ML18101A231

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SONGS ISFSI Only QAPD Letter
ML18101A231
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 09/24/2018
From: Bruce Watson
Reactor Decommissioning Branch
To: Thomas J. Palmisano
Southern California Edison Co
MGVaaler NMSS/DUWP/RDB 415.3178 T5A64
References
CAC 000083, EPID L-2018-DP3-0000, EPID L-2018-DP3-0001, EPID L-2018-DP3-0002, EPID L-2018-DP3-0003
Download: ML18101A231 (8)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 24, 2018 Mr. Thomas J. Palmisano Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 AND THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION - REVIEW OF CHANGES TO THE DECOMMISSIONING QUALITY ASSURANCE PROGRAM (CAC 000083; EPIDS L-2018-DP3-0001, L-2018-DP3-0000, L-2018-DP3-0002, AND L-2018-DP3-0003)

Dear Mr. Palmisano:

The U.S. Nuclear Regulatory Commission (NRC) has completed its review of the proposed changes to the San Onofre Nuclear Generating Station (SONGS), Units 1, 2, and 3, Decommissioning Quality Assurance Program, Revision 6 (DQAP), in response to your letter dated May 1, 2018 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML18124A055), as supplemented by letter dated August 16, 2018 (ADAMS Accession No. ML18233A411), which requested approval of the proposed DQAP revision.

The DQAP is associated with Facility Operating Licenses DPR-13, NPF-10, and NPF-15, for SONGS, Units 1, 2, and 3, respectively, and Docket No.72-041 for the Independent Spent Fuel Storage Installation (ISFSI). The proposed changes to the SONGS DQAP, which are considered to be reductions in commitments, were submitted for NRC review and approval in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.54(a)(4) regarding changes to the quality assurance program.

The proposed SONGS DQAP revision reflects the change in facility conditions at SONGS that will follow completion of the transfer of all spent nuclear fuel from the spent fuel pools to dry fuel storage at the ISFSI, and represents a reduction in commitments from the previously approved SONGS DQAP. Subsequent to this transition, there will be no structures, systems, or components (SSCs), items or activities classified as safety-related as defined in Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. In addition, the highest level of safety significance for the remaining items and activities at the facility is designated as important to safety under 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, as defined and discussed in Appendix B of the SONGS DQAP.

T. Palmisano Specific changes include:

  • Removing the Nuclear Oversight Board and Onsite Review Committee from Appendix G of the SONGS DQAP and replacing them with the Independent Management Assessment and Independent Safety Review function, respectively, as described in the revised SONGS DQAP Appendix D.
  • Changing the Quality Assurance Program basis from American National Standards Institute (ANSI) and American Nuclear Society (ANS) standards to primarily using Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging Used in Transport of Radioactive Material, Revision 2, as a guidance document.
  • Other changes to the SONGS DQAP that are also designated as reductions in commitments to the previously approved DQAP, and are described in the attachments to the May 1, 2018, submittal, as supplemented by the August 16, 2018, letter.

The NRC staff has completed its review of your request and has determined that the Quality Assurance Program, as described in the SONGS DQAP submitted on May 1, 2018, and supplemented by letter dated August 16, 2018, is in conformance with the applicable quality assurance program requirements of Appendix B to 10 CFR Part 50.

The NRC staff also concludes that the proposed SONGS DQAP, Revision 6, follows the NRC guidance described in the enclosed NRC safety evaluation and conforms to NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light Water Reactor] Edition, Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants," Revision 1, dated August 2015 (ADAMS Accession No. ML15037A441), and is, therefore, acceptable.

T. Palmisano As described in Southern California Edisons (SCE or the licensee) letter dated May 1, 2018, as supplemented by letter dated August 16, 2018, requesting NRC approval of the proposed changes to the SONGS DQAP, the revised SONGS DQAP will be implemented within 60 days following SCEs notification to the NRC that all spent nuclear fuel has been transferred out of the spent fuel pools and placed in storage at the ISFSI.

If you have any questions, please contact Marlayna Vaaler at (301) 415-3178 or via e-mail at Marlayna.Vaaler@nrc.gov.

Sincerely,

/RA/

Bruce A. Watson, CHP, Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos. 50-206, 50-361, 50-362, and 72-041

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

ML18101A231

  • via memorandum **via e-mail OFFICE NMSS/DUWP/RDB/PM NMSS/DUWP/LA NRO/DCIP/QVIB/BC*

NAME MVaaler CHolston KKavanagh DATE 9/2/2018 9/13/2018 9/5/2018 OFFICE NMSS/DSFM/IOB/BC** NMSS/DUWP/RDB/BC NMSS/DUWP/RDB/PM NAME PSilva BWatson MVaaler DATE 9/5/2018 9/24/18 9/18/2018 SAFETY EVALUATION BY THE OFFICES OF NEW REACTORS AND NUCLEAR MATERIAL SAFETY AND SAFEGUARGS DECOMMISSIONING QUALITY ASSURANCE PROGRAM CHANGES SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 AND THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. 50-206, 50-361, 50-362, AND 72-041

1.0 INTRODUCTION

By letter dated May 1, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18124A055), as supplemented by letter dated August 16, 2018 (ADAMS Accession No. ML18233A411), Southern California Edison (SCE) submitted for the U.S. Nuclear Regulatory Commission (NRC) staffs review and approval the Decommissioning Quality Assurance Program (DQAP) for the San Onofre Nuclear Generating Station (SONGS),

Units 1, 2 and 3, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.54(a)(4). The SONGS DQAP provides an overview of the program controls for assuring quality related to the items and activities at SONGS during decommissioning.

Specifically, the proposed SONGS DQAP reflects the change in facility conditions at SONGS that will follow completion of the transfer of all spent nuclear fuel from the spent fuel pools to dry fuel storage in the onsite independent spent fuel storage installation (ISFSI),

and represents a reduction in commitments from the previously approved SONGS DQAP.

Subsequent to this transition, there will be no structures, systems, or components (SSCs),

items or activities classified as safety-related as defined in Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. In addition, the highest level of safety significance for the remaining items and activities at the facility is designated as important to safety under Subpart H, Quality Assurance, of 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and Subpart G, Quality Assurance, of 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, as defined and discussed in Appendix B of the SONGS DQAP. The NRC staff verified that the SONGS DQAP is based on the applicable portions of these quality assurance requirements.

2.0 REGULATORY EVALUATION

The NRCs regulatory requirements related to Quality Assurance (QA) programs are set forth in Appendix B to 10 CFR Part 50, 10 CFR 50.34(b)(6)(ii), and 10 CFR 50.54(a). In addition, the Commissions regulatory requirements related to QA programs for the packaging and transportation of radioactive material and independent storage of spent nuclear fuel are addressed in 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, respectively.

Enclosure

Appendix B to 10 CFR Part 50 establishes the requirements for the design, fabrication, construction, and testing of SSCs for the SONGS facility. The pertinent requirements of Appendix B apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying SSCs.

The regulations in 10 CFR 50.34, Content of applications; technical information, require that every applicant for an operating license include information in its Final Safety Analysis Report (FSAR) on the managerial and administrative controls to be used to ensure safe operation. The information on the controls shall also include a discussion on how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

The regulations in 10 CFR 50.54, Conditions of licenses, require each power plant subject to the requirements of Appendix B to 10 CFR Part 50 to implement a QA program, and the regulations in 10 CFR 50.54(a)(4) require licensees to receive NRC prior approval of changes to their QA program that reduce commitments.

The regulations in 10 CFR Part 71, Subpart H, establish the quality assurance requirements applying to the design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair, and modification of components of packaging that are important to safety.

The regulations in 10 CFR Part 72, Subpart G, establish the quality assurance requirements that apply to design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair, modification of SSCs, and decommissioning components that are important to safety.

3.0 TECHNICAL EVALUATION

The request for review and approval of the SONGS DQAP, which includes changes that are considered to be reductions in commitments, was submitted in a letter dated May 1, 2018, and supplemented by letter dated August 16, 2018, in accordance with the provisions of 10 CFR 50.54(a)(4). The May 1, 2018, letter included Revision 6 to the SONGS DQAP as .

In evaluating the adequacy of the SONGS DQAP, the NRC staff used guidance contained in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants," Revision 1, dated August 2015 (ADAMS Accession No. ML15037A441), which provides acceptance criteria for QA program descriptions.

In addition, the staff used the guidance contained in NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, dated March 2000 (ADAMS Accession No. ML003686776).

The primary changes proposed in Revision 6 of the SONGS DQAP include:

  • Limiting the application of the SONGS DQAP to only important to safety SSCs and associated activities. Following completion of the transfer of all spent fuel from the spent fuel pools to dry fuel storage in the ISFSI, there will be no SSCs, items or activities classified

as safety-related, as defined in Appendix B to 10 CFR Part 50, at the SONGS facility. The highest level of safety significance for the remaining items and activities at the facility is designated as important to safety under 10 CFR Part 71 and 10 CFR Part 72, and as defined in Appendix B of the SONGS DQAP. In the proposed change, the SONGS DQAP is only applicable to important to safety SSCs associated with spent fuel storage and transportation packages under 10 CFR Part 71 and 10 CFR Part 72. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, the NRC has previously approved this type of change for other decommissioning nuclear facilities (Reference Nos. 1, 2, 3, 4, and 5).

  • Changing the Quality Assurance Program basis from commitments to American National Standards Institute (ANSI) and American Nuclear Society (ANS) standards to primarily using Regulatory Guide (RG) 7.10, Establishing Quality Assurance Programs for Packaging Used in Transport of Radioactive Material, Revision 3, dated June 2015 (ADAMS Accession No. ML1406A505). RG 7.10 was previously included in the SONGS DQAP as an additional guidance document. Revision 6 also involves the elimination of commitments to standards and other RGs that are no longer necessary following completion of the transfer of all spent fuel from the spent fuel pools to dry fuel storage in the ISFSI. RG 7.10 includes quality assurance program guidance for important to safety activities under 10 CFR Part 71.

The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety.

  • Removing the discussion regarding the Security Plan, Emergency Plan, and the Fire Protection Program from Section 2.0, Quality Assurance Program. There have been no changes to the programs and procedures that implement these licensing requirements; reference to them is simply being removed from the SONGS DQAP. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, not referencing these programs in the SONGS DQAP is consistent with other decommissioning reactor QA programs previously approved by the NRC (Reference Nos. 1, 2, 3, 4, and 5).
  • Completely rewriting all of the SONGS DQAP except for Sections 1.0, Organization, 2.0, Quality Assurance Program, 5.0, Instructions, Procedures, and Drawings, and 18.0, Audits. The rewrite was done using similar language the NRC has previously approved for other nuclear facilities that have transferred all of the spent nuclear fuel from the spent fuel pools to the ISFSI (Reference Nos. 1 and 2), and is consistent with RG 7.10.

The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety.

  • Removing the need to perform periodic procedure reviews from Section 5.0. Any issues identified with the procedures would be documented and corrected using the SONGS Corrective Action Program. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, not having the requirement to perform periodic procedure reviews in the SONGS DQAP is consistent with other decommissioning reactor QA programs previously approved by the NRC (Reference Nos. 1, 2, 3, 4, and 5).
  • Removing the specific reference regarding audits of the Emergency Preparedness and Safeguards programs. These audits are still described in and required by the Emergency Plan and Security Plan, only the reference to them is being removed from the SONGS DQAP. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, not having a discussion regarding audits of the Emergency Preparedness and Safeguards programs in the SONGS DQAP is consistent with other decommissioning reactor QA programs previously approved by the NRC (Reference Nos. 1, 2, 3, 4, and 5).
  • Removing Appendix C, "Quality Assurance Program for Fire Protection Program, and the associated reference to RG 1.191, "Fire Protection Program for Nuclear Power Plants during Decommissioning and Permanent Shutdown," dated May 2001 (ADAMS Accession No. ML011500010). The requirements under 10 CFR 50.48(f) related to fire protection will continue to apply to the SONGS facility throughout decommissioning. In addition, the implementation of the Fire Protection Program is listed in Appendix D, Administrative Controls, of the SONGS DQAP. Furthermore, RG 1.191 states that subject to the requirements of 10 CFR 50.48(f)(3), a licensee may make changes to the fire protection program without prior NRC approval provided the changes do not reduce the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, taking into account the plant conditions and activities during decommissioning. In this situation, there are no changes proposed to the fire protection program. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety.
  • Removing the reference to Regulatory Issue Summary (RIS) 2000-18, Guidance on Managing Quality Assurance Records in Electronic Media, dated October 23, 2000 (ADAMS Accession No. ML003739359), from Appendix C, Regulatory Requirements and Commitments. RIS 2000-18 provides a list of four guidance documents developed by the Nuclear Information and Records Management Association (NIRMA) on establishing an electronic recordkeeping system to maintain the integrity, authenticity, and acceptability of QA records during their required retention period. The four guidelines were instead added to Section 17, Quality Assurance Records, of the SONGS DQAP. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance

and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety.

  • Changes made in response to a Request for Additional Information (RAI) issued to SCE by the NRC on July 19, 2018 (ADAMS Accession No. ML18193A200), as provided in SCEs response letter dated August 16, 2018. Specifically, the NRC staff requested clarification on the applicable controls and conditions from the NRCs Safety Evaluation (SE) approving Arizona Public Services (APSs) request for changes to the QA program at the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, dated September 28, 2005 (ADAMS Accession No. ML052710224), as well as the NRCs SE endorsing the guidelines contained in the Nuclear Energy Institutes (NEIs) 14-05, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, dated February 9, 2015 (ADAMS Accession No. ML14322A535). The RAI also requested clarification on SONGS intent by committing to both SEs described above. In its response, SCE proposed to include a statement in Revision 6 of the SONGS DQAP that states, in part, Controls shall be established in applicable procedures to ensure the requirements of the NRC Safety Evaluation are satisfied prior to acceptance. In addition, SONGS included a statement to clarify its commitment to NEI 14-05. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, the NRC previously approved this type of change for other decommissioning reactor facilities (Reference Nos. 2, 3, and 4).
  • Replacing the Nuclear Oversight Board described in the SONGS DQAP, Revision 5, Appendix G, Administrative Controls, with an Independent Management Assessment (IMA) function and describing it in the new Revision 6, Appendix D. The IMAs are periodically performed to monitor overall performance and confirm that the activities affecting quality comply with the SONGS DQAP and that the SONGS DQAP is effectively implemented.

IMAs are performed by individuals designated by the executive officer, who are independent of the activities being assessed and posses the appropriate level of expertise. The IMAs will ensure that independent oversight of activities being performed at SONGS will continue during dry fuel storage and decommissioning. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, the NRC previously approved this type of change for other decommissioning reactor facilities (Reference Nos. 2, 3, and 5).

  • Replacing the Onsite Review Committee described in the SONGS DQAP, Revision 5, Appendix G, with an Independent Safety Review (ISR) function and describing it in the new Revision 6, Appendix D. Independent safety reviewers perform ISRs of proposed changes, tests, and experiments to important to safety SSCs, activities, program documents, and procedures that are subject to the SONGS DQAP requirements. The proposed changes to the SONGS DQAP also include a description of the training requirements for the independent safety reviewers, as well as the organizational structure, functional

responsibilities, level of authorities, and interfaces for the ISR. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety. In addition, the NRC previously approved this type of change for other decommissioning reactor facilities (Reference Nos. 1, 2, 4, and 5).

  • Changes made in response to an RAI issued to SCE by the NRC on July 19, 2018, as included in SCEs response letter dated August 16, 2018. Specifically, the NRC staff requested an explanation on why the training requirements described in the SONGS DQAP do not reflect all of the site personnel and are limited only to personnel involved in performing spent fuel safety, radiation protection, and final status survey activities. In its response, SCE proposed to include a statement in Revision 6 of the SONGS DQAP that removed the applicability of the training requirements to just the personnel noted above. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety.
  • Removing Appendix H, DQAP Implementing Programs/Procedures. This appendix contained the list of procedures used to implement the SONGS DQAP. The requirement to maintain and implement procedures is still required by the SONGS DQAP in accordance with Section 5.0. The NRC staff reviewed the proposed changes and determined that these changes continue to meet the guidance and acceptance criteria contained in Chapter 12 of NUREG-1567, and therefore meet the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G, for items and activities that are important to safety.

In Appendix C of Revision 6 of the SONGS DQAP (Attachment 2 of the May 1, 2018, submittal),

SCE commits to comply with the following regulatory requirements and commitments:

  • 10 CFR Part 71, Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material;
  • 10 CFR Part 72, Subpart G, Quality Assurance for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor Related Greater than Class C Waste;
  • RG 7.10, Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material, Revision 2, March 2005, with the exception of the annual audit frequency. SONGS is on a 24-month audit frequency in accordance with implementing plant procedures; and
  • NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety, February 1996 (ADAMS Accession No. ML15127A114).

4.0 CONCLUSION

The NRC staff used the acceptance criteria in Chapter 12 of NUREG-1567 and NUREG-0800, Section 17.5, as the basis for evaluating the acceptability of the changes to the SONGS DQAP, in conformance with the applicable portions of 10 CFR Part 71, 10 CFR Part 72, and Appendix B to 10 CFR Part 50. The SONGS DQAP adequately describes the provisions to meet the quality assurance requirements of 10 CFR Part 71, 10 CFR Part 72, and Appendix B to 10 CFR Part 50 for activities that are important to safety for a facility that has moved all its spent fuel from the spent fuel pools to the ISFSI. Accordingly, the NRC staff concludes that the proposed changes to the SONG DQAP in Revision 6 follow the NRC guidance contained within, conform to the format of NUREG-0800, Section 17.5, and comply with the quality assurance requirements contained in 10 CFR Part 71 and 10 CFR Part 72, and are, therefore, acceptable. The NRC staff may also conduct a quality assurance implementation inspection at SONGS to verify that the SONGS DQAP is being implemented appropriately once all spent fuel has been removed from the spent fuel pools and moved to the SONGS ISFSI.

5.0 REFERENCES

1. Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, Yankee Nuclear Power Station - Quality Assurance Program Changes (TAC No. MA5032), dated June 20, 2000 (ADAMS Accession No. ML003725064).
2. Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, Maine Yankee -

Approval of Quality Assurance Program Changes (TAC NO. L24046), dated February 23, 2007 (ADAMS Accession No. ML070570160).

3. Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, Zion Nuclear Power Station, Units 1 and 2 - Request for NRC Approval of Revision 17 to the Zion Nuclear Power Station Quality Assurance Project Plan (TAC Nos. J53032 and J53033),

dated December 30, 2014 (ADAMS Accession No. ML14353A454).

4. Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, Entergy Vermont Yankee Quality Assurance Program Manual, Vermont Yankee Nuclear Power Station and Independent Spent Fuel Storage Facility - Review and Acceptance of Changes (CAC No. L53120), dated June 16, 2016 (ADAMS Accession Nos. ML16165A466 and ML16165A467).
5. Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, Entergy Vermont Yankee Quality Assurance Program Manual, Vermont Yankee Nuclear Power Station and Independent Spent Fuel Storage Facility - Review and Acceptance of Changes (EPID L-2017-DP3-0002), dated May 1, 2018 (ADAMS Accession No. ML18099A166).
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