipment, and services shall be 1nonitored as necessary to assure such items and services meet procurement document requirements.

Procedures shall describe-each organization's responsibilities for the control of purchased material, equipment, and services, .including the interfaces between all affected organizations.

All materials, equipment, and services shall meet the specified technical and quality requirements.

Verification that a supplier can meet the specified technical and quality requirements shall be documented.

A Supplier~s QA Program that satisfies specified quality requirements shall be listed on the PG&E Qualified Suppliers List. The PG&E Qualified Suppliers List shall be controlled.

Suppliers of commercial grade calibration services may be qualified based on their accreditation by a nationally-recognized accrediting body, as an alternative to qualification by supplier audit, commercial grade survey, or in-process surveillance.

The effectiveness of contractors and supplier's quality controls shall be assessed at intervals consistent with the impoliance, complexity, and quantity of the product or service. Supplier performance and compliance with procurement documents are monitored by source verification, receipt inspection, or a combination of the two.

Source verification and/or receipt inspection activities are performed to assure that the requirements of the procurement documents have been met. Accepted items are appropriately marked, removed from the inspection area, and located in a controlled storage area until use.

ITS SSCs and services from a supplier whose QA Program has not been reviewed or accepted may be used provided additional controls such as source inspection, special receipt instructions, and/or testing are imposed. These additional controls shall be docmnented and approved by the appropriate level of management.

Spare and replacement patis are procured such that their performance and quality are at least equivalent to those of the patts that will be replaced. Commercial grade items are controlled by written procedure.

Designated Quality personnel or other personnel with appropriate qualifications are responsible for assuring source inspections, surveys, or audits of suppliers are performed as necessary.

Documentation of acceptance shall be available prior to installation or acceptance for use.

L-4 Attachment 2.1 Rev. 33 Page 16 of29 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS The Identification and Control of Materials, Parts and Components apply to SSCs designated as ITS in Appendix A. Materials, parts, and components shall be identified and controlled in a matmer to preclude the use of incorrect or defective items.

Implementing procedures shall describe the organizational responsibilities and controls to ensure that only correct and accepted items are used.

Materials, parts, and components, including partially fabricated subassemblies, batches, lots, and consumables, shall be identified in a manner that each can be traceable to its applicab]e drawing, specification, or other technic~l documentation at any stage from initial receipt through fabrication, installation, repair, modification or use of an item. When required by code, standard, or specification; traceability of materials, parts, or components to specific inspection or test records shall be provided for and verified.

Items having limited shelf or operating life are controlled to preclude use after the shelf life or operating life has expired.

Identification marking, where employed, shall be clear, unambiguous, and indelible and its application shall not impair the function of the identified item or any other item. When an item is subdivided, the identifying marking shall be transferred to each resulting pa1t. Markings shall not be rendered illegible by treatment, process, assembly, installation, or coating unless other means of identification and determining acceptability are provided.

L-4 Attachment 2.1 Rev. 33 Page 17 of29 9.0 SPECIAL PROCESSES Special Processes apply to SSCs designated as ITS in Appendix A. Special processes shall be controlled and perfotmed by qualified personnel using written procedures or instructions in accordance with applicable codes, standards, specifications, criteda, or other special requirements.

A special process is an activity, in which the quality of the result is highly dependent upon either process variables or the skill and performance of the person doing the work, and the specified quality is difficult to verify by inspection and test after the process is completed.

Special processes include, but are not limited to: welding, heat treating, nondestructive examination, and chemical cleaning.

Equipment used for special processes shall be qualified, maintained, stored, issued in accordance applicable procedures and operated by qualified personneL The implementing instructions shall contain the criteria for assuring proper process control and compliance with applicable codes, standards, QA p1'ocedures, and design specifications. Records of qualifications and controls shall be maintained.

L-4 Attachment 2.1 Rev. 33 Page 18 of29 10.0 INSPECTION Inspection activities apply to SSCs designated as lTS in Appendix A. A comprehensive program of inspection of items and activities affecting quality shall be conducted to verify conformance with established requirements. Procedures shall describe the organizational responsibilities necessary to carry out the inspection program.

Inspections shal1 be planned in accordance with approved procedures, and based on drawings_,

specifications, and other controlled documents. Inspections shall be performed in accordance with written and approved inspection plans and/or inspection procedures to verify that the quality of items and activities conform to applicable and documented instructions, procedures, and drawings. Acceptance/rejection criteria and mandatmy quality control inspection hold points shall be identified, where applicable. Work shall not proceed beyond such hold points without the appropriate documented concmTence by Quality personnel or assigned and authorized personnel.

The inspection results, including acceptance/rejection criteria_, shall be documented and evaluated.

Unacceptable inspection results shall be evaluated and resolved in accordance with procedures. Where applicable~ modifications, repairs and replacements; are re-inspected to the same standard or method to verify acceptability. Inspection records shall be maintained.

Inspections shall be performed by qualified individuals other than those who performed or directly supervised the activity being inspected.

L~4 Attachment 2.1 Rev. 33 Page 19 of29 11.0 TEST CONTROL Test Control applies to the 10 CFR 72 SSCs designated as ITS in Appendix A.

A prograu1 of testing shall be conducted, as necessaty~ to demonstrate that SSCs will pe1form satisfactorily in service. This program shall ensure that the necessary testing is identified and performed at the appropriate time in accordance with written test procedures that incorporate or reference the requirements and acceptance limits contained in the applicable design documents.

The procedures that implement testing shall specify the appropriate prerequisites for the test (e.g.

environmental conditions~ specification of instrumentation, and completeness of tested item), sufficient instruction for the pmforniance of the test, witness or hold points, acceptance/rejection criteria and limits, and the 1'equired test documentation. The procedures shall provide for evaluation and documentation of the test results; data; and their acceptability as detennined by a qualified person or group. Test results that do not meet the acceptance criteria shalJ be documented and evaluated to determine the appropriate corrective action. Where applicable, modifications, repairs, and replacements; are re-tested to verify acceptability. Test records shall be maintained.

L-4 Attachment 2.1 Rev. 33 Page 20 of29 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT The Control of Measuring and Test Equipment applies to SSCs designated as ITS in Appendix A.

Organizational responsibilities shall be delineated for establishing, implementing, and assuring the effectiveness of the calibration program for measuring and test equipment (M&TE).

M&TE, including reference standards, used to determine the acceptability of items or activities shall be maintained within prescribed accuracy limits, suitable range, type, and accuracy to verify conformance with requirements.

Procedures for control ofM&TE shall provide for the identification (labeling, codes, or alternate documented control syste1n), recall, and calibration (including documented pre-calibration checks) of the M&TE. The calibration procedures shall delineate special controls, where applicable, for usage, handling, and storage required for environmental conditions such as temperature, humidity, cleanliness, or radiation to maintain accuracy or operating characteristics of the M&TE.

Calibrations standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shaH be documented. Special calibration' and control measures are not required when normal commercjal practices provide adequate accuracy Instruments shall be calibrated prior to use. The calibration intervals, whether calendar- or usage-based, shall be predetermined and to the extent practical, consistent with the instrument manufacturer's guaranteed repeatability and/or the user's experience. Indication of expiration, if feasible, will be displayed on or with the M&TE. Special calibration shall be required whenever the accuracy of the equipment is suspect M&TE or instrumentation found to be out of calibration shall be evaluated and documented.

Records of M&TE usage shall be 1naintained, such that measures may be taken to determine the validity of previous inspections performed and the acceptability of items inspected or tested since the previous calibration when the M&TE is suspect.

L-4 Attachment 2.1 Rev. 33 Page21 of29 13.0 HANDLING, STORAGE, AND SHIPPING Handling, Storage and Shipping requirements apply to SSCs designated as ITS in Appendix A. Material and equipment shall be handled, stored, and shipped in accordance with design and .procurement requirements in a manner that will prevent damage, deterioration, or loss.

Special coverings, equipment, and protective environments shall be specified and' provided where necessmy for the protection of items from damage or deterioration. When such. special protective features are required, their existence shall be verified and monitored as necessary to assure they continue to serve their intended function.

Special handling tools and equipment shall be provided where necessary to ensure items can be handled safely and without damage.

Markings or labeling shall be used to indicate the .p resence of special environments or the need for special controls. Provisions shall be described for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials.

Special handling, preservation, storage, cleaning, packaging, and shipping requirements are established and accomplished by suitably trained individuals in accordance with predetermined work and inspection instructions.

L-4 Attachment 2.1 Rev. 33 Page 22 of29 14.0 INSPECTION, TEST, AND OPERATING STATUS Inspection, Test and Operating Status requirements apply to SSCs designated as ITS in Appendix A. The inspection, test, and/or operating status of material, equipment, and operating systems shaH be readily apparent and verifiable.

The procedures used to indicate status shall provide means for assuring that required inspections and tests are performed in the prescribed sequence; and acceptability is indicated; to prevent inadvertent use or operation. Items accepted and released are identified to indicate their inspection status prior to forwarding them to a controUed storage area or *r eleasing them for installation or further work. Deviations :fi.*mn the prescribed sequence shall be subject to the same level of control as the generation of the original sequence to prevent the bypassing or omission of a required test or inspection.

The operating status of nonconforming, inoperable or malfunctioning ITS SSCs shall be identified and documented to prevent inadvertent operation. Identification of status may be by such means as, but not limited to, tags, stamps, maddngs, labels, oi* travelers. In some instances, records traceable to the item may be used.

The procedures implementing control of inspection, test, and operating status shall clearly delineate authority for the application, change, or removal of a status identifier.

L-4 Attachment 2.1 Rev. 33 Page 23 of29 15.0 CONTROL OF NONCONFORMING CONDITIONS The Control of Nonconforming Conditions applies to SSCs designated as ITS in Appendix A. Items and activities that do not conform to requirements shall be controlled in a manner that will prevent their inadvertent use or installation. Nonconforming conditions are documented, reviewed and accepted, rejected, repaired or reworked in accordaJ!ce with quality procedures. Organizations affected by nonconform-ing conditions shall be notified of such conditions.

Measures shall be established to identify, label and segregate nonconforming items to indicate their unacceptable status and to prevent inadvertent use or installation until the nonconformance is properly dispositioned. Labels associated with a nonconforming item shall only be removed by authorized personnel.

The acceptability of nonconforming items shall be verified and documented prior to use. Documentation shall include a description of the change, waiver, or deviation that has been accepted.

In cases where required documentary evidence that items have passed required inspections and tests is not available, tl1e associated materials or equipment shall be considered nonconforming. Until suitable documenta1y evidence is available to show that the material or equipment is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fu1fi11 their intended safety :fu.llctions.

Nonconfonning conditions shall be processed as conditions adverse to quality in accordance with Section 16.0.

L-4 Attachment 2.1 Rev. 33 Page24 of29 16.0 CORRECTIVE ACTION Corrective Action applies to SSCs designated as ITS in Appendix A. Conditions adverse to quality shall be identified, controlled, reviewed, and evaluated to determine remedial action and corrective action and implement those actions as soon as practicable.

A systematic review and evaluation of conditions adverse to quality shall be conducted and documented.

Conditions adverse to quality shall include, but not be limited to: engineering, design, and drafting errors; equipment failures and malfunctions; abnormal occurrences; deficiencies; deviations; and defective material, equipment, and services. The evaluation and corrective action taken should be based on safety significance.

Findings and actual or recomtnended conecti~e actions shall be reported to management for review and

~ssessment. Corrective actions shall be accmnplished in a timely manner commensurate with the safety significance.

Significant conditions adverse to quality shall be evaluated for reportability to the NRC. Significant conditions adverse to quality_, the cause of the condition, and the corrective action taken to preclude recurrence shall be documented and reported to management. Follow-up reviews shall be conducted to verify that the corrective action was properly implemented and effective in correcting the identified condition.

L-4 Attachment 2.1 Rev. 33 Page 25 of29 17.0 QUALITY ASSURANCERECORDS The requirements for Quality Assurance Records apply to those SSCs that are designated as ITS described in Appendix A.

Sufficient records shall be 1naintained to furnish evidence of both the quality of items and activities affecting quality and to meet applicable code, standard, regulatory, and license requirements. The records include ali documents referred to, or described in the HBQAP as records or required by quality procedures.

At a n1inimum quality records include operating logs, maintenance and modification procedures, related inspection results_, and reportable occurrences and other records as required by the applicable license, Technical Specifications and Code of Federal Regulations. Additionally, records required by the HBQAP, and furnished by vendors, suppliers, subcontractors, and contractors that perfonn or supply quality-related activities or SSCs that are ITS are also QA Records and shall be maintained.

A management control system for the collection, storage, and maintenance of completed quality assurance

. (QA) rec_ords shall be maintained. This records management program shall be designed and implemented to assure that the QA records are complete, i*eadily retrievable when needed, and protected from damage or destruction during storage by fire, flooding, theft, enviromnental conditions, or other causes.

QA records stored electronically will follow the guidance for electronic records management given in the Nuclear Information and Records Management Association (NIRMA) technical guidelines, TG 11-1998, "Authentication of Records;" TG 15-1998, "Management ofElectronic Records;" TG 16-1998, "Software Configuration Management and Quality Assurance;') and TG 21-1998, "Electronic Records Protection and Restoration." QA records will be stored on electronic media (that is, optical disk, magnetic tape, network array, etc.) meeting the requirements of the NIRMA guidelines. Altmnately_, records stored on optical

• disks may meet the requirements of Generic Letter 88-18, "Plant Record Storage on Optical Disk," dated October 20, 1988. Information Systems will determine the appropriate electronic media. Regardless of the electronic media selected, the process must be capable of producing legible, accurate, and complete records during the required retention period.

Electronic QA records, including backup copies, are stored in two redundant electronic media storage systems at physically-independent electronic locations. QA records in electrmiic format (e.g., pdf fmmat) 1nay be filed and stored on the electronic media storage systems. Selected QA records on other media (e.g.>

paper hardcopies, microfilm, DVDs) are maintained in a Permanent Records Storage Facility.

Detailed records for items or activities shall be specified by instmctions, procedures, drawings, or specification or other documents that prescribe the item or activity and shall be generated by the organization responsible for the item or activity including PG&E and non-PG&E organizations.

L-4 Attachment 2.1 Rev. 33 Page 26 of29 18.0 AUDITS The requirements for Audits app]y to SSCs designated as ITS in Appendix A. Measures shall establish a comprehensive system of planned and periodic audits. These assess, monitor and verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the HBQAP and implementing activities.

Internal and supplier audits are petfonned in accordance with written procedures and/or check lists.

Audits are perfo1med by qualified personnel not having direct responsibility in the areas audited.

Auditors shall have experience, training or qualifications commensurate with the scope and complexity of their audit responsibility.

Scheduling, preparation, personnel selection, performance, reporting, response, follow-up action, and records management are performed in accordance with written procedures. Audit scopes and schedules are established to meet applicable regulatory require1nents and are based on the status and safety significance of the activities to be audited.

. Detailed audit schedules are documented in accordance with Quality procedures. At a minimum, the conformance of decommissioning activities and ISFSI operations to applicable regulatmy requirements is audited at least once every 24 months or more frequently as performance dictates.

External audits of suppliers providing ITS materials, parts, equipment or services are ,scheduled and performed based on the importance of an sse or activity to confirm implementation of their Quality Program requirements, but not less than every 3 years.

Audits that are not mandated by regulation have a grace period of up to 90 days, when the urgency of other priorities makes meeting the specified schedule dates impracticaL For audit activities deferred using a grace period, the next scheduled due date shall be based on the originally scheduled due date, but may not exceed the original due date plus 90 days.

Audit reports shall be prepared, issued to and reviewed by responsible management ofboth the audited and auditing organizations. Audit records shall .be generated and retained. Follow-up action~ including re-audit of deficient areas, shall be taken, where applicable.

L-4 Attachment 2.1 Rev. 33 Page 27 of29 APPENDIX A IMPORTANT-TO-SAFETY STRUCTURES, SYSTEMS AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart Hand 10 CFR 72 Subpatt G will be applied, as a minimum, to quality activities affecting th~ ITS SSCs associated with spent fuel storage and transportation package that are listed below. The quality categ01y is based on the guidance in NUREG/CR-6407. In addition, the HB ISFSI FSAR, Holtec International ill-STORM Safety Analysis Repmt (SAR), Holtec lntemational Ill~STAR SAR and associated specifications include additional classification infonnation.

NOTE There are no HBPP safety related SSCs remaining at the site.

The quality classification of NRC Licensed HB ISFSI Dry Fuel Storage Components and Transportation Packages is made by the NRC Certificate Holder. The Certificate Holder is responsible for design and licensing controls for these components u_nder their NRC approved Quality Assurance Program. PG&E utilizes these types of components and packages under the provisions of a NRC General License for Radioactive Material Transportation Packages (10 CFR 71) and Spent Fuel and GTCC Storage ( 10 CFR 72).

IMPORTANT TO SAFETY AS DEFINED BY 10 CFR 71 AND 10 CFR 72 A. Dry Spent Fuel and GTCC Storage (10 CFR 72) sse Quality Category Desi~n/Liceuse Responsible Multi-Purpose Canister A PG&E Fuel Basket and Basket Spacers A PG&E Damaged Fuel Container A PG&E Hi -Star 100 HB Overpack A PG&E Transporter Lift Links A PG&E GTCC Waste Container A PG&E Hi-Star HB GTCC Overpack A PG&E HB ISFSI Storage Vault B PG&E Fuel Spacers B PG&E Transporter Connector Pins B PG&E Helium Fill Gas B PG&E

• Lid Retention Device B PG&E Cask Transp01ter B PG&E Process Waste Container B PG&E B. Transport of Spent Fuel and GTCC Waste (10 CFR 71) sse Quality Category D esi2n!License Responsible Multi-Purpose Canister A Holtec International Fuel Basket and Basket Spacers A Holtec International Damaged Fuel Container A Holtec International Hi-Star 100 HB Overpack A Holtec International GTCC Waste Container A Holtec International Hi-Star HB GTCC Overpack A Holtec International Fuel Spacers B Holtec International Helium Fi11 Gas B Holtec International

L-4 Attachment 2.1 Rev. 33 Page 28 of29 APPENDIXB ADMINISTRATIVE CONTROLS 1.0 PROGRAMS AND PROCEDURES The program and procedures listed below shall be established and controlled to support HBPP Unit 3 and/or HB ISFSI.

1.1 HBPP U1iit 3 a) Radiation Protection Program b) Radiological Environmental Monitoring Program c) Radioactive Effluent Control Program 1.2 HB ISFSI a) Radiation Protection Program b) Emergency PIan c) Radiological Environmental Monitoring Program d) Security Program (as defined in security license bases documents) 1.3 Management and Administrative Programs The management and administrative programs quality requirements applicable to ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP as described in administrative procedures. Applicable regulatory and quality requirements for the management and administrative programs in Appendix B are designated in administrative programs and procedures.

2.0 RADIOLOGICAL MONITORING Administrative controls for radiological monitoring of gaseous effluents and the environment shall be controlled and implemented to ensure conformance with USNRC Regulatory Guide 4.15 (December 1977).

• 3.0 TECHNICAL SPECIFICATION ACTIVITffiS In addition to the applicable quality assurance requirements specified in the HBQAP, Technical Specification activities shall be controlled in accordance with the Limiting Conditions for Operations (LCO) and Surveillance Requirements (SR).

4.0 OFFSITE DOSE CALCULATION MANUAL The Offsite Dose Calculation Manual (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, and conduct of the radiological environmental monitoring program. The ODCM shall also contain the radioactive effluent controls and radiological enviromnental monitoring activities *and descriptions of the information that should be included in the Annual Radiological Environmental Monitoring Repmt, and Annual Radioactive Effluent Release Report.

Licensee initiated changes to the ODCM: .

1. Sha11 be documented and records of reviews performed shall be retained. This documentation sha11 contain:

i) sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s ), and

L-4 Attachment 2.1 Rev. 33 Page 29 of29 ii) a determination that the change(s) will maintain the level of radioactive effluent control required by 10CFR 20.1302, 40CFR Part 190, IOCFR 50.36a and Appendix Ito 10CFR 50, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

2. . Shall beco1ne effective after review and approval of the HB Director; and

3. Shall be submitted to the Cmmnission in the form of a complete, legible copy of the entire ODCM as a part of or concunent with the Radioactive Effluent Release Rep01t for the period of the rep~tt in which any change in the ODCM was made. Each change shall be identified by marlcings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.0 RADIOACTIVE EFFLUENT CONTROLS PROGRAM This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable (A LARA). The program ( 1) shall be contained in the ODCM, (2) shall be implemented by written procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded.

6.0 REPORTING REQUIREMENTS The following reports shall be submitted in accordance with 10 CFR 50.4.

6.1 Occupational Radiation Exposure Report An annual rep01t shall be made of personnel exposure, in accordance with the requirements of 10 CFR Part 20.2206. The repmt shall be submitted by April 30 of each year.

6.2 Annual Radiological Envil*onmental Monitoring Report The Annual Radiological Environmental Monitoring Report covering the operation of the unit during the previous calendar year shall be sub1nitted by May 1 of each year. The report shaH include summaries, interpretations, and analyses of trends of the resuJts of the Radiological Environmental Monitoring Program for the repmting period. The material provided shall be consistent with the objectives outlined in the ODCM, and in 10 CFR 50, Appendix I> Sections IV.B.2, N.B.3, and IV.C.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of radiological environmental samples and of environmental radiation 1neasurements taken during the period pursuant to the quality related locations specified in the table and figures in the ODCM, as well as summarized *and tabulated results of these analyses and measurements. In the ~vent that some individual results are not available for inclusion with the report, the repmt shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual rep01t.

6,3 Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Repmt covering the activities of the unit in the previous year shall be submitted prior to April I of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released frmn the unit. The material provided shall be consistent with the objectives outlined in the ODCM and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section N.B.l.

Enclosure 3 PG&E Letter HBL-16-001 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

VOLUME 4, REVISION 32

Nuclear Power Generation NUMBER L-4 VOLUME 4 Humboldt Bay REVISION 32 EFFEC DATE 9-4-14 Power Plant PAGE 1 of1 TITLE APPROVED BY ORIGINAL SIGNED 9-4-14 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

DIRECTOR/PLANT MANAGER I DATE HB NUCLEAR (Procedure Classification- Quality Related)

1.0 DESCRIPTION

This document describes the Quality Assurance Plan to be applied to Humboldt Bay Power Plant Unit 3 during decommissioning, and includes Humboldt Bay Independent Spent Fuel Storage Installation (HB ISFSI) activities. The HBQAP satisfies the requirements of 10 CFR 50 Appendix B, and 10 CFR 72 Subpart G. In addition, NRC Approval No. 202, Revision 8 "Quality Assurance Program for Radioactive Material Packages" has approved the HBQAP as satisfying the provisions of 10 CFR 71 subpart H for the procurement, maintenance, repair and use of radioactive materials transport packages.

2.0 ATTACHMENTS 2.1 Humboldt Bay Quality Assurance Plan (HBQAP), Revision 32.

3.0 RESPONSIBLE ORGANIZATION Director, Quality

L-4 Attachment 2.1 Rev. 32 Page 1 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

TABLE OF CONTENTS Section Title Page INTRODUCTION 2 1.0 ORGANIZATION 3 2.0 QUALITY ASSURANCE PROGRAM 8 3.0 DESIGN CONTROL 10 4.0 PROCUREMENT DOCUMENT CONTROL 11 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 12 6.0 DOCUMENT CONTROL 13 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 14 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 15 9.0 SPECIAL PROCESSES 16 10.0 INSPECTION 17 11.0 TEST CONTROL 18 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 19 13.0 HANDLING, STORAGE, AND SHIPPING 20 14.0 INSPECTION, TEST, AND OPERATING STATUS 21 15.0 CONTROL OF NONCONFORMING CONDITIONS 22 16.0 CORRECTIVE ACTION 23 17.0 QUALITY ASSURANCE RECORDS 24 18.0 AUDITS 25 APPENDIX A APPLICABLE STRUCTURES, SYSTEMS, AND COMPONENTS 26 B ADMINISTRATIVE CONTROLS 28

L-4 Attachment 2.1 Rev. 32 Page 2 of29 HUMBOLDT BAY QUALITY ASSURANCE PLAN (HBQAP)

INTRODUCTION Pacific Gas and Electric (PG&E) has established and is implementing a comprehensive Quality Assurance Program for Humboldt Bay Power Plant Unit 3 (HBPP Unit 3) and Humboldt Bay Independent Spent Fuel Storage Installation (HB ISFSI) to assure compliance with established regulatory requirements set forth by the Nuclear Regulatory Commission (NRC). This Quality Assurance Program is described in the Humboldt Bay Quality Assurance Plan (HBQAP).

The Humboldt Bay QA Program consists of the HBQAP and implementing procedures and instructions. The HBQAP describes the responsibilities for implementing quality requirements; establishing and maintaining the QA Program; and assessing the performance of activities subject to theHBQAP.

The HBQAP is a comprehensive statement of the quality assurance controls governing the Important to Safety (ITS) Structures Systems and Components (SSC). The HBQAP describes the organizational structure, functional responsibilities, levels of authority, line of communication, and interfaces. The HBQAP satisfies the requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart Hand 10 CFR 72 Subpart G. The requirements for management and administrative controls are described in appendix B of this HBQAP.

The requirements and commitments contained in the HBQAP are mandatory and must be implemented, enforced, and adhered to by all individuals and organizations performing activities affecting quality. Workers are encouraged to actively participate in the continued improvement and implementation of the HBQAP. Any necessary changes should be promptly communicated and implemented.

The implementation of the requirements of the HBQAP is performed in a graded approach commensurate with any items or activities importance to safety. This graded approach is applicable to ITS SSCs and is responsive to NRC Regulatory Guide 7.10.

The HBQAP is implemented through the use of approved procedures (i.e. policies, procedures, manuals, instructions, or other documents) that provide written guidance for the control of ITS items and activities. The HBQAP also provides for development of documentation to demonstrate objective evidence of compliance with the stated requirements.

L-4 Attachment 2.1 Rev. 32 Page 3 of29 1.0 ORGANIZATION PG&E's efforts are to assure the quality and safety of the decommissioning of the HBPP Unit 3, packaging and transportation of radioactive material and the operation and maintenance of the HB ISFSI utilizing the HBQAP. The program is organized in a structured manner with clearly defined levels of authority, assignments of responsibility and lines of communication.

Assignment of the responsibility for an item or activity includes responsibility for its quality. The Quality Organization provides independent oversight of quality activities and maintains lines of communication with Senior Management.

PG&E has assumed full responsibility for the establishment and execution of the HBQAP prescribed herein, programs and administrative procedures. The work of executing selected portions of the HBQAP may be delegated to organizations external to PG&E; however, in all such instances, PG&E retains overall responsibility.

Specific responsibilities pertaining to quality assurance matters are assigned by the HBQAP and its implementing procedures and instructions to various individuals throughout PG&E. In each instance, the assignment of a responsibility to an individual includes with it a commensurate delegation of sufficient authority that the person can, in fact, fulfill that responsibility. Unless otherwise specifically prohibited, it is understood that the functions, tasks and activities necessary a

to carry out responsibility may be delegated to and performed by other qualified individuals.

All delegations of functions, tasks, activities and authority shall be documented. Individuals may fulfill more than one function unless_prevented by the need to maintain independence as specified in the HBQAP. .

Figure 1 illustrates the organizational structure, functional responsibilities, levels of authority, line of communication, and interfaces of persons and organizations performing activities governed by the HBQAP.

The functional responsibilities shown in Figure 1 are further described below. Generic titles are used for the functions and responsibilities. Differences (if any) between actual titles used in the organization are traceable to the HBQAP titles by the use of administrative procedures.

The PRESIDENT establishes the corporate policies, goals, and objectives related to all ofPG&E's activities and operations.

The SENIOR VICE PRESIDENT -ENERGY SUPPLY reports to the President and oversees PG&E's energy procurement and power generation assets, including nuclear, fossil and hydroelectric, cogeneration and renewable sources, with a focus on planning for and delivering reliable, affordable and clean electricity and gas for distribution to PG&E's customers.

The SENIOR VICE PRESIDENT - CHIEF NUCLEAR OFFICER (CNO) is responsible for overall HBPP Unit 3 decommissioning, and HB ISFSI activities, safety and for taking measures needed to ensure acceptable performance ofthe HB ISFSI staff in designing, fabricating, constructing, testing, operating, modifying, decommissioning, and providing technical support to the HB ISFSI and during HBPP Unit 3 decommissioning.

L-4 Attachment 2.1 Rev. 32 Page 4 of29 The CNO, or designee, as specified in administrative procedures, approves and signs official company correspondence to the U.S. Nuclear Regulatory Commission (NRC) or its representatives. The CNO approves revisions to the QA Program as described herein that constitute a reduction in a commitment made to the NRC. The CNO is responsible for designating individual(s) to perform an Independent Management Review to periodically assess the effectiveness of the HB QA Program.

The DIRECTOR- QUALITY (Quality Director) is responsible for assuring that the HBQAP and implementing procedures are effectively implemented and complied with by all involved organizations, both internal and external to PG&E. The Quality Director has the organizational freedom and requisite authority to assess, review, inspect, audit, and monitor the conduct of quality activities to assure compliance with the HBQAP and other regulatory requirements. The Quality Director reports to the CNO, and has access to the President, HB Director, and appropriate managers for any significant quality problem or deficiency.

The Quality Director is responsible for maintaining and submitting for approval changes to the HBQAP. The Quality Director is responsible for the review of all regulatory submittals as they pertain to the HBQAP and his/her concurrence is required prior to submittal.

Reporting to the Quality Director are the quality assurance, supplier quality and independent quality control inspection functions. These individuals or groups do not have direct responsibility for performing the work being verified; are trained and qualified in QA concepts and practices; are independent of the organization responsible for performing the task and have direct access to management levels. The Quality Organization is sufficiently free from direct pressures for cost and schedule that assures the ability to: (a) identify quality problems; (b) initiate, recommend, or provide solutions through designated channels; and (c) verify implementation of solutions.

Individuals within the Quality Organization have the authority to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming material. Organizational positions with stop work authority are identified in the implementing procedures.

The DIRECTOR- HUMBOLDT BAY (HB Director) is responsible for the conduct of activities related to the HBPP Unit 3 and the HB ISFSI. This includes responsibility for operation, maintenance, engineering, radiation protection, training, security, radioactive material packaging, transport and decommissioning. The day-to-day responsibilities are delegated to and executed by the HB management team that directly reports to the HB Director. Specific responsibilities are described in administrative procedures.

The HB Director is responsible for the Independent Safety Reviewer process. The HB Director is also responsible for the development of, programs, procedures, and instructions required for HBPP Unit 3 and HB ISFSI within the requirements and/or limits established in the HBQAP; HBPP Unit 3 and HB ISFSI Technical Specifications; and administrative guidelines established in the HBPP Unit 3 Defueled Safety Analysis Report (DSAR) and HB ISFSI Final Safety Analysis Report (FSAR). The HB Director is the Design Authority for the HBPP Unit 3 and HB ISFSI.

L-4 Attachment 2.1 Rev. 32 Page 5 of29 The HB Director shall delegate these responsibilities to other members of the HB management team during his/her absence.

The ENGINEERING MANAGER is responsible for technical aspects of the engineering and design of HBPP Unit 3 and HB ISFSI SSCs established for monitoring system performance and trends; performance of modifications to the HB ISFSI; configuration control and design bases defense and management; quality classification of SSCs; and the specification of technical and quality requirements for the purchase of services, materials and equipment.

The ISFSI MANAGER is responsible for the operation and maintenance of the HB ISFSI.

The RADIATION PROTECTION MANAGER is responsible for implementing the radiation protection program for the protection of the workers and members of the public.

An INDEPENDENT MANAGEMENT REVIEW is periodically performed to assess the effectiveness of the HB QA Program, including audit program. Results of the Independent Management Review are provided to the CNO for corrective action, as necessary. Individual(s) that perform the Independent Management Review are appointed by the CNO. In addition, the Independent Management Review includes oversight of the HBQAP implementation and matters relating to decommissioning activities and safe storage of spent nuclear fuel, as directed by the CNO.

INDEPENDENT SAFETY REVIEWER(S) (ISR) perfonns independent safety reviews of proposed changes, tests and experiments to SSCs, activities, program documents and procedures that are subject to the HBQAP requirements. ISRs shall be individuals without direct responsibility for the performance of these activities under review, and shall be competent and knowledgeable in the subject area being reviewed. ISRrs are designated by the HB Director.

CORPORATE SUPPORT for ITS activities includes, but is not limited to, procurement, records, employee concerns, and licensing. Each organization documents and maintains a written description of its internal organization.

SUPPLIERS that provide ITS SSCs or services are required to comply with the HBQAP or to a QA Program approved by PG&E. Supplier QA Programs are required to comply with the applicable portions of 10 CFR 50, Appendix B; 10 CFR 71, Subpart H; or 10 CFR 72, Subpart G.

The Quality Program requirements are defined in the contract or similar procurement document.

Suppliers to PG&E are required to document their internal organization, to the extent necessary for PG&E, to assure the supplier is capable of effectively managing, directing, and executing the requirements of the procurement documents.

L-4 Attachment 2.1 Rev. 32 Page 6 of29 Staff Qualifications Except as specified in other portions of the HBQAP, each member of the staff shall meet or exceed the following minimum qualifications:

For HB Unit 3, the minimum qualifications of ANSI N18.1 (1971) for comparable positions are applicable.

For the HB ISFSI, the minimum qualifications are described in the ISFSI FSAR.

The following requirements and clarifications apply to the positions listed below, and are applicable to both HBPP Unit 3 and the HB ISFSI; The RADIATION PROTECTION MANAGER shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2, April, 1987.

The QUALITY DIRECTOR shall have knowledge of QA regulations, policies, practices, and standards; and experience working in QA, nuclear power plant, fuel storage facility, or in a similar highly technological industry. At the time of assignment to the active position, the Quality Director shall have six years of experience in implementing Quality Assurance.

At least one year of these six years of experience shall be nuclear power plant or fuel storage facility experience in the overall implementation of a Quality Assurance Program (QAP). A minimum of one year of this six-year experience requirement shall be related technical or academic training. A maximum of four years of this six-year experience requirement may be fulfilled by related technical or academic training.

The one year of qualifying nuclear power plant or fuel storage facility experience in the overall implementation of the Quality Assurance program can be obtained outside the Quality Assurance organizations.

L-4 Attachment 2.1 Rev. 32 Page 7 of29 Figure 1 Organization Chart President PG&E Senior Vice President Energy Supply Corporate or Contract Support

• Records

• Licensing ---,

• Procurement Senior Vice President

• Employee Concerns ChiefNuclear Officer

• Other (as required)

I I Director Director Independent Quality Humboldt Bay Management Review I

L----------------------------------------------

I I I Engineering ISFSI Radiation Protection Independent Safety Manager Manager Manager Reviewers

L-4 Attachment 2.1 Rev. 32 Page 8 of29 2.0 QUALITY ASSURANCE PROGRAM 2.1 PROGRAM APPLICABILITY The HBQAP requirements, apply to SSCs designated as ITS in Appendix A.

The quality requirements for the management and administrative programs in Appendix B that support ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP.

The quality requirements for the management and administrative programs that support HBPP Unit 3 are designated in administrative programs and procedures.

A graded approach is used to define the controls applied to quality activities commensurate with the activity's impmiance to safety. The graded approach also applies to the level of quality oversight for quality activities.

Activities that require review and concurrence by Quality personnel are delineated in administrative procedures and are based on the activity's importance to safety.

The effectiveness of the implementation of the HBQAP shall be assured through Quality Related programs, procedures and drawings.

2.2 PROGRAM CONTROL The status and adequacy of the HBQAP shall be regularly monitored and it shall be revised as necessary to improve its effectiveness or to reflect changing conditions.

The HBQAP, including any changes, supplements, or appendices are issued and maintained as controlled documents. Changes to the HBQAP requirements shall be made in accordance with 10 CPR 50.54.

Changes to the HBQAP that do not reduce commitments shall be included in the periodic updates required

• by 10 CFR 50.71. Prior to issuance for use, proposed changes to the HBQAP that reduce commitments are reviewed and concurred with in writing by the Quality Director and are approved by the CNO, or designee, prior to being submitted to and approved by the NRC in accordance with 10 CPR 50.54.

Implementation of the HBQAP is accomplished through separately issued procedures, instructions, and drawings. Each organization is responsible for the establishment and implementation of detailed procedures and instructions prescribing the quality activities for which they are responsible. Such documents are derived from the requirements and reflect the responsibilities specified in the HBQAP.

Questions or disputes involving interpretations of HBQAP requirements and commitments are referred to the Quality Director for resolution. Questions or disputes involving the responsibilities defined in the HBQAP are referred to the CNO.

Questions or disputes involving other quality matters are resolved by referring the matter, in a timely manner, to successively higher levels of management until, if necessary, the matter reaches the management level which has direct authority over all contesting parties.

L-4 Attachment 2.1 Rev. 32 Page 9 of29 2.3 INDOCTRINATION AND TRAINING Indoctrination and training for personnel implementing ITS activities are conducted to assure suitable proficiency is achieved and maintained. The extent of indoctrination and training is commensurate with the scope, complexity and importance to safety of the assigned task; in conjunction with the education and experience of the individual. Personnel involved in implementing the activities within the scope of the HBQAP shall be responsible for the quality of their work. At a minimum, these personnel shall receive:

• Indoctrination in the requirements of the HBQAP;

• Indoctrination in their organization's implementing procedures; and

• Training and quaJification in tasks requiring special skills or knowledge, as required.

Indoctrination, training, qualification, andre-qualification (when applicable) shall be prescribed and performed in accordance with written procedures; and applicable codes, standards and regulatory requirements; which specify the management responsibilities; training areas; frequency of training; method of qualification and requalification; and documentation requirements.

Training and qualification records are maintained in accordance with implementing procedures.

2.4 REGULATORY COMMITMENTS Regulatory commitments, where applicable, are specified in the Unit 3 DSAR, ISFSI FSAR, Technical Specifications or Licenses.

L-4 Attachment 2.1 Rev. 32 Page 10 of29 3.0 DESIGN CONTROL Design Control applies to the 10 CFR 72 SSCs designated as ITS in Appendix A. Design activities shall be controlled to assure that design, technical, and quality requirements are correctly translated into design documents and that changes to design and design documents are properly controlled. Design control procedures shall address responsibilities for:

( 1) Interface contro 1 (2) Design input (3) Design performance (4) Design verification (5) Design change Systematic methods shall be established and documented for communicating needed design information across the external and internal design interfaces, including changes to the design information, as work progresses. Document control measures shall be established for design documents that reflect commitments in applicable design basis documents (e.g., specifications, calculations, computer programs, system descriptions, drawings).Provisions for design input shall defme the technical objectives for SSCs being designed or analyzed. Design inputs shall be documented, reviewed and approved and translated to design documents. Required design analyses (such as stress, thermal, hydraulic and accident analysis; material compatibility; maintenance and repair and ALARA considerations) shall be performed in a planned, controlled, and correct manner. PG&E procedures shall identify the review and approval responsibilities for design analyses.

PG&E shall provide for reviewing, confrrming, or substantiating the design to assure that the design meets the specified design inputs. Design verification shall be performed by competent individuals or groups other than those who performed the original design, but who may be from the same department.

The results of the design verification efforts shall be documented with the identification of the verifier clearly provided. The design verification shall be completed prior to relying upon the component system or structure to perform its function. Procedures shall assure that verified computer codes are certified for use and that their applicability is specified.

Changes or modifications to the designated SSCs in Appendix A shall be approved by the Design Authority, or designee, as specified in administrative procedures, prior to implementation. Procedures for implementing design changes, including field changes, shall assure that the impact of the change is carefully considered, required actions documented, and information concerning the change transmitted to affected persons and organizations. These changes shall be subjected to design control measures commensurate with those applied to the original design.

Nonconforming activities such as, deviations, errors or deficiencies in approved design documents, including design methods (such as computer codes), shall be controlled as described in Sections 15.0 and 16.0.

L-4 Attachment 2.1 Rev. 32 Page 11 of29 4.0 PROCUREMENT DOCUMENT CONTROL Procurement Document Control applies to SSCs designated as ITS in Appendix A. Procurement documents shall include those requirements necessary to assure that the items and services to be provided will be of the desired quality.

Procedures that implement procurement document control shall describe the organizational responsibilities for procurement planning; preparation, review, approval and control of procurement documents; supplier selection; bid evaluations; identification of replacement parts, where applicable; and review and evaluation of the supplier's QA Program prior to initiation of activities affected by the program.

Procedures shall be established to review the adequacy of the technical and QA requirements stated in procurement documents; determine that requirements are correctly stated, inspectable, and controllable; assure adequate acceptance and rejection criteria; and provide for the preparation, review, and approval of procurement documents in accordance with applicable requirements. The review and documented concurrence of the adequacy of technical, and QA requirements stated in procurement documents shall be performed by independent personnel trained and qualified in applicable QA practices and concepts.

Changes to procurement documents shall be subject to the same controls as the original document.

L-4 Attachment 2.1 Rev. 32 Page 12 of29 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Controls for Instructions, Procedures, and Drawings apply to SSCs designated as ITS in Appendix A.

Activities, other than skill of the craft, shall be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings. These documents shall include quantitative or qualitative acceptance criteria for verifying that an activity was satisfactorily accomplished, where applicable (i.e., verification activities for procurement, inspection tests).

Procedures prescribing a preplanned method of conducting activities required by the HBQAP shall be established in accordance with the applicable regulation, codes, standards, and specifications.

Changes to or deviations from established instructions, procedures, or drawings require the same review and approval as the original document. Instructions, procedures, or drawings, including changes and deviations, subject to the HBQAP shall be maintained.

Administrative controls shall be established that provide the methods by which temporary changes can be made to approved procedures, including the designation of persons authorized to approve such changes.

Temporary changes that clearly do not change the intent of the approved procedure from the standpoint of nuclear safety may be approved by two members of the HBPP/ISFSI management team. Such changes shall be documented and, if appropriate, incorporated into the next revision of the affected procedure.

Administrative controls for approval and timely notification or training of personnel affected by the temporary change shall be implemented.

Procedures subject to the HBQAP shall be periodically reviewed as described in administrative procedures.

L-4 Attachment 2.1 Rev.32 Page 13 of29 6.0 DOCUMENT CONTROL Document Control applies to SSCs designated as ITS in Appendix A, and the administrative programs described in Appendix B. Documents and changes to documents that prescribe or verify activities affecting quality shall be controlled in a manner that precludes the use of inappropriate or outdated documents.

A document control system shall be established to identify the current revision of instructions, procedures, specifications, drawings, and procurement documents. Written procedures shall identify those responsible for preparing, reviewing, approving, and issuing documents.

Procedures and instructions shall assure that documents, including changes, are prepared; reviewed by a qualified individual other than the person who generated the document; approved for release by authorized personnel; distributed to the location where the activity is performed prior to commencing work; and used in performing the activity.

Procedures, instructions and other documents that implement HBQAP requirements shall be reviewed and concurred with by the Quality Organization. Revisions to procedures, instructions and other documents shall also be reviewed and concurred with by the Quality Organization, as specified in administrative procedures.

L-4 Attachment 2.1 Rev. 32 Page 14 of29 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Control of Purchased Material, Equipment, and Services applies to SSCs and associated activities that are designated as ITS in Appendix A. Supplier activities that provide purchased material, equipment, and services shall be monitored as necessary to assure such items and services meet procurement document requirements.

Procedures shall describe each organization's responsibilities for the control of purchased material, equipment, and services, including the interfaces between all affected organizations.

All materials, equipment, and services shall meet the specified technical and quality requirements.

Verification that a supplier can meet the specified technical and quality requirements shall be documented.

A Supplier's QA Program that satisfies specified quality requirements shall be listed on the PG&E Qualified Suppliers List. The PG&E Qualified Suppliers List shall be controlled.

Suppliers of commercial grade calibration services may be qualified based on their accreditation by a nationally-recognized accrediting body, as an alternative to qualification by supplier audit, commercial grade survey, or in-process surveillance.

The effectiveness of contractors and supplier's quality controls shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service. Supplier performance and compliance with procurement documents are monitored by source verification, receipt inspection, or a combination of the two.

Source verification and/or receipt inspection activities are performed to assure that the requirements of the procurement documents have been met. Accepted items are appropriately marked, removed from the inspection area, and located in a controlled storage area until use.

ITS SSCs and services from a supplier whose QA Program has not been reviewed or accepted may be used provided additional controls such as source inspection, special receipt instructions, and/or testing are imposed. These additional controls shall be documented and approved by the appropriate level of management.

Spare and replacement parts are procured such that their performance and quality are at least equivalent to those of the parts that will be replaced. Commercial grade items are controlled by written procedure.

Designated Quality personnel or other personnel with appropriate qualifications are responsible for assuring source inspections, surveys, or audits of suppliers are performed as necessary.

Documentation of acceptance shall be available prior to installation or acceptance for use.

L-4 Attachment 2.1 Rev. 32 Page 15 of29 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS The Identification and Control of Materials, Parts and Components apply to SSCs designated as ITS in Appendix A. Materials, parts, and components shall be identified and controlled in a manner to preclude the use of incorrect or defective items.

Implementing procedures shall describe the organizational responsibilities and controls to ensure that only correct and accepted items are used.

Materials, parts, and components, including partially fabricated subassemblies, batches, lots, and consumables, shall be identified in a manner that each can be traceable to its applicable drawing, specification, or other technical documentation at any stage from initial receipt through fabrication, installation, repair, modification or use of an item. When required by code, standard, or specification; traceability of materials, parts, or components to specific inspection or test records shall be provided for and verified.

Items having limited shelf or operating life are controlled to preclude use after the shelf life or operating life has expired.

Identification marking, where employed, shall be clear, unambiguous, and indelible and its application shall not impair the function of the identified item or any other item. When an item is subdivided, the identifying marking shall be transferred to each resulting part. Markings shall not be rendered illegible by treatment, process, assembly, installation, or coating unless other means of identification and determining acceptability are provided.

L-4 Attachment 2.1 Rev. 32 Page 16 of29 9.0 SPECIAL PROCESSES Special Processes apply to SSCs designated as ITS in Appendix A. Special processes shall be controlled and performed by qualified personnel using written procedures or instructions in accordance with applicable codes, standards, specifications, criteria, or other special requirements.

A special process is an activity, in which the quality of the result is highly dependent upon either process variables or the skill and performance of the person doing the work, and the specified quality is difficult to verify by inspection and test after the process is completed.

Special processes include, but are not limited to: welding, heat treating, nondestructive examination, and chemical cleaning.

Equipment used for special processes shall be qualified, maintained, stored, issued in accordance applicable procedures and operated by qualified personnel.

The implementing instructions shall contain the criteria for assuring proper process control and compliance with applicable codes, standards, QA procedures, and design specifications. Records of qualifications and controls shall be maintained.

L-4 Attachment 2.1 Rev. 32 Page 17 of29 10.0 INSPECTION Inspection activities apply to SSCs designated as ITS in Appendix A. A comprehensive program of inspection of items and activities affecting quality shall be conducted to verify conformance with established requirements. Procedures shall describe the organizational responsibilities necessary to carry out the inspection program.

Inspections shall be planned in accordance with approved procedures, and based on drawings, specifications, and other controlled documents. Inspections shall be performed in accordance with written and approved inspection plans and/or inspection procedures to verify that the quality of items and activities conform to applicable and documented instructions, procedures, and drawings. Acceptance/rejection criteria and mandatory quality control inspection hold points shall be identified, where applicable. Work shall not proceed beyond such hold points without the appropriate documented concurrence by Quality personnel or assigned and authorized personnel.

The inspection results, including acceptance/rejection criteria, shall be documented and evaluated.

Unacceptable inspection results shall be evaluated and resolved in accordance with procedures. Where applicable, modifications, repairs and replacements; are re-inspected to the same standard or method to verify acceptability. Inspection records shall be maintained.

Inspections shall be performed by qualified individuals other than those who performed or directly supervised the activity being inspected.

L-4 Attachment 2.1 Rev.32 Page 18 of29 11.0 TEST CONTROL Test Control applies to the 10 CFR 72 SSCs designated as ITS in Appendix A.

A program of testing shall be conducted, as necessary, to demonstrate that SSCs will perform satisfactorily in service. This program shall ensure that the necessary testing is identified and performed at the appropriate time in accordance with written test procedures that incorporate or reference the requirements and acceptance limits contained in the applicable design documents.

The procedures that implement testing shall specify the appropriate prerequisites for the test (e.g.

environmental conditions, specification of instrumentation, and completeness of tested item), sufficient instruction for the performance of the test, witness or hold points, acceptance/rejection criteria and limits, and the required test documentation. The procedures shall provide for evaluation and documentation of the test results; data; and their acceptability as determined by a qualified person or group. Test results that do not meet the acceptance criteria shall be documented and evaluated to determine the appropriate corrective action. Where applicable, modifications, repairs, and replacements; are re-tested to verify acceptability. Test records shall be maintained.

L-4 Attachment 2.1 Rev. 32 Page 19 of29 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT The Control of Measuring and Test Equipment applies to SSCs designated as ITS in Appendix A.

Organizational responsibilities shall be delineated for establishing, implementing, and assuring the effectiveness of the calibration program for measuring and test equipment (M&TE).

M&TE, including reference standards, used to determine the acceptability of items or activities shall be maintained within prescribed accuracy limits, suitable range, type, and accuracy to verify conformance with requirements.

Procedures for control of M&TE shall provide for the identification (labeling, codes, or alternate documented control system), recall, and calibration (including documented pre-calibration checks) of the M&TE. The calibration procedures shall delineate special controls, where applicable, for usage, handling, and storage required for environmental conditions such as temperature, humidity, cleanliness, or radiation to maintain accuracy or operating characteristics of the M&TE.

Calibrations standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shall be ~

documented. Special calibration and control measures are not required when normal commercial practices provide adequate accuracy Instruments shall be calibrated prior to use. The calibration intervals, whether calendar- or usage-based, shall be predetermined and to the extent practical, consistent with the instrument manufacturer's guaranteed repeatability and/or the user's experience. Indication of expiration, if feasible, will be displayed on or with the M&TE. Special calibration shall be required whenever the accuracy of the equipment is suspect. M&TE or instrumentation found to be out of calibration shall be evaluated and documented.

Records of M&TE usage shall be maintained, such that measures may be taken to determine the validity of previous inspections performed and the acceptability of items inspected or tested since the previous calibration when the M&TE is suspect.

L-4 Attachment 2.1 Rev. 32 Page 20 of29 13.0 HANDLING, STORAGE, AND SHIPPING Handling, Storage and Shipping requirements apply to SSCs designated as ITS in Appendix A. Material .

and equipment shall be handled, stored, and shipped in accordance with design and procurement requirements in a manner that will prevent damage, deterioration, or loss.

Special coverings, equipment, and protective environments shall be specified and provided where necessary for the protection of items from damage or deterioration. When such special protective features are required, their existence shall be verified and monitored as necessary to assure they continue to serve their intended function.

Special handling tools and equipment shall be provided where necessary to ensure items can be handled safely and without damage.

Markings or labeling shall be used to indicate the presence of special environments or the need for special controls. Provisions shall be described for the storage of chemicals, reagents (including control of shelf life); lubricants, and other consumable materials.

Special handling, preservation, storage, cleaning, packaging, and shipping requirements are established and accomplished by suitably trained individuals in accordance with predetermined work and inspection instructions.

L-4 Attachment 2.1 Rev. 32 Page 21 of29 14.0 INSPECTION, TEST, AND OPERATING STATUS Inspection, Test and Operating Status requirements apply to SSCs designated as ITS in Appendix A. The inspection, test, and/or operating status of material, equipment, and operating systems shall be readily apparent and verifiable.

The procedures used to indicate status shall provide means for assuring that required inspections and tests are performed in the prescribed sequence; and acceptability is indicated; to prevent inadvertent use or operation. Items accepted and released are identified to indicate their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work. Deviations from the prescribed sequence shall be subject to the same level of control as the generation of the original sequence to prevent the bypassing or omission of a required test or inspection.

The operating status of nonconforming, inoperable or malfunctioning ITS SSCs shall be identified and documented to prevent inadvertent operation. Identification of status may be by such means as, but not limited to, tags, stamps, markings, labels, or travelers. In some instances, records traceable to the item may be used.

The procedures implementing control of inspection, test, and operating status shall clearly delineate authority for the application, change, or removal of a status identifier.

L-4 Attachment 2.1 Rev. 32 Page 22 of29 15.0 CONTROL OF NONCONFORMING CONDITIONS The Control of Nonconforming Conditions applies to SSCs designated as ITS in Appendix A. Items and activities that do not conform to requirements shall be controlled in a manner that will prevent their inadvertent use or installation. Nonconforming conditions are documented, reviewed and accepted, rejected, repaired or reworked in accordance with quality procedures. Organizations affected by nonconforming conditions shall be notified of such conditions.

Measures shall be established to identify, label and segregate nonconforming items to indicate their unacceptable status and to prevent inadvertent use or installation until the nonconformance is properly dispositioned. Labels associated with a nonconforming item shall only be removed by authorized personnel.

The acceptability of nonconforming items shall be verified and documented prior to use. Documentation shall include a description of the change, waiver, or deviation that has been accepted.

In cases where required documentary evidence that items have passed required inspections and tests is not available, the associated materials or equipment shall be considered nonconforming. Until suitable documentary evidence is available to show that the material or equipment is in conformance, affected systems shall be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.

Nonconforming conditions shall be processed as conditions adverse to quality in accordance with Section 16.0.

L-4 Attachment 2.1 Rev. 32 Page 23 of29 16.0 CORRECTIVE ACTION Corrective Action applies to SSCs designated as ITS in Appendix A. Conditions adverse to quality shall be identified, controlled, reviewed, and evaluated to determine remedial action and corrective action and implement those actions as soon as practicable.

A systematic review and evaluation of conditions adverse to quality shall be conducted and documented.

Conditions adverse to quality shall include, but not be limited to: engineering, design, and drafting errors; equipment failures and malfunctions; abnormal occurrences; deficiencies; deviations; and defective material, equipment, and services. The evaluation and corrective action taken should be based on safety significance.

Findings and actual or recommended corrective actions shall be reported to management for review and assessment. Corrective actions shall be accomplished in a timely manner commensurate with the safety significance.

Significant conditions adverse to quality shall be evaluated for reportability to the NRC. Significant conditions adverse to quality, the cause of the condition, and the corrective action taken to preclude recurrence shall be documented and reported to management. Follow-up reviews shall be conducted to verify that the corrective action was properly implemented and effective in correcting the identified condition.

L-4 Attachment 2.1 Rev. 32 Page 24 of29 17.0 QUALITY ASSURANCE RECORDS The requirements for Quality Assurance Records apply to those SSCs that are designated as ITS described in Appendix A.

Sufficient records shall be maintained to furnish evidence of both the quality of items and activities affecting quality and to meet applicable code, standard, regulatory, and license requirements. The records include all documents referred to, or described in the HBQAP as records or required by quality procedures.

At a minimum quality records include operating logs, maintenance and modification procedures, related inspection results, and reportable occurrences and other records as required by the applicable license, Technical Specifications and Code of Federal Regulations. Additionally, records required by the HBQAP, and furnished by vendors, suppliers, subcontractors, and contractors that perform or supply quality-related activities or SSCs that ITS are also QA Records and shall be maintained.

A management control system for the collection, storage, and maintenance of completed quality assurance (QA) records shall be maintained. This records management program shall be designed and implemented to assure that the QA records are complete, readily retrievable when needed, and protected from damage or destruction during storage by fire, flooding, theft, environmental conditions, or other causes.

QA records stored electronically will follow the guidance for electronic records management given in the Nuclear Information and Records Management Association (NIRMA) technical guidelines, TG 11-1998, "Authentication of Records;" TG 15-1998, "Management of Electronic Records;" TG 16-1998, "Software Configuration Management and Quality Assurance;" and TG 21-1998, "Electronic Records Protection and Restoration." QA records will be stored on electronic media (that is, optical disk, magnetic tape, network array, etc.) meeting the requirements of the NIRMA guidelines. Alternately, records stored on optical disks may meet the requirements of Generic Letter 88-18, "Plant Record Storage on Optical Disk," dated October 20, 1988. Information Systems will determine the appropriate electronic media. Regardless of the electronic media selected, the process must be capable of producing legible, accurate, and complete records during the required retention period.

Electronic QA records, including backup copies, are stored in two redundant electronic media storage systems at physically-independent electronic locations. QA records in electronic format (e.g., pdf format) may be filed and stored on the electronic media storage systems. Selected QA records on other media (e.g.,

paper hardcopies, microfilm, DVDs) are maintained in a Permanent Records Storage Facility.

Detailed records for items or activities shall be specified by instructions, procedures, drawings, or specification or other documents that prescribe the item or activity and shall be generated by the organization responsible for the item or activity including PG&E and non-PG&E organizations.

L-4 Attachment 2.1 Rev. 32 Page 25 of 29

• 18.0 AUDITS The requirements for Audits apply to SSCs designated as ITS in Appendix A. Measures shall establish a comprehensive system of planned and periodic audits. These assess, monitor and verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the HBQAP and implementing activities.

Internal and supplier audits are performed in accordance with written procedures and/or check lists.

Audits are performed by qualified personnel not having direct responsibility in the areas audited.

Auditors shall have experience, training or qualifications commensurate with the scope and complexity of their audit responsibility.

Scheduling, preparation, personnel selection, performance, reporting, response, follow-up action, and records management are performed in accordance with written procedures. Audit scopes and schedules are established to meet applicable regulatory requirements and are based on the status and safety significance of the activities to be audited.

Detailed audit schedules are documented in accordance with Quality procedures. At a minimum, the conformance of decommissioning activities and ISFSI operations to applicable regulatory requirements is audited at least once every 24 months or more frequently as performance dictates.

External audits of suppliers providing ITS materials, parts, equipment or services are scheduled and performed based on the importance of an sse or activity to confirm implementation of their Quality Program requirements, but not less than every 3 years.

Audits that are not mandated by regulation have a grace period of up to 90 days, when the urgency of other priorities makes meeting the specified schedule dates impractical. For audit activities deferred using a grace period, the next scheduled due date shall be based on the originally scheduled due date, but may not exceed the original due date plus 90 days.

Audit reports shall be prepared, issued to and reviewed by responsible management of both the audited and auditing organizations. Audit records shall be generated and retained. Follow-up action, including re-audit of deficient areas, shall be taken, where applicable.

L-4 Attachment 2.1 Rev. 32 Page 26 of29 APPENDIX A IMPORTANT-TO-SAFETY STRUCTURES, SYSTEMS AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart Hand 10 CFR 72 Subpart G will be applied, as a minimum, to quality activities affecting the ITS SSCs associated with spent fuel storage and transportation package that are listed below. The quality category is based on the guidance in NUREG/CR-6407. In addition, the HB ISFSI FSAR, Holtec International HI-STORM Safety Analysis Report (SAR), Holtec International HI-STAR SAR and associated specifications include additional classification information.

NOTE There are no HBPP safety related SSCs remaining at the site.

The quality classification ofNRC Licensed HB ISFSI Dry Fuel Storage Components and Transportation Packages is made by the NRC Certificate Holder. The Certificate Holder is responsible for design and licensing controls for these components under their NRC approved Quality Assurance Program. PG&E utilizes these types of components and packages under the provisions of a NRC General License for Radioactive Material Transportation Packages (10 CFR 71) and Spent Fuel and GTCC Storage (1 0 CFR 72).

IMPORTANT TO SAFETY AS DEFINED BY 10 CFR 71 AND 10 CFR 72 A D*ry S;pen t F ueI an d GTCC Storage (10 CFR 72) sse Quality Category Design/License Responsible Multi-Purpose Canister

• A PG&E Fuel Basket and Basket Spacers A PG&E Damaged Fuel Container A PG&E Hi-Star 100 HB Overpack A PG&E Transporter Lift Links A PG&E GTCC Waste Container A PG&E Hi-Star HB GTCC Overpack A PG&E HB ISFSI Storage Vault B PG&E Fuel Spacers B PG&E Transporter Connector Pins B PG&E Helium Fill Gas B PG&E Lid Retention Device B PG&E Cask Transporter B PG&E Process Waste Container B PG&E B. Transport of Spent Fuel and GTCC Waste (10 CFR 71) sse Quality Category Design/License Responsible Multi-Purpose Canister A Holtec International Fuel Basket and Basket Spacers A Holtec International Damaged Fuel Container A Holtec International Hi-Star 100 HB Overpack A Holtec International GTCC Waste Container A Holtec International Hi-Star HB GTCC Overpack A Holtec International Fuel Spacers B Holtec International Helium Fill Gas B Holtec International

L-4 Attachment 2.1 Rev. 32 Page 27 of29 C. Radioactive Material Transport Packages- Greater than Type A Shipments 10 CFR 71)

NRC Certificate Holder*

• Radioactive Material Transport Packages subject to the provisions of 10 CFR 71, Subpart C, "General Licenses" are "Important-to-Safety" and subject to the applicable requirements of the HBQAP. SSC and Quality Category are as determined by the NRC Certificate Holder for the cask chosen for the shipment.

L-4 Attachment 2.1 Rev. 32 Page 28 of29 APPENDIXB ADMINISTRATIVE CONTROLS 1.0 PROGRAMS AND PROCEDURES The program and procedures listed below shall be established and controlled to support HBPP Unit 3 and/or HB ISFSI.

a) Radiation Protection Program b) Emergency Plan c) Radioactive Effluent Control Program d) Security Program (as defined in security license bases documents) e) Radiological Environmental Monitoring Program f) Fire Protection Program The management and administrative programs quality requirements applicable to ITS SSCs in Appendix A are subject to the specific criterion in the HBQAP as described in administrative procedures. To assure compliance with applicable regulatory and quality requirements for the management and administrative programs that support HBPP Unit 3 are designated in administrative programs and procedures.

2.0 RADIOLOGICAL MONITORING Administrative controls for radiological monitoring of gaseous effluents and the environment shall be controlled and implemented to ensure conformance with USNRC Regulatory Guide 4.15 (December 1977).

3.0 TECHNICAL SPECIFICATION ACTIVITIES In addition to the applicable quality assurance requirements specified in the HBQAP, Technical Specification activities shall be controlled in accordance with the Limiting Conditions for Operations (LCO) and Surveillance Requirements (SR).

4.0 OFFSITE DOSE CALCULATION MANUAL The Offsite Dose Calculation Manual (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, calculation of gaseous effluent monitoring alarm and trip setpoints, and conduct of the radiological environmental monitoring program. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities and descriptions of the information that should be included in the Annual Radiological Environmental Monitoring Report, and Annual Radioactive Effluent Release Report.

Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

i) sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change( s), and ii) a determination that the change( s) will maintain the level of radioactive effluent control required by 10CFR 20.1302, 40CFR Part 190, 10CFR 50.36a and Appendix I to 10CFR 50, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

L-4 Attachment 2.1 Rev. 32 Page 29 of29

2. Shall become effective after review and approval of the Plant Manager; and

3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented 5.0 RADIOACTIVE EFFLUENT CONTROLS PROGRAM This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable (ALARA). The program (1) shall be contained in the ODCM, (2) shall be implemented by written procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded.

6.0 REPORTING REQUIREMENTS The following reports shall be submitted in accordance with 10 CPR 50.4.

6.1 Occupational Radiation Exposure Report An annual report shall be made of personnel exposure, in accordance with the requirements of 10 CFR Part 20.2206. The report shall be submitted by April30 of each year.

6.2 Annual Radiological Environmental Monitoring Report The Annual Radiological Environmental Monitoring Report covering the operation of the unit during the previous calendar year shall be submitted by May 1 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the ODCM, and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Monitoring Report shall include the results of analyses of radiological environmental samples and of environmental radiation measurements taken during the period pursuant to the quality related locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual report.

6.3 Annual Radioactive Effluent Release Report The Annual Radioactive Effluent Release Report covering the activities of the unit in the previous year shall be submitted prior to April 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary ofthe quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.l.