ML092030545
| ML092030545 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, 07100174  |
| Issue date: | 07/22/2009 |
| From: | Scherer A Southern California Edison Co |
| To: | Document Control Desk, NRC/NMSS/SFPO |
| References | |
| Download: ML092030545 (8) | |
Text
I~V SOUTHERN CALIFORNIA 1$
EDISON An EDISON INTERNATIONAL Company July 22, 2009 A. Edward Scherer Director Nuclear Regulatory Affairs U. S. Nuclear Regulatory Commission ATTN: Document Control Desk, Director, Spent Fuel Project Office, Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001
Subject:
Docket Nos. 50-206, 50-361, and 50-362 Request for Renewal of Quality Assurance Program Approval for Radioactive Material Packages San Onofre Nuclear Generating Station, Units 1, 2, and 3
References:
1.
July 30,2004 letter from Robert J. Lewis (NRC) to A. Edward Scherer (SCE),
Subject:
Quality Assurance Program Approval for Radioactive Material Packages No. 0174, Revision 7, San Onofre Nuclear Generating Station, Units 1, 2, and 3 2.
July 16, 2004 letter from A. Edward Scherer (SCE) to Director, Office of Nuclear Material Safety and Safeguards (NRC),
Subject:
Docket Nos. 50-206, 50-361 and 50-362, Quality Assurance Program Approval for Radioactive Packages, San Onofre Nuclear Generating Station, Units 1, 2 and 3 3.
June 10, 2009 letter from Michael P. Short (SCE) to Document Control Desk (NRC),
Subject:
Docket Nos. 50-361 and 50-362, Updated Final Safety Analysis Report and Updated Fire Hazard Analysis, Revised April 2009, San Onofre Nuclear Generating Station,
Units 2 and 3
Dear Sir or Madam:
The purpose of this letter is to request a renewal of the Nuclear Regulatory Commission's (NRC's) approval of the San Onofre Nuclear Generating Station (SONGS) Quality Assurance (QA) Program for Radioactive Material Packages.
The current NRC Quality Assurance Program Approval for Radioactive Material Packages (Number 0174, Revision 7) expires August 31,2009. References 1 and 2 cite the previous NRC approval and Southern California Edison (SCE) request, respectively.
P.O. Box 128 San Clemente, CA 92674
Document Control Desk July 22, 2009 Title 10 CFR 71.101 (b) requires that licensees establish, maintain, and execute a quality assurance program. Title 10 CFR 71.101 (c) requires licensees obtain NRC approval of their QA Program for Radioactive Material Packages. Additionally, 10 CFR 71.101 (f) provides that a previously approved QA program which satisfies the applicable criteria of Appendix B of Part 50 and which is established, maintained, and executed regarding transport packages will be accepted.
SCE's current QA Program, Topical Report SCE-1, submitted on June 10,2009 (Reference 3), is applied to radioactive material packages. This previously approved program satisfies the requirements of 10 CFR 71.101 (f).
Additionally, SCE has established further guidance as to the application of this program in the SONGS Topical Quality Assurance Manual, Chapter 5-G, which is enclosed for reference.
This letter contains no regulatory commitments.
If you have any questions or require further information, please contact me.
Sincerely,
Enclosure:
As stated cc:
E. E. Collins, Regional Administrator, NRC Region IV J. E. Whitten, Region IV, San Onofre Unit 1 J. C. Shepherd, NRC Project Manager, San Onofre Unit 1 R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3
SONGS Topical Quality Assurance Manual Units 1,2 & 3 CHAPTER5-G PACKAGING AL~ TRANSPORTION OF RADIOACTIVE MATERIALS 1.0 The purpose ofthis TQAM Chapter is to describe the quality assurance program provisions which will be applied to the packaging and transportation ofradioactive materials greater than the type A quantity limits to implement the requirements of 10CFR71 Subpart H.
2.0 GENERAL RESPONSffiILITIES 2.1 The Manager ofNuclear Fuel is responsible for procurement of offsite spent fuel transportation packaging and related spent fuel shipping services.
2.2 The Manager, Health Physics is responsible for (1) packaging and transportation of radioactive materials at the station and (2) procurement ofpackaging and transportation services for radioactive materials except for spent fuel.
3.0 QUALITY ASSURANCE PROGRAM 3.1
- The quality assurance program is applicable to the procurement, maintenance, repair, and use of radioactive material transportation packages.
RESPONSIBILITY: Division Managers and Supervision as defined throughout this TQAM Chapter 3.2 Controls shall be provided over quality affecting activities to an extent consistent with their importance to safety and as necessary to assure conformance to the approved design for each individual package used for the shipment ofradioactive material.
RESPONSIBILITY: Division Managers and Supervision implementing this TQAM Chapter 3.3 Quality affecting activities shall be accomplished under suitably controlled conditions which include the use ofappropriate equipment; suitable environmental conditions for accomplishing the activities, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied.
RESPONSIBILITY: Division Managers and Supervision implementing this TQA1\\tI Chapter 3.4 The need for special controls, processes, test equipment, tools, and skills to attain the required quality and the need for verification of quality by inspection and testing shall be considered during planning and included, where applicable, in the quality affecting activities.
RESPONSIBILITY: Division Managers and Supervision implementing this TQAM Chapter Page 1 of6 Rev: 11 Approved: 07-16-2009 TL: C001752
SONGS Topical Quality Assurance Manual Units 1,2 & 3 CHAPTER5-G PACKAGING Al\\TJ) TRANSPORTION OF RADIOACTIVE MATERIALS 3.5 The requirements and procedures ofthe quality assurance program shall be based on the following considerations concerning the complexity and proposed use of the radioactive material package and its components:
(1)
The impact of malfunction or failure ofthe item to safety (2)
The design and fabrication complexity or uniqueness ofthe item (3)
The need for special controls and surveillance over processes and equipment (4)
The degree to which functional compliance can be demonstrated by inspection or test (5)
The quality history and degree of standardization of the item RESPONSIBILITY: Division Managers and Supervision implementing this TQAM Chapter and suppliers 3.6 Training and indoctrination ofpersonnel in quality assurance program requirements shall be provided in accordance with TQAM Chapter 1-H.
RESPONSIBILITY: As defined in TQAM Chapter 1-H 3.7 Management shall regularly review the quality assurance program status consistent with the reporting mechanisms of TQAM Chapter I-A.
4.0 DESIGN CONTROL 4.1 The design ofthe radioactive material packages shall be controlled by approved suppliers whose quality assurance programs comply with 10CFR71.
RESPONSIBILITY: Manager, Nuclear Fuel Management; Manager, Design Engineering; Director, Nuclear Oversight.
5.0 PROCUREMENT DOCUMENT CONTROL 5.1 Procurement document control measures shall be provided consistent with the provisions of TQAM Chapter 3-A. These measures shall assure that procurement specifications, contracts, purchase orders and associated documents for procurement ofradioactive material packages and related transportation services contain applicable regulatory requirements, design disclosure documentation, source inspection and audit provisions, codes and standards compliance, quality verification document submittal requirements, and appropriate quality assurance program provisions.
RESPONSIBILITY: Manager, Health Physics; Manager, Nuclear Fuel Management; and as defmed in TQAM Chapter 3-A.
Page 2 of6 Rev: 11 Approved: 07-16-2009 TL: C001752
SONGS Topical Quality Assurance Manual Units 1,2 & 3 CHAPTER5-G PACKAGING AND TRANSPORTION OF RADIOACTIVE MATERIALS 6.0 INSTRUCTIONS AND PROCEDURES 6.1 Instructions and procedures shall be developed and implemented in accordance with the requirements ofTQAM Chapters 1-C and 5-A.
RESPONSIBILITY: As defined in TQAM Chapters 1-C and 5-A.
7.0 DOCUMENT CONTROL 7.1 Document control measures shall be provided in accordance with the requirements ofTQAM Chapter I-D.
RESPONSIBILITY: As defined in TQAM Chapter I-D.
8.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 8.1 Suppliers providing radioactive material packages and related transportation services shall be subject to source evaluation in accordance with the provisions of TQAM Chapter 3-B. Source inspection and surveillance will also be provided consistent with the TQAM Chapter 3-D as appropriate to the item or service procured.
RESPONSIBILITY: As defined in TQA1\\1 Chapters 3-B and 3-D.
8.2 Upon receipt ofpurchased radioactive material packages at the station, a receiving inspection shall be performed in accordance with TQAM Chapter 4-A.
RESPONSIBILITY: As defined in TQAM Chapter 4-A 8.3 Documentary evidence shall be requested from the suppliers in accordance with TQAM Chapter 3-A to assure the radioactive material packages conform to the procurement requirements prior to use ofthe packages. This documentation shall be maintained by SCE in accordance with TQAM Chapter 1-D and be sufficient to identify the specific requirements met by the packages.
RESPONSIBILITY: As defined in TQA1\\1 Chapters 3-A and I-D.
9.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND
. COMPONENTS 9.1 Identification and control systems shall be provided at the station in accordance with TQAJ.\\1 Chapters 4 and 5 (applicable sections) to assure that radioactive material packages and components thereof are identified and this identification is traceable to associated quality records. These controls shall prevent the use of incorrect or defective items.
Page 3 of6 Rev: 11 Approved: 07-16-2009 T1: COO1752
SONGS Topical Quality Assurance Manual Units 1,2 & 3 CHAPTER5-G PACKAGING AND TRANSPORTION OF RADIOACTIVE MATERIALS RESPONSIBILITY: Manager, Site Support Services; Director, Maintenance &
Construction Services; Manager, Health Physics; Director, Nuclear Oversight 10.0 CONTROL OF SPECIAL PROCESSES 10.1 Special processes including welding, heat treating, and nondestructive examination shall be controlled in accordance with TQAM Chapter 5-C related to radioactive material package repair or maintenance by SCE.
RESPONSIBILITY: As defined in TQAM Chapter 5-C.
11.0 INSPECTION 11.1 Inspection ofthe radioactive material package during fabrication and upon receipt at the station shall be performed in accordance with TQAM Chapters 3-D and 4-A.
RESPONSIBILITY: As defined in TQAM Chapters 3-D and 4-A 11.2 Inspection ofthe radioactive material package while in use at the station and prior to release for transportation offsite shall be performed. Inspection of activities shall be performed for each work operation or activity, where necessary, to assure quality. Inspections shall be in accordance with approved procedures and instructions which set forth the requirements and acceptance criteria and specify inspection responsibilities. Inspection Points (hold/witness) as required, shall be indicated in appropriate work documents. If inspection is impossible or disadvantageous, indirect control by monitoring methods, equipment, and personnel shall be provided. Both inspection and process monitoring shall be provided when control is inadequate without both. Records shall be kept in sufficient detail and contain the information required by TQAM Chapter 1-C to permit adequate confirmation ofthe inspection program.
RESPONSIBILITY: Director, Maintenance & Construction Services; Manager, Health Physics; Director, Nuclear Oversight 12.0 TESTING 12.1 Testing ofradioactive material packages at the station as a minimum includes those tests required by the certificate of compliance and necessary to maintain the license ofthe package. The test program and procedures shall include provisions for assuring that all prerequisites for the given test are met, that adequate test instrumentation is available and used, and that the test is performed under suitable' environmental conditions. The test results shall be documented and evaluated to assure that the test requirements have been satisfied.
RESPONSIBILITY: Director, Maintenance & Construction Services; Manager, Health Physics; Director, Nuclear Oversight Page 4 of6 Rev: 11 Approved: 07-16-2009 11: C001752
SONGS Topical Quality Assurance Manual Units 1,2 & 3 CHAPTER5-G PACKAGING A..ND TRAt~SPORTION OF RADIOACTIVE MATERIALS 13.0 CALIBRATION 13.1 A program for calibration and control of measuring test equipment used in quality affecting activities shall be established and implemented consistent with the requirements ofTQAM Chapter 4-E.
RESPONSIBILITY: As defined in TQAM Chapter 4-E.
14.0 HANDLING, STORAGE, AND SHIPPING CONTROLS 14.1 Controls shall be established as appropriate for handling, storage, shipping, cleaning, and preservation ofradioactive material packages to prevent damage or deterioration while at the station.
RESPONSIBILITY: Manager, Site Support Services; Director, Maintenance &
Construction Services; Manager, Health Physics.
14.2 Requirements for control ofpackages in transit after release to the carrier for shipment shall be documented and provided to the carrier for implementation consistent with 10CFR71 requirements.
RESPONSIBILITY: Manager, Health Physics and Manager, Nuclear Fuel Management.
15.0 INSPECTION, TEST, AND OPERATING STATUS 15.1 Controls shall be established to indicate by the use oftags or other suitable means the status of inspection and tests performed at the station related to the radioactive material packages. These controls shall provide for identification of items which have satisfactorily passed required inspections and tests where necessary to preclude inadvertent bypassing ofthe inspections and tests. Controls shall also assure that the operating status of components ofthe packages, such as position indication/tagging ofvalves and switches, is identified to prevent inadvertent operation.
RESPONSIBILITY: Manager, Site Support Services; Director, Maintenance &
Construction Services; Manager, Health Physics; Director, Nuclear Oversight 16.0 NONCONFORMANCES 16.1 Control ofnonconforming items shall be provided in accordance with TQAl\\1 Chapter 4-D.
RESPONSIBILITY: As defined in TQAM Chapter 4-D.
Page 5 of6 Rev: 11 Approved: 07-16-2009 TL: C001752
SONGS Topical Quality Assurance Manual Units 1,2 & 3 CHAPTER5-G PACKAGING AND TRA1~SPORTION OF RADIOACTIVE MATERIALS 17.0 CORRECTIVE ACTION 17.1 Corrective action systems shall be provided in accordance with TQAi\\1 Chapter I-F.
RESPONSIBILITY: As defined in TQAM Chapter I-F.
18.0 QUALITY ASSURANCE RECORDS 18.1 Records which establish conformance with the quality assurance program as described by this TQAM Chapter shall be provided and maintained by SCE in accordance with TQAM Chapter I-D.
RESPONSIBILITY: Division Managers and Supervision implementing this TQAM Chapter; and as described in TQAM Chapter I-D.
19.0 AUDITS 19.1 Audits of all aspects ofthe quality assurance program as described by this TQAM Chapter shall be planned, performed, and documented in accordance with TQAi\\1 Chapter I-E.
RESPONSIBILITY: Director, Nuclear Oversight Page 60f6 Rev: 11 Approved: 07-16-2009 TL: C001752