ML18193A200

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SONGS ISFSI Only DQAP RAI
ML18193A200
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 07/19/2018
From: Vaaler M
Division of Decommissioning, Uranium Recovery and Waste Programs
To: Thomas J. Palmisano
Southern California Edison Co
MVaaler NMSS DUWP
References
CAC 000083, EPID L 2018-DP3-0002, EPID L-2018-DP3-0000, EPID L-2018-DP3-0001, EPID L-2018-DP3-0003
Download: ML18193A200 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 19, 2018 Mr. Thomas J. Palmisano Vice President, Chief Nuclear Officer Southern California Edison Co.

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 -

REQUEST FOR ADDITIONAL INFORMATION REGARDING REVISION 6 OF THE DECOMMISSIONING QUALITY ASSURANCE PROGRAM (CAC NO. 000083; EPID L-2018-DP3-0001, EPID L-2018-DP3-0000, EPID L-2018-DP3-0002, AND EPID L-2018-DP3-0003)

Dear Mr. Palmisano:

By letter dated May 1, 2018, Southern California Edison (SCE) submitted an application seeking U.S. Nuclear Regulatory Commission (NRC) review and approval of Revision 6 of the Decommissioning Quality Assurance Program (DQAP) for the San Onofre Nuclear Generating Station (SONGS), Units 1, 2, and 3, respectively, and the Independent Spent Fuel Storage Installation (ISFSI). The proposed changes to the DQAP, which are considered to be reductions in commitments, have been 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).

The proposed DQAP reflects the transition of the decommissioning status 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 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.

In order to complete its review, the NRC staff requests additional information as specified in the Enclosure to this letter. The requested information was discussed with SCE during a teleconference with NRC staff on July 18, 2018. In order to continue the review of the SONGS DQAP, please respond to this request for additional information within 30 days.

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

Sincerely,

/RA/

Marlayna Vaaler, Project Manager 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:

Request for Additional Information cc: Distribution via Listserv

ML18193A200

  • via email OFFICE NMSS/RDB/PM NMSS/DUWP/LA NRO/DCIP/QVIB1/BC NMSS/RDB/BC NAME MVaaler CHolston TJackson*

BWatson DATE 7/11/2018 7/12/2018 7/12/2018 7/19/18

REQUEST FOR ADDITIONAL INFORMATION CHANGES TO THE DECOMMISSIONING QUALITY ASSURANCE PROGRAM TO REFLECT AN ISFSI-ONLY CONFIGURATION SOUTHERN CALIFORNIA EDISON SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 DOCKET NOS. 50-206, 50-361, 50-362, AND 72-041 By letter dated May 1, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18124A055), Southern California Edison (SCE) ) submitted an application seeking U.S. Nuclear Regulatory Commission (NRC) review and approval of Revision 6 of the Decommissioning Quality Assurance Program (DQAP) for the San Onofre Nuclear Generating Station (SONGS), Units 1, 2, and 3, respectively, and the Independent Spent Fuel Storage Installation (ISFSI). The proposed changes to the DQAP, which are considered to be reductions in commitments, have been 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).

The proposed DQAP reflects the transition of the decommissioning status 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 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. The following additional information is necessary to complete the NRC staffs technical review.

SONGS-RAI-1 The requirements of Criterion VII, Control of Purchased material, Equipment, and Services, of Appendix B to 10 CFR Part 50 states, in part, that Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.

Appendix C, Regulatory Requirements and Commitments, of the SONGS DQAP includes two alternatives for the procurement of commercial calibration and testing services as part of the commercial-grade dedication process.

Clarify if the applicable controls and conditions from the NRC Safety Evaluation (SE) approving the Arizona Public Service (APS) request for changes to the quality assurance 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 NRC SE endorsing the guidelines contained in the Nuclear Energy Institutes (NEI) 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), are described in the applicable implementing procedures at SONGS.

In addition, given that NRCs endorsement of NEI 14-05 expands the acceptance of the International Laboratory Accreditation Cooperation accreditation process documented in the APS SE, please clarify your intent to use this process by committing to both of the alternatives.

SONGS-RAI-2 The requirements of Criterion II, Quality Assurance Program, of Appendix B to 10 CFR Part 50, states, in part, that The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Section 3.0, Facility Staff Qualifications, in Appendix D, Administrative Controls, of the SONGS DQAP limits the applicability of the American National Standards Institute (ANSI) N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, to spent fuel safety and radiation protection personnel, including those individuals that will be performing the final status survey activities.

Explain why the training requirements described in the SONGS DQAP do not reflect all of the site personnel and are limited to personnel only involved in performing spent fuel safety, radiation protection, and final status survey activities.