ML15254A054

Boiling Water Reactor (LACBWR) - Revision 28 of the LACBWR Quality Assurance Program Description (Oapd)

ML15254A054
Person / Time
Site:	La Crosse  File:Dairyland Power Cooperative icon.png
Issue date:	08/18/2015
From:	Nick B Dairyland Power Cooperative
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LAC-14351
Download: ML15254A054 (43)

Text

Pre~kent arid CEO CO 0P~

• ATt V.~ rn U August 18, 2015 10 CFR 50.54(a)(3)

In reply, please refer to LAC-14351 DO3CK¢ET NO. 50-409 and 72-046 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-000t SUBJELr: Dairyland Power Cooperative La Crosse Bolling Water Reactor (LACBWR)

Possession-Only License DPR-45 Revision 28 of the LACBWR Ouality Assurance Program Description .(OAPD)

REFERENCES:

1) LACBWR Possession-Only License No. DPR-45

2) LACI3WR Quality Assuran~ce Program Description, Revision 27 The purpose of this letter reviewis of to the submnit Revision 28 of tire LACBWR QAPD. The changes reflect LACBWR's annual QAPD If you have any questions concerning this submittal, please contact Cheryl Olson, LACBWR PIantIISFSI Manager at (608) 689-4207.

Sincerely, Barbara A. Nick, President; and CEO

• BAN:CLO:tco

Enclosures:

1) LACBWR Quality Assurance Program Description, Revision 28

2) LACBWR QAPD, Revision 28, Summary of Changes cc wlEnclostures: Marlayna Vaaler Project Manager U.S. Nuclear Regulatory Commission Cynthia D. Pederson Regional Administrator, Region Ill 6)oSL U.S. Nuclear Regulatory Commission t41$~s(o A "ThuchsroneEnergy" Cooperatve ____.-;

3200 East Ave, S, o PO Box 817 ' La Crosse, WI 54602-0817 *-60a-787-1258 o 608-787-1469 fax o www.dairynet.com Dairyland Power Cooperative is an equal opportunilty provider and employer,

Document Control Desk LAC-14xxx Page 2 £ Auguist 18, 2015 STATE OF WISCONSIN )

)

COUNTY OP LA CROSSE )

acknowledged the same.

MY commission expires 'f ' '

LAUUR!E A.ENGEM No*.Wr Pubii*

A Touchstone E~nergy°Cooperative .

3200 East Ave. S. aP0 Box 817 o La Crosse, WI S4602-08I.7 o608-787-1.258 o 608-787-1469 fax owww.clairyniet.com Dalryiarnd Power Cooperative Is an equal opportunity provider and employer.

QAPD, Revision 28 Summary and Evaluation of Changes LACBWR QuarTy ASURANCE PROGR1 DI *~WfON (QAPD)

Reviio 28" Sutmmary of Changes The Dlaiiyland Power Cooperative (DPC) suspend~xd its LACBWR dismantloment activities in 2014, secure~d the plat in a safe and stable conditiorn (Passive SAFSTOR), and is in the final stages of negotiating a contracted dismantlemn~rt agreement. The attached revision to the QAPD consist of changes in titles of two ctrrent positions and elarification of programs that apply to dismantlement activities.

Throughout the QAPD, the position of Ptant/lSESI Supervisor has been revised to Plant/ISESt Manager and the position of Health Physics Supervisor has been revised to Radiation Protection Manager to be consistent with* industry practices. Additionally, in Appendix C, Administrative Controls (for programs applicable to SAPSTOR activities), the following programs have been dele.ted:

.1.1. 1SFSI operations and maintenance.

1.1.5 Physical Security Plan implementation.

1.1.6 Emnergency Platn inplenmertation.

- End of Changes-Page. 1 of I

DAIRYLAND POWER COOPEFRATIVE LA CROSSE SOILING WATER RFACTO#R QUALITY ASSUtIANCE PROGRAM DESCRIPTION REVISION 28

.PREPARED BY. PATh ~-4&-2oi~

Manager, Quality Assurance APPROVED BY.

President and CEO J2ATE ~ ,q ev/J'-

DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR STATEMENT909QUA!iT ASSuANcE P0U*LCY The Quality Assurance Program Description (QAPD) described herein has been developed by Dairyland Power Cooperative (DPC) to provide a consolidated overview of the quality program controls that govern the operation and maintenance of the La Crosse Boiling Water Reactor (LACBWR) Independent Spent Fuel Storage Installation (ISFSI) and the Passive SAFSTOR decommissioning of the LACBWR plant. The QAPO describes the quality assurance organizational structure, functional responsibilities, levels of authority and interfaces.

The QAPD applies to the Passive SAFSTOR decommissioning activities performed under 10 CFR 50, Appendix 8 and alt activities associated with structures, systems, and components which are Important to Safety under 1J0 CFR 72. The QAPD also applies to transportation packages licensed by the NRC under 10 CFR 71.

Requirements of the QAPO are performed in a graded approach commensurate with an item's or an activity's importance to safety. This graded approach is responsive to NRC Regulatory Guide 7.10. The applicability of the requirements of the QAPD to other items and activities is determined on a case by case basis. The QAPD satisfies the requirements of 10 CFR 50 Appendix B, 10 CFR 71 Subpart H, and 10 CFR 72 Subpart 0.

The Manager, Quality Assurance is responsible for the establishment and implementation of a quality assurance program which meets ali regulatory requirements. The quality assurance program, as described in this QAPD, is implemented through the use of approved procedures (i.e., policies, directives, procedures, manuals, instructions, or other documents) which provide written guidance for the control of important to Safety items and activities and provides for the development of documentation to demonstrate objective evidence of compliance with stated requirements.

Presrdent and CEO J / _

/ date QAPD Rev. 28 QAPD

DAIRYLAND POWER COOPERATIVE LA GROSSE BOILING WATER REACTOR QUALITY ASSURANCE PROGRAM OESCRIPTION STATEMENT OF POLICY............................................................................. i

0.0 INTRODUCTION

..................................................................................... 1 I. ORGANIZATION .....................................................................................

.2 Ii. QUALITY ASSURANCE PROGRAM.................................................................. 5 III. DESIGN CONTROL AND REVIEW ................................................................... 8 iV. PROCUREMENT DOCUMENT CONTROL ........................................................... 9 V. INSTRUCTIONS, PROCEDURES AND DRAWINGS.................................................. 10 Vi. DOCUMENT CONTROL ............................................................................. 11 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES ............................. 12 Viii. IDENTIFICATION AND CONTROL OF MATERIAL. PARTS, AND COMPONENTS...................... 13 IX. CONTROL OF SPECIAL PROCESSES............................................................... 14

. INSPECTION ........................................................................................ 15 Xi. TEST CONTROL .................................................................................... 16 XII. CONTROL OF MEASURING AND TEST EQUIPMENT................................................ 17 XiiI. HANDLING, STORAGE, AND SHIPPING ............................................................. 18 XIV. INSPECTION, TEST, AND OPERATING STATUS .................................................... ¶19 XV. CORRECTIVE ACTION .............................................................................. 20 XVI. QUALITY ASSURANCE RECORDS.................................................................. 21 XVII. AUITS .............................................................................................. 23 XVIII. OPERATIONS REVIEW COMMITTEE ................................................................ 25 APPENDIX A - IMPORTANT TO SAFETY STRUCTURES. SYSTEMS, AND COMPONENTS.......... 27 APPENDIX B - REGULATORY COMMITMENTS, ALTERNATIVES, AND EXCEPTIONS............... 29 APPENDIX C - ADMINISTRATIVE CONTROLS ....................................................- 30 TABLE 1 - REGULATORY COMPARISON MATRIX .................................................. 34 FIGURE 1- LACB*WR FACILITY, ORGANIZATION..................................................... 35 FIGURE 2 - DAIRYLAND POWER COOPERATIVE MANAGEMENT ORGANFZATION................. 38 QAPD ii Rev. 28

A., n~

The LACBWR Quality Assurance Program Description (QAPD) is designed to meet the requirements of 10 CFR 50, Appendix 5, 10 CFR 71, Subpart H-,and 10 CFR 72, Subpart G and reflects the direction of applicable regulatory guides and industry standards, as they apply to the operation and maintenance of the LACBWR lSFS! and the Passive SAFSTOR phase of decommissioning the LACBWR plant, thereby assuring that risk to the health and safety of the public is not increased.

The quality assurance program described herein is applied by Dairyland Power Cooperative (DPG) to assure safe operation of the LACBWR lSFSI and safe Passive SAFSTOR decommissioning of the LACBWR plant. The QA program shall be applied to activities with a graded approach to quality that is commensurate with an item's or an activity's importance to safety such as design, engineering, procurement, installation, maintenance, modification, operations, and decommissioning by DPC or its contractors, and their subcontractors.

Quality Assurance (QA) as defined herein encompasses all those planned and systematic actions necessary to provide adequate confidence that an important To Safety structure, system, or component will perform its intended function satisfactorily. QA is recognized as an Interdisciplinary function and not the sole responsibility of QA personnel.

It is DPC's policy that the group performing and directly responsible for the work, such as project management, engineering, design, procurement, installation, maintenance, testing, and dismantlement shall be responsible for the quality of work. This includes quality control and verification that all work is performed in accordance with approved documents. QA personnel have responsibility for auditing these groups and assuring DPC management that the QA program is being fully and effectively implemented.

The requirements and commitments contained in this QAPD are mandatory and must be implemented, enforced, and adhered to by all individuals and organizations. Employees are encouraged to actively participate in the continued development of the QA program as well as its implementation.

B. _Terms and Definitions The terms and definitions fisted below are used frequently throughout this document.

COMPAY- Dairyland Power Cooperative (DPC)

LACBWR - La Crosse Boiling Water Reactor.

• QUALITY ASSURANCE _(QA*) - All those planned and systematic actions necessary to provide adequate confidence that structures, systems, or components (SSCs) will perform satisfactorily in service.

QAPD 1 QAPD IRev.

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to control CONTROL QUALITY and measure(C)the -characteristics actions Those quality of which an item, process or afacility provide meansto established requirements.

- Operations Review Committee.

!AIIY- Encompasses the plant site, which is undergoing decommissioning, and the ISFSI site where spent fuel is stored. Excluded are the DPC transmission substation adjacent to the plant site and power transmission apparatus located beyond the LACBWR switchyard.

P - Encompasses the buildings that functionally supported the operation of the LACBWR nuclear power facility.

ADMINISTRAT*IVE CONTROL PRCD_!RE (A*CM_ - A document which establishes the guidelines and requirements governing functional activities.

QA MANUAL - A manual comprised of the QA Program Description.

- Safety Review Committee.

SCHEDULE INTER VAL - A time frame within which a scheduled activity shall be performed with a maximum allowable extension not to exceed 25 percent of the schedule interval.

iMPORTANT TO SAFETY (ITS) - A classification given to structures, systems, and components (SSCs) that provide nuclear safety design functions. (See Appendix A for complete details).

PASV ASOI- Requires thorough initial clean-up, but allows intermittent inspection of the site and shutdown of active systems such as radiation monitoring.

L ORGAN4IZTUt ON A. General Reauiremen~ts Figure 1 shows the organizational structure for the LACBWR facility and establishes the functional lines of authority and responsibility of various groups and individuals participating in the LAC8WR QA program. The authority and duties of persons or groups responsible for the direction, impfementation, and auditing of this program are as follows:

I. DPC President and CEO has corporate responsibility for all quality assurance matters relating to decommissioning the LACBWR plant and operation and maintenance of the LACBWR ISFSI. This individual has delegated the authority and responsibility for administration of quality assurance for LACBWR to the Manager, Quality Assurance.

2. Vice President (VP). Generationi reports directly to the President and CEO and has corporate responsibility for the administration and operation of the LACBWR decommissioning and operation and maintenance of the LACBWR ISFSI.

QAPD 2 QAPIJ 28 2Rev.

3. Site Manaoer. Genoa administration (SM-G) has and operation theLACBWR of the overall responsibility for the ISFSI, the maintenance of the LACBWR plant in Passive SAFSTOR, and the operation of the Genoa 3 coat-fired plant. The 5MG is the Chairman of the Operations Review Committee (ORC), a member of the Safety Review Committee and reports directly to the VP, Generation on alt LACBWR lSFSI or Plant matters. As ORG Chair, the SMG approves all procedures that implement the requirements of N~RC-approved programs and plans.

4. P.Jan~t/ISFSl Manaaie. who reports directly to the Site Manager, Genoa, has on-site responsibility for LACBWR plant decommissioning and operation and maintenance of the LACBWR ISF~l within the limits set forth in the Decommissioning Plan, Technical Specifications and this QAPD. This individual has responsibility for implementing the quality assurance requirements at the operating 1SFSI and decommissioning plant through administrative control procedures and procedures required to fulfill the requirements of this program. Activities performed by outside individuals or groups, including $RCI outside consultants, and representatives of NRC activities, with regard to the LACBWR facility are performed under the authority and responsibility of the Plant/ISFSI Manager.

The Plant/llFSI Manager has daily responsibility for the groupsI designated in the organizational chart for the facility, including maintenance and training activities. The Piant/ISFSi Manager is the ISPSI Security Supervisor and has access to the DPC President and CEO if necessary for security matters, and is responsible for implementation and administration of the LACBWR ISFSI Physical Security Program.

5. Manager. Quality Assuranc~e reports directly to the VP, Generation, with direct access to the DPC President and CEO, if necessary, for quality assurance matters. This individual has responsibility for establishing a quality assurance program and performing audits of the program to determine its effectiveness. This individual has the authority and organizational freedom to verify activities affecting quality and is independent of undue influences and responsibilities for schedules and costs. The Manager, Quality Assurance has the responsibility and authority to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming materials.

...This individual also has the responsibility and authority to-identify.....

quality problems, to recommend or provide solutions, and to verify their implementation. The individual is responsible for administration of the.....

corrective action program.

6. Radiation P..rotecti~on Manaie~r reports directly to the Plant/iSFSI Manager and is responsible for the administration, maintenance, and implementation of the Radiation Protection Program, Process Control Program, Offsite Dose Calculation Manual, Radioactive Effluent Controls Program, and Radiological E~nvironmental Monitoring Program.

QAPD 3 QAPD 28 3Rev.

7. Safety Genoa Managerr functionally reports and has responisibiiity directly safety for industrial to the practices Site Manager, at the plant in accordance with applicable regulations.

8. !SFSI Security Proje~ctManager reports directly to the Plant/ISFSI Manager and has responsibility for ensuring regulatory requirements are adequately met. This individual ensures that the Security Plan, related procedures, training and contingency requirements are developed and maintained current.

9. Technical Engineer reports directly to the Plant/f SF5i Manager and has responsibility for facility licensing during decommissioning, and eventual license termination activities. This individual is the principle liaison on behalf of the Genoa Site Manager and the PlantIiSFSI Manager for contact with the NRC and other regulatory agencies.

10. Coeratioris Re~vlew Committee (ORO) is an advisory committee to the Site Manager, Genoa and Plant/lSFSI Manager and has responsibility for performing independent safety reviews of ISFS! and plant activities prior to implementation of the proposed activity requiring the review.

The safety review shall be a thorough review conducted by qualified independent safety reviewers who are knowledgeable in the subject area being reviewed.

11. SafetyReview Commi~ttee (SRC) is an advisory committee responsible to the President and CEO for providing independent safety review and audit of designated activities on all matters pertaining to ISF$I nuclear safety and existing procedures which are a part of the ISFSI regulatory compliance requirements.

12. Administrative Staff reports directly to the Site Manager. Genoa and is responsible for maintenance of QA records, procedures, indexes, and providing general administrative support.

8. LACBWR Facility Orcanization Reouiraments Figure 1 shows the organization structure for the LACSWR facility which consists of the tSFSI staff and Passive SAFSTOR decommissioning team.

Job descriptions have been provided for key supervisory and some support positions and identify the authority and responsibility that are associated Swith that position. ..... .

C. D~airyiand Power Coop)erative Mar, aaement Oroaanization Figure 2 shows the organization structure for Dairyland Power Cooperative. The LACBWR facility is a responsibility of the President and CEO. rhe responsibility for all purchases as they apply to all generating stations, including LACBWR, and responsibility for control, identification, and issuance of all materials, parts, and components is the responsibility of the Vice President and Chief Financial Officer.

QAPD 4 OAPD 28 4Rev.

I. QUALITYASsStJA~ PA Oa The QA program described herein sets forth the requirements for the OA organization, personnel responsibilities, controls, and measures established to achieve, maintain, and document quality. These requirements include, but are not limited to, the following:

1. incorporation of applicable regulatory criteria, codes, standards, and design bases for ITS SSCs into the ISFSJ operations and maintenance procedures.

2. Performance of all Installation, calibration, and testing on all necessary ITS SSCs in accordance with approved (SF81 procedures.

3. Approved procedures being used in the operation, maintenance, repair, and modification of the ISFSl In compliance with licensing regulations and consistent with quality practices established by OPC.

4. Maintenance of QA recordkeeping, including reports, test results, records, and fogs.

5. Resolution of items identified as adverse to quality with appropriate notifications made to DPC Corporate Management.

6. Performance of audits and surveillances by QA personnel to verity that iSFSl administrative controls, procedures, and procurement documents contain the necessary QA input requirements and appropriate documentation thereof.

B. Aooicblltv J The LACBWR QAPD applies to plant Passive SAFSTOR decommissioning activities (10 CFR 50, Appendix B) and all activities associated with the ISFSi (10 CFR 72) and iTS SSCs. The QAPD also applies to transportation packages licensed by the NRC under 10 CFR 71.

Requirements of the QAPO are performed in a graded approach to quality which is commensurate with an item's or an activity's importance to safety.

This graded approach is responsive to NRC Regulatory Guide 7.10. The QAPO satisfies the requirements of 10 CFR 50 Appendix 8, 10 CFR 71 Subpart H, and 10 CFR 72 Subpart G.. ...

The LACBWR QA program utilizes the Important To Safety (iTS)........

classification process to apply and enforce a graded approach to quality in tasks related to ISFSI SSCs (refer to Appendix A for details).

C. R~e*ulatorv Com mit me~nts Except when alternatives or exceptions are identified, the Implementing procedures for the QAPD shall comply with the quality assurance guidance documents listed in Appendix B. Additionally, the following clarifications apply to all guidance documents listed in Appendix B:

QAPD 5 QAPD 28 5Rev.

1. if the guidance in anyprovided of the listed in thedocuments is incontrolling QAPD is the conflict with the document.

QAPD, the guidance

2. Standards, guides, codes, etc., identified in any commitment document are not quality assurance program requirements unless that document is also listed in the Appendix.

3. Guidance applicable to safety related items and activities (10 CFR 50) are applicable to comparable items and activities (Important To Safety) required by 10 CFR 71 and 10 CFR72.

D. Administrative Controls The Administrative Controls defined in Appendix C were developed to support operation of the LACBWR plant while in SAF$TOR (dismantlement). These requirements were previously included in the Technical Specifications and were relocated to this QAPO during active decommissioning. These requirements are being maintained to support Passive SAFSTOR decommissioning activities and will also be required when decommissioning of the LACSWR plant reconvenes In the future.

The remaining Administrative Controls will be only applicable to the LACBWR ISFSI.

E. lma~piZeme.tatio Individuals that are assigned responsiblities as described in Section 1, UORGANIZATIONI,U shall prepare administrative and quality assurance procedures as necessary to implement the requirements of this program in support of operation and maintenance of the LACBWR ISFSI. Procedures shall include appropriate quantitative and qualitative acceptance criteria necessary to determine that the activity is being properly performed. Audit or surveillance reports are distributed to DPC management for their review and assessment of the QA program, as to effectiveness, scope, adequacy, and implementation, indoctrination in the QA program requirements shall be provided to all facility personnel and contractors performing activities that could affect the quality of structures, systems, or components.

F. Personnel T~rainino and Qualificatio~n Each member of the facility staff (including audit, surveillance and inspection personnel) shall have sufficient qualifications to perform their assigned duties. Rlegulatory GUide 1.8 (Revision I ~dated 5/77) is used for-determining and assessing appropriate staff qualifications.

Training programs are established and implemented to ensure that personnel achieve and maintain suitable proficiency. Additionally, personnel training and qualification records are maintained in accordance with procedures.

In addition to the above, the following specific qualification requirements are required:

1. The position of the Manager, Quality Assurance shall meet the following minimum qualifications:

QAPD 6 QAPD28 6Rev.

a. Graduate of aor or university, four-year accredited the equivalent engineering in practical or science experience plus college five (5) or more years in positions of leadership, such as lead engineer, project engineer, audit team leader, etc.

b. At least two years of this experience should be associated with nuclear quality assuranceactivities, and at least onie year of this experience shall be in a quality assurance organization. An additional two years of quality assurance program implementation may be substituted for the one-year experience within a quality assurance organization.

c. A master's degree in engineering or business management is considered equivalent to two years of experience.

2. The position of Radiation Protection Manager shalt meet the following minimum qualifications:

a. Academic degree in an engineering/science field or equivalent as provided for in paragraph (c), below.

b. Minimum of five years professional experience in the area of radiological safety, three years of which shall be in applied radiation work in a nuclear facility.

c. Technical experience in the area of radiological safety beyond the five year minimum may be substituted on a one-for-one basis towards the academic degree requirement (four years of technical experience being equivalent to a four year academic degree).

d. Academic and technical experience must total a minimum of nine years.

3. The position of Operations Review Committee member shall meet the following minimum qualifications:

a. Knowledgeable of the regulatory requirements and operational aspect of an lSFSI.

b. At least 5 years of professional experience and either a Bachelor's Degree in Engineering or the Physical Sciences or shalt have equivalent qualifications in accordance with ANSI 18,1-1971.

c. Knowledge in the subject areas requiring review.

The Site Manager, Genoa shall evaluate potential committee member's qualifications and document the appointmen*t of a committee member(s) based on their qualifications.

QAPD 7 OAPD 28 7Rev.

Ill. pESIGN CONIROLAND R~EVIE This section establishes the requirements to assure that important To Safety (ITS) structures, systems, and components (SS~s) of the LACBWR~ISFSi are added, deleted, changed or modified in accordance with the codes, standards, and regulations that governed the original design, except as amended and approved. Measures shall be established for the review, evaluation, and approval of all design changes governing ISFSI SSCs. Design control and review for ITS $SCs shall be performed by a Design Authority utilizing their approved 10 CFR 50 Appendix B or 10 CFR 72 Subpart 0 Quality Assurance Program.

SDesign, fabrication, or modification of storage and shipping casks used for shipment of radioactive materials will not be conducted under this section.

B. Responsibilities

1. The LACBWR staff is responsible for establishing procedures to implement design control and the incorporation of design documents into work orders, procedures and instructions.

2. The Plant/ISFSI Manager is responsible for the review of design~drawings, specifications, calculations, and procurement documents to assure that quality standards are included or referenced.

3. The Design Authority is responsible for the incorporation of design bases, regulatory requirements, codes and standards into drawings and specifications related to ITS SSCs design and changes thereto.

4. The ORC is responsible for reviewing all proposed changes and recommending approval or disapproval to the Plant/lSFSI Manager for ISFSt related changes. The review shahl determine whether the proposed modifications require prior NRC approval.

5. The Site Manager, Genoa and Plant/ISFSI Manager are responsible for reviewing the recommendations for ISFSI related activities from the ORC and taking appropriate action. If prior NRC approval is needed, any license amendment request shall be referred to the $RC.

6. The SRC is responsible for pro~vidIng an independent review of changes to the ISF81. They shall provide assurance that the modification meets the design bases, regulatory requirements, and applicable codes and standards.

7. The Technical Enoineer is responsible for the Owner's review of proposed changes to the design of the LACBWR ISFSI to ensure full compliance to the LACBWR design basis, regulatory requirements and applicable codes and standards.

C. Recuirements I. A Work Order shall be initiated for all modifications to ITS SSCs and systems maintained operational during 1SFS! activities. Work Orders may be initiated by any knowledgeable person.

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28

2. Design bases, standards shallregulatory requirements, be delineated and and specify applicable quality appropriate codes and standards and requirements for all proposed ISFSI modifications to ITS SSCs and systems maintained operational during ISFSI activities.

These conditions shall be incorporated into drawings, specifications, procurement documents, and procedures.

3. The Owner's Acceptance Review procedure and Work Control procedure shall describe and control design changes to ISFS! ITS SSCs.

4. All proposed ISFSI modifications shall be reviewed to determine whether they require prior NRC approval.

LV. PR _UqM Ir W f A. General This section establishes the measures to assure that procurement documents (purchase requisitions and orders) covering material, equipment, and services for ISF$i ITS SSCs specify appropriate quality requirements. The purchase order specifies or references the applicable requirements, design bases, codes, and standards to assure quality.

8. Resoaonsibilitles

1. The LACBWR staff Is responsible for developing procedures to control the preparation, review, and approval of purc*hase orders for material, equipment, and services covered by the QA program.

2. The LACBWR staff is responsible for initiation of purchase requisition worksheets for material, equipment, and services required for maintenance, repair, and modifications.

3. The Design Authority Is responsible for preparing engineering specifications which detail the technical and quality requirements for ITS material, equipment, and services.

4. The LACBWR staff is responsible for preparing purchase requisition worksheets for material, equipment, and services.

5. Purchasing is responsible for preparing, reviewing, approving, issuing, ........

and controlling purchase orders.

6. QA personnel are responsible for review of ITS procurement documents to ensure inclusion of appropriate quality requirements.

0. Requirements

1. Purchase requisitions for new material, equipment, and services and for spare or replacement parts shall be initiated by any department personnel. The purchase requisition shall contain the information such as quantity, item description, and technical and quality requirements necessary for procurement of the item.

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2. information Purchase orders to assurespecifications shall include necessary that contain material, equipment, the andallservices are of adequate quality. This shall include material selection, design data, equipment description, source inspection and testing requirements, cleaning and packaging requirements, and required documentation as deemed necessary.

3. Documentation that is required to provide evidence that materials, equipment, and services are of adequate quality shall be clearly delineated in purchase orders. This shall include a listing of each item of documentation to be submitted, when it is to be submitted, what requires approval prior to manufacture, and to whom it shall be submitted.

4. To the extent necessary, ITS procurement dOcUments shall require suppliers of material, equipment, and services to have a quality assurance program complying with the pertinent provisions of 10 CFR 21, 10 CFR 50, Appendix B, andlor 10 CFR 72, Subpart G. Suppliers shall be required to provide OPO access to their facilities and records for inspection and audit, as required, to determine compliance with provisions of the purchase order. These requirements shall extend to lower tier procurements, as determined by DPC management.

5. ITS purchase requisitions shall be reviewed by QA personnel to assure that all necessary quality requirements are included or referenced.

8. Formal purchase orders that have been prepared from the purchase requisition shall be reviewed to assure all required information is correctly incorporated.

7. Changes in technical content in procurement documents shall be initiated and reviewed in accordance with the same procedures utilized in preparationt of the original document.

v. INSTRu~cTOs. POC W ESI AD ORAWI SS A. Gieneral This section establishes the measures to assure that activities relating to lSFSJ activities are performed in accordance with approved instructions,

...procedUres, and drawings.

8. _Resnonsibilities

1. The LACBWR I$FSi staff is responsible for preparing or reviewing all procedures that are required for Implementation of the QAPD.

2. The Site Manager, Genoa Is responsible for approval of ISFSi related procedures that implement NRC-approved programs and plans.

3. The ORC is responsible for reviewing all initial and revised procedures that affect ISFSI operations and sallai determine whether changes to these procedures require prior NRC approval.

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4. The SRC shalt procedures whenreview new procedures it is determined by theorORG changes that to existing prior NRC approval is required.

1. Detailed instruction for iSFSI activities shall be contained in procedures and checklists covering the following activities:

a. administrative control,

b. general security system operation,

c. Security Plan implementation, di. quality assurance,

e. surveillance and test activities of equipment,

2. For activities other than those within normal craft expertise, instructions for maintenance and repair of IBSF! equipment or systems shall be contained in procedures. These procedures shall contain instructions for preparation, performance, testing, and return to service. The procedures may reference manufacturer's instruction manuals, drawings, and other sources, as applicable.

3. instructions, procedures, or drawings for ITS activities shall delineate methods and sequences when an activity is to be performed. These documents shall include appropriate quantitative or qualitative acceptance criteria for determining that the activity has been satisfactorily performed.

4. The department responsible for an activity shall be required to provide the necessary technical input and review of changes to instructions, procedures, or drawings.

5. Changes to or deviations from established instructions, procedures, or drawings wilt require the same review and approval as the original document. However, temporary changes to procedures that do not change the intent of the original procedure may be made in ink, dated, and approved by two people of the management staff.

6. Procedures will be reviewed periodically as set forth in administrative procedures ...

A.Gnea This section establishes the requirements for document control as it applies to the LACBWR ISFSI.

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B. Aesoonsibilities

1. The LACBWR rocedure ISFSI stafftheis issuance for controlling responsible for preparingand of procedures a standard for preparing procedures for controlling the distribution of operating, maintenance, repair, and modification procedures for the ISFSI.

C. Rajeet

1. Procedures shall be established for the issuance of procedures, drawings, and specifications. A document control procedure shali be prepared to provide a uniform system of document identification.

2. All documents shaft have an identification number, title, date, and revision number. Documents shall be filed and controlled by use of this ldentificatlorn. Each type of document shall be fifed in a central location identified in a document control procedure.

3. Drawings, specifications, and procedures, including revisions, shalt be reviewed for adequacy and approved for release by authorized personnel. The required reviews and approvals shall be specified in a document control procedure.

4. The Administrative Staff shall assure that current documents are distributed to and used at the location where the prescribed activity is performed. Documents and revisions shall be distributed as specified in a document control procedure. Preliminary and superseded documents shall be clearly identified and closely controlled to preclude their misuse.

5. An index of each type of document shall be established and maintained to provide the current status of documents.

VII. COQITIOLOF PURCHASED MAT*ER!AL. 2QUIPUENT,AtID SEAIVICES A. eel This sectIon establishes the requirements to assure that purchased ITS material, equipment, and services for the ISFSi, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.

B. FResnonsibillties

1. QA personnel are responsible for developing procedures for Supplier evaluation and qualification and for coordinating supplier evaluation, qualification, and evaluating supplier quality programs. QA personnel are responsible for developing procedures for receiving inspection of material and equipment.

2. LACBWR I6S1~ staff shall be responsible for evaluating supplier manufacturing and technical capabilities.

QAPD 12 QAPD 28 12Rev.

C. Su~olier Ouapllfication

1. Qualification of suppliers supplier, supplier's shall and reputation consist of DPC'sinexperience experience within the the field, and the nucl ear industry, a QA program and/or other factors, as appropriate.

2. Suppliers of casks used for shipment and storage of radioactive material shalt be evaluated to ensure that the design and fabrication of packaging are performed under the control of an NRC-approved and DPC-accepted QA program.

D. S~ource lnsl~ect~on

1. When appropriate, suppliers shall be requested to furnish DPC with sufficient information concerning their manufacturing and inspection plan to permit DPC or their designated agent to plan and implement a source inspection plan.

2. When appropriate, inspection plans shall include wetness and hold points for inspection of items, witnessing of processes or tests, audit of required quality documentation, and verification that vendors have complied with the specification requirements and have documented any deviation from the specifications.

E. Re~ceivin9 Inspection.

I. Items shall be examined by appropriately trained staff upon receipt for shipping damage, correctness of identification, and specified quality documentation, In accordance with approved instructions.

2. Documentary evidence attesting that items conform to purchase order requirements shall be available at the ISFSI prior to installation or use of the item.

3. Documentary evidence shall be sufficient in order to identify that the specific requirements, such as codes, standards, and specifications, can be confirmed for the purchased item. This requirement shall be satisfied by having available copies of the purchase order and appropriate documents referenced therein.

4. All ITS materials, parts, and components wlfl be segregated upon

....receipt and will be placed In a receiving inspection hotd area separate-from storage facilities. After acceptance, the material will be identified

• as acceptable and placed in specified storage.

5. During receiving inspection, if a nonconformance or discrepancy exists, the material shaft be placed on hold and will remain in a hold status until final disposition is determined. A Corrective Action Report (CAR) shall be initiated.

6. Items dispositloned as unacceptable for use shall be rejected and removed from the controlled receiving inspection area.

QAPD 13 QAPD 13Rev.

28

V.i. VIII. AND ~ONTROL OF MATE~UAI.S. ~RTS. At~D C4~MPQNEC4TS This section establishes the requirements for identification and control of ITS material, parts, and components, based on the ISFS! system designation, from receipt at the facility through installation or use.

1. The LACBWR ISFSI staff is responsible for establishing the overall requirements for the identification and control of materials, parts, and components from receipt through installation or use, and/or developing procedures and instructions for the control and issuance of quality related materials, parts, and components.

2. The PlantIISFSt Manager shall approve and ensure implementation of procedures or instructions for the identification and control of materials, parts, and components.

3. Appropriately trained 1SFSI staff is responsible for control of, identification, and issuance of all ITS material, parns, and components.

C. Req*uiernents.

1. Approved instructions and procedures shall be implemented for the identification end control of materials, parts, and components from receipt through installation or use. An identification system utilizing purchase order numbers shall be implemented for identification of material, parts, and components.

2. Specifications shahl require that materials, parts, and components are identified in accordance with purchase order numbers and shall require that documentation have identification providing traceability to an Item.

3. Physical identification by purchase order number shall be used to the maximum extent possible for relating an item at any time to applicable documentation. Identification shall be either on the item or records traceable to the item. Where physical identification is impractical, physical separation, procedural control, or other appropriate means shall be employed.

IX. CONTROL OF SPECIAL PfOCESSES

'A.

This section establishes the measures to assure special processes, including welding, heat treating, and non-destructive testing that are identified as ISFS! ITS, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

QAPD 14 QAPD 28 14Rev.

B. Responsibilities.

I. The LAGBWR how that describe ISFS! staff is responsible personnel for establishing and procedures are qualifiedprocedures for special processes.

2. QA personnel are responsible for reviewing of procedures for welding, heat treating, cleaning, non-destructive examination, and filler metal control and for assuring maintenance, repair, and modification work involving special processes is performed by qualified personnel in accordance with qualified procedures.

3. The PlantlISFSI Manager is responsible for assuring the qualification of personnel in special processes and maintaining records of qualified personnel and procedures performing t8FS1 activities.

C. Roleet

1. Welding, heat treating, cleaning, and non-destructive examination shall be accomplished under controlled conditions in accordance with applicable codes, standards, criteria, and other special requirements, using qualified personnel anid procedures. Qualification of personnel and procedures shall comply with the requirements of applicable codes and standards.

2. Welders and welding procedures shall be qualified, as appropriate, in accordance with Section IX of the ASME 8oiler and Pressure Vessel Code and/or appropriate American Welding Society (AWS) Welding Codes.

3. Non-destructive examination personnel shall be qualified in accordance with the American Society for Non-destructive Testing Standard SNT-TC-1 A.

4. Procedures shall be established to describe the method used to control the receipt, storage, baking, drying, and disbursal of welding filler metals.

5. Equipment used for accomplishing special processes shall be calibrated, maintained, stored, handled, and issued in accordance with applicable procedures or instructions.

X. INSPECTI!ON A. _Gen.eral -

This section establishes a program for inspection of ISFSI activities to verify conformance with approved procedures, drawings, and specifications.

1. The LACBWR ISFSI staff is responsible for assuring adequate inspection requirements are included in engineering specifications, and reviews of any inspection procedures implementing this section are completed.

QAPD 15 QAPD 15Rev.

28

2. QA and personnel are responsible assuring adequate for establishing inspection requirementsinspection procedures are included in procedures. They are also responsible for coordinating the assignments of qualified inspection personnel

3. The Plant/ISFSI Manager shall be responsible for approving ISFSI inspection procedures or instructions and shalt ensure sufficient inspections are performed to provide adequate confidence that project activities meet predetermined requirements.

C. Rqieet

1. Inspections shall be performed only by qualified personnel. in no case shall an acceptance inspection be performed by the individual who performed the activity.

2. Provisions to ensure inspection planning is properly accomplished are to be established. Planning activities shall Identify the characteristics arnd activities to be inspected, the inspection techniques, the acceptance criteria, and the organization responsible for performing the inspections.

3. Mandatory inspection hold points, which require witnessing or inspecting of an activity before proceeding, shall be indicated in the appropriate procedure, specification, or work order. The inspection shall be documented to indicate approval and release prior to continuation of the a'ctivity.

4. Inspection requirements shall apply to all activities whether performed by company personnel or contractor personnel, and shall require that inspection procedures and instructions, along with necessary drawings, are provided prior to commencing inspection activities.

5. Inspection requirements governing modifications, repairs, and replacement shaht be in accordance with the original design and inspection requirements or as amended by approved changes to the original design.

A. eel This section establishes the requirements for an ISFSi test program to demonstrate that ITS SSCs will perform satisfactorily in service. The test program shall include, but not be limited to, surveillance testing, special tests, post maintenance testing, and testing following iSFSi modification or significant changes in procedures.

6. Rsoibllites

1. The LACBWR ISFSI staff is responsible for establishing the requirements to control the test program and for preparation and review of test procedures, surveillance during testing, and review and documentation of test results. The LACBWR staff Is also responsible for establishing specifications, requirements and acceptance criteria QAPD 16 QAPO28 16Rev.

for the testing review following lSFSI and approve of modifications or installation results for testing activities and following modifications.

2. The Plant/ISFSI Manager is responsible for the approval of ISFS1 test procedures or instructions.

3. The ORG is responsible for review of all ITS proposed test procedures, special testing procedures, performance testing procedures following ISFSi modification and 10 CFR 72.48 evaluations.

4. The SRC is responsible for reviewing 10 CFR 72.48 evaluations to verity that ISFSI tests do not require prior NRC approval.

C. Requirements

1. A program shall be established to assure all testing required to demonstrate that ITS SSCs wilt perform satisfactorily in service is identified and documented.

2. Testing shall be performed in accordance with approved test procedures that incorporate or reference the requirements and acceptance criteria contained in applicable design documents and Technical Specifications.

3. Test procedures shall incorporate, but niot be limited to, requirements for such items as: hold points, witness points, caution notes, emergency requirements, and test jumper logs.

4. Test procedures shall include, as a minimum, provisions for assuring that:

a. Prerequisites have been completed that include, as a minimum:

1) Control of systems status as necessary.

2) Availability of calibrated instrumentation and special equipment.

b. Test objectives and applicable acceptance imimts are stated.

c. Test results are documented.

d. Detailed instructions for performing the test are included. -

e. Test results are reviewed and approved.

5. Test reports shall include identification of the inspector, individual conducting the test, the data recorder, the type of observation made, the equipment used, the test results, the acceptability of the test results, and approved disposition for any deviations.

8. Test results which fall to meet the requirements and acceptance criteria sh~all be properly noted and appropriate corrective action taken.

QAPD 17 QAPD 28 17Rev.

XII. CONTAOL OP MEMURING ~NC~ TEST EOUIPMEt#

This section establishes the requirements for written procedures for the control, calibration, and periodic adjustment of tools, gauges, instruments, and other measuring and test equipment used to verify conformance to established ISFSl technical requirements.

B. pesponsibifitie~ss

1. The LACBWRt ISFSI staff is responsible for establishing requirements for a program for the control, calibration, arid periodic adjustment of tools, gauges, instruments, and other measuring and test equipment used.

2. Personnel using Measuring and Test Equipment are responsible for ensuring tools, gauges, instruments, and other measuring and test equipment are calibrated to assure compliance with the implementing procedures.

3. The Plant/lSFSI Manager is responsible for ensuring implementation of the requirements of this section of the manual for ISFSl activities and for approving ISFSI procedures or instructions.

C. Requirerents

1. Inspection, test, and work procedures shall include provisions to assure tools, gauges, instruments, and other inspection, measuring, and test equipment and devices used in activities affecting quality are of the proper range, type, and accuracy to verify conformance to established requirements and test parameters.

2. To assure equipment accuracy, inspection, measuring, and test equipment shall be controlled, calibrated, adjusted, and maintained periodically, or prior to use. Calibrations are performed against certified measurement standards that are traceable to nationally recognized standards. Where national standards do not exist, provisions will be established to document the basis for calibration.

Control measures and procedures shall prevent the use of calibrated tools, gauges, instruments, and other measuring and test equipment by unauthorized personnel: Special calibration and control measures are not required for devices when normal commercial practices provide

.... adequate accuracy.

3. When an item of measuring and test equipment is found to be out of calibration, an investigation will be conducted and documented to determine the validity of previous inspections, tests, or calibrations which were performed with the use of that item.

4. Records or logs of the calibration history of measuring and test equipment shall be maintain~ed.

5. Measuring and test equipment shall be controlled by a permanently affixed serial number. Calibration decais, tags or stickers shall be QAPD 18 OAPD18Rev.

28

and shahl date of reflect thecalibration) displayed nextdevice due date ofontheeach calibration,prominently calibration (for recurring and identity of person performing the calibration.

This section establishes the requirements for ISFSI procedures to control the handling, storage, shipping, cleaning, packaging, and preservation of ITS material and equipment to prevent damage, deterioration, or foss through shipment, installation or use.

B. ReeD~onslboitittes

1. The LACBWR ISFSi staff is responsible for establishing requirements for the handling, storage, and shipping of materials, parts, and components covered by the QA program.

2. The PiantIISFSI Manager is responsible for approval of all implementing procedures or instructions related to the ISFSI and ensuring the implementation of the requirements of this section of the QAPD.

1. The requiremnents for handling, storage, shipping, cleaning, and preservation of materials, and equipment shall be documented in approved procedures.

2. Procurement documents shall include instructions for the handling, storage, shipping, cleaning, and preservation of the item being supplied, as applicable.

3. Procurement documents specify marking requirements, special covering, and protective environments, such as inert gas atmosphere, moisture content levels, and temperature levels, as applicabte.

4. Specifications and procedures establish the requirements for special handling tools and equipment to ensure safe and adequate handling of critical, sensitive, or radioactive items,

5. Special handling toots and equipment will be inspected and tested in accordance with approved procedures, at Specified intervals, to verify that tools and equipment are adequately maintained.

6. Materials and equipment will normally be handled by materials handling personnel. Other special shipments which require special equipment and handling will be handled by knowledgeable and trained personnel.

7. Storage of material and equipment will be in areas free from fumes, vapors, and dust. Storage will be in areas protected from the weather, as appropriate, and In which chemical storage is excluded, except as may be specifically authorized in writing. Storage will be in areas QAPD t9 QAPD 28 19Rev.

requirements specified for the item. satisfy the handling and storage which This section describes the system for indicating the inspection, test, and operating status of ITS components and systems at the ISFSI.

1. The LACBWR I$FSI staff is responsible for ensuring that the status of operating equipment or systems to be removed from service for maintenance, test, inspection, repair, or modification is in accordance with the approved LACBWR procedures and shall monitor the status of activities for compliance with approved procedures and shall ensure inspection results are properly logged. They shall establish the procedures for implementing the work inspection or status sheets during maintenance, repair, and modifications and shall ensure inspection results are properly logged. The LACBWR ISFSI staff is also responsible for the control of ISFSI status during modifications.

1. Equipment or systems not ready for normal service shall be clearly identified by use of tags.

2. Equipment or system inspection and test status shall be indicated.

3. $SCs that are found to be unacceptable during or after testing shall have their status clearly identified.

xv. cOnIRECTIVE TO This section establishes measures to assure that conditions adverse to quality at the ISFSI, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and noni-conformances are promptly identified and corrected. This includes the control of materials, parts, or components that do riot conform to requirements, thereby ....

preventing their inadvertent use or installation.

1. The LACBWR ISFSI staff is responsible for establishing procedures for the identification, review, and correction of conditions adverse to quality which includes the control, evaluation, and disposition of deficient materials, parts, and components.

2. The LACBWR ISFS! staff is responsible for reviewing nonconforming items that cannot be corrected by vendor action and recommending disposition. The LACBWR 1SFSI staff is also responsible for preparing procedures for repair and rework of nonconforming items.

QAPD 20 QAPD 20Rev.

28

3. The LACBWR is responsible forofreviewing conditions adverse ISFSI to quality to staff determine the cause the condition and for recommending corrective action to preclude repetition.

4. The ORC is responsible for reviewing significant conditions adverse to quality and recommending corrective action.

C. 2, giuji

1. Conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, shalt be reported on a Corrective Action Report (CAR). Materials, parts, or components that do not conform to requirements shall be identified and placed in a hold status. Nonconforming items shall remain in a segregated area until approved disposition has been determined.

2. The CAR shall identify the condition, the cause of the condition, and the corrective action taken.

3. For vendor-supplied items or services, the vendor shall be notifiled of all nonconforming items and requested to correct the deficiencies.

LACBWR ISFSI staff with assistance from Purchasing shall be responsible for coordinating the disposition of deficient items with vendors. QA personnel are responsible for inspecting and accepting or rejecting items that have been corrected by vendors.

4. Deficiencies which cannot be corrected by the vendor shall be reviewed by the LACBWR I$FSI staff who will recommend repair, rework, accept, or reject. Items shall be repaired or reworked only In accordance with approved procedures and shalt be re-inspected after repair by QA personnel. LAGCBWR ISFS! staff shall ensure that documented and approved procedures are available prior to repair or rework.

5. Items which are accepted for use with a known deficiency sha[l be fully documented with the specification requirement, justification for acceptance, and effect of such use. All such items shall be approved by the Plant/f SFSI Manager prior to use.

6. Conditions adverse to quality which involve design deficiencies, or recommended corrective actions that Involve a design change, shall be

..... reviewed by LACBWR ISFSI staff or applicable Design- Authority. -

,.XVl. ,QUALITY ASSURANCE RECORDS A. General This section establishes measures for maintaining ISFS! records which cover all documents and records associated with the operation, maintenance, installation, repair, and modification of SSCs covered by the QAPD. Also included are historical records gathered and collected during plant and iSFSl operations which are either required to support the dry cask storage systems stored at the ISFSI or ultimate shipment to a federal repository.

QAPD 21 QAPD 21Rev.

28

8. Resoo.nsibllities_

1. The LACBWR ISFSI staff is responsible for establishing the requirements of this section.

2. The Site Manager, G3enoa is responsible for approving and ensuring implementation of procedures for this section.

c. SoaeRqieet

1. Originals of special process records are stored in a fire-retardant area designed to accommodate such records.

2. On-site storage facility is constructed in such a manner as to safeguard the contents from fire, extreme temperature, and moisture variations.

3. Entry to the record storage areas is controlled, and only authorized personnel are permitted access.

4. Storage requirements shall meet ANSI N45.2.9, "Requirements for Collection, Storage, and Maintenance of Quality Assurance Records."

0. .System Reauirements

1. A system shall be established to identify all documents that must be kept permanently (lifetime records). An index of non-permanent records shall be established.

2. An approved document listing will be reviewed on a regular basis to verify that the record file contains the latest revisions of all required documents.

3. A system will be established to control the issuance and return of all records.

E. Rcr eeto in addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at feast the minimum period indicated.

1. The following records shall be retained for at feast five years:

a. Records and logs of ISFSI operation.

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

c. All Reportable Events submitted to the Commission.

d. Records of surveillance activities, inspections, and calibrations required by the NAG-MPG CoC and FSAR.

QAPD 22 QAPD 28 22Rev.

e. MPG Records CoGofand changes FSAR.made to the procedures required by the NAC-

f. Record of changes made to programs and procedures required by Appendix C.

g. Records of radioactive shipments.

h. Records of sealed source and fission detector teak tests and results.

i. Records of annual physical inventory of all sealed source material of record.

j. QA Audits.

2. The following records shall be retained for the duration of the LACBWR license:

a. Facility design modification packages and work order packages.

b. Records of new and irradiated fuel inventory, fuel transfers and assembly burn-up histories.

c. Records of radiation exposure for alt individuals enterdng radiation control areas.

d. Records of facility radiation and contamination surveys.

0 e. Records of gaseous and liquid radioactive material released to the environs, and records of analyses required by the Radiological Environmental Monitoring Program.

f. Records of training and qualification for current members of the facility staff.

g. Records of in-service inspections performed pursuant to Technical Specifications.

h. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 GFR 50.59 and 10 GFR 72.48.

i. Records of meetings of the ORG and the SRC.

.......... j. Records of decommissioning and/or dIsmarntlement of the facility....

k. Records of reviews performed for changes to the Offsite Dose Calculation Manual and the Process Control Program.

I.Records of the test results obtained in welding procedures and welder performance qualifications and a listing of qualified personnel and procedures.

e m. Records of training, test results, and a listing of qualified personnel.

QAPD 23 QAPD 28 23Rev.

XVH. AUOmS A. General This section establishes the requirements for a system of planned and documented audits to verify compliance with all aspects of the QA program and to assess the effectiveness of the program as it applies to the ISFSI.

The system provides for the reporting and review of audit results by appropriate levels of supervision and management.

8. Resoonsilbilitie~s

1. QA personnel are responsible for developing audit checklists, designating end training audit personnel, and conducting audits.

2. The SRG performs independent review arnd audit to verify that the ISFSI is being maintained consistent with company safety, administrative, and licensing provisions. The evaluations of t$SFS activities shall be performed by QA personnel or a qualified offsite entity under the cognizance of the SRC.

C. Reauirements Implementing procedure(s) for the internal audit/survey program shalt include controls to ensure that the following are met:

1. Audits shall be performed in accordance with written procedures or checklists by appropriately trained personnel having no direct responsibilities in the area audited. Deficiencies from previous audits shall be reviewed and re-audited, as appropriate. The checklists are used as guides to the auditor.

2. Audits may be conducted by QA personnel or other qualified personnel, such as technical specialists from other company departments and outside consultants.

3. Audit and surveillance results shall be documented and reviewed with supervision responsible for the area audited, who shall take necessary action to correct reported deficiencies. Follow-up action, including re-audit/re-survey of deficient areas, is initiated as deemed appropriate.

... 4. QA personnel shall assess the following: -

a. evaluation of quality assurance practices, procedures, and instructions;

b. effectiveness of implementation; and

c. conformance with approved procedures.

5. Audit schedules assure that the following areas are audited at the indicated frequencies or more frequently as performance dictates.

a. The conformance of ISFSi operation to provisions contained within the NAG-MPG CoG Technical Specifications and applicable license QAPD 24 OAPD 24Rev.

28

conditions is audited shall include elementsatsuch leastas:

once every 24 months. The audit

• Training and qualifications of the staff.

• Actions taken to correct deficiencies occurring with equipment, structure, systems, or method of operation that affect nuclear safety.

• Performance of activities required by the QA program to meet the criteria of 10 CFR 50}, Appendix B, 10 CFR 71, Subpart K and 10 CFR 72, Subpart G.

• Implementation of the programs required by Appendix C, 1.0 through 2.5.

b. Other activltlesfdocuments as requested by the President and CEO or SRC.

7. Deficiencies or nonconformances identified during an audit shall be documented and brought to the attention of the Site Manager, Genoa and the Plant/ISFSI Manager. Follow-up shall be performed to verify that corrective actions have been taken to correct the deficiencies or nonconformances.

8. AudIt reports are sent to DPC management for their review and assessment of the QA program.

9. Audit reports shalt be forwarded to the President and CEO, and to the management positions, responsible for the areas audited, within 30 days after completion of the audit.

10. External audits or surveys of suppliers providing Important To Safety materials, parts, equipment or services are performed at the indicated frequency or more frequently as performance dictates.

it. Suppliers providing commercial grade calibration services who are accredited by a nationtally recognized accrediting body, using procedures consistent with those found in ANSIIISO/IEC 17025 tmGeneral Requirements for the Competence of Testing and Calibration LaboratoriesD, do rnot have to be periodically surveyed if the conditions of the NRC Safet~y Evaluation dated September 28, 2005 are met (see Appendix B). Controls shall be established in applicable procedures to ensure the requirements of the NRC Safety Evaluation are satisfied.

XVIII. OPERATI*ONS REVIIEW COMMiTTEE A. Genea rhis section establishes the requirements for the Operations Review Committee (ORC) for ISFSI activities which shall consist of thorough reviews conducted by qualified independent safety reviewers. Persons performing these reviews shall be k~nowledgeable in the subject area being reviewed, Independent safety reviews must be completed prior to implementation of the proposed activity requiring the review.

QAPD 25 QAPD 28 25Rev.

13. Resoonsibiiities ORG members shall be individuals without d~irect responsibility for the

• performance of the activities under review. These reviewers may be from the same functionally cognizant organization as the individual or group performing the original work.

C. Rcieet The following subjects shalt be independently reviewed by a qualified ORG member:

1. Review of proposed changes to the LACBWR Technical Specifications, and review of those changes submitted to LACBWR by the Certificate Hotder for the NAG-MPG System for implementation consideration.

2. Review of proposed tests and experiments not described in the NAG-MPG FSAR.

3. Review of proposed changes or modifications to the ISFSI site, ISFSI SSCs, or equipment that affect nuclear safety.

4. Review of all procedures and programs required by Appendix C and changes thereto that require an evaluation in accordance with 10 CFR 72.°48.

5. Render determination, in writing tG the Site Manager, Genoa if any items considered under 1 through 4 above, as appropriate and as provided for In 10 CFR 50.90 or 10 CFR 72.48 as requiring prior NRC approval.

QAPD 26 QAPD26Rev.

28

APPENDIX A (Page 1 of 2)

The pertinent quality assurance requirements of 10 CFR 50, Appendix 8, 10 CFR 71 Subpart H and 10 CFR 72 Subpart 6 will be applied, as a minimum, to alt quality activities affecting the Important To Safety (ITS) Structures, Systems and Components (SSCs) associated with spent fuel storage and transportation package.

The safety classification of 88Cc of the LACBWR ISFSI facility may be revised based on engineering evaluations and a revision to the NAG-MPG FSAR. These modifications are controlled In accordancewith the Design Control process and are not considereda reduction In the commitments to the QAPD.

The quality classificationof NRC.licensed Dry Spent Fuel Storage Components and TransportationPackages may not be revised using the LACBWR Design Control process. These modifications must be made by the Certificate Holder. The Certificate Holder is responsiblefor design and licensing controls for these components under their NRC-approved Quality Assurance Program. DPC ut~iizes these types of components and packages under the provisions of a NRC General License for Radioactive Material TransportationPackages(10 CFR 71) and Spent Fuel Storage (10 CFRU 72).

items and services associated with Packaging and Transportation of Radioactive Material as described In 10 CFR 71, and Independent Storage of Spent Nuclear Fuel as described in 10 CFR 72, will also fall under the requirements of the QAPD.

ITS SSCs associated with spent fuel storage and radioactive material transportation packages are defined below:

A. Dry Spent Fuel Storage (10 CFR 72)

.. ... . .... . .. . . .. .... .... DeSlgn~ icense Trasp rtbe Storagze ,Canatrand Fuel Basket As.sembly.... ... A .. - NAC Intl.

Vertical Concrete Cask B -NAG Intl.

Trnsfer Cask and Adlapter Plate B NAG Intl.

(SF51 Pad .. . .:- . . ., , - , , , . .. . " ...._ -.. . ... C . .. * -,*.. L A..i:.

CBW R . . .

LiftingYoke . .B NAG Intl.

Damagled Fuel Canl. .. . .. ... .A . NAC Intl.

QAPD 27 QAPD28 27Rev.

APPENDIX (Page 2 of 2)A IMPO0RTANTTo sAFT m RW uRns. $SeMs AJDCMOET 8, Transport of Sptfl Fuel end GTCC Waste (10 CFR 71) 580 Quality Categowy Respnltrl.-se T'ransporae Storage Canisters and Fuel Baske*Assemb],Ly Damaned Fuel ,Ca,,n.. ... ... . ....

A A.

j .

NAC Intl.

NAC Intl.

Transportable Storage Canister and Baskot Assembly For A I NAC Intl.

GTCC Waste.Containe rs .... ____

• Stoimqe Transport Cask (STC)  : ... , -'n. . .A

"  : "...NAG Int- .. .

C. Rtadioective Materilt Transport Package (10 CFA 71)

Radioactive Material Transport Packages subject to the provisions of 10 CFR 71, Subpart C, uGeneral Licenses," are Important To Safety and subject to the applicable requirements of the QAPD.

NOTES:

1. See NAG-MPG Final Safety Analysis Report for additional classification information.

2. See NAC Storage Transport Cask (STC) Fins!Safety Analysis Report and associated NAG specifications for additional classification information.

3. For the definition of Quality Categories A, B, and C refer to NUJREG/CR-6407.

QAPD 28 QAPD 28 28Rev.

APPENDIX B 1.0 R&GaULATORY coBeIMxeNTs.

1.1 Regulatory Guide 1.8, 1-R-5177', Personnel Selection and Training, Endorses ANSI N18.1-1971.

1.2 Regulatory Guide 7.10, Revision 2 (3/05), "ESstablishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material.w 1.3 NUREGICR-6407, "Classification of Transportation Packaging and Dry Fuel Storage System Components According to important to Safety 2.1 Letter from NRC to Arizona Public Service Company titled "Paio Verde Nuclear Generating Station, Units 1, 2 and 3 - Approval of Change to Quality Assurance Program (Commercial-Grade Calibration Services)

TAC Nos. M04402, MC4403, and MC4404)" and associated NRC Safety Evaluation dated September 28, 2005.

None QAPD 29 QAPD28 29Rev.

A*PIPEND) C (Page 4 of 4)

These Administrative Controls were developed to support operation of the LACBWR plant white in SAFSTOR (dismantlement). These requirements were previously included in the Technical Specifications and were relocated to this QAPD during active decommissioning. These requirements are also being maintained to support Passive SAFSTOR decommissioning activities and will also be required when decommissioning of the LACBWR plant reconvenes in the future. The remaining Administrative Controls will only be applicable to the LACBWR ISFSI.

1.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

1.1.1 All programs specified in Section 2 of this Appendix.

1.1.2 Fire Protection Program implementation,.

1.1.3 Radiation Protection Program implementation.

1.1.4 Procedure for controlling temporary changes.

1,2 Each procedure required by Section 1.1 above and programs listed in Section 2.1 through 2.5, and any changes thereto, shall be independently reviewed in accordance with Section XVIII and approved by the designated manager (i.e., Plant/ISFSI Manager) or designee prior to implementation.

2. POGRA3E AND MNUALS 2.1 Process Control Prooram (PCP)

The PCP shall be maintained on-site and will be available for NRC review. Licensee-initiated changes to the POP shall be submitted to the NRC in the annual Radioactive Effluent Release Report for the period in which the change(s) was made. This submittal shall contain:

2.1. 1 Information to support the rationale for the change; 2.1.2 A determination that the change did not reduce the overall ....

conformance of the solidified waste product to existing criteria for solid wastes; and ...

2.1.3 Documentation of the fact that the change has been reviewed and found acceptable by the ORG.

2.2 Offsite Dose_ Ca~lculation M~anual (00CM)

The 0DCM shall be maintained by the licensee. Changes to the ODCM will be outlined in the annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

QAPD 30 QAPD 28 30Rev.

(Page 4 of4)C APPENW~X 2.2.1 Detailed information to support the rationale for the change.

information submitted should consist of a package of those pages of the 0DCM changed with each page numbered and provided with an approval and date box, together with appropriate analyses or evaluations justifying the change(s); and 2.2.2 A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations.

A program shall be provided conforming to 10 CFR 50.36a for control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the 0DCM, (2) shahl be implemented by health physics procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

2.3.1 Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation, including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; 2.3.2 Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 CFR 20, Appendix B, Table 2, and Column 2; 2.3.3 Monitoring, sampling and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20 and with the methodology and parameters described in the 0DCM.

2.3.4 Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas conforming to 10 CFR Part 50, Appendix I; 2.3.5 Determination of cumulative and projected dose contributions...

from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the 00CM at least every year; 2.3.6 Limitations on the annual and quarterly doses to a member of the public from tritium and all radionuclides in particulate form with half-lives greater than eight days in gaseous effluents released to areas beyond the site boundary conforming to 10 CFR 50, Appendix I; QAPD 31 QAPD 28 31Rev.

APPENDIX C (Page 4 of 4) 2.3.7 Limitations on the annual dose or dose commitment to any member of the public due to release of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

2.4 R dooialE v on etlM ntrn Pr r m A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide representative measurements of radioactivity in the highest potential exposure pathways. The program shall (1) be contained in the ODCM; (2) conform to the guidance of 10 CFR 50, Appendix I; and (3) include the following:

2.4.1 Monitoring, sampling, analysis, and reporting of radiation and radionudlides in the environment In accordance with the methodology and parameters described in the ODCM.

2.4.2 Participation in an Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in the environmental sample matrices are performed as part of the Quality Assurance Program for environmental monitoring.

2.5 Reortl9 enuire~nts In addition to applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted prior to March 1 of each year in accordance with 10 CFR 50.4.

2.5.1 Annutal Radiolocaical Environmental Monitoring Re!ort An Annual Radiological Environmental Monitoring Report which shall include summarized and tabulated results, including interpretations and analysis of data trends, of environmental samples taken during the previous calendar year. In the event that some results are not available for inctusion with the report, the report shall be submitted noting and explaining the reasons ....

for the missing results. The missing data shall be submitted as soon as possible in a supplementary report. ...

The report shall also include the following: a summary description of the Radiological Environmental Monitoring Program; a map of all sampling locations keyed to a table giving distances and directions from the plant; the results of the Interlaboratory Comparison Program; arnd a discussion of all analyses in which the lower limit of detection (LLD) was not achievable.

QAPD 32 QAPD 32Rev.

28

APPENDIX C (Page 4 of 4) 2.5.2 Annua Radioactiv Effunt Releas Re~oor Paragraph (a)(2) of 10 CFR 50.S6a, "Technical Specifications on Effluents from Nuclear Power Reactors,tm requires that a report be Smade to the Commission annually. The report shall specify the quantity of each of the principal radionuclides released to unrestricted areas by liquid or gaseous effluents during the previous year. With the exception of the collection of hourly meteorological data, the information submitted shall be in Saccordance with Appendix B of Regulatory Guide 1.21 (Revision

1) dated June 1974 with data summarized on at least a quarterly basis.

This same report shall include an assessment, performed in accordance with the ODCM, of radiation doses to members of the public from radioactive liquid and gaseous effluents released beyond the effluent release boundary. This report shall contain any changes made to the 00CM during the previous twelve months.

QAPD 33 28 QAPD33Rev.

0 TABLE I REGULATORY COMPARISOfl MATRIX LAC.WR RE.GULATORY GUIDE 7.10 ._____

QUALITY ASSURANCE* PROGRAM REUAOYGIF .0 10 CFR 50 (SECTION) IMPLEMENT~hi*G PROCEDURES EGLTRGUD7.0 APPENDIX B (SECTION) (SECTION)

0.0 INTRODUCTION

I. ORGANIZATION ACP-03.0l 1.1,1.2 I iI. QUALITY ASSURANcE PROGRAM~ ...... tACP..03.O1, ACP-O7l.... ,12. .82.4,:2.5 _____... ___-_...

mI. DE=SIGNCONTROL AND REVIEW" .. . I.ACP-03.+03, ACP-001, ACP-07.03 3.1,3.2,3.3 .... ________"_

IV. PROCUREMENT DOCUMENT CONTROL - AOP-05.01 4.,4.2, 4.3 IV,V, VI V.INTRCTON, ROEDRE, NDDRWIGSACP..07.01, ECP-02 51, 52V VI. DOCUMENT CONTROL ACP-.07.O1, ECP-02 [6.1 6.2,6.3,65.4.V VI.CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND ACP-05.0, ACP-1 1.01 71,7.,.,7. Vii, Viii VI.SERVICES -

• __ _ __ _ __

VIII. IDENTIFICATlON AND CONTROL OF MATERIALS, PAATS, & ACP-.09.01  !'8 .......... VI.... .

COMPONENTS ______ Vi____________

IX. CONTROL OF SPECIAL PROCESSES ACP-10,01 9IX X. iNSPECTION !ACP-1 1.01 ;10.102 X XI. TEST CONTROL. ACP-12.O1 i11.1, 11.2,11l.3, 11.4, 11.5 X{I XII. CONTROl. OF MEASURING AND TEST EQUIPMENT ACP-13.01 112.1, 12.2 XliI Xili. H-ANDUNG, STORAGE, &SNIPPING " ACP-05.01 13.1, 13.2 XII Xl.INSPECTION, TEST AND OPERATING STATUS ACP=I 1.0l, ACP-12.01, ACP-15.04 14 XIV XV. CORRECTIVE ACTION PROGRAM +ACP-16.D, ACP-.17.02, ACP-17.04 15, 16.1,286.2 XV, XVI XVl. QUALITY ASSURANCE RECORIDS iACP-18.01 17.'1,17.2, t7.3, 17.4, 17.6 XVII X~il. ADITS AC-03.Ol18.1, 18.2, 18.3, 18.4, 18.5, ti ACP0301 __18.6, 18.7XVI XVItl OPERATIONS REVIEVI COMMITrEE ACP-.02.13 N(A j NA QAPD 34 QAPO 28 34Rev.

FiGURlE 1 LACBWR FACILITY ORGANIZ*ATUON QAPO Rv. 28

0 FiGURIE 2 DAIRYLANID POWER COOPlERATIVE MANAGEENT ORGAtAZATIOW 0

1

(*1:* 38 e.

36 26 QAPO

• ACP-07.01 Issue 88 Page11 of 2 TO: .. ,NRC.Washington- Document Control Desk CONTROLLED DISTRIBUTiON NO....5 FROM: LACBWR PlanIIISFSi Manager 8/20/2015

SUBJECT:

Qhanes o LACBWflQQntro~led Douments

1. The following documents have teen revised or issued new.

QAPD Issue 28 Ouality Assurance Program Description

• Please file the documents in the appropriate controlled document binder and location. The superseded material shall be destroyed.

[] The documents listed above shall be reviewed, end affected personnel shall be notified of the changes. Read and Heed Training shall be documented on Page 2 of 2 as rcequired.

2. The following documents have been CANCELLED. Please destroy all copies.

1Sf_ DATE__________

Please return this notification to the LACBWR Administrative Staff within ten (10) working days.