ML16020A004

Dairyland Power Cooperative, La Crosse Boiling Water Reactor - Revision 29 of the Quality Assurance Program Description (QAPD)

ML16020A004
Person / Time
Site:	La Crosse  File:Dairyland Power Cooperative icon.png
Issue date:	10/29/2015
From:	Nick B Dairyland Power Cooperative
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LAC-14359
Download: ML16020A004 (39)

Text

BARBARA A. NICK President and CEO DAIRYLAND POWER COOPERATIVE October 29, 2015 10 CFR 50.54(a)(4)

In reply, please refer to LAC- 14359 DOCKET NO. 50-409 and 72-046 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)

Possession-Only License DPR-45 Revision 29 of the LACBWR Quality Assurance Program Description (OAPD)

REFERENCES:

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

2) LACBWR Quality Assurance Program Description, Revision 28 The purpose of this letter is to submit Revision 29 of the LACBWR QAPD for USNRC approval prior to implementation. Dairyland Power Cooperative and LaCrosseSolutions, LLC have recently submitted an application to transfer the LACBWR Possession-Only License No. DPR-45 to LaCrosseSolutions, LLC. Revision 29 of the QAPD is reflective of that change and, with NRC approval, would be implemented at the time of the license transfer.

If you have any questions concerning this submittal, please contact Cheryl Olson, LACBWR ISFSJ/Plant 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 t'7ie A Touchstone Energye Cooperative ___.

3200 East Ave. S.

• P0 Box 817

• La Crosse, WI 54602-0817

• 608-787-1258

• 608-787-1469 fax

• www.dairynet.com Dairyland Power Cooperative is an equal opportunity provider and employer.

Document Control Desk LAC-14359 Page 2 October 29, 2015 cc w/

Enclosures:

Marlayna Vaaler Project Manager U.S. Nuclear Regulatory Commission Cynthia D. Pederson Regional Administrator, Region III U.S. Nuclear Regulatory Commission STATE OF WISCONSIN )

)

CONY OFLCossE Personally came before me this *4 . day of * , ' ,* ,20 15, the above named, Barbara A. Nick, to me known to be the person who executed the foregoing instrument and acknowledged the same.

Notarublic, La Crosse County Wisconsin My commission expires 5"- Aq 5" /

LAURIE A. ENGEN Notary Public State of Wisconsin A Touchstone Energye Cooperative ___*

3200 East Ave. S. P0 Box 817 o La Crosse, WI 54602-0817 a 608-787-1258

• 608-787-1469 fax . www.dairynet.com Dairyland Power Cooperative is an equal opportunity provider and employer.

A LA CROSSE BOILING WATER REACTOR QUALITY ASSURANCE PROGRAM DESCRIPTION REVISION 29 La Crosse Solutions, L *JQW!NS):

Author: .-. /

rr Date /

Anthony R. Bejm~¶dependent Consultant QA Approval: "J James E. Werner, SOLUTIONS QA Manager 'Datei!

Manager Approval:

Date Corporate QA Appro* val: *R44',*__. Aug 14 2015 9:.35 P.M Mike Nicol, Ene~rgySolutions Corporate Director, QA Date Dairyland Power Cooperative (DPC)

QA Approval: 9-3o -2Qtoll Ed Martin, Manager, Quality Assurance Date Manager Approval:

Lane S. Peters, Site Manager, Genoa Date Dt

v LA CROSSE BOILING WATER REACTOR STATEMENT OF QUALITY ASSURANCE POLICY The Quality Assurance Program Description (QAPD) described herein has been developed by Dairyland Power Cooperative (DPC) and La Crosse Solutions, LLC (SOLUTIONS) 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 decommissioning of the LACBWR plant. The QAPD describes the quality assurance organizational structure, functional responsibilities, levels of authority and interfaces.

The QAPO applies to all activities associated with structures, systems, and components which are Important to Safety under 10 CFR 72. The QAPD also applies to transportation packages licensed by the NRC under 10 CFR 71. Requirements of the QAPD 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 decommissioning 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 G.

The SOLUTIONS Executive Vice President and General Manager is responsible for the establishment and implementation of a quality assurance program which meets all 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.

Solutions Executive Dairyland Executive Executive-!P sident and General Manager President and CEO ..

DteD -- Date QAPD i QAPD Rev. 29

LA CROSSE BOILING WATER REACTOR (LACBWR)

QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD)

TABLE OF CONTENTS SECTION PAGE STATEMENT OFPOLICY ................................................................................. i

0.0 INTRODUCTION

........................................................................ 3 I. ORGANIZATION ....................................................................... 4 I1. QUALITY ASSURANCE PROGRAM...................................................................... 6 III. DESIGN CONTROL AND REVIEW ....................................................................... 10 IV. PROCUREMENT DOCUMENT CONTROL............................................................... 11 V. INSTRUCTION, PROCEDURES AND DRAWINGS....................................................... 13 VI. DOCUMENT CONTROL.................................................................................. 14 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES ............................... 14 VIII. IDENTIFICATION ANif ClONTROL OF MATERIAL, DPATS, AND COMPONENTS ....................... 16 IX. CONTROL OF SPECIAL PROCESSES................................................................... 17 X. INSPECTION ............................................................................................. 18 XI. TEST CONTROL ....................................................................... 18 XII. CONTROL OF MEASURING AND TEST EQUIPMENT................................................... 20 XIII. HANDLING, STORAGE, AND SHIPPING................................................................. 21 XIV. INSPECTION, TEST, AND OPERATING STATUS........................................................ 22 XV. CORRECTIVE ACTION................................................................................... 22 XVI. QUALITY ASSURANCE RECORDS...................................................................... 23 XVII. AUDITS ................................................................................................... 26 APPENDIX A - IMPORTANT TO SAFETY STRUCTURES, SYSTEMS, AND COMPONENT ............ 29 APPENDIX B - REGULATORY COMMITMENTS, ALTERNATIVEBS, AND EXCEPTIONS................ 31 APPENDIX C - ADMINISTRATIVE CONTROLS.......................................................... 32 FIGURE 1 - La CROSSE SOLUTIONS ORGANIZATION ................................................. 36 QAPD ii Rev. 29

0.0 INTRODUCTION

A. General Upon NRC approval, SOLUTIONS will be the NRC licensee responsible for all activities under the LACBWR License. SOLUTIONS will commence decommissioning of the LACBWR site. DPC will retain ownership of the land and spent fuel and be the owner licensee. DPC will be subcontracted for the management and operation of the LACBWR ISFSI. Upon completion of decommissioning, SOLUTIONS will apply to the NRC to transfer responsibility for the NRC License back to DPC. Thereafter, DPC will maintain the ISESI, and be. responsible for the ultimate disposition of the spent nuclear fuel.

In order to minimize disruption and maximize efficiency, this revision of the LACBWR Quality Assurance Program Description (QAPD) was jointly developed by DPC and SOLUTIONS to facilitate the various stages of license transition described above. During the decommissioning activities, SOLUTIONS will subcontract the operations and maintenance of the ISFSI to DPC. Although DPC procedures and processes will continue to be used for the operations and maintenance of the ISFSI, SOLUTIONS will be the licensee with overall responsibility and authority to ensure the QAPD requirements applicable to the ISESI are effectively implemented by DPC, or others, as applicable. The requirements of this QAPD will apply to all ISESI activities and selected plant decommissioning activities.

The QAPD is designed to meet the requirements of 10 CFR 50, Appendix B, 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 ISESI and the decommissioning of the LACBWR plant, thereby assuring that risk to the health and safety of the public is not increased.

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 management that the QA program is being fully and effectively implemented. QA is recognized as an interdisciplinary function and not the sole responsibility of QA personnel.

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 listed below are used frequently throughout this document.

LACBWR - La Crosse Boiling Water Reactor.

QAPD 3 QAPD3Rev.

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QUALIFIED TECHNICAL REVIEW - Thorough reviews of the documents specified in this QAPD shall be conducted by a Qualified Technical Reviewer.

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.

QUALITY CONTROL (QC) - Those quality actions which provide a means to control and measure the characteristics of an item, process or facility to established requirements.

FACILITY - 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.

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

SCHEDULE INTERVAL - 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.

MPORTANT O~r SAET (TS)i - A ~ Sul,= aL,,..,u,, gie t structures, systems, and components (SSCs) that provide nuclear safety design functions. (See Appendix A for complete details).

ORGANIZATION A. General Requirements

1. This section defines the responsibilities of key project members accountable for implementation of the QAPD. Functions and actions can be delegated; however, the responsibility remains with the designated individual.

2. Onsite and offsite organizations shall be established for station and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safe storage of nuclear fuel.

3. Since SOLUTIONS and DPC will be working to the requirements of this QAPD, each organization is depicted on the Figure 1, La Crosse Solutions Organization. This QAPD identifies key on-site project management team positions for SOLUTIONS and their off-site corporate support groups. The QAPD also defines the DPC management team that will manage the ISFSI operations.

4. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as QAPD 4 QAPD4Rev.

29

.1 appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

5. The individuals who carry out health physics and quality assurance activities may functionally report to an appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

B.1Orgqanization - SOLUTIONS

1. President - The President manages the operation of EnergySolutions stewardship projects at U.S. Reactor sites, and assures that the LACBWR project receives timely and effective support from EnergySolutions corporate groups. The President meets periodically with the GM and other key managers to review the operation of the LACBWR ISESI and decommissioning and to address project management, quality, and related issues. The President shall have corporate responsibility for the safe storage of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure the safe storage of nuclear fuel.

2. Executive Vice President and General Manaqer (GM) - This executive provides direct oversight of the project, and other selected tasks, to ensure the project is properly planned, staffed and executed. The GM has overall authority and responsibility for the establishment and effective implementation of the QAPD. The GM has periodic meetings with the management team to review plans and progress and to address stakeholder, quality, and project management issues. The GM delegates to DPC and the management team the day-to-day responsibilities for the ISFSI and decommissioning by approved documents, respectively.

3. Proiect Manaqer (PM) - The PM is responsible for all decommissioning activities, including fire protection and industrial safety activities at the decommissioning site. The PM shall have authority over those on site activities necessary for safe storage of nuclear fuel which have been subcontracted~to DPC. The PM is also responsible for the functions described in Appendix C of this QAPD, and for the Qualified Technical Review process utilized for decommissioning. The PM retains authority for each proposed test, experiment, or modification to systems or equipment that affect the safe storage of nuclear fuel which has been subcontracted to DPC.

4. Quality Assurance Managqer (QAM) - The QAM reports to the PM, and has access to the EnergySolutions Corporate QA Director for quality matters. The QAM is responsible for establishing and maintaining the QAPD, monitoring the project's quality objectives through overview and inspection activities, and providing feedback to management on the effectiveness of the QAPD. The QAM evaluates, accepts, and performs oversight of supplier and subcontractor Quality Assurance Programs.

The QAM provides orientation and training on applicable quality QAPD 5 QAPD5Rev.

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requirements to the SOLUTIONS organization. The QAM periodically provides reports on project quality activities to the PM, and the management team.

5. Radiation Protection Managqer (RPM) - The RPM is responsible for all radiation protection, environmental protection, site closure, and waste shipping activities at the entire site.

6. Licensing Managqer (LM) -The LM is responsible for all interface activities with the Regulators such as licensing submittals, regulatory reports, reportability issues, QAPD revisions, REMP/ODCM reports, financial reports, Decommissioning Plan revisions, SNM Inventory reports, etc.

B.2Orgqanization - OPC (subcontracted)

1. Site Manager, Genoa (SMG) - The SMG has responsibility for the administration and operation of the LACBWR ISFSI and the operation of the Genoa 3 coal-fired plant and the Qualified Technical Review process utilized at the ISFSI..

2. ISESI Managqer (IM) - The IM reports directly to the SMG and is responsible for operation and maintenance of the LACBWR ISFSI within the limits set forth in the Decommissioning Plan, Technical Specifications and this QAPD.

3. Security Project Managqer (3PM) - The SPM reports directly to the ISFSI Manager and is responsible for ensuring regulatory requirements are adequately met and the Security Plan, related procedures, training and contingency requirements are developed and maintained current.

4. QA Specialist / Engqineer - The QA Specialist / Engineer is responsible for performing independent overviews of ISESI related activities, administering the ISFSI's corrective action program, providing orientation and training on applicable quality program requirements to DPC staff, and interfacing with SOLUTIONS off-site QA staff.

5. Engqineering Managqer (EM) - The EM is responsible for the engineering of ISESI activities and for ensuring that adequate technical review is applied to changes, tests, and experiments.

II. QUALITY ASSURANCE PROGRAM A. General The GA program described herein sets forth the requirements for the QA 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 ISFSI operations and maintenance procedures.

2. Performance of all installation, calibration, and testing on all necessary QAPD 6 Rev. 29

4.t ITS SSCs in accordance with approved ISFSI procedures.

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

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

5. Resolution of items identified as adverse to quality with appropriate notifications made to management.

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

B. Applicability

1. The entire QAPD described herein is applied to the LACBWR ISFSI in a graded approach to quality that is commensurate with an item's or an activity's importance to safety.

2. The following sections of the QAPD described herein or an industry equivalent may be applied to the decommissioning of the LACBWR plant in a graded approach to quality that is commensurate with an item or activities importance to safety:

a. For any Radioactive Material Transport Packages subject to the provisions of 10 CFR 71, Subpart C, "General Licenses," the full QAPD applies. For these activities associated with the ISFSI, the implementation of the QAPD is by the DPC staff as noted herein.

For these activities associated with decommissioning, the implementation of the QAPD is by the appropriate SOLUTIONS staff.

b. For all other decommissioning activities, the applicable portions of Sections 1, II, XV, XVI and XVII and Appendix C of this QAPD may apply.

c. The applicability of the requirements of this QAPD may be extended to other activities as designated by the Project Manager.

Decommissioning activities are otherwise controlled by procedures, processes and policies deemed adequate by the management responsible for the successful completion of those activities.

C. Regqulatory Commitments 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:

1. If the guidance in any of the listed documents is in conflict with the QAPO, the guidance provided in the QAPD is the controlling document.

QAPD 7 QAPD7Rev.

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f

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 previously included in the Technical Specifications and were relocated to this QAPD at the completion of fuel transfer to support decommissioning. The Qualified Technical Review was added at the time SOLUTIONS became the licensee. The following subjects shall be independently reviewed by a Qualified Technical Reviewer:

1. 10 CFR 50.59 and 10 CFR 50.82 evaluations for changes in the facility as described in the Decommissioning Plan (DP) and Post Shutdown Decommissioning Activities Report (PSDAR), changes in procedures as described in the DP and PSDAR, and tests or experiments not described in the OP and PSDAR to verify that such actions do not involve a change to the Technical Specifications or will not require NRC approval pursuant to 10 CFR 50.59 and 10 CFR 50.82;

2. Proposed changes to the programs required by Appendix C, and to verify that such changes do not involve a change to the Technical Specifications and will not require NRC approval pursuant to 10 CFR 50.59 and 10 CFR 72.48; and

3. Proposed changes to the license or Technical Specifications.

E. Implementation

1. Individuals that are assigned responsibilities as described in Section I, "ORGANIZATION," 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 ISESI and decommissioning activities as applicable. Procedures shall include appropriate quantitative and qualitative acceptance criteria necessary to determine that the activity is being properly performed.

2. Audit or surveillance reports are distributed to management for their review and assessment of the QA program, as to effectiveness, scope, adequacy, and implementation.

3. Indoctrination in the QA program requirements through General Employee Training shall be provided to all facility personnel and contractors performing activities that could affect the quality of structures, systems, or components, or engaged in decommissioning activities.

4. Independent Management Assessments are periodically performed to monitor overall performance and confirm that activities affecting quality QAPD 8 QAPO8Rev.

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comply with the QAPD and that the QAPD is effectively implemented.

Independent Management Assessment is performed by individual(s) designated by the President, independent of activities assessed, and who provide the appropriate level of expertise in the activities assessed. The Independent Management Assessment results are communicated in an understandable form and in a timely fashion to a level of management having the authority to effect corrective action. In addition, these results are reported in a timely fashion to the President.

F. Personnel Training and Qualification

1. Each member of the facility staff (including audit, surveillance and inspection personnel) shall have sufficient qualifications to perform their assigned duties. Regulatory Guide 1.8 -1977 (ANSI N18.1 -

197 1) is utilized for determining and assessing appropriate staff qualifications.

2. 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.

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

a. The position of the QA Manager shall meet the following minimum qualifications:

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

• At least two years of this experience should be associated with nuclear quality assurance activities, and at least one 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.

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

b. The position of Radiation Protection Manager shall meet the following minimum qualifications:

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

• 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.

• Technical experience in the area of radiological safety beyond QAPD 9 QAPO 9Rev.

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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).

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

c. The position of Qualified Technical Reviewers shall meet the following minimum qualifications:

• Qualified Technical Reviewers shall be knowledgeable in the subject area being reviewed.

• Qualified Technical Reviewers shall be individuals without direct responsibility for the document under review; these reviewers may be from the same functionally cognizant organization as the individual or group performing the original work.

• Qualified Technical Reviewers shall have at least 5 years of professional experience and either a Bachelor's degree in Engineering or the Physical Sciences or shall have equivalent qualifications evaluated on a case by case basis and approved by the Project Manager or Site Manager, Genoa.

• The Project Manager shall appoint Qualified Technical Reviewers for decommissioning activities and the Site Manager, Genoa shall appoint Qualified Technical Reviewers for ISFSI-related activities.

Ill. DESIGN CONTROL AND REVIEW A. General This section establishes the requirements to assure that Important To Safety (ITS) structures, systems, and components (SSCs) 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. The Engineering Manager (EM) shall ensure that the design control and review for ITS SSCs shall be performed by the appropriate Design Authority (ref. Appendix A) utilizing their approved 10 CFR 50 Appendix B or 10 CFR 72 Subpart G Quality Assurance Program.

Design, 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 DPC staff is responsible for establishing procedures to implement QAPD 10 QAPD10Rev.

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-p design control and the incorporation of design documents into work orders, procedures and instructions.

2. The EM 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. The EM is also responsible for the review of design drawings, specifications, calculations, and procurement documents to assure that quality standards are included or referenced.

3. The Qualified Technical Reviewer is responsible for providing an independent review of changes to the ISFSI ITS SSCs. They shall provide assurance that the modification meets the design bases, regulatory requirements, and applicable codes and standards. The review shall determine whether the proposed modifications require prior NRC approval. If prior NRC approval is needed, any license amendment request shall be referred to SOLUTIONS licensing support.

C. Requirements

1. *A Work Order shall be initiated for all modifications to ITS SSCs and systems maintained operational during ISESI activities. Work Orders may be initiated by any knowledgeable person.

2. Design bases, reguiatory requirements, and appiicabie codes and standards shall be delineated and specify appropriate quality 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. All proposed ISESI modifications shall be reviewed to determine whether they require prior NRC approval.

IV. PROCUREMENT DOCUMENT CONTROL A. General This section establishes the measures to assure that procurement documents (purchase requisitions and orders) covering material, equipment, and services for ISFSI ITS SSCs specify appropriate quality requirements. The purchase order specifies or references the applicable requirements, design bases, codes, and standards to assure quality.

B. Responsibilities

1. The DPC staff is responsible for developing procedures to control the preparation, review, and approval of purchase orders for material, equipment, and services covered by the QA program.

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

3. The Engineering Manager is responsible for preparing engineering QAPD 11 QAPD 11Rev.

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specifications which detail the technical and quality requirements for ITS material, equipment, and services.

4. The DPC staff is responsible for preparing purchase requisitions for material, equipment, and services.

5. Purchasing is responsible for preparing, reviewing, approving, issuing, and controlling purchase orders.

6. The QA Specialist / Engineer is responsible for review of ITS procurement documents to ensure inclusion of appropriate quality requirements.

C. 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.

2. Purchase orders shall include specifications that contain all the information necessary to assure material, equipment, and services 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, and/or 10 CFR 72, Subpart G. Suppliers shall be required to provide 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 management.

5. ITS purchase requisitions shall be reviewed by the QA Specialist /

Engineer to assure that all necessary quality requirements are included or referenced.

6. 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 QAPD 12 QAPD12Rev.

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in preparation of the original document.

V. INSTRUCTION

S. PROCEDURE

S, AND DRAWINGS A. General This section establishes the measures to assure that activities relating to ISFSI activities are performed in accordance with approved instructions, procedures, and drawings.

B. Responsibilities

1. The DPC staff is responsible for preparing or reviewing all procedures that are required for implementation of the QAPD.

2. The ISESI Manager is responsible for approval of ISFSI related procedures that implement NRC-approved programs and plans.

3. The Qualified Technical Reviewer is responsible for reviewing all initial and revised procedures that affect ITS ISESI operations and shall determine whether changes to these procedures require prior NRC approval.

C. Requirements

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

a. administrative control,

b. general security system operation,

c. Security Plan implementation,

d. quality assurance,

e. surveillance and test activities of equipment,

f. fire protection program, and

g. Emergency Plan Implementation.

2. For activities other than those within normal craft expertise, instructions for maintenance and repair of ISESI equipment or systems shall be contained in procedures or Work Orders. The guidance shall contain instructions for preparation, performance, testing, and return to service. The guidance 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.

QAPD 13 QAPO 13Rev.

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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 will 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.

VI. DOCUMENT CONTROL A. General This section establishes the requirements for document control as it applies to the LACBWR ISFSI.

B. Responsibilities

1. The DPC staff is responsible for preparing a standard procedure for controlling the issuance of procedures and for preparing procedures for controlling the distribution of operating, maintenance, repair, and modification procedures for the ISFSI.

C. Requirements

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

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

3. Drawings, specifications, and procedures, including revisions, shall 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. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES QAPD 14 QAPD 29 14Rev.

A. General This section material, establishes equipment, and the requirements services to assure for the ISFSI, that purchased whether purchased ITS directly or through contractors and subcontractors, conform to the procurement documents.

B. Responsibilities

1. The QA Specialist / Engineer is responsible for developing procedures for supplier evaluation and qualification and for coordinating supplier evaluation, qualification, and evaluating supplier quality programs.

The QA Specialist / Engineer is responsible for developing procedures for receiving inspection of material and equipment.

2. DPC staff shall be responsible for evaluating supplier manufacturing and technical capabilities.

C. Supplier Qualification

1. Qualification of suppliers shall consist of assessing past experience with the supplier, supplier's reputation and experience in the field, and in the nuclear industry, a QA program and/or other factors, as appropriate.

2. Suppliers of casks used for shipment and storage of radioactive material shall be evaluated to ensure that the design and fabrication of packaging are performed under the control of an NRC-approved and DPC-accepted (ISFSl~scope) or SOLUTIONS-accepted (decommissioning scope) QA program.

D. Source Inspection

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 witness 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. Receivingq Inspection

1. 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 QAPD 15 QAPD15Rev.

29

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 will be segregated upon receipt and will be placed in a receiving inspection hold 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 shall be placed on hold and will remain in a hold status until final disposition is determined. A corrective action document shall be initiated.

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

VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS A. General This section establishes the requirements for identification and control of ITS material, parts, and components, based on the ISFSI system designation, from receipt at the facility through installation or use.

B. Responsibilities

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

3. Appropriately trained DPC staff is responsible for control of; identification, and issuance of all ITS material, parts, and components.

C. Requirements

1. Approved instructions and procedures shall be implemented for the identification and 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 shall 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 QAPD 16 QAPD16Rev.

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

B. Responsibilities

1. The DPC staff is responsible for establishing procedures that describe how personnel and procedures are qualified for special processes.

2. The QA Specialist / Engineer is 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 qualfie proceures

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

C. Requirements

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 and 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 Boiler 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-1A.

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.

QAPD 17 QAPD17Rev.

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

B. Responsibilities

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

2. The QA Specialist I Engineer is responsible for establishing inspection procedures and assuring adequate inspection requirements are included in procedures. They are also responsible for coordinating the assignments of qualified inspection personnel.

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

C. Requirements

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 and 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 activity.

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 shall be in accordance with the original design and inspection requirements or as amended by approved changes to the original design.

XI. TEST CONTROL A. General QAPD 18 QAPD18Rev.

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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 ISESI modification or significant changes in procedures.

B. Responsibilities

1. The DPC 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 OPC staff is also responsible for establishing specifications, requirements and acceptance criteria for testing following ISFSI modifications or installation activities and the review of results for testing following modifications.

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

3. The Qualified Technical Reviewer is responsible for review of all ITS proposed test procedures, special testing procedures, performance testing procedures following ISESI modification and performing 10 CFR 72.48 evaluations to verify 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 will 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 not 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 limits are stated.

c. Test results are documented.

d. Detailed instructions for performing the test are included.

QAPD 19 QAPD19Rev.

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• 1

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.

6. Test results which fail to meet the requirements and acceptance criteria shall be properly noted and appropriate corrective action taken.

XII. CONTROL OF MEASURING AND TEST EQUIPMENT A. General 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 ISFSI technical requirements.

B. Responsibilities

1. The DPC staff is responsible for establishing requirements for a program for the control, calibration, and 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 ISFSI Manager is responsible for ensuring implementation of the requirements of this section of the manual for ISFSI activities and for approving ISFSI procedures or instructions.

C. Requirements

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 QAPD 20 QAPO20Rev.

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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 maintained.

5. Measuring and test equipment shall be controlled by a permanently affixed serial number. Calibration decals, tags or stickers shall be displayed prominently on each device and shall reflect the date of calibration, due date of the next calibration (for recurring calibration) and identity of person performing the calibration.

Xlll. HANDLING, STORAGE, AND SHIPPING A. General This section establishes the requirements for ISESI procedures to control the handling, storage, shipping, cleaning, packaging, and preservation of ITS material and equipment to prevent damage, deterioration, or loss through shipment, installation or use.

B. Responsibilities

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

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

C. Requirements

1. The requirements 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 applicable.

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 tools 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 QAPD 21 QAPD 21Rev.

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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 which satisfy the handling and storage requirements specified for the item.

XIV. INSPECTION, TEST, AND OPERATING STATUS A. General This section describes the system for indicating the inspection, test, and operating status of ITS components and systems at the ISFSI.

B. Responsibilities

1. The OPC 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 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 DPC staff is also responsible for the control of ISFSI status during modifications.

C. Reciuirements

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

XV. CORRECTIVE ACTION A. -General 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 non-conformances are promptly identified and corrected. This includes the control of materials, parts, or components that do not conform to requirements, thereby preventing their inadvertent use or installation.

B. -Responsibilities

1. The DPC staff is responsible for establishing procedures for the QAPD 22 QAPO 22Rev.

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identification, review, and correction of conditions adverse to quality which includes the control, evaluation, and disposition of deficient materials, parts, and components.

2. The DPC staff is responsible for reviewing nonconforming items that cannot be corrected by vendor action and recommending disposition.

The DPC staff is also responsible for preparing procedures for repair and rework of nonconforming items.

3. The DPC staff is responsible for reviewing conditions adverse to quality to determine the cause of the condition and for recommending corrective action to preclude repetition.

C. Requirements

1. Conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, shall be reported on a corrective action document. 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 corrective action document 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 notified of all nonconforming items and requested to correct the deficiencies.

DPC staff with assistance from procurement support staff shall be responsible for coordinating the disposition of deficient items with vendors. The QA Specialist / Engineer is 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 DPC staff who will recommend repair, rework, accept, or reject. Items shall be repaired or reworked only in accordance with approved procedures and shall be re-inspected after repair by the QA Specialist/IEngineer. DPC 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 shall be fully documented with the specification requirement, justification for acceptance, and effect of such use. All such items shall be approved by the corrective action document 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 DPC staff or applicable Design Authority (ref. Appendix A).

7. Conditions that may be reportable per 10CFR72.242, 10CFR71.95, or 100FR21 shall be reported in accordance with approved procedures.

XVI. QUALITY ASSURANCE RECORDS QAPD 23 QAPD23Rev.

29

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

The requirements below do not apply to records that are determined to be exempt from records keeping requirements in accordance with the terms of any NRC-approved records exemption that may be granted to SOLUTIONS for records related to the LACBWR site.

B. Responsibilities

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

2. The ISFSI Manager is responsible for approving and ensuring implementation of procedures for this section.

C. Requirements

1. Record Management System - Quality Records shall be identified, controlled and stored in accordance with written procedures. The record system includes the retention of those design, fabrication, inspection, operation, and surveillance records essential to demonstrate product quality. It provides for the identification of materials and their corresponding manufacturing, installation, inspection, test, and audit results. Requirements and responsibilities for the transmittal, distribution, retention, maintenance, and disposition of records are specified in approved procedures. QA records shall be protected against damage, deterioration, unauthorized change, or loss. For any work performed, the records to be generated must be identified, along with a means of matching the record to the item or activity to which it applies. Records must be legible, reproducible, and accurate. For subcontractors/sub-suppliers, the original QA record of the deliverables will be transmitted to SOLUTIONS or DPC when applicable.

2. Authentication - Documents shall be considered valid records only if stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated, including the use of electronic approval and authorization. This authentication may take the form of a statement by the responsible individual or organization. Handwritten signatures are not required if the document is clearly identified as a statement by the reporting individual or organization. These records may be originals or reproduced copies.

3. Indexing - The records indexing system must include records identification, location of the record within the system, and minimum retention time. The records and/or indexing system(s) shall provide QAPD 24 QAPD24Rev.

29

sufficient information to permit identification between the record and the items or activities to which it applies.

4. Distribution and Control - The records shall be distributed, handled, and controlled in accordance with written procedures. Measures shall be established to preclude the entry of unauthorized personnel into the storage area, or the distribution of records to unauthorized personnel.

Records maintained by the supplier at their facility or other location shall be accessible to the purchaser or their designated alternate.

5. Classification of records - Records shall be classified for retention and storage requirements as either lifetime or nonpermanent. Records that meet any of the following criteria are designated Lifetime records and must be maintained.

a. Project lifetime records shall include, as a minimum, design specifications, stress reports or stress calculations, "as-built" and interface control drawings, copies of material test reports, tabulation of materials for "as-built" configuration, NDE reports including examination reports, and nonconformance reports.

Lifetime record retention is based on the life of the program, life of the item, life of the facility, or life of the license, as applicable.

b. Nonpermanent records are required to show evidence that an activity was performed in accordance with applicabie requirements. Retention times must be established in writing.

In addition, retention periods specified in various governing codes and standards (e.g. 10CFR71, 10 CFR 72) will be included in the retention requirements established in approved procedures for QA records.

For subcontractors/sub-suppliers, the original QA record of the deliverables will be transmitted to SOLUTIONS or DPC when applicable.

6. Storage Requirements - The records shall be stored in predetermined location(s) that meet the requirements of applicable standards, codes, and regulatory agencies. Prior to storage of records, a written storage procedure shall be prepared and responsibility assigned for enforcing the requirements of that procedure.

Records shall be stored to prevent damage from moisture or temperature. All records maintained in hard copy form shall be firmly attached to binders or placed in folders, envelopes, or boxes for storage in file cabinets or within containers on shelving. Records may be stored in electronic media provided that the process for managing and storing the records are documented in approved procedures.

Media used for the retention of records include, but are not limited to, microfilm, compact disks, magnetic media, optical disks or servers.

The format used must be capable of producing legible and complete documents during the entire retention period.

a. Records shall be stored in facilities that minimize the risk of damage or destruction from the following:

QAPD 25 QAPD25Rev.

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b. Natural disasters such as wind, flood, or fires;

c. Environmental conditions such as high and low temperatures and humidity; and

d. Infestation by insects, mold, or rodents.

7. Disposition - Various regulatory agencies have requirements concerning records that are within the scope of the QAPO. The most stringent requirements shall be used in determining the final disposition.

XVII. AUDITS 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.

B. Responsibilities

1. The QA Specialist / Engineer is responsible for developing audit checklists, designating and training audit personnel, and conducting audits.

2. The QA Specialist / Engineer performs independent review and audit to verify that the ISESI is being maintained consistent with company safety, administrative, and licensing provisions.

C. Requirements Implementing procedure(s) for the internal audit/survey program shall 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 the QA Specialist I Engineer or other qualified personnel, such as technical specialists from other 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.

QAPD 26 QAPD26Rev.

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4. The QA Specialist / Engineer 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 NAC-MPC CoC Technical Specifications and applicable license conditions is audited at least once every 24 months. The audit shall include elements such as:

• 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 H and 10 CFR 72, Subpart G.

• Implementation of the programs required by Appendix 0, 1.0 through 2.5.

b. Other activities/documents as requested by SOLUTIONS or OPC management.

6. Deficiencies or nonconformances identified during an audit shall be documented and brought to the attention of the Project Manager and ISFSI Manager, as applicable. Follow-up shall be performed to verify that corrective actions have been taken to correct the deficiencies or non conform an ces.

7. Audit reports are sent to management for their review and assessment of the QA program.

8. Audit reports shall be forwarded to the SOLUTIONS Senior Executive Vice President and General Manager, the DPC President and CEO, and to the management positions responsible for the areas audited, within 30 days after completion of the audit.

9. 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.

10. Suppliers providing commercial grade calibration and testing services who are accredited by a nationally recognized accrediting body, using procedures consistent with those found in ANSI/ISO/lEO 17025 "General Requirements for the Competence of Testing and Calibration QAPD 27 QAPD27Rev.

29

t.

Laboratories", do not have to be periodically surveyed if the conditions of the NRC Safety Evaluation dated February 9, 2015 are met (see Appendix B). Controls shall be established in applicable procedures to ensure the requirements of the NRC Safety Evaluation are satisfied.

QAPD 28 QAPO 28Rev.

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APPENDIX A (Page 1 of 2)

IMPORTANT TO SAFETY STRUCTURES, SYSTEMS AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50, Appendix B, 10 CFR 71 Subpart H and 10 CFR 72 Subpart G will be applied, as a minimum, to all quality activities affecting the Important To Safety (ITS) Structures, Systems and Components (S50s) associated with spent fuel storage and transportation package.

NOTE The safety classification of SSCs of the LACBWR 1SF SI facility may be revised based on engineering evaluations and a revision to the NAG-MPC FSAR. These modifications are controlled in accordance with the Design Control process and are not considered a reduction in the commitments to the QAPD.

The quality classification of 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 responsible for design and licensing controls for these components under their NRC-approved Quality Assurance Program. SOLUTIONS utilizes these types of components and packages under the provisions of a NRC General License for Radioactive Material Transportation Packages (10 CFR 71) and Spent Fuel Storage (10 CFR 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 550s associated with spent fuel storage and radioactive material transportation packages are defined below:

IMPORTANT TO SAFETY AS DEFINED BY 10 CFR 71 AND 10 CFR 72 A. Dry Spent Fuel Storage (10 CFR 72)

Quality Design SSC Category Authority Transportable Storage Canister and Fuel Basket Assembly A NAG Intl.

Vertical Concrete Cask B NAC Intl.

Transfer Cask and Adapter Plate B NAC Intl.

ISFSI Pad C DPC Lifting Yoke B NAC Intl.

Damaged Fuel Can A NAG Intl.

QAPD 29 QAPO 29Rev.

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APPENDIX A (Page 2 of 2)

IMPORTANT TO SAFETY STRUCTURES, SYSTEMS AND COMPONENTS B. Transport of Spent Fuel and GTCC Waste (10 CFR 71)

Quality Dsg uhrt SCCategory Dsg uhrt Transportable Storage Canisters and Fuel Basket Assembly A NAC Intl.

Daagd ue CnA NAC Intl.

Transportable Storage Canister and Basket Assembly For GTCCANCInl WateCotanesA NAC Intl.

C. Radioactive Material Transport Packages (10 CFR 71)

Radioactive Material Transport Packages subject to the provisions of 1 0 CFR 71, Subpart C,."General Licenses," are Important To Safety and subject to the applicable requirements of the QAPD.

NOTES:

1. See NAC-MPC Final Safety Analysis Report for additional classification information.

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

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

QAPD 30 QAPO30Rev.

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APPENDIX B REGULATORY COMMITMENTS. ALTERNATIVES AND EXCEPTIONS 1.0 REGULATORY COMMITMENTS 1.1 Regulatory Guide 1.8, l-R-5/77, Personnel Selection and Training, Endorses ANSI N18.1-1971 (as applicable).

1.2 Regulatory Guide 7.10, Revision 2 (3/05), "Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material."

1.3 NUREG/CR-6407, "Classification of Transportation Packaging and Dry Fuel Storage System Components According to Important to Safety (2/96)."

2.0 ALTERNATIVES 2.1 Nuclear Energy Institute (NEI) NEI 14-05, "Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services," revision 0, and associated NRC Safety Evaluation dated February 9, 2015.

3.0 EXCEPTIONS None QAPD 31 QAPD31Rev.

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A' APPENDIX C (Page 1 of 4)

ADMINISTRATIVE CONTROLS These Administrative Controls were developed to support operation of the LACBWR plant while in SAFSTOR (dismantlement) and operation of the LACBWR ISFSI.

These requirements were previously included in th'e Technical Specifications and were relocated to this QAPD during active decommissioning.

1.0 PROCEDURES 1.1 Written procedures shall be established, implemented, and maintained covering the Plant decommissioning activities referenced below and in Section 2.0:

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.

1.2 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 by a Qualified Technical Reviewer and approved by the Project Manager or designee prior to implementation.

2.0 PROG RAMS A ND MANUALS 2.1 Process Control Procqram (PCP)

The PCP shall be maintained on-site and will be available for NRC review. Licensee-initiated changes to the PCP 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 a Qualified Technical Reviewer.

QAPD 32 QAPO 32Rev.

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APPENDIX C (Page 2 of 4)

ADMINISTRATIVE CONTROLS 2.2 Offsite Dose Calculation Manual (ODCM)

The 00CM shall be maintained by the licensee. Changes to theO0DCM will be outlined in the annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

2.2.1 Detailed information to support the rationale for the change.

Information submitted should consist of a package of those pages of the ODOM 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.

2.3 Radioactive Effluent Controls Prociram 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 ODCM, (2) shall be implemented by health physics procedures and instructions, 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 0DCM; 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 airborne particulate in accordance with 10 CFR 20 and with the methodology and parameters described in the 00CM.

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 0DCM at least every year; QAPD 33 QAPO 33Rev.

29

APPENDIX C (Page 3 of 4)

ADMINISTRATIVE CONTROLS 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; 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 Radioloqical Environmental Monitorinq Progqram 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 theO0DCM; (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 radionuclides in the environment in accordance with the methodology and parameters described in the 0DCM.

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 Reportingq Reguirements 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 AnnualIRadiological EnvironmentalIMonitoring Report 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 inclusion 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.

QAPD 34 QAPO 34Rev.

29

APPENDIX C (Page 4 of 4)

ADMINISTRATIVE CONTROLS 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; and a discussion of all analyses in which the lower limit of detection (LLD) was not achievable.

2.5.2 Annual Radioactive Effluent Release Report Paragraph (a)(2) of 10 CFR 50.36a, 'Technical Specifications on Effluents from Nuclear Power Reactors," requires that a report be made 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 accordance 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 00CM, of radiation doses to members of the public from radioactive liquid and airborne particulate released beyond the effluent release boundary. This report shall contain any changes made to the 00CM during the previous twelve months.

QAPD 35 QAPD35Rev.

29

FIGURE 1 La Crosse Solutions' Organization SOLUTIONS (off-site)

Pres'ident EXecutive Vice President and.

Corporate QA'Direc~tor,

. General Manger EnergySolutions SOLUTIONS (on-site dismantlement) ' P~etMngr"

• Radiation Protection "Licensing Manager QA Manager

- Manager r" ISFSI ACTIVITIES (subcontracted to DPC) Site Manager,- Genoa*

. ISFSI Mariager i

S~ecurity Force QAPD 36 Rev. 29

BARBARA A. NICK President and CEO DAIRYLAND POWER COOPERATIVE October 29, 2015 10 CFR 50.54(a)(4)

In reply, please refer to LAC- 14359 DOCKET NO. 50-409 and 72-046 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)

Possession-Only License DPR-45 Revision 29 of the LACBWR Quality Assurance Program Description (OAPD)

REFERENCES:

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

2) LACBWR Quality Assurance Program Description, Revision 28 The purpose of this letter is to submit Revision 29 of the LACBWR QAPD for USNRC approval prior to implementation. Dairyland Power Cooperative and LaCrosseSolutions, LLC have recently submitted an application to transfer the LACBWR Possession-Only License No. DPR-45 to LaCrosseSolutions, LLC. Revision 29 of the QAPD is reflective of that change and, with NRC approval, would be implemented at the time of the license transfer.

If you have any questions concerning this submittal, please contact Cheryl Olson, LACBWR ISFSJ/Plant 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 t'7ie A Touchstone Energye Cooperative ___.

3200 East Ave. S.

• P0 Box 817

• La Crosse, WI 54602-0817

• 608-787-1258

• 608-787-1469 fax

• www.dairynet.com Dairyland Power Cooperative is an equal opportunity provider and employer.

Document Control Desk LAC-14359 Page 2 October 29, 2015 cc w/

Enclosures:

Marlayna Vaaler Project Manager U.S. Nuclear Regulatory Commission Cynthia D. Pederson Regional Administrator, Region III U.S. Nuclear Regulatory Commission STATE OF WISCONSIN )

)

CONY OFLCossE Personally came before me this *4 . day of * , ' ,* ,20 15, the above named, Barbara A. Nick, to me known to be the person who executed the foregoing instrument and acknowledged the same.

Notarublic, La Crosse County Wisconsin My commission expires 5"- Aq 5" /

LAURIE A. ENGEN Notary Public State of Wisconsin A Touchstone Energye Cooperative ___*

3200 East Ave. S. P0 Box 817 o La Crosse, WI 54602-0817 a 608-787-1258

• 608-787-1469 fax . www.dairynet.com Dairyland Power Cooperative is an equal opportunity provider and employer.

A LA CROSSE BOILING WATER REACTOR QUALITY ASSURANCE PROGRAM DESCRIPTION REVISION 29 La Crosse Solutions, L *JQW!NS):

Author: .-. /

rr Date /

Anthony R. Bejm~¶dependent Consultant QA Approval: "J James E. Werner, SOLUTIONS QA Manager 'Datei!

Manager Approval:

Date Corporate QA Appro* val: *R44',*__. Aug 14 2015 9:.35 P.M Mike Nicol, Ene~rgySolutions Corporate Director, QA Date Dairyland Power Cooperative (DPC)

QA Approval: 9-3o -2Qtoll Ed Martin, Manager, Quality Assurance Date Manager Approval:

Lane S. Peters, Site Manager, Genoa Date Dt

v LA CROSSE BOILING WATER REACTOR STATEMENT OF QUALITY ASSURANCE POLICY The Quality Assurance Program Description (QAPD) described herein has been developed by Dairyland Power Cooperative (DPC) and La Crosse Solutions, LLC (SOLUTIONS) 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 decommissioning of the LACBWR plant. The QAPD describes the quality assurance organizational structure, functional responsibilities, levels of authority and interfaces.

The QAPO applies to all activities associated with structures, systems, and components which are Important to Safety under 10 CFR 72. The QAPD also applies to transportation packages licensed by the NRC under 10 CFR 71. Requirements of the QAPD 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 decommissioning 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 G.

The SOLUTIONS Executive Vice President and General Manager is responsible for the establishment and implementation of a quality assurance program which meets all 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.

Solutions Executive Dairyland Executive Executive-!P sident and General Manager President and CEO ..

DteD -- Date QAPD i QAPD Rev. 29

LA CROSSE BOILING WATER REACTOR (LACBWR)

QUALITY ASSURANCE PROGRAM DESCRIPTION (QAPD)

TABLE OF CONTENTS SECTION PAGE STATEMENT OFPOLICY ................................................................................. i

0.0 INTRODUCTION

........................................................................ 3 I. ORGANIZATION ....................................................................... 4 I1. QUALITY ASSURANCE PROGRAM...................................................................... 6 III. DESIGN CONTROL AND REVIEW ....................................................................... 10 IV. PROCUREMENT DOCUMENT CONTROL............................................................... 11 V. INSTRUCTION, PROCEDURES AND DRAWINGS....................................................... 13 VI. DOCUMENT CONTROL.................................................................................. 14 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES ............................... 14 VIII. IDENTIFICATION ANif ClONTROL OF MATERIAL, DPATS, AND COMPONENTS ....................... 16 IX. CONTROL OF SPECIAL PROCESSES................................................................... 17 X. INSPECTION ............................................................................................. 18 XI. TEST CONTROL ....................................................................... 18 XII. CONTROL OF MEASURING AND TEST EQUIPMENT................................................... 20 XIII. HANDLING, STORAGE, AND SHIPPING................................................................. 21 XIV. INSPECTION, TEST, AND OPERATING STATUS........................................................ 22 XV. CORRECTIVE ACTION................................................................................... 22 XVI. QUALITY ASSURANCE RECORDS...................................................................... 23 XVII. AUDITS ................................................................................................... 26 APPENDIX A - IMPORTANT TO SAFETY STRUCTURES, SYSTEMS, AND COMPONENT ............ 29 APPENDIX B - REGULATORY COMMITMENTS, ALTERNATIVEBS, AND EXCEPTIONS................ 31 APPENDIX C - ADMINISTRATIVE CONTROLS.......................................................... 32 FIGURE 1 - La CROSSE SOLUTIONS ORGANIZATION ................................................. 36 QAPD ii Rev. 29

0.0 INTRODUCTION

A. General Upon NRC approval, SOLUTIONS will be the NRC licensee responsible for all activities under the LACBWR License. SOLUTIONS will commence decommissioning of the LACBWR site. DPC will retain ownership of the land and spent fuel and be the owner licensee. DPC will be subcontracted for the management and operation of the LACBWR ISFSI. Upon completion of decommissioning, SOLUTIONS will apply to the NRC to transfer responsibility for the NRC License back to DPC. Thereafter, DPC will maintain the ISESI, and be. responsible for the ultimate disposition of the spent nuclear fuel.

In order to minimize disruption and maximize efficiency, this revision of the LACBWR Quality Assurance Program Description (QAPD) was jointly developed by DPC and SOLUTIONS to facilitate the various stages of license transition described above. During the decommissioning activities, SOLUTIONS will subcontract the operations and maintenance of the ISFSI to DPC. Although DPC procedures and processes will continue to be used for the operations and maintenance of the ISFSI, SOLUTIONS will be the licensee with overall responsibility and authority to ensure the QAPD requirements applicable to the ISESI are effectively implemented by DPC, or others, as applicable. The requirements of this QAPD will apply to all ISESI activities and selected plant decommissioning activities.

The QAPD is designed to meet the requirements of 10 CFR 50, Appendix B, 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 ISESI and the decommissioning of the LACBWR plant, thereby assuring that risk to the health and safety of the public is not increased.

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 management that the QA program is being fully and effectively implemented. QA is recognized as an interdisciplinary function and not the sole responsibility of QA personnel.

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 listed below are used frequently throughout this document.

LACBWR - La Crosse Boiling Water Reactor.

QAPD 3 QAPD3Rev.

29

QUALIFIED TECHNICAL REVIEW - Thorough reviews of the documents specified in this QAPD shall be conducted by a Qualified Technical Reviewer.

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.

QUALITY CONTROL (QC) - Those quality actions which provide a means to control and measure the characteristics of an item, process or facility to established requirements.

FACILITY - 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.

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

SCHEDULE INTERVAL - 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.

MPORTANT O~r SAET (TS)i - A ~ Sul,= aL,,..,u,, gie t structures, systems, and components (SSCs) that provide nuclear safety design functions. (See Appendix A for complete details).

ORGANIZATION A. General Requirements

1. This section defines the responsibilities of key project members accountable for implementation of the QAPD. Functions and actions can be delegated; however, the responsibility remains with the designated individual.

2. Onsite and offsite organizations shall be established for station and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safe storage of nuclear fuel.

3. Since SOLUTIONS and DPC will be working to the requirements of this QAPD, each organization is depicted on the Figure 1, La Crosse Solutions Organization. This QAPD identifies key on-site project management team positions for SOLUTIONS and their off-site corporate support groups. The QAPD also defines the DPC management team that will manage the ISFSI operations.

4. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as QAPD 4 QAPD4Rev.

29

.1 appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

5. The individuals who carry out health physics and quality assurance activities may functionally report to an appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

B.1Orgqanization - SOLUTIONS

1. President - The President manages the operation of EnergySolutions stewardship projects at U.S. Reactor sites, and assures that the LACBWR project receives timely and effective support from EnergySolutions corporate groups. The President meets periodically with the GM and other key managers to review the operation of the LACBWR ISESI and decommissioning and to address project management, quality, and related issues. The President shall have corporate responsibility for the safe storage of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure the safe storage of nuclear fuel.

2. Executive Vice President and General Manaqer (GM) - This executive provides direct oversight of the project, and other selected tasks, to ensure the project is properly planned, staffed and executed. The GM has overall authority and responsibility for the establishment and effective implementation of the QAPD. The GM has periodic meetings with the management team to review plans and progress and to address stakeholder, quality, and project management issues. The GM delegates to DPC and the management team the day-to-day responsibilities for the ISFSI and decommissioning by approved documents, respectively.

3. Proiect Manaqer (PM) - The PM is responsible for all decommissioning activities, including fire protection and industrial safety activities at the decommissioning site. The PM shall have authority over those on site activities necessary for safe storage of nuclear fuel which have been subcontracted~to DPC. The PM is also responsible for the functions described in Appendix C of this QAPD, and for the Qualified Technical Review process utilized for decommissioning. The PM retains authority for each proposed test, experiment, or modification to systems or equipment that affect the safe storage of nuclear fuel which has been subcontracted to DPC.

4. Quality Assurance Managqer (QAM) - The QAM reports to the PM, and has access to the EnergySolutions Corporate QA Director for quality matters. The QAM is responsible for establishing and maintaining the QAPD, monitoring the project's quality objectives through overview and inspection activities, and providing feedback to management on the effectiveness of the QAPD. The QAM evaluates, accepts, and performs oversight of supplier and subcontractor Quality Assurance Programs.

The QAM provides orientation and training on applicable quality QAPD 5 QAPD5Rev.

29

requirements to the SOLUTIONS organization. The QAM periodically provides reports on project quality activities to the PM, and the management team.

5. Radiation Protection Managqer (RPM) - The RPM is responsible for all radiation protection, environmental protection, site closure, and waste shipping activities at the entire site.

6. Licensing Managqer (LM) -The LM is responsible for all interface activities with the Regulators such as licensing submittals, regulatory reports, reportability issues, QAPD revisions, REMP/ODCM reports, financial reports, Decommissioning Plan revisions, SNM Inventory reports, etc.

B.2Orgqanization - OPC (subcontracted)

1. Site Manager, Genoa (SMG) - The SMG has responsibility for the administration and operation of the LACBWR ISFSI and the operation of the Genoa 3 coal-fired plant and the Qualified Technical Review process utilized at the ISFSI..

2. ISESI Managqer (IM) - The IM reports directly to the SMG and is responsible for operation and maintenance of the LACBWR ISFSI within the limits set forth in the Decommissioning Plan, Technical Specifications and this QAPD.

3. Security Project Managqer (3PM) - The SPM reports directly to the ISFSI Manager and is responsible for ensuring regulatory requirements are adequately met and the Security Plan, related procedures, training and contingency requirements are developed and maintained current.

4. QA Specialist / Engqineer - The QA Specialist / Engineer is responsible for performing independent overviews of ISESI related activities, administering the ISFSI's corrective action program, providing orientation and training on applicable quality program requirements to DPC staff, and interfacing with SOLUTIONS off-site QA staff.

5. Engqineering Managqer (EM) - The EM is responsible for the engineering of ISESI activities and for ensuring that adequate technical review is applied to changes, tests, and experiments.

II. QUALITY ASSURANCE PROGRAM A. General The GA program described herein sets forth the requirements for the QA 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 ISFSI operations and maintenance procedures.

2. Performance of all installation, calibration, and testing on all necessary QAPD 6 Rev. 29

4.t ITS SSCs in accordance with approved ISFSI procedures.

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

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

5. Resolution of items identified as adverse to quality with appropriate notifications made to management.

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

B. Applicability

1. The entire QAPD described herein is applied to the LACBWR ISFSI in a graded approach to quality that is commensurate with an item's or an activity's importance to safety.

2. The following sections of the QAPD described herein or an industry equivalent may be applied to the decommissioning of the LACBWR plant in a graded approach to quality that is commensurate with an item or activities importance to safety:

a. For any Radioactive Material Transport Packages subject to the provisions of 10 CFR 71, Subpart C, "General Licenses," the full QAPD applies. For these activities associated with the ISFSI, the implementation of the QAPD is by the DPC staff as noted herein.

For these activities associated with decommissioning, the implementation of the QAPD is by the appropriate SOLUTIONS staff.

b. For all other decommissioning activities, the applicable portions of Sections 1, II, XV, XVI and XVII and Appendix C of this QAPD may apply.

c. The applicability of the requirements of this QAPD may be extended to other activities as designated by the Project Manager.

Decommissioning activities are otherwise controlled by procedures, processes and policies deemed adequate by the management responsible for the successful completion of those activities.

C. Regqulatory Commitments 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:

1. If the guidance in any of the listed documents is in conflict with the QAPO, the guidance provided in the QAPD is the controlling document.

QAPD 7 QAPD7Rev.

29

f

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 previously included in the Technical Specifications and were relocated to this QAPD at the completion of fuel transfer to support decommissioning. The Qualified Technical Review was added at the time SOLUTIONS became the licensee. The following subjects shall be independently reviewed by a Qualified Technical Reviewer:

1. 10 CFR 50.59 and 10 CFR 50.82 evaluations for changes in the facility as described in the Decommissioning Plan (DP) and Post Shutdown Decommissioning Activities Report (PSDAR), changes in procedures as described in the DP and PSDAR, and tests or experiments not described in the OP and PSDAR to verify that such actions do not involve a change to the Technical Specifications or will not require NRC approval pursuant to 10 CFR 50.59 and 10 CFR 50.82;

2. Proposed changes to the programs required by Appendix C, and to verify that such changes do not involve a change to the Technical Specifications and will not require NRC approval pursuant to 10 CFR 50.59 and 10 CFR 72.48; and

3. Proposed changes to the license or Technical Specifications.

E. Implementation

1. Individuals that are assigned responsibilities as described in Section I, "ORGANIZATION," 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 ISESI and decommissioning activities as applicable. Procedures shall include appropriate quantitative and qualitative acceptance criteria necessary to determine that the activity is being properly performed.

2. Audit or surveillance reports are distributed to management for their review and assessment of the QA program, as to effectiveness, scope, adequacy, and implementation.

3. Indoctrination in the QA program requirements through General Employee Training shall be provided to all facility personnel and contractors performing activities that could affect the quality of structures, systems, or components, or engaged in decommissioning activities.

4. Independent Management Assessments are periodically performed to monitor overall performance and confirm that activities affecting quality QAPD 8 QAPO8Rev.

29

comply with the QAPD and that the QAPD is effectively implemented.

Independent Management Assessment is performed by individual(s) designated by the President, independent of activities assessed, and who provide the appropriate level of expertise in the activities assessed. The Independent Management Assessment results are communicated in an understandable form and in a timely fashion to a level of management having the authority to effect corrective action. In addition, these results are reported in a timely fashion to the President.

F. Personnel Training and Qualification

1. Each member of the facility staff (including audit, surveillance and inspection personnel) shall have sufficient qualifications to perform their assigned duties. Regulatory Guide 1.8 -1977 (ANSI N18.1 -

197 1) is utilized for determining and assessing appropriate staff qualifications.

2. 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.

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

a. The position of the QA Manager shall meet the following minimum qualifications:

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

• At least two years of this experience should be associated with nuclear quality assurance activities, and at least one 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.

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

b. The position of Radiation Protection Manager shall meet the following minimum qualifications:

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

• 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.

• Technical experience in the area of radiological safety beyond QAPD 9 QAPO 9Rev.

29

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).

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

c. The position of Qualified Technical Reviewers shall meet the following minimum qualifications:

• Qualified Technical Reviewers shall be knowledgeable in the subject area being reviewed.

• Qualified Technical Reviewers shall be individuals without direct responsibility for the document under review; these reviewers may be from the same functionally cognizant organization as the individual or group performing the original work.

• Qualified Technical Reviewers shall have at least 5 years of professional experience and either a Bachelor's degree in Engineering or the Physical Sciences or shall have equivalent qualifications evaluated on a case by case basis and approved by the Project Manager or Site Manager, Genoa.

• The Project Manager shall appoint Qualified Technical Reviewers for decommissioning activities and the Site Manager, Genoa shall appoint Qualified Technical Reviewers for ISFSI-related activities.

Ill. DESIGN CONTROL AND REVIEW A. General This section establishes the requirements to assure that Important To Safety (ITS) structures, systems, and components (SSCs) 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. The Engineering Manager (EM) shall ensure that the design control and review for ITS SSCs shall be performed by the appropriate Design Authority (ref. Appendix A) utilizing their approved 10 CFR 50 Appendix B or 10 CFR 72 Subpart G Quality Assurance Program.

Design, 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 DPC staff is responsible for establishing procedures to implement QAPD 10 QAPD10Rev.

29

-p design control and the incorporation of design documents into work orders, procedures and instructions.

2. The EM 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. The EM is also responsible for the review of design drawings, specifications, calculations, and procurement documents to assure that quality standards are included or referenced.

3. The Qualified Technical Reviewer is responsible for providing an independent review of changes to the ISFSI ITS SSCs. They shall provide assurance that the modification meets the design bases, regulatory requirements, and applicable codes and standards. The review shall determine whether the proposed modifications require prior NRC approval. If prior NRC approval is needed, any license amendment request shall be referred to SOLUTIONS licensing support.

C. Requirements

1. *A Work Order shall be initiated for all modifications to ITS SSCs and systems maintained operational during ISESI activities. Work Orders may be initiated by any knowledgeable person.

2. Design bases, reguiatory requirements, and appiicabie codes and standards shall be delineated and specify appropriate quality 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. All proposed ISESI modifications shall be reviewed to determine whether they require prior NRC approval.

IV. PROCUREMENT DOCUMENT CONTROL A. General This section establishes the measures to assure that procurement documents (purchase requisitions and orders) covering material, equipment, and services for ISFSI ITS SSCs specify appropriate quality requirements. The purchase order specifies or references the applicable requirements, design bases, codes, and standards to assure quality.

B. Responsibilities

1. The DPC staff is responsible for developing procedures to control the preparation, review, and approval of purchase orders for material, equipment, and services covered by the QA program.

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

3. The Engineering Manager is responsible for preparing engineering QAPD 11 QAPD 11Rev.

29

specifications which detail the technical and quality requirements for ITS material, equipment, and services.

4. The DPC staff is responsible for preparing purchase requisitions for material, equipment, and services.

5. Purchasing is responsible for preparing, reviewing, approving, issuing, and controlling purchase orders.

6. The QA Specialist / Engineer is responsible for review of ITS procurement documents to ensure inclusion of appropriate quality requirements.

C. 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.

2. Purchase orders shall include specifications that contain all the information necessary to assure material, equipment, and services 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, and/or 10 CFR 72, Subpart G. Suppliers shall be required to provide 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 management.

5. ITS purchase requisitions shall be reviewed by the QA Specialist /

Engineer to assure that all necessary quality requirements are included or referenced.

6. 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 QAPD 12 QAPD12Rev.

29

in preparation of the original document.

V. INSTRUCTION

S. PROCEDURE

S, AND DRAWINGS A. General This section establishes the measures to assure that activities relating to ISFSI activities are performed in accordance with approved instructions, procedures, and drawings.

B. Responsibilities

1. The DPC staff is responsible for preparing or reviewing all procedures that are required for implementation of the QAPD.

2. The ISESI Manager is responsible for approval of ISFSI related procedures that implement NRC-approved programs and plans.

3. The Qualified Technical Reviewer is responsible for reviewing all initial and revised procedures that affect ITS ISESI operations and shall determine whether changes to these procedures require prior NRC approval.

C. Requirements

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

a. administrative control,

b. general security system operation,

c. Security Plan implementation,

d. quality assurance,

e. surveillance and test activities of equipment,

f. fire protection program, and

g. Emergency Plan Implementation.

2. For activities other than those within normal craft expertise, instructions for maintenance and repair of ISESI equipment or systems shall be contained in procedures or Work Orders. The guidance shall contain instructions for preparation, performance, testing, and return to service. The guidance 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.

QAPD 13 QAPO 13Rev.

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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 will 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.

VI. DOCUMENT CONTROL A. General This section establishes the requirements for document control as it applies to the LACBWR ISFSI.

B. Responsibilities

1. The DPC staff is responsible for preparing a standard procedure for controlling the issuance of procedures and for preparing procedures for controlling the distribution of operating, maintenance, repair, and modification procedures for the ISFSI.

C. Requirements

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

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

3. Drawings, specifications, and procedures, including revisions, shall 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. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES QAPD 14 QAPD 29 14Rev.

A. General This section material, establishes equipment, and the requirements services to assure for the ISFSI, that purchased whether purchased ITS directly or through contractors and subcontractors, conform to the procurement documents.

B. Responsibilities

1. The QA Specialist / Engineer is responsible for developing procedures for supplier evaluation and qualification and for coordinating supplier evaluation, qualification, and evaluating supplier quality programs.

The QA Specialist / Engineer is responsible for developing procedures for receiving inspection of material and equipment.

2. DPC staff shall be responsible for evaluating supplier manufacturing and technical capabilities.

C. Supplier Qualification

1. Qualification of suppliers shall consist of assessing past experience with the supplier, supplier's reputation and experience in the field, and in the nuclear industry, a QA program and/or other factors, as appropriate.

2. Suppliers of casks used for shipment and storage of radioactive material shall be evaluated to ensure that the design and fabrication of packaging are performed under the control of an NRC-approved and DPC-accepted (ISFSl~scope) or SOLUTIONS-accepted (decommissioning scope) QA program.

D. Source Inspection

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 witness 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. Receivingq Inspection

1. 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 QAPD 15 QAPD15Rev.

29

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 will be segregated upon receipt and will be placed in a receiving inspection hold 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 shall be placed on hold and will remain in a hold status until final disposition is determined. A corrective action document shall be initiated.

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

VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS A. General This section establishes the requirements for identification and control of ITS material, parts, and components, based on the ISFSI system designation, from receipt at the facility through installation or use.

B. Responsibilities

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

3. Appropriately trained DPC staff is responsible for control of; identification, and issuance of all ITS material, parts, and components.

C. Requirements

1. Approved instructions and procedures shall be implemented for the identification and 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 shall 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 QAPD 16 QAPD16Rev.

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

B. Responsibilities

1. The DPC staff is responsible for establishing procedures that describe how personnel and procedures are qualified for special processes.

2. The QA Specialist / Engineer is 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 qualfie proceures

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

C. Requirements

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 and 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 Boiler 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-1A.

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.

QAPD 17 QAPD17Rev.

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

B. Responsibilities

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

2. The QA Specialist I Engineer is responsible for establishing inspection procedures and assuring adequate inspection requirements are included in procedures. They are also responsible for coordinating the assignments of qualified inspection personnel.

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

C. Requirements

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 and 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 activity.

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 shall be in accordance with the original design and inspection requirements or as amended by approved changes to the original design.

XI. TEST CONTROL A. General QAPD 18 QAPD18Rev.

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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 ISESI modification or significant changes in procedures.

B. Responsibilities

1. The DPC 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 OPC staff is also responsible for establishing specifications, requirements and acceptance criteria for testing following ISFSI modifications or installation activities and the review of results for testing following modifications.

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

3. The Qualified Technical Reviewer is responsible for review of all ITS proposed test procedures, special testing procedures, performance testing procedures following ISESI modification and performing 10 CFR 72.48 evaluations to verify 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 will 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 not 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 limits are stated.

c. Test results are documented.

d. Detailed instructions for performing the test are included.

QAPD 19 QAPD19Rev.

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• 1

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.

6. Test results which fail to meet the requirements and acceptance criteria shall be properly noted and appropriate corrective action taken.

XII. CONTROL OF MEASURING AND TEST EQUIPMENT A. General 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 ISFSI technical requirements.

B. Responsibilities

1. The DPC staff is responsible for establishing requirements for a program for the control, calibration, and 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 ISFSI Manager is responsible for ensuring implementation of the requirements of this section of the manual for ISFSI activities and for approving ISFSI procedures or instructions.

C. Requirements

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 QAPD 20 QAPO20Rev.

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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 maintained.

5. Measuring and test equipment shall be controlled by a permanently affixed serial number. Calibration decals, tags or stickers shall be displayed prominently on each device and shall reflect the date of calibration, due date of the next calibration (for recurring calibration) and identity of person performing the calibration.

Xlll. HANDLING, STORAGE, AND SHIPPING A. General This section establishes the requirements for ISESI procedures to control the handling, storage, shipping, cleaning, packaging, and preservation of ITS material and equipment to prevent damage, deterioration, or loss through shipment, installation or use.

B. Responsibilities

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

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

C. Requirements

1. The requirements 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 applicable.

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 tools 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 QAPD 21 QAPD 21Rev.

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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 which satisfy the handling and storage requirements specified for the item.

XIV. INSPECTION, TEST, AND OPERATING STATUS A. General This section describes the system for indicating the inspection, test, and operating status of ITS components and systems at the ISFSI.

B. Responsibilities

1. The OPC 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 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 DPC staff is also responsible for the control of ISFSI status during modifications.

C. Reciuirements

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

XV. CORRECTIVE ACTION A. -General 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 non-conformances are promptly identified and corrected. This includes the control of materials, parts, or components that do not conform to requirements, thereby preventing their inadvertent use or installation.

B. -Responsibilities

1. The DPC staff is responsible for establishing procedures for the QAPD 22 QAPO 22Rev.

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identification, review, and correction of conditions adverse to quality which includes the control, evaluation, and disposition of deficient materials, parts, and components.

2. The DPC staff is responsible for reviewing nonconforming items that cannot be corrected by vendor action and recommending disposition.

The DPC staff is also responsible for preparing procedures for repair and rework of nonconforming items.

3. The DPC staff is responsible for reviewing conditions adverse to quality to determine the cause of the condition and for recommending corrective action to preclude repetition.

C. Requirements

1. Conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, shall be reported on a corrective action document. 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 corrective action document 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 notified of all nonconforming items and requested to correct the deficiencies.

DPC staff with assistance from procurement support staff shall be responsible for coordinating the disposition of deficient items with vendors. The QA Specialist / Engineer is 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 DPC staff who will recommend repair, rework, accept, or reject. Items shall be repaired or reworked only in accordance with approved procedures and shall be re-inspected after repair by the QA Specialist/IEngineer. DPC 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 shall be fully documented with the specification requirement, justification for acceptance, and effect of such use. All such items shall be approved by the corrective action document 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 DPC staff or applicable Design Authority (ref. Appendix A).

7. Conditions that may be reportable per 10CFR72.242, 10CFR71.95, or 100FR21 shall be reported in accordance with approved procedures.

XVI. QUALITY ASSURANCE RECORDS QAPD 23 QAPD23Rev.

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

The requirements below do not apply to records that are determined to be exempt from records keeping requirements in accordance with the terms of any NRC-approved records exemption that may be granted to SOLUTIONS for records related to the LACBWR site.

B. Responsibilities

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

2. The ISFSI Manager is responsible for approving and ensuring implementation of procedures for this section.

C. Requirements

1. Record Management System - Quality Records shall be identified, controlled and stored in accordance with written procedures. The record system includes the retention of those design, fabrication, inspection, operation, and surveillance records essential to demonstrate product quality. It provides for the identification of materials and their corresponding manufacturing, installation, inspection, test, and audit results. Requirements and responsibilities for the transmittal, distribution, retention, maintenance, and disposition of records are specified in approved procedures. QA records shall be protected against damage, deterioration, unauthorized change, or loss. For any work performed, the records to be generated must be identified, along with a means of matching the record to the item or activity to which it applies. Records must be legible, reproducible, and accurate. For subcontractors/sub-suppliers, the original QA record of the deliverables will be transmitted to SOLUTIONS or DPC when applicable.

2. Authentication - Documents shall be considered valid records only if stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated, including the use of electronic approval and authorization. This authentication may take the form of a statement by the responsible individual or organization. Handwritten signatures are not required if the document is clearly identified as a statement by the reporting individual or organization. These records may be originals or reproduced copies.

3. Indexing - The records indexing system must include records identification, location of the record within the system, and minimum retention time. The records and/or indexing system(s) shall provide QAPD 24 QAPD24Rev.

29

sufficient information to permit identification between the record and the items or activities to which it applies.

4. Distribution and Control - The records shall be distributed, handled, and controlled in accordance with written procedures. Measures shall be established to preclude the entry of unauthorized personnel into the storage area, or the distribution of records to unauthorized personnel.

Records maintained by the supplier at their facility or other location shall be accessible to the purchaser or their designated alternate.

5. Classification of records - Records shall be classified for retention and storage requirements as either lifetime or nonpermanent. Records that meet any of the following criteria are designated Lifetime records and must be maintained.

a. Project lifetime records shall include, as a minimum, design specifications, stress reports or stress calculations, "as-built" and interface control drawings, copies of material test reports, tabulation of materials for "as-built" configuration, NDE reports including examination reports, and nonconformance reports.

Lifetime record retention is based on the life of the program, life of the item, life of the facility, or life of the license, as applicable.

b. Nonpermanent records are required to show evidence that an activity was performed in accordance with applicabie requirements. Retention times must be established in writing.

In addition, retention periods specified in various governing codes and standards (e.g. 10CFR71, 10 CFR 72) will be included in the retention requirements established in approved procedures for QA records.

For subcontractors/sub-suppliers, the original QA record of the deliverables will be transmitted to SOLUTIONS or DPC when applicable.

6. Storage Requirements - The records shall be stored in predetermined location(s) that meet the requirements of applicable standards, codes, and regulatory agencies. Prior to storage of records, a written storage procedure shall be prepared and responsibility assigned for enforcing the requirements of that procedure.

Records shall be stored to prevent damage from moisture or temperature. All records maintained in hard copy form shall be firmly attached to binders or placed in folders, envelopes, or boxes for storage in file cabinets or within containers on shelving. Records may be stored in electronic media provided that the process for managing and storing the records are documented in approved procedures.

Media used for the retention of records include, but are not limited to, microfilm, compact disks, magnetic media, optical disks or servers.

The format used must be capable of producing legible and complete documents during the entire retention period.

a. Records shall be stored in facilities that minimize the risk of damage or destruction from the following:

QAPD 25 QAPD25Rev.

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b. Natural disasters such as wind, flood, or fires;

c. Environmental conditions such as high and low temperatures and humidity; and

d. Infestation by insects, mold, or rodents.

7. Disposition - Various regulatory agencies have requirements concerning records that are within the scope of the QAPO. The most stringent requirements shall be used in determining the final disposition.

XVII. AUDITS 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.

B. Responsibilities

1. The QA Specialist / Engineer is responsible for developing audit checklists, designating and training audit personnel, and conducting audits.

2. The QA Specialist / Engineer performs independent review and audit to verify that the ISESI is being maintained consistent with company safety, administrative, and licensing provisions.

C. Requirements Implementing procedure(s) for the internal audit/survey program shall 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 the QA Specialist I Engineer or other qualified personnel, such as technical specialists from other 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.

QAPD 26 QAPD26Rev.

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4. The QA Specialist / Engineer 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 NAC-MPC CoC Technical Specifications and applicable license conditions is audited at least once every 24 months. The audit shall include elements such as:

• 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 H and 10 CFR 72, Subpart G.

• Implementation of the programs required by Appendix 0, 1.0 through 2.5.

b. Other activities/documents as requested by SOLUTIONS or OPC management.

6. Deficiencies or nonconformances identified during an audit shall be documented and brought to the attention of the Project Manager and ISFSI Manager, as applicable. Follow-up shall be performed to verify that corrective actions have been taken to correct the deficiencies or non conform an ces.

7. Audit reports are sent to management for their review and assessment of the QA program.

8. Audit reports shall be forwarded to the SOLUTIONS Senior Executive Vice President and General Manager, the DPC President and CEO, and to the management positions responsible for the areas audited, within 30 days after completion of the audit.

9. 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.

10. Suppliers providing commercial grade calibration and testing services who are accredited by a nationally recognized accrediting body, using procedures consistent with those found in ANSI/ISO/lEO 17025 "General Requirements for the Competence of Testing and Calibration QAPD 27 QAPD27Rev.

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t.

Laboratories", do not have to be periodically surveyed if the conditions of the NRC Safety Evaluation dated February 9, 2015 are met (see Appendix B). Controls shall be established in applicable procedures to ensure the requirements of the NRC Safety Evaluation are satisfied.

QAPD 28 QAPO 28Rev.

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APPENDIX A (Page 1 of 2)

IMPORTANT TO SAFETY STRUCTURES, SYSTEMS AND COMPONENTS The pertinent quality assurance requirements of 10 CFR 50, Appendix B, 10 CFR 71 Subpart H and 10 CFR 72 Subpart G will be applied, as a minimum, to all quality activities affecting the Important To Safety (ITS) Structures, Systems and Components (S50s) associated with spent fuel storage and transportation package.

NOTE The safety classification of SSCs of the LACBWR 1SF SI facility may be revised based on engineering evaluations and a revision to the NAG-MPC FSAR. These modifications are controlled in accordance with the Design Control process and are not considered a reduction in the commitments to the QAPD.

The quality classification of 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 responsible for design and licensing controls for these components under their NRC-approved Quality Assurance Program. SOLUTIONS utilizes these types of components and packages under the provisions of a NRC General License for Radioactive Material Transportation Packages (10 CFR 71) and Spent Fuel Storage (10 CFR 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 550s associated with spent fuel storage and radioactive material transportation packages are defined below:

IMPORTANT TO SAFETY AS DEFINED BY 10 CFR 71 AND 10 CFR 72 A. Dry Spent Fuel Storage (10 CFR 72)

Quality Design SSC Category Authority Transportable Storage Canister and Fuel Basket Assembly A NAG Intl.

Vertical Concrete Cask B NAC Intl.

Transfer Cask and Adapter Plate B NAC Intl.

ISFSI Pad C DPC Lifting Yoke B NAC Intl.

Damaged Fuel Can A NAG Intl.

QAPD 29 QAPO 29Rev.

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APPENDIX A (Page 2 of 2)

IMPORTANT TO SAFETY STRUCTURES, SYSTEMS AND COMPONENTS B. Transport of Spent Fuel and GTCC Waste (10 CFR 71)

Quality Dsg uhrt SCCategory Dsg uhrt Transportable Storage Canisters and Fuel Basket Assembly A NAC Intl.

Daagd ue CnA NAC Intl.

Transportable Storage Canister and Basket Assembly For GTCCANCInl WateCotanesA NAC Intl.

C. Radioactive Material Transport Packages (10 CFR 71)

Radioactive Material Transport Packages subject to the provisions of 1 0 CFR 71, Subpart C,."General Licenses," are Important To Safety and subject to the applicable requirements of the QAPD.

NOTES:

1. See NAC-MPC Final Safety Analysis Report for additional classification information.

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

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

QAPD 30 QAPO30Rev.

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APPENDIX B REGULATORY COMMITMENTS. ALTERNATIVES AND EXCEPTIONS 1.0 REGULATORY COMMITMENTS 1.1 Regulatory Guide 1.8, l-R-5/77, Personnel Selection and Training, Endorses ANSI N18.1-1971 (as applicable).

1.2 Regulatory Guide 7.10, Revision 2 (3/05), "Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material."

1.3 NUREG/CR-6407, "Classification of Transportation Packaging and Dry Fuel Storage System Components According to Important to Safety (2/96)."

2.0 ALTERNATIVES 2.1 Nuclear Energy Institute (NEI) NEI 14-05, "Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services," revision 0, and associated NRC Safety Evaluation dated February 9, 2015.

3.0 EXCEPTIONS None QAPD 31 QAPD31Rev.

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A' APPENDIX C (Page 1 of 4)

ADMINISTRATIVE CONTROLS These Administrative Controls were developed to support operation of the LACBWR plant while in SAFSTOR (dismantlement) and operation of the LACBWR ISFSI.

These requirements were previously included in th'e Technical Specifications and were relocated to this QAPD during active decommissioning.

1.0 PROCEDURES 1.1 Written procedures shall be established, implemented, and maintained covering the Plant decommissioning activities referenced below and in Section 2.0:

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.

1.2 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 by a Qualified Technical Reviewer and approved by the Project Manager or designee prior to implementation.

2.0 PROG RAMS A ND MANUALS 2.1 Process Control Procqram (PCP)

The PCP shall be maintained on-site and will be available for NRC review. Licensee-initiated changes to the PCP 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 a Qualified Technical Reviewer.

QAPD 32 QAPO 32Rev.

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APPENDIX C (Page 2 of 4)

ADMINISTRATIVE CONTROLS 2.2 Offsite Dose Calculation Manual (ODCM)

The 00CM shall be maintained by the licensee. Changes to theO0DCM will be outlined in the annual Radioactive Effluent Release Report per Section 2.5.2. This submittal shall contain:

2.2.1 Detailed information to support the rationale for the change.

Information submitted should consist of a package of those pages of the ODOM 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.

2.3 Radioactive Effluent Controls Prociram 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 ODCM, (2) shall be implemented by health physics procedures and instructions, 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 0DCM; 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 airborne particulate in accordance with 10 CFR 20 and with the methodology and parameters described in the 00CM.

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 0DCM at least every year; QAPD 33 QAPO 33Rev.

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APPENDIX C (Page 3 of 4)

ADMINISTRATIVE CONTROLS 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; 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 Radioloqical Environmental Monitorinq Progqram 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 theO0DCM; (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 radionuclides in the environment in accordance with the methodology and parameters described in the 0DCM.

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 Reportingq Reguirements 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 AnnualIRadiological EnvironmentalIMonitoring Report 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 inclusion 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.

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APPENDIX C (Page 4 of 4)

ADMINISTRATIVE CONTROLS 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; and a discussion of all analyses in which the lower limit of detection (LLD) was not achievable.

2.5.2 Annual Radioactive Effluent Release Report Paragraph (a)(2) of 10 CFR 50.36a, 'Technical Specifications on Effluents from Nuclear Power Reactors," requires that a report be made 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 accordance 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 00CM, of radiation doses to members of the public from radioactive liquid and airborne particulate released beyond the effluent release boundary. This report shall contain any changes made to the 00CM during the previous twelve months.

QAPD 35 QAPD35Rev.

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FIGURE 1 La Crosse Solutions' Organization SOLUTIONS (off-site)

Pres'ident EXecutive Vice President and.

Corporate QA'Direc~tor,

. General Manger EnergySolutions SOLUTIONS (on-site dismantlement) ' P~etMngr"

• Radiation Protection "Licensing Manager QA Manager

- Manager r" ISFSI ACTIVITIES (subcontracted to DPC) Site Manager,- Genoa*

. ISFSI Mariager i

S~ecurity Force QAPD 36 Rev. 29