ML19241A245

the Independent Spent Fuel Storage Installation - Decommissioning Quality Assurance Plan

ML19241A245
Person / Time
Site:	San Onofre
Issue date:	08/27/2019
From:	Bauder D Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML19241A245 (48)

Text

Douglas R Bauder Vice President Decomm1ss10nmg &

Chief Nuclear Officer San Onofre Nuclear Generatmg Stat10n An EDISON INTERNATION,\L"' Companl 10CFR50 54(a) 10 CFR 71 106(b)

August27,2019 U S Nuclear Regulatory Comm1ss1on ATTN Document Control Desk Washington, DC 20555-0001 SUBJECT Docket Nos. 50-206, 50-361, 50-362, and 72-041 Decomm1ss1onmg Quality Assurance Plan San Onofre Nuclear Generating Station, Umts 1, 2, and 3 and the Independent Spent Fuel Storage Installation REFERENCE Letter from T J Palmisano (SCE) to NRC Document Control Desk dated August 9, 2017, Subject Decomm1ss1oning Quality Assurance Plan San Onofre Nuclear Generating Station, Units 1, 2, and 3 and Independent Spent Fuel Storage Installation - (ADAMS Accession No ML17223A196)

Dear Sir or Madam In accordance with the requirements of 10 CFR 50 54 (a) and 10 CFR 71 106 (b) Southern California Edison hereby submits the update to the Decomm1ss1oning Quality Assurance Program (DQAP) for San Onofre Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation (Attachment 1)

A summary of the changes to the DQAP since the referenced submittal 1s provided in accordance with 10 CFR 50 71 (e) in Attachment 2 There are no commitments contained in this letter or its attachments Should there be any questions regarding this submittal, please contact Mr Albert Bates, Manager, Regulatory Affairs, at (949) 368-6945 perjury that the foregoing 1s true and correct Executed on (JO /)4-

J/.f 552/_p Sincerely,

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Jfvf 55 PO Box 128 San Clemente, CA 92674 (949) 368-9275 PAX 89275 Fax (949) 368-9881 doug bauder@sce com Decomm1ss1onmg Quality Assurance Program (DQAP) Rev1s1on 5 Summary of Changes m the Decomm1ss1onmg Quality Assurance Program, Rev1s1ons 4 and 5 cc S Moms, Regional Administrator, NRC Region IV M Doell, NRC ProJect Manager, SONGS Units 1, 2 and 3

Attachment 1 Decomm1ss1onmg Quality Assurance Program (DQAP)

Rev1s1on 5

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DECOMMISSIONING QUALITY ASSURANC E PROGRAM

{DQAP)

Revision 5 Southern California Edison (SCE)

San Onofre Nuclear Generating Station (SONGS) 1

Southern Cahforma Edison San Onofre Nuclear Generating Station Decomm1ss1omng Quality Assurance Program (DQAP)

Approvals Manager, Regulatory Affairs and Nuclear Oversight Date Vice President of Decomm1ss1ornng and Chief Nuclear Officer Date 2

Introd uct1on Southern CalJforma Edison (SCE) announced plans on June 7, 2013, to permanently retire Urnts 2 and 3 at the San Onofre Nuclear Generating Station (SONGS) On June 12, 2013 SONGS submitted a Cert1f1cat1on of Permanent Cessation of Power Operations to the Nuclear Regulatory Comm1ss1on (NRC), certifying that SCE has permanently ceased power operations of SONGS Umts 2 and 3 To address this changing environment at SONGS, a Decomm1ss1ornng Quahty Assurance Program (DQAP) has been developed to support the decomm1ss1oning act1v1t1es of the station (Umts 1, 2 & 3) and ensure continued oversight of Decomm1ss1ornng and the Independent Spent Fuel Storage Installation (ISFSI)

The SONGS DQAP reflects the quality act1v1t1es pertaining to a decomm1ss1omng nuclear site through compliance with established regulatory requirements set forth by the NRC The DQAP ensures the protection of the pubhc health and safety through performance-based assessments and compliance-based auditing utilizing implementing procedures and instructions The DQAP describes the respons1b1lit1es for implementing quality reqwrements, establishing and maintaining the DQAP, and assessing the performance of act1v1t1es subject to the DQAP The 1mplementat1on of the SONGS DQAP 1s performed in a graded approach commensurate with the items and act1v1ties importance to safety The SONGS DQAP includes a descnpt1on of the orgamzat1onal structure and functional respons1bi1Jt1es of the station management regarding the 1mplementat1on of important to safety activ1t1es at SONGS The DQAP also outlines the oversight roles and respons1b1ht1es for the Quality Assurance (QA) staff and program expectations for the various station organizations The DQAP sat1sf1es the requirements of 10 CFR 50 Appendix B, Quality Assurance Cntena for Nuclear Power Plants and Fuel Processmg Plants, 10CFR71, Subpart H, Quality Assurance for Packagmg and TransportatJOn of Rad10act/ve Mat<pna/, and 10CFR72, Subpart G, Qua/tty Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Radtoactlve Waste Add1t1onal regulatory commitments are listed within Appendix B of the DQAP 3

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Table of Contents Page Approvals 2 Introd uct1on 3 List of Appendixes 5 10 Orgarnzat1on 6 20 Quality Assurance Program 9 30 Design Control 11 40 Procurement Document Control 13 50 Instructions, Procedures and Drawings 14 60 Document Control 15 70 Control of Purchased Material, Equipment and Services 16 80 ldent1ficat1on and Control of Material, Parts and Components 17 90 Control of Special Processes 18 10 0 Inspection 19 11 0 Test Control 20 12 0 Control of Measuring and Test Eqwpment 21 13 0 Handling, Storage and Shipping 23 140 Inspection, Test and operating Status 24 15 0 Nonconforming Materials, Parts and Components 25 16 0 Corrective Action 26 17 0 Quallty Assurance Records 27 18 0 Audits 28 4

List of Appendixes Page Appendix A Organization Chart 29 Appendix B* Regulatory Requirements and Commitments 30 Appendix C Quality Assurance Program for Fire Protection Program 31 Appendix D List of Acronyms 32 Appendix E References 33 Appendix F Def1rntJons 34 Appendix G Adm1rnstrat1ve Controls 37 Appendix H DQAP Implementing Programs/Procedures 38 5

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' r I I,,, -- ,.J Orgamzat1on 1 0 Orgamzat1on Southern California Edison (SCE) 1s responsible for the establishment and execution of the QA Program for the San Onofre Nuclear Generating Station (SONGS) The SCE orgarnzat1onal structure of departments involved with implementing the SONGS DQAP as well as departmental interfaces 1s presented m Appendix A The titles of managers used m the DQAP are generic, or functional titles and their formal titles may vary Unless otherwise spec1f1cally proh1b1ted, respons1b1llt1es of managers described 1n the DQAP may be delegated to, and performed by, other qualified ind1v1duals The ultimate respons1b1l1ty for operation, maintenance, inspection, test, modrficatmn, decomm1ss1onrng, and storage of spent fuel resides with the SCE President The Chief Nuclear Officer (CNO) has the overall respons1b1hty for the establishment and execution of the SONGS DQAP Respons1b1lit1es The authorities and duties of persons and orgarnzatJons performing act1v1t1es affecting the important to safety functions of Structures, Systems, and Components (SSC) are established and delineated in writing These act1v1t1es include both the performing functions of attaining quality obJect1ves and the QA functions The CNO 1s responsible for (a) Regulatory Affairs (ma1ntaming licensing documents, submitting routine regulatory agency reports, and for addressing Nuclear Regulatory Comm1ss1on (NRC) or other regulatory issues), (b} Emergency Preparedness, (c) Decomm1ss1ornng ProJects, (d} Nuclear Oversight and Safety Culture (oversight of quality and safety conscience work environment for actlv1t1es performed at SONGS),

(e) Plant management and (f) the adm1nrstrat1on and 1mplementat1on of the DQAP at SONGS The DQAP 1s reviewed and approved by the Manager responsible for Nuclear Oversight, and the CNO The CNO 1s responsible for appraising management of the effectiveness of the DQAP implementation and 1s the arbitrator for non-conforman ces of unusual complexity CNO also directs actions to be taken based on reports and trending of quality issues submitted by the Manager responsible for Nuclear Oversight D1rect1on for implementing the DQAP act1v1t1es 1s provided by the CNO through the Manager responsible for Nuclear Oversight Management of lrne organizations at SONGS are responsible to ensure that the quality of organrzatJonal

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work and act1v1t1es meets the requirements set forth 1n the DQAP and SONGS implementing procedures Nuclear Oversight The Manager responsible for Nuclear Oversight reports to the CNO and shall not be assigned respons1b1ht1es that would prevent the required attention to quality affecting matters Although reporting to the CNO with other lme organrzat1ons, the Manager responsible for Nuclear Oversight shall have the necessary independence from other line management to ensure effective oversight for all organizations The manager has the following respons1b1llt1es

• Management of day-to-day oversight of 1mplementat1on of the DQAP for all quality activ1t1es

• Authority and obligation to raise any cond1t1ons adverse to qua/Jty to the CNO for resolution 6

• Assuring quality act1v1tres at SONGS are performed m accordance with 1mplementmg procedures

• Managing the performance of audits, assessments, and inspections in order to verify that important to safety act1v1t1es have been correctly performed

• Reporting on oversight act1v1t1es to the CNO

• Authority to stop work when quality 1s adversely affected Nuclear Oversight personnel report directly to the Manager responsible for Nuclear Oversight and implement the relevant prov1s1ons of the DQAP utilizing written implementing procedures They perform independent oversight of line functions and act1v1t1es A member of the Nuclear Oversight orgamzat1on shall not perform oversight of act1v1t1es for which the member has been directly responsible Further, they have the respons1b1hty and authority to stop work when quality 1s adversely affected and 1mmed1ately

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raise concerns to the Manager responsible for Nuclear Oversight Nuclear Oversight personnel shall have suff1c1ent authority and orgamzat1onal freedom to 1dent1fy any quality problems and to verify 1mplementat1on of corrective actions Add1t1onally, Nuclear Oversight personnel shall have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and safety cons1derat1ons Station Management The Manager responsible for Decomm1ss1omng Projects reports to the CNO and 1s responsible for managing all decomm1ss1omng project act1v1t1es being performed at SONGS The Manager responsible for Decomm1ss1omng Oversight reports to the Manager responsible for Decomm1ss1omng Projects The Manager responsible for Engineering Oversight reports to the Manager responsible for Decomm1ss1omng Oversight with respons1b1hty for design authority The Manager responsible for ISFSI Engineering reports to the Plant Manager and 1s responsible for QA program 1mplementat1on for systems engineering, engineering programs, engrneerrng design, and engrneerrng for nuclear fuel management--

The Manager responsible for Regulatory Affairs reports to the CNO with respons1b1ht1es for marntarnrng hcensrng documents, submitting routine regulatory agency reports, and developrng strategies for addressing regulatory issues The Manager responsible for Emergency Preparedness, reports to the Plant Manager with respons1b1htres

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for emergency planning The Manager responsible for Rad1at1on Protection and Waste reports to the Manager responsible for Decomm1ss1omng Oversight The Plant Manager reports to the CNO and 1s responsible for Operations and Training, ISFSI Engineering, Maintenance and Work Control, Security, Emergency Preparedness and Corrective Action Program (CAP) act1v1t1es performed at SONGS and ensures all actrv1t1es are consistent with QA program requirements 7

The Independent Safety Reviewer (ISR) performs independent safety reviews of proposed changes, tests and expertments to SSCs, act1v1t1es, program documents and procedures that are subject to the SONGS DQAP requirements ISRs shall be md1v1duals without direct respons1b1lity for the performance of act1v1t1es under review, and shall be competent and knowledgeable 1n the subject area bemg reviewed Other facility staff shall follow the requirements of section 5 0 Admm1straflve Controls, of the SONGS Technrcal Spec1f1cat1ons Other Corporate SCE Organrzat1ons

• Supply Cham Management 1s responsible for procurement of materials, equipment and services, material shipping, and for preparation, negotiations, and admin1strat1on of procurement contracts for SONGS reporting to SCE Corporate Management

• Corporate Records Center reports to SCE Corporate Management and 1s responsible for storage and retrteval of company records (including nuclear records) placed in their custody They interface with site Records Management related to long term storage of nuclear records

• Information Technology 1s responsible for managing computer application, computing system, and network services, including nuclear computer program development, technology, and support act1v1t1es, except plant computer systems Delegation of Quality Assurance Work SCE may delegate the execution of work under the DQAP to others such as contractors, agents, or consultants, however, SCE retains overall respons1b1lity for those actlv1t1es and the DQAP Delegation 1s clearly 1dent1fied in documentation and SCE retains the right to verify compliance with SCE quality requirements and regulatory requirements applicable to that organrzat1on's QA Program Reporting '

SCE management 1s involved with QA matters on a continuing basis Regular reports summarizing the quality of SONGS act1v1t1es are reviewed and approved by the Manager responsible for Nuclear Oversight These reports contain status of program adherence to the DQAP, issues 1dent1fied, unresolved items, and other items of interest to quahty act1v1t1es These reports are submitted to the CNO and other SONGS management as deemed appropriate The CNO shall penod1cally have an external aud1! performed to evaluate the effectiveness of the SONGS QA Program These external audits are performed by md1v1dual(s) designated by the CNO who are independent of SONGS oversight act1v1t1es and who have the appropriate level of expertise in the act1v1t1es audited These periodic external audits shall be performed on a 24 month frequency with a 90 day grace period which 1s not to impact the established 24 month cycle for the audit The external audit results are communrcated via a written report m a timely manner to a level of management havmg the authority to execute effective corrective action In add1t1on, these results are reported to the SCE President through the SONGS CNO Records Records of the biennial audit of the QA program including audit plan, checklist, audit report, and the record of completion of corrective act1on(s) shall be retained 1n accordance with proper 1mplementmg procedures 8

Quality Assurance Program 2 O Quality Assurance Program The QA Program for San Onofre Nuclear Generating Station (SONGS} 1s described m the Decomm1ss1omng Quality Assurance Program (DQAP) This DQAP provides control over act1v1t1es affecting quality to an extent consistent with their importance to ensure safety and compliance The DQAP includes spec1f1c monitoring act1v1t1es which are measured against acceptance criteria rn a manner suff1c1ent to provide SONGS managemen t assurance that the act1v1t1es affecting quality are performed 1n an acceptable manner The SONGS DQAP requirements apply to regulatory programs and SSCs designated as important to safety which are listed in the engineering Q-Lrst The DQAP sat1sf1es the requrrements of 10 CFR 50 Appendix B Quality Assurance Cntena for Nuclear Power Plants and Fuel Processmg Plants, 10CFR71, Subpart H, Qua/Jty Assurance for Packagmg and Transportation of RadJOact,ve Matenal, and 1 OCFR72, Subpart G, Quality Assurance for Independen t Storage of Spent Nuclear Fuel and High-Level Radioactive Waste Add1t1onal regulatory commitment s are listed within Appendix B of the DQAP Implementation of the SONGS DQAP 1s controlled through separately issued procedures, instructrons and drawings Each organization 1s responsible for the establishment and 1mplementat1on of procedures and instructions prescribing the rmportant to safety actrv1tres for whrch they are responsible Act1v1t1es affecting quality shall be accomplished under surtably controlled cond1t1ons Controlled cond1t1ons include the use of appropriate equipment, surtable environmental conditions for accomplishi ng the act1v1ty, such as adequate cleanness, and assurance that all prerequ1s1tes for the given act1v1ty have been satisfied The QA program takes into account the need for special controls, processes, test eqwpment, tools, and skills to attain the required quality, and the need for verification of quality by inspection and test Changes to the DQAP will be implemented 1n accordance with 10 CFR 50 54(a} and 10 CFR 71 106 Program Control and Authority The Manager responsible for Nuclear Oversrght 1s responsible for ensuring that the applicable portions of the DQAP are properly documented approved and implemented (with trained staff, necessary materials and approved procedures available} before an act1v1ty w1th1n the scope of the DQAP 1s executed Disputes arising between departments or organizations on any QA matter that cannot be resolved at a lower level of managemen t will be referred to the CNO Add1t1onal requirements for spec1f1c programs are described rn section 5 0 Adm1mstratlve Controls, of the SONGS Technical Spec1f1catrons with the exception of security requirements which are contained rn the SONGS Physical Secunty Plan, and Emergency Plan requirements which are contained 1n the SONGS Permanently Defueled Emergency Plan (PDEP} SONGS Fire Protection Program requirements are addressed in Appendix C of this DQAP Personnel Training and Quahf1cat1ons lnd1v1dual managers are responsible for ensuring that personnel working under their cognizance are provided with the necessary indoctrination training and resources to accomplish assrgned act1v1t1es which fall under the scope of the DQAP 9

Members of the SONGS staff (including audit and inspection personnel) shall have the appropriate quahficat1ons necessary to perform their assigned duties defined m implementing procedures hsted in Appendix H of the DQAP These implementing procedures provide the criteria ut1hzed for determining and assessing appropriate staff quahf1cat1on Add1t1onally, plant Technical Spec1f1cat1ons cite references that stipulate the use of specific industry standards addressing qualif1cat1ons Training programs are established and implemented to ensure that personnel achieve and maintain sUJtable prof1c1ency Personnel training and qualif1cat1on records are maintained in accordance with approved procedures QA Lead Auditors are qualified and cert1f1ed by the Manager responsible for Nuclear Oversight m accordance with approved procedures Training methods, minimum experience requirements, and cert1f1cat1on practices are in accordance with established procedures and based on criteria set forth m QA 1mplementmg procedures Prof1c1ency evaluations are performed and documented for ind1v1duals leading audits and appropriate cert1f1catton renewal or re-qualif1cat1on actions are taken Records Records of the 1mplementat1on for staff indoctrination and trammg, as well as records for Lead Auditor, Auditor, Technical Spec1al1st and Inspection Personnel quahf1cat1on shall be mamtamed m accordance with approved procedures and show the appropriate documentary evidence of trammg completion

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Design Control 3 0 Design Control Design acbv1t1es shall be controlled to ensure that the design, including applicable regulatory requirements and design bases, technical and quality requirements are correctly translated to design documents which include spec1f1cat1ons, drawings, procedures and instructions Design changes to SSCs that have current important to safety functions shall also be properly controlled using design control measures commensurate with those applied to the original design Design changes are reviewed and approved by the same design groups cognizant in the d1sc1pline affected by the change that reviewed and approved the original documentation unless alternative design groups are designated Design act1v1t1es associated with the nuclear station changes or modifications may be performed by SCE or qualified contractors Design groups shall have access to background information, shall be competent in the spec1f1c area of design interest, and shall understand the requirements and intent of the original design Measures shall be established for the selection and review for su1tab1lity of application of materials, parts, equipment, and processes that are essential to SSCs that have current important to safety functions Design control implementing procedures shall define respons1b1ht1es for the following Design Input Design Performance Design Interface Control Design Verif1cat1on Design Change Design inputs shall be 1dent1f1ed, documented and correctly translated into design outputs Design inputs shall be spec1f1ed to a level of detail necessary to allow the design act1v1t1es to be carried out in a controlled manner The final design output shall relate to the design input in sufficient detail to facilitate design verif1cat1on The design organization shall prescribe and document the design act1v1t1es to the level of detail necessary to permit the design process to be completed in a correct manner which permits venf1cat1on that the design meets requirements Design documents shall support facility design, construction, safe storage and handling of spent fuel, and decomm1ss1oning projects Appropriate quality standards shall be 1dent1f1ed and documented, and their selection reviewed and approved Dev1at1ons from original design standards shall be reviewed to ensure that the designated quality requirements remain in the design of SSCs that have current important to safety functions Design control measures shall be applied to items such as the following stress, thermal, hydraulic, and accident analyses, compat1b1l1ty of materials, access1b1hty for in-service inspection, maintenance, and repair, and dehneat1on of acceptance criteria for 1nspect1ons and tests for those SSCs that have current important to safety functions Design analyses shall be sufflc1ently detailed such that a person technically qualified m the subject can review and understand the analyses and verify the adequacy of the results without add1t1onal input Interface controls (internal and external between part1c1pating design organizations and across technical d1sc1plines) for the purpose of developing, rev1ew1ng, approving, releasing, distributing, and revising design inputs and outputs shall be defined 1n procedures Design 1nformat1on transmitted across interfaces shall 1dent1fy the status of the design information or documentation provided 11

Changes or mod1ficat1ons to designated SSCs shall be approved by the Design Authority or des1gnee, as specified 1n adm1mstrat1ve procedures Procedure for implementing design changes and field changes, shall assure that the impact of the change 1s considered, required actions documented, and information concerning the change transmitted to affected persons or orgamzat1ons Applicable regulatory criteria (1 e 10CFR50 59 or 10CFR72 48) shall be used to determine 1f NRC approval 1s required prior to 1mplementat1on of a design change For SSCs that have current important to safety functions, these changes shall be subject to design control measures commensura te with those applied to the original design Design verification for SSCs that have current important to safety functions shall provide assurance that the final design 1s correct and has been performed in accordance with approved procedures describing pos1t1on respons1b1llt1es and authorities for the design reviews Documentation to be reviewed for this design work includes the necessary calculations and/or analysis, design criteria speclf1cat1ons, drawings, procedures, and instructions to permit a comprehensive review Design verif1cat1on may be accomplished through design reviews, alternate calculations, or quahf1cat1on testing These alternate methods of design verif1cat1on are defined in design documentation Records of design reviews and associated design documents are required by internal written procedures to be ma1nta1ned in SONGS Records Managemen t Design verif1cat1on shall be performed by competent ind1v1duals or groups other than those who performed the original design, but who may be from t~e same department Alternative design groups may be used 1f the assignment 1s designated by the responsible engineering manager Design control procedures describe the pos1t1ons responsible for design reviews and other design verification act1v1t1es, and their authority and respons1b1llt1es Where a test program 1s used to verify the adequacy of a spec1f1c design feature in lieu of other, verifying or checking processes, 1t shall include sU1table qualification testing of a prototype umt under the most adverse design cond1t1ons The results of the design venf1cat1on act1v1t1es shall be documented with the 1dent1fication of the verifier clearly documented Design verif1cat1on shall be qimpleted prior to relying upon the SSC to perform its function Nonconforming act1v1t1es such as dev1at1ons, errors, or defic1enc1es in the approved design documents, including design methods (e g, computer codes), shall be controlled Computer programs used to calculate or develop important to safety data shall be subject to validation and verif1cat1on Procedure shall assure that ver1f1ed computer codes are cert1f1ed for use and that their apphcab1hty 1s specified Design documentation and records which provide evidence that the design and design verif1cat1on process was performed in accordance with the DQAP, shall be collected, stored and maintained in accordance with approved procedures This documentation includes final design documents, such as drawings, spec1f1cat1ons, calculations, and rev1s1ons there to and documentation which 1dent1f1es important steps, including sources of design inputs that support the final design \

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Procurement Document Control 4 0 Procurement Document Control SCE establishes measures to ensure that applicable requirements necessary to assure adequate quality requirements are included or referenced m procurement documents for material, equipment, and services which are designated as important to safety, 1dent1f1ed m SONGS Q-list, or required by SONGS Technical Spec1ficat1ons whether they are purchased by SCE or by its contractors or subcontractors Measures are established to assure that the applicable requirements are included or referenced m documents for procurement of materials, equipment, and services for the design, fabrication, and use during decomm1ss1oning act1v1t1es and of packaging for radioactive material Measures are established to assure that, to the extent necessary, contractors or subcontractors provide a QA Program consistent with the applicable prov1s1ons of 10 CFR 50 Appendix B, 10 CFR 71 Subpart H, and 10 CFR 72 Subpart G Procurement document control applies to SSCs that are 1dent1f1ed in the SONGS Q-L1st as important to safety and any spare or replacement parts for those SSCs Procurement documents shall include those requirements necessary to assure that the items and services to be provided meet the spec1f1ed technical and quality requirements Specifically, the procurement system assures that the appropriate technical and quality requirements are specified for procurement of items and services considering the important to safety function, complexity of the design, manufacturing, degree of mspectab11ity, and testability upon receipt and other factors which affect the quality of products and services Procedures that implement procurement document control shall describe the orgamzat1onal respons1b1llt1es for procurement planning, preparation, review, approval and control of procurement documents, supplier selection, bid evaluation, 1dent1ficat1on of replacement parts where applicable, and review and evaluation of supplier's QA Program prior to 1rnt1at1on of act1v1t1es affected by the DQAP Procedures shall be established to review the adequacy of the technical and QA requirements spec1f1ed w1thm procurement documents The review shall determine whether the requirements are correctly specified, inspectable and controlled Appropriate acceptance/ reJect1on cntena shall be clearly spec1f1ed The review and documented concurrence with respect to the adequacy of technical and QA requirements spec1f1ed with procurement documents shall be performed by independent personnel who have been trained and qualified to applicable QA practices and concepts Changes to procurement documents shall be subject to the same controls and the ongmal documents 13

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Instructions. Procedures and Drawings 5 0 Instructions, Procedures and Drawings SCE establishes measures to assure that quality act1v1t1es are prescribed by and performed in accordance with documented instructions, procedures, or drawings Documented and approved instructions, procedures, and drawings are required to accompl!sh important to safety work These instructions, procedures, and drawings include, as appropriate, quant1tat1ve or qualitative acceptance criteria for determining that act1v1t1es have been satisfactorily accomplished Controls are established which ensure that instructions, procedures, and drawings are current and accurately reflect plant design and regulatory reqwrements Changes or dev1at1ons from established instructions, procedures or drawings for SSCs and other quality act1v1t1es that have current important to safety functions, require the same review and approval as the original document Instructions, procedures and drawings, including changes and dev1at1ons subJect to the SONGS DQAP, shall be mamta1ned and reviewed periodically as required by adm1rnstrat1ve procedures Administrative controls shall be established that provide the methods by which temporary changes can be made to procedures which are approved, including the des1gnat1on of persons authorized to approve such changes These changes shall be documented and, If appropriate, incorporated into the next rev1s1on of the affected procedure

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Documents comprising instructions, procedures, spec1ficat1ons, and drawings prepared by outside contractors for the performance of site act1v1t1es are reviewed and approved by the responsible SONGS' manager or designated representative 14

Document Control 6 O Document Control SCE establishes measures to control the issuance of documents, such as instructions, procedures, drawings and other document or records, including changes thereto, which prescribe act1v1t1es affecting quality These measures assure that documents, such as procedures, instructions and drawings, are available for use m quality act1v1t1es Written procedures shall defme the type of documents to which the document control system applies These procedures also define the process for controlling the preparation, review, approval, issuance, and d1stribut1on of documents affecting quality Documents and changes to documents that prescribe or verify act1v1t1es affecting quality shall be controlled m a manner that precludes the use of inappropriate or outdated documents The document control system procedures shall be established to 1dent1fy the current rev1s1on of instructions, procedures, spec1f1cat1ons, drawing and procurement documents Procedures and instructions shall assure that documents are reviewed by qualified personnel, other than the personnel who prepared the documents These procedures and instructions shall also assure that documents are approved for release by authorized personnel, distributed (as appropriate) to the location where the act1v1ty 1s being performed prior to the commencement of work, and utilized and adhered to when conducting act1v1tres The rev1ewmg organization shall have access to pertinent background data and 1nformat1on upon which to base their approval Changes to documents for SSCs that have current important to safety functions or other quality actrv1t1es shall be reviewed and approved by the same orgarnzat1on that performed the original review and approval unless SCE designates another responsible organization Minor changes to documents, such as inconsequential editorial corrections, shall not require that the revised documents receive the same review and approval as the original documents To avoid a possible om1ss1on of a required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a dec1s1on shall be clearly delineated Procedures, instructions and other documents, including rev1s1ons, which implement requirements of the SONGS DQAP, shall be reviewed and concurred with by Nuclear Oversight 15

'f Control of Purchased Materials, Equipment and Services 7 0 Control of Purchased Materials, Equipment and Services Control of purchased material, equipment, and services applres to SSCs and associated act1v1t1es that are designated as important to safety or other quality related act1v1tJes Supplier act1v1t1es that provide purchased material, equipment, and services shall be monitored as necessary to assure such items and services meet procurement document requirements These measures shall include prov1s1ons, as appropriate, for source evaluation and selection, obJect1ve evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and exammat1on of products upon delivery Procedures shall describe each organization's respons1b11it1es for the control of purchased material, equipment, and services, mcfudmg the interfaces between all affected orgarnzatrons Materials, equipment, and services shall meet the spec1f1ed technical and qualrty requirements Verification that a suppher can meet the specified technical and qualrty requirements shall be documented A Suppher's QA Program that sat1sf1es spec1f1ed qualrty requirements shall be listed on the SONGS Evaluated Supplrers List The SONGS Evaluated Supphers List shall be controlled The suppliers of calrbratron services for SONGS will be qualified to perform cahbrat1ons by fully sat1sfy1ng all regulatory requirements, spec1f1cally an approved Appendix B cahbrat1on program The effectiveness of contractors and supplier's QA program shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or service Suppher performance and compliance with procurement documents are monitored by source venf1cat1on, receipt inspection, or a combmat1on of the two Recervmg mspect1on shall verify by obJect1ve evidence the acceptab1lrty of ,terns m accordance with facility procedures Accepted items are appropriately marked, removed from the mspect1on area, and located 1r,i a controlled storage area until use Documentary evidence shall be retained at SONGS and shall be sufficient to 1dent1fy the spec1f1c requirements, such as codes, standards, or spec1f1cat1ons, met by the purchased material and equipment For the acquiring of services only, such as third-party inspection, engmeermg and consulting services, audrtmg and installation, repair, overhaul, or maintenance work, from supphers whose QA Program has not been reviewed or accepted, those suppliers may be used provided add1t1onal controls such as technical venf1cat1on of data produced, surveillance and/or audrt of the act1v1ty, or review of obJect1ve evidence are employed These add1t1onal controls shall be documented rn the request for services and approved by the appropriate level of management Due to the ehm1nat1on of all active safety related components at SONGS based on the decomm1ss1onrng status of the site, SCE will no longer perform Commercial Grade Ded1cat1on of parts or components If future needs for CGD arise, SONGS will use qual1f1ed contracted services with an approved and established CGD program Designated quality personnel or other personnel wrth appropriate quahfrcatrons are responsible for assuring source mspect1ons, surveys, or audits of suppliers are performed as necessary Documentation of acceptance shall be available prior to rnstallat1on or acceptance for use

/'

16

Identification and Control of Materials, Parts and Components 8 0 ldentif1cat1on and Control of Materials, Parts and Components SCE establishes measures for the 1dent1ficat1on and control of material, parts, and components, including partially fabricated assemblies, obtained for use m important to safety act1v1t1es necessary to prevent the use of incorrect or defective items SONGS shall establish a process for the 1dent1ficat1on and control of

,terns to ensure only accepted materials, parts and components are available for use in important to safety act1v1t1es Implementing procedures shall describe the orgarnzat1onal respons1b11it1es and controls m place at SONGS to assure that only correct and accepted items are utilized ldent1ficat1on 1s maintained either on the items or documents traceable to the items When such controls are requ1[ed, the following methods of 1dent1f1cat1on and control are to be ut1lrzed ldent1ficat1on such as batch, heat number, lot, serial number or part number 1s maintained from 1rnt1al receipt up to and including installation, and throughout the use of the items The 1dent1f1cat1on relates the item to the applicable design or other specification document when appropriate SONGS ut1lrzes physical 1dent1f1cat1on when possible Other means, including physical separation or procedural controls are ut1flzed when physical 1dent1f1cat1on 1s not practical Markings are applied using materials and methods that are clear, legible and do not detrimentally affect the function or service lrfe of the items that are marked Markings are transferred to each part of an 1dent1fied item when subd1v1ded Markings are not obliterated or masked by surface treatments or coatings unless alternative 1dent1ficat1on methods are established When codes, standards, or spec1ficat1ons require spec1f1c 1dent1f1cat1on or traceability requirements of an item, procedures shall describe how to maintain traceab1l1ty to spec1f1cat1on, grade of material, heat, batch, lot, part or serial number, or inspection / test or other record Prov1s1ons are made in procedures for maintenance or replacement of markings or 1dent1f1cat1on due to damage from handling or aging, excessive deterioration due to environmental exposure, and for updating records while in storage Items having limited calendar or operating life are controlled to preclude use after the shelf fife or operating fife has expired Verification of correct 1dent1ficat1on of material, parts, and components 1s accompflshed and documented prior to release for fabrication, assembly, shipment, construction, or installation and use The record of verrf1cat1on 1s maintained for the period provided in the governing procurement document, spec1f1cat1on, drawing, procedure, or instruction 17

Control of Special Processes 9 0 Control of Special Processes SCE establishes measures to assure that special processes, including welding, heat treatment, chemical cleaning and nondestructive testing, are controlled and accomplished by qual1f1ed personnel using approved written procedures in accordance with applicable codes, standards, spec1frcat1ons, criteria and other special requirements A special process 1s an act1v1ty, in which the quality of the result 1s highly dependent upon either a process variable or the skill and experience 9f the ind1v1dual performing the act1v1ty, and the spec1f1ed quality 1s d1ff1cult to verify by 1nspect1on and test after the process evolutions are completed Special processes shall be controlled by instructions, procedures, drawings, checklists, travelers, or other appropriate means Special process instructions shall include or reference procedure, personnel, and equrpment quallf1cat1on requirements and specific cond1t1ons where they are necessary for accomplishment of the process These cond1t1ons shall include proper equrpment, controlled parameters of the process, spec1f1ed environment, and any equipment calibration requirements Equipment used for special processes shall be maintained, stored, issued and qualified 1n accordance with applicable procedures and operated by qualified personnel The implementing procedures or instructions shall specify the acceptance criteria for special process control and ensure compliance with appllcable codes, standards, QA procedures and design specrf1cat1ons Records of personnel and equipment qualification and results of special processes shall be maintained m accordance with approved procedures 18

Inspection 10 0 Inspection SCE establishes and executes measures for inspection of important to safety act1v1t1es, by or for the org'i'mzat1on performing the activity, m order to verify conformance with approved instructions,

/

procedures, drawings, and spec1ficat1ons for accomplishing the act1v1t1es A comprehensive program of inspections shall be established and implemented to verify conformance of an item or act1v1ty with the spec1f1ed requirements and inspection methods used contained m approved inspection procedures, instructions, drawings and checklists Inspections will be performed by personnel qualified to validate that the act1v1ties meet this acceptance criteria spec1f1ed in applicable design documents Examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality recording evidence of completing and verifying a manufacturing, inspection, or test operation Inspections shall be performed by qualified 1nd1v1duals other than those who perform or directly supervise the act1v1ty being inspected While performing the inspection act1v1ty, inspectors functionally report to the Manager responsible for Nuclear Oversight Where mandatory hold or witness points are required for witness or rnspect1on act1v1t1es by designated personnel, the designated hold points shall be indicated rn appropriate documentation Work shall not progress beyond the point of an assigned hold point unless work 1s complete or consent to waive the hold point 1s given by the designated organization Inspections shall be planned ensuring characteristic to be inspected, methods used to perform the 1nspect1on and acceptance criteria are documented If inspection of processed or fabricated items 1s impractical monitoring of the processing method and equipment shall be utilized Process monitoring shall be performed by qualified personnel or a qual1f1ed automated process Inspection and process monitoring shall both be used 1f quality control 1s inadequate without both Final inspection shall include records review and examinations, measurements or tests to verify adequate quality measures were employed in the construction, fabrication or processing Final inspection results shall document the as-found cond1t1on including final acceptance I reJect1on criteria evaluation Unacceptable inspection results shall be evaluated and resolved in accordance with approved procedures Any modlf1cat1ons, repairs and replacements are re-inspected to the same standard or method to verify acceptability for items that have current important to safety functions Inspection records shall be maintained in accordance with approve procedures and processes 19

Test Control 11 0 Test Control SCE establishes measures for a test program to demonstrate that important to safety SSCs will perform satisfactorily in service Specifically, a program for testing shall be executed as necessary in order to demonstrate that important to safety SSCs will perform satisfactorily m service This program shall ensure that the necessary testing 1s 1dent1fied and performed at the appropriate time m accordance with approved test procedures which incorporate or reference the requirements, and acceptance cntena spec1f1ed within applicable design documents The test program shall include, as appropriate, proof tests prior to installation, preoperat1onal tests, and operational tests of SSCs The procedures that implement testing shall specify the appropriate prerequ1s1tes for the test (e g test personnel qualif1cat1on requirements, environmental cond1t1ons, spec1f1cat1on of instrumentation, safety measures, and completeness of tested ,tern), suff1c1ent instruction for the performance of the test, hold or witness points, acceptance/ rejection criteria and hm1ts, and the required test documentation Test results are evaluated by qualified personnel to determine compliance with estabhshed acceptance cntena Test results which do not meet acceptance criteria, shall be documented and evaluated in order to determine the appropriate corrective actions The test program shall require that mod1ficat1ons, repairs, and replacement of items that have current important to safety functions be tested, utilizing the same criteria as the original items to the extent apphcable to the current safety functions If alternative tests are required, the alternative tests must be reviewed and approved by the same organization that estabhshed the original requirements unless SCE designates another responsible organization Test records shall be maintained in accordance with approved procedures 20

Control of Measuring and Test Equipment 12 0 Control of Measuring and Test Equipment SCE estabhshes measures to assure that permanent plant instrumentation and tools, gages, instruments, and other measuring and test equrpment (M&TE), used m important to safety act1v1t1es, are controlled, cahbrated and adJusted m order to ma,ntam accuracy w1thm necessary hmrts Organizational respons1b11It1es shall be delineated for estabhshmg, implementing, and assuring the effectiveness of the calibration program for M&TE Reference standards used to determine the acceptability of items and act1v1t1es, shall be of appropriate type, and maintained within prescribed accuracy hm1ts, surtable range and accuracy in order to verify conformance to specified requirements Procedures for the control and calibration of permanently installed plant equipment shall specify 1dent1ficat1on requirements (labellng, codes, or other documented control system), the recall process and calibration process and frequencies (including documented pre-calibration checks) of the M&TE to nationally recognized standards Cahbrat1on methods are documented and performed by competent personnel in an environment that does not adversely affect the cahbrat,on The calibration procedures shall specify recording of as-found cond1t1ons and a means for determining which equipment shall be included m the cahbrat1on program M&TE used in the cahbrat1on of permanently installed plant equipment shall have ranges, prec1s1on, and accuracy equal to or greater than that to be calibrated and where this rs 1mpract1cal, the cognizant authority shall document rationale for accuracy Procedures for the control of M&TE used to calibrate permanent plant equipment and other important to safety act1v1t1es shall specify 1dent1f1cat1on requirements (labeling, codes, or other documented control system), the recall process and calibration process and frequencies (including documented pre-calibration checks) of the M&TE to nationally recognized standards Calibration methods are documented and performed by qualified personnel 1n an environment that does not adversely affect the cahbrat,on The cahbrat,on procedures shall delineate special controls where apphcable, for usage, handhng and storage required for environmental cond1t1ons such as temperature, hum1d1ty, cleanliness, or rad1at1on, m order to maintain accuracy and operating characteristics of the M&TE Cahbrat1on reference standards shall be based on nationally recognized standards or accepted values of natural physical constants Where national standards do not exist, the basis for the calibration shall be documented Special cahbrat,on and control measures are not required when normal commercial practices provide adequate accuracy (e g rulers, tape measures, level, and other such devices)

I M&TE rs calibrated at spec1f1ed intervals or 1mmed1ately before use on the basis of the ,tern's required accuracy, intended used, frequency of use, stability characteristics and other cond1t1ons affecting ,ts performance As-found condition of M&TE shall be recorded The cahbrat,on intervals, whether calendar or usage based, shall be pre-determined and to the extent practical, be consistent with the instrument manufacture's spec1f1ed repeatabrhty and/or the user's experience Cahbrat,on reference standards shall be based on traceability to nationally recognized standards or accepted values of natural physical constants Where national standards do not exist, M&TE ,s cahbrated against standards that have an accuracy of at least four (4) times the required accuracy of the equrpment being cahbrated, or when this rs not possible, have an accuracy that ensures the equipment being calibrated will be wrthm the required tolerance lnd1cat1on of exp1rat10n, 1ffeas1ble, will be displayed on or with the M&TE M&TE which rs found to be damaged, out-of-cahbrat1on or for which accuracy rs suspect, shall be tagged and segregated, and a special cahbrat1on performed M&TE found to be out of cahbrat,on shall be 21

evaluated and documented The acceptability shall be determined of items measured, inspected, or tested with a damaged or out of cahbrat1on device Records of M&TE calibration results (including as-found cond1t1ons} shall be maintained Add1t1onally, records of M&TE usage shall be maintained, so that measures may be executed to determine the vahdrty of previous measurements performed, and the acceptabrhty of items inspected or tested since the previous calibration when the M&TE was not suspect 22

Handling, Storage and Shipping 13 0 Handling, Storage and Sh1ppmg SCE estabhshes measures to control the handling, storage, sh1ppmg, cleaning and preservation of important to safety ,terns, material and equipment, m accordance with work and inspection instructions, m order to prevent damage or deterioration Measures and controls shall be established ensuring ,terns, material and equipment are handled, stored and shipped ,n accordance with design and procurement requirements, m a manner that will prevent damage, deter1orat1on or loss Special handling, preservation, storage, cleaning, packaging and sh1ppmg requirements are established and accomplished by trained personnel m accordance with approved procedures and 1nstruct1ons Special coverings, equipment and protective environments shall be spec1f1ed and provided where necessary for the protection of ,terns, material, and equipment from damage and deter1orat1on Special protective measures are spec1f1ed and provided when reqwred to maintain acceptable quality When special protective features are required, their existence shall be verified and monitored as necessary to assure that the special protective features continue to serve ,ts intended function Special handling tools and equipment shall be provided where necessary to ensure ,terns, material and equipment can be handled safely and without damage Markings or labeling shall be used to indicate the presence of special environments, or the need for special controls Prov1s1ons shall be described for the storage of chemicals,, reagents (mcludmg control of shelf hfe), lubricants and other combustible materials I

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Inspection, Test and Operating Status 14 0 Inspection, Test and Operatmg Status SCE establishes measures for indicating the status of important to safety items undergoing inspections and tests to prevent the umntent1onal bypass of required inspections or tests In add1t1on, SCE estabhshes measures for indicating the operating status of important to safety components and systems to prevent their inadvertent operation The methods used to indicate inspection, test and operatmg status includmg control of these status md1cators are prescribed by approved procedures The mspectlon, test and/or operatmg status of material, eqwpment and operating systems shall be readily apparent and verifiable The procedures used to indicate status shall provide means for assuring 1nspect1ons and tests are performed in the prescribed sequence, and acceptab1hty 1s md1cated in order to prevent inadvertent operation Items accepted and released are 1dentrfied to indicate their inspection status prior to forwarding the items to a controlled storage area or releasing the item for mstallat1on or further work Dev1at1ons from the required sequence shall be subJect to the same level of control as the generation of the ongmal sequence to prevent the bypassmg or omission of reqwred test or inspection The operating status of nonconforming, inoperable or malfunctromng SSCs shall be 1dent1f1ed and documented to prevent inadvertent operation A system of markings 1s used to identify the status of material, equipment, work, testing, and operations ldent1ficat1on of status may be by such means as, but not hm1ted to tags, stamps, markings, labels, log books, or travelers In some s1tuat1ons, records traceable to the item may be used The procedures implementing control of inspections test, and operating status shall delineate authority for the application, change, or removal of status 1dent1f1ers 24

Non-conforming Materials, Parts or Components 15 0 Nonconforming Materials, Parts or Components SCE establishes measures to control important to safety materials, parts and components which do not conform to requirements The measures used to control nonconforming materials, parts and components are described by approved procedures Items received, constructed for, or installed at SONGS that do not meet specific requirements of the procurement documentation, testing or inspection, are to be 1dent1fied as nonconforming items and not1f1cat1on 1s to be made to the affected organizations Dev1at1ons perta,nmg to a characteristic of a material, component, system, or structure, from those spec1f1ed m the design documents are treated as nonconformances Items 1dent1f1ed as nonconforming require a corrective action document to be written and the affected orgamzat1ons informed m accordance with approved procedures Nonconforming ,terns 1dent1f1ed through receipt mspectron are processed by Engineering through the use of a corrective action document Supplier nonconformances are processed by Nuclear Oversight through the use of corrective action documents When an item 1s 1dent1f1ed as bemg nonconforming, the ind1v1dual 1dent1fying the nonconformance 1rnt1ates a corrective action document and the ,tern rs reqwred to be 1dent1fied and marked as such 1n accordance with approved procedures Items marked as nonconforming are to be segregated from other mcomrng and accepted items and controlled to prevent release and inadvertent use Items that are 1mpract1cal to segregate (e g ,terns that have been constructed or installed) other precautions will be taken to ensure against the item's release and inadvertent use An engineering review process controlled by approved SONGS procedures rs to be used to evaluate nonconfor~ng items for reportabrlity and final d1spos1tmn Nonconforming ,terns discovered in installed items are evaluated to determine their operability and use 1s controlled until the final d1spos1tron of the nonconformance and associated d1spos1t1on 1mplementat1on Personnel performing the engineering evaluations shall have a demonstrated knowledge of the item and ,ts use, knowledge of the requirements and access to necessary background information Nonconforming ,terns are evaluated and either accepted to be used as-rs, reiected, repaired or reworked Procedures are established to ensure that

,terns that are accepted for use as-1s, cond1t1onal release, or repaired have a technical Just1ficat1on documented before the ,tern can be released for use Items that are designated for repair or rework are re-inspected upon completion of the repair or rework to ensure that the repaired or reworked item meets applicable requrrements, or there rs a technical 1ust1f1cat1on, prior to being released for use in the facility Nonconforrnance documentation rs maintained m an electronic storage medium for retention and storage in accordance with approved procedures I

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Corrective Action 16 0 Corrective Action SCE establishes measures to assure that cond1t1ons adverse to quality, such as failures, malfunctions, defic1enc1es, defective material and equipment, and nonconformances, are promptly 1dent1f1ed, evaluated and corrected usrng the Corrective Action Program For S1gnrf1cant Conditions Adverse to Quality, measures shall assure that the cause of the cond1t1on 1s determined, documented, and corrective action taken to preclude the likelihood of repet1t1on The timeliness of act1v1t1es and the level of management review shall be commensurate with the s1grnf1cance of the cond1t1on Each ind1v1dual working at SONGS 1s responsible for prompt 1dentrf1cat1on and reporting of any cond1t1ons that are adverse to quality by generating corrective action document Management at all levels encourages the 1dent1ficat1on of cond1t1ons that are adverse to quality and 1s committed to supporting an expeditious and obJectrve review of the issue with the completion of effective corrective actions to resolve the issue The Corrective Action Program and 1mplement1ng procedures will ensure prompt 1dent1f1cat1on, documentation, class1f1cat1on, evaluation, reporting requirements and correction of cond1t1ons adverse to quality The timeliness of corrective actions will be commensurate with the s1grnf1cance of the cond1t1on For S1gnrf1cant Cond1t1ons Adverse to Quality, procedures provide measures to determine the cause, implement corrective actions to preclude the likelihood of repet1t1on, and report the cause and corrective actions taken to appropriate levels of management Follow-up reviews shall be performed rn order to verrfy the 1mplementat1on and completion of corrective actions taken to assure effectiveness rn addressing the significant cond1t1ons adverse to quality Reports of cond1t1ons adverse to quality are analyzed to 1dent1fy pervasive trends in quality performance and are reported to appropriate levels of management for review and assessment 26

Quality Assurance Records 17 0 Quality Assurance Records SCE establishes measures to assure that required QA records are properly 1dentrf1ed, stored, maintained, retained, and retrievable to provide obJect1ve evidence that important to safety act1v1t1es are m compliance with the regulations and station implementing procedures Document Management Centers (DMC) are established by the Records Management organization at predetermined locations for storage, indexing, maintenance, and retention of records The management of records shall be accomplished through the use of a document control program utilizing approved procedures Documents 1dentrfied as records will be clean, and legible Records shall have traceability to items and act1v1t1es for important to safety work, and provide obJect1ve evidence of the work or activity These records shall be class1f1ed by the Records Management organization as hfe-t1me or non-permanent with a spec1f1ed retention period for non-permanent records Guidance on storage, retention and handling of records are also controlled in approved SONGS implementing procedures Access to records 1s controlled by authorized personnel who are designated by approved procedures Access to and retrieval of records, which are being maintained within schedule retention, 1s based on a need to know and 1s controlled by approved procedures Requirements and respons1b1lit1es for record transmittals, retention, and maintenance subsequent to completion of work are consistent with applicable codes, standards, procurement documents, Technical Spec1f1cat1ons, Certrf1cate of Compliance (C of C), and the DQAP The review, 1dent1f1cat1on, indexing, categorization and filing of records are accomplished in accordance with approved procedures These procedures include prov1s1ons for ready 1dentificat1on and retnevab1hty of stored documents Documents released for schedule retention by responsible organization are protected against deterioration or destruction from fire, flooding, theft, and environmental cond1t1ons such as temperature and hum1d1ty I

For the ISFSI, records pertaining to the design, fabrication, erection, testing, maintenance, and use of structures, systems, and components considered important to safety shall be maintained in the DMC or by the Certificate Holder until the NRC terminates the license or the C of C Requirements for the electronic storage of records will be m accordance with approved procedures Electronic QA records including backup copies are stored in two redundant electronic media storage systems at physically-independent electronic locations QA records m electronic format (e g pdfformat) may be filed and stored on the electronic media storage systems Selected QA records on other media (e g paper hardcop1es, m1crof1lm, DVDs) are maintained ma Permanent Records Storage Facility Records generated for SSCs that were once classified as safety-related or quality-related but no longer have a safety function do not need to be retained for purposes of the DQAP (but may need to be retained for other purposes, such as compliance with 10 CFR 50 75(g), other regulations, or the Technical Spec1f1cat1ons, or for business reasons) 27

Audits 18 0 Audits SCE establishes measures for a system of planned and documented audits in order to verify compliance with all aspects of the DQAP, and determine the effective 1mplementat1on of programs covered by the DQAP QA internal and supplier audits are planned and performed by Nuclear Oversight personnel trained in SONGS audit techniques utilizing SONGS approved written procedures and/or checklists External audits by licensees / ut1ht1es, Contractors, or Consultants acting for SCE to satisfy SCE audit requirements shall have the results evaluated by SCE to ensure acceptability Lead Auditors shall have experience, trammg or qualifications commensurate with the scope and complexity of their audit respons1b1lity lnd1v1duals performing audits shall not have direct respons1b1llt1es 1n the areas being audited Scheduling, preparation, personnel selection, performance, reporting, response, follow-up, and records management for audits are performed in accordance with written procedures Audit scopes and schedules are based upon the status of work progress, important to safety act1v1t1es being performed, regulatory requirements and prior experience with the organization being audited Internal audits for the SONGS Decomm1ss1onmg Quality Assurance Plan (DQAP) shall continue on a 24-month cycle with a 90 day grace perrod Grace periods are not intended to be used repet1t1vely, merely as an admm1strative convenience to extend audit intervals Therefore, the next performance due date 1s based on the originally scheduled date When spec1f1c audits are 1dent1f1ed as requiring a more frequent perrod1c1ty, for example, annual audits of Emergency Preparedness and Safeguards, the shortest period1c1ty will be adhered to for acbv1t1es covered by those specific regulatory requirements The frequency of internal audits will be prescribed by the plant implementing procedure which governs the conduct of QA audits An audit schedule shall be mamtamed and revised at least annually, to ensure that programs receive necessary audits to support regulatory compliance Add1t1onal audits may be added to the schedule to supplement audits of spec1f1c subjects when necessary to provide adequate coverage 1

External audits of suppliers providing important to safety materials, parts, equrpment or services are scheduled and performed based on the importance of the act1v1ty and to confirm 1mplementat1on of the supplier's QA Program at a frequency of not less than three (3) years with a 90 day grace perrod The supplier audit requirement shall not apply to standard off-the-shelf items and bulk commod1t1es where required quality can adequately be determined by receipt 1nspect1on or post-installation test Audit reports shall be prepared, reviewed, approved and d1strrbuted m accordance with approved procedures Results of audits are reviewed with the management of the organization audited durrng exit interviews and are documented m formal audit reports to SONGS management Responsible management m the areas audited shall implement the necessary corrective actions required to address defic1enc1es These actions are documented and reviewed period1cally and, 1f needed, re-exam med during re-audits of the subject area to verify def1c1ent areas have completed corrective actions Audit records mcludmg audit plans, checklists, audit reports, written replies, and the record of completion of corrective action shall be retained m accordance with proper 1mplementrng procedures 28

SONGS DQAP Revision 5 Appendix A: Organization Chart Nuclear Site Management Organization Chl,:fN,tle,r Off~'" ICNOf J

0:rtctot.

Ot!r.orncit.l\p.oni,.

ProjecU Gtnml Pblt;cr!r1 DemntmJsslOr\lr'C Nutlfars.fety 0.ffl!f;!lt

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()per.ill°"'&

r..1n.,g l Sewrilv 29

- - 7 Appendix B - Regulatory Requirements and Commitments Regulatory Commitments 1 10 CFR 50 Appendix B, Quality Assurance Cntena for Nuclear Power Plants and Fuel Processmg Plants 2 10 CFR 71 Subpart H, Quality Assurance for Packagmg and Transportation of Rad10active Matenal 3 10 CFR 72, Subpart G, Quaflty Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Rad10act1Ve Waste 4 Regulatory Guide 7 10, "Establishmg Quality Assurance Programs for Packagmg Used m the Transportat10n of Rad10active Matenal" (Rev1s1on 2 - March 2005), with exception to the annual audit frequency SONGS 1s on a 24-month audit frequency rn accordance with 1mplement1ng plant procedures 5 NUREG/CR-6407, Class1f1caflon of Transportation Packagmg and Dry Fuel Storage System Components Accordmg to Important to Safety (2/96) 6 Regulatory Guide 1 191, F,re Protection Program For Nuclear Power Plants Dunng Decomm1ss1onmg and Permanent Shutdown (May 2001) 7 NRG RIS 2000-18, Gwdance on Managmg Quality Assurance Records m Electromc Med,a Exception

• In lreu of adopting NIRMA Gu1dehnes TG-11-1998, TG15-1998, TG-16-1998, and TG21-1998, SONGS adopts TG11-2011, TG15-2011, TG16-2011, and TG21-2011 30

I ~

Appendix C* Quality Assurance Program for Fire Protection Program The fire protection program consists of components, procedures, and personnel utilized in carrying out act1v1t1es of fire protection including such things as fire prevention, detection, annunc1at1on, control, confinement, suppression, extingu1shment, admin1strat1ve procedures, inspection, testing, maintenance, and training With respect to the decomm1ss1oned Units 2 and 3, the NRG regulation for the Fire Protection Program 1s 10CFR50 48(f} Add1t1onally, NRG Regulatory Guide 1 191 (May 2001) "Fire Protection Program for Nuclear Power Plants during Decomm1ss1onmg and Permanent Shutdown" 1s used as guidance to implement this NRG Regulation The Fire Protection Program requirements apply to SSCs required to prevent fires, rapidly detect, control, and extinguish fires that do occur and could result in a rad1olog1cal hazard and, min1m1ze the nsk the public, environment, and plant personnel resulting from fires that could result in a release of rad1oact1ve materials Those fire protection systems/components required to protect safety related and important to safety SSCs are designated as Quality Class Ill-FPS per an engineering Q-L1st 31

""~--;.:-;-7rtrrc1>.r~~-v ,--r;:.7~r,-"' ... 1,

_, "'"'- l1 ~ _ ,,,. _[r...,.. ~ 4 J Appendix D* List of Acronyms ANSI American National Standards Institute ASME American Society of Mechanical Engineers CofC Cert1f1cate of Compltance DMC Document Management Center DQAP Decomm1ss1onmg Quality Assurance Program IMR Independent Management Review ISFSI Independent Spent Fuel Storage Installation ISR Independent Safety Reviewer M&TE Measuring & Test Equipment NOE Non-Destructive Exam 1nat1on NRC Nuclear Regulatory Comm1ss1on QA Quality Assurance RG Regulatory Guide SCE Southern Cahforrna Edison SONGS - San Onofre Nuclear Generat1nQ Station SSC Systems, Structures and Components 32

Appendix E* References Developmental References

1) ASME NQA-1-2008 / 2009 Addenda Qua/tty Assurance Reqwrements for Nuclear Fact/tty Appltcattons

2) NUREG 1757, Consoltdated Decomm1sst0nmg Gwdance, Volume 1 - Rev1s1on 2, Decomm1ss1onmg Process for Mater,a/ Licenses (

33

Appendix F Defimt1ons Basic component When applied to nuclear power reactors, any plant structure, system, component, or part thereof necessary to assure (1) The integrity of the reactor coolant pressure boundary, (11) The capability to shut down the reactor and mamtam 1t m a safe shutdown cond1t1on, or (111) The capability to prevent or m1t1gate the consequences of accidents which could result in potential offs1te exposures comparable to those referred to in§ 50 34(a) (1), § 50 67(b) (2), or§ 100 11 of 10 CR 50, as applicable Certificate holder (1 OCFR71)

A person who has been issued a cert1f1cate of compliance or other package approval by the NRC Cert1f1cate holder ( 10CFR72)

A person who has been issued a Certificate of Compliance by the Comm1ss1on for a spent fuel storage cask design Cert1f1cate of Compliance or C of C {10CFR71)

The cert1f1cate issued by the NRC under subpart D of 10 CFR 71, which approves the design of a package for the transportation of rad1oact1ve material Cert1f1cate of Compliance or CoC (10CFR72)

The cert1f1cate issued by the Comm1ssmn that approves the design of a spent fuel storage cask in accordance with the prov1s1ons of subpart L of 10CFR72 Decomm1ss1on To remove a facility or site safely from service and reduce residual rad1oact1v1ty to a level that permits (1) Release of the property for unrestricted use and termination of the license, or (2) Release of the property under restricted cond1t1ons and termination of the license Design bases (1 OCFR50)

Design bases means that information which 1dentlf1es the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design These values may be (1) restraints derived from generally accepted "state of the art" practices for ach1evmg functional goals, or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals Design bases (1 OCFR71)

Information which 1dent1f1es the spec1f1c functions to be performed by a structure, system, or component of a fac1hty, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design These values may be restraints derived from generally accepted "state of the art" practices for ach1evmg functional goals, or requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals Design bases (10CCR72)

Information that 1dent1fies the specific functions to be performed by a structure, system, or component of a fac1hty or of a spent fuel storage cask and the spec1f1c values or ranges of values chosen for controlling parameters as reference bounds for design These values may be restraints derived from generally accepted state-of-the-art practices for ach1evmg functional goals or requirements derived from analysis (based on calculation or experiments) of the effects of a postulated event under which a structure, 34

system, or component must meet its functional goals The values for controlling parameters for external events include (1) Estimates of severe natural events to be used for deriving design bases that will be based on cons1derat1on of historical data on the associated parameters, physical data, or analysis of upper limits of the physical processes involved, and (2) Estimates of severe external man-induced events to be used for deriving design bases that will be based on analysis of human act1v1ty in the region, taking into account the site characteristics and the risks associated with the event Dev1at1on A departure from the technical or quality assurance requirements defined in procurement documents, safety analysis report, construction permit, or other documents provided for bas1crcomponents installed in a facility subject to the regulations of this part Greater than Class C waste or GTCC waste Low-level radioactive waste that exceeds the concentration limits of rad1onuchdes establrshed for Class C waste in 10 CFR 61 55 Important to Safety SSCs which are designed, fabricated, erected and tested to qualrty standards commensurate with the importance of the safety functions to be performed Important to Safety SSC's include the following categories

• Safety Related -

Safety-related SSCs, as applrcable to SONGS, means those structures, systems and components that are relred upon to remain functional during and following design basis everits to assure the capability to prevent or m1t1gate the consequences of accidents which could result in potential offs1te exposures comparable to the applicable gu1delrne exposures set forth rn 10 CFR 100 11

• Non-Safety Related, Augmented Qualrty SSCs which are class1f1ed Non Safety-Related - Augmented Quality do not meet the definition of "Safety-Related" but are subject to select quality assurance requirements of 10 CFR 50, Appendix B rn a graded approach Important to Safety- ISFSI systems, structures, component cond1t1ons/funct1ons, or act1v1t1es required to store spent nuclear fuel safely Independent spent fuel storage installation or ISFSI A complex designed and constructed for the interim storage of spent nuclear fuel, solrd reactor-related GTCC waste, and other rad1oact1ve materials associated with spent fuel and reactor-related GTCC waste storage An ISFSI which 1s located on the site of another fac1lrty licensed under this part or a fac1lrty licensed under part 50 of this chapter and which shares common ut1ht1es and services with that fac1lrty or 1s physically connected with that other facility may still be considered independent Package The packaging together with its rad1oact1ve contents as presented for transport Packaging The assembly of components necessary to ensure compliance with the packaging requirements 10 CFR 71 It may consist of one or more receptacles, absorbent materials, spacing structures, thermal insulation, rad1at1on shielding, and devices for cooling or absorbing mechanical shocks The vehicle, tie down system, and aux1lrary equipment may be designated as part of the packaging 35

Permanent cessation of operat1on(s)

A cert1f1cat1on by a licensee to the NRC that 1t has permanently ceased or will permanently cease reactor operat1on(s), or a final legally effective order to permanently cease operat1on(s) has come into effect Procurement document A contract that defines the requirements which fac1llt1es or basic components must meet in order to be considered acceptable by the purchaser Quality Affecting Act1v1t1es that are performed in a SONGS program utilizing SONGS implementing procedures that are requrred by the DQAP These act1v1t1es shall be conducted under the SONGS QA program outlined in the DQAP and are sub1ect to Nuclear Oversight audit and surveillance These quality work items including but are not limited to following functions designing, purchasing, constructing, fabricating, handling, sh1pp1ng, storing, cleaning, preserving, erecting, installing, inspecting, testing, operating, maintaining, repamng, or modifying Applicable secs are defined within the SONGS Q-L1sts Spent fuel storage cask or cask All the components and systems associated with the container in which spent fuel or other rad1oact1ve materials associated with spent fuel are stored in an ISFSI Spent nuclear fuel or Spent fuel Fuel that has been withdrawn from a nuclear reactor following irrad1at1on, has undergone at least 1 year's decay since bemg used as a source of energy in a power reactor, and has not been chemically separated mto its constituent elements by reprocessing Structures, systems, and components important to safety (10CFR72)

Those features of the ISFSI, and spent fuel storage cask whose functions are (1) to maintain the cond1t1ons required to store spent fuel, high-level rad1oact1ve waste, or reactor related GTCC waste safely, (2) To prevent damage to the spent fuel, the high-level rad1oact1ve waste, or reactor-related GTCC waste container during handling and storage, or (3) To provide reasonable assurance that spent fuel, high-level rad1oact1ve waste, or reactor-related GTCC waste can be received, handled, packaged, stored, and retrieved without undue nsk to the health and safety of the public 36

Appendix G Admmistrat1ve Controls INDEPENDENT REVIEWS Nuclear Oversight Board (NOB)

The NOB serves the Chief Nuclear Officer (CNO) with an independent overview of selected SONGS decomm1ss1ornng acttv1t1es, placing particular emphasis on those act1v1t1es which affect the safe decomm1ss1ornng of the facility and changes to the SONGS ISFSI, including the protection of the public and the environment The Nuclear Oversight Board (NOB) functmns in an advisory capacity Details regarding the membership and quahf1cat1ons, schedule of meetings, scope and authority are contained in implementing procedures Ons1te Review Committee (OSRC)

The OSRC ensures 1mplementat1on of the requirements of the Urnt 1 Technical Spec1ficat1on Section D 6 6 1 and serves the CNO with ons1te review of the Urnt 2 & 3 decomm1ss1ornng act1v1t1es and ISFSI operation as necessary on matters of Nuclear Safety OSRC details regarding the membership, quorum, agenda and schedule of meetings are contained m implementing procedures 37

Appendix H. DQAP Implementing Programs/Procedures DQAP QA Criterion Title Implementing Programs and Procedures Section S0123-Vll-20 Rad1at1on Protection Proaram Authorities and Duties of Nuclear S0123-Xll-1 3 Overs1aht Personnel Nuclear Oversight Board Functions and S0123-Xll-18 17 Resoons1b1htles Emergency Preparedness Program S0123-VIII-ADMIN-1 Maintenance Emergency Preparedness Program S0123-VIII-ADMIN-2 Trainina Emergency Preparedness Program Drill S0123-VIII-ADMIN-3 Develooment and Evaluation S0123-VIII-ADMIN-4 10CF50 54 (q) Screenina and Evaluations S0123-VIII-ER0-1 PDEP Standards and Expectations 10 Organization 1 Shift Manager I Emergency Director S0123-VIII-ER0-2 Checklist Rad1at1on Protection Coordinator S0123-VIII-ER0-5 Checklist S0123-VIII-ER0-6 Dose Assessment S0123-FP-1 Fire Protection Proaram S0123-MA-1 Maintenance D1v1sion S0123-CH-1 Chem1strv Proaram Special Nuclear Material Accountability S0123-X-1 7 (Physical Inventory)

S0123-XV-60 1 Ons1te Review Committee (OSRC)

S0123-SE-1 Securitv S0123-Xll-2 3 Stoo Work Procedure S0123-XV-SA-1 Self-Assessment Process S0123-0DCM SONGS Offs1te Dose Calculation Manual Authorities and Duties of Nuclear S0123-Xll-1 3 Oversight Personnel Personnel Qualrf1cat1on Program for the S0123-XV-33 San Onofre Oraarnzat1on Quality Assurance S0123-XV-5 3 Maintenance Rule Proaram 20 Program Site Housekeeping and Cleanness S0123-HK-1 Control Proaram Rad1olog1cal Environmental Monitoring S0123-RM-1 Proqram S023-XXI-TRN Conduct of Tra,rnna Changing the DQAP and UFSAR Chapter S0123-Xll-2 26 17 Engineering Design Change Process -

S0123-XXIV-101 NECPS 30 Design Control S0123-CC-2 Conf1qurat1on Manaaement Program

\ S0123-XV-44 10 CFR 50 59 and 72 48 Proaram Procurement Document 40 Control S0123-XXXll-2 1 Procurement Technical Document Control 38

Procedure and Instruction Format and Instructions, Procedures S0123-XV-109 5 0 Content and Drawings S0123-XV-HU-3 Human Performance Program Corporate Documentation Management S0123-Vl-29 (COM-SONGS) Record Process 60 Document Control Management Review/Approval of Procedures and S0123-Xll-5 6 Instructions S0123-MS-1 Material Support ProQram Control of Purchased S0123-Xll-1819 Supplier Audits 70 Matenal, Equipment and S0123-Xll-20 4 Rece1vmQ Inspection Services S0123-XV-93 Contractor Controls Source Ver1f1cat1on or surveillance S0123-Xll-7 12 Act1v1t1es ldentlf1cat1on and Control 80 of Matenal, Parts and S0123-Xl-3 2 Storage of Quality-Affecting Items Components Control of Special S0123-Xll-18 19 Supplier Audits 90 Processes S0123-MA-1 Maintenance D1v1s1on S0123-MA-1 Maintenance D1v1s1on 10 0 Control of Inspection Nuclear Oversight Planning and S0123-Xll-10 22 Inspection S023-XX-37 Work Management Process Technical Spec1f1cat1on/LCS S0123-TS-1 Adm1rnstrat1ve Controls (Section 5) 11 0 Test Control Program Technical Spec1f1cation Licensee S0123-TS-2 Controlled Spec1ficat1on Surveillance Reqwrements S0123-CL-1 Calibration ProQram Control of Measunng and 12 0 S0123-Vll-20 Rad1at1on Protection Program Test Equipment S0123-MT-1 Measunng And Test Equipment Program Handling, Storage and 13 0 S0123-Xl-3 2 Storage of Quality-Affecting Items Shipping Inspection, Test and S0123-Xll-20 4 Receiving Inspection 14 0 Operating Status S0123-XX-5 Work Author1zat1on and Taaaing Nonconforming Materials, S0123-XV-50 Corrective Action ProQram 15 0 Parts and Components S0123-XXXll-2 1 Procurement Technical Document Control 16 0 Corrective Actron S0123-XV-50 Corrective Action Program Corporate Documentation Management S0123-Vl-29 (COM-SONGS) Record Process Quality Assurance 17 0 Management Records Enterprise IT Software Quality Assurance S0123-XV-771 and System Controls for SONGS S0123-Xll-18 1 Audit ProQram 18 0 Audits Authorities And Duties of Nuclear S0123-Xll-1 3 Oversight Personnel 39

Attachment 2 Summary of Changes m the Decomm1ss1onmg Quahty Assurance Program, Rev1s1ons 4 and 5

Summary of Changes to the Decomm1ss1onmg Quality Assurance Program (DQAP)

Rev1s1ons 4 & 5 DQAP section Change(s) Bas1s/Just1f1cat1on Reduction? Y/N UFSAR Chapter 17, Quality Assurance Program, was replaced by the Decomm1ss1oning Quality Assurance Plan (DQAP) on August 10, 2015 when SONGS received approval by the NRC The biennial submittal of the DQAP was provided to the NRC in August of 2017 This document represents the changes since the last biennial submittal in 2017 Rev1s1on 4 - Organizational changes 1 0 Organization p 6 Changed reporting structure for Admin1strat1ve changes to reflect N CNO organizational changes due to current state of decomm1ss1oning organization All previously accepted commitments / respons1b1ht1es retained 1 0 Organization - Changed reporting structure and Adm1rnstrat1ve changes to reflect N Station Management d1v1s1on of respons1b1ht1es for orgarnzat1onal changes due to current state of p 7 Manager responsible for decomm1ss1ornng organization All previously Engineering ISFSI engineering will accepted commitments / respons1b1ht1es be responsible for QA program retained 1mplementat1on for systems engineering, engineering programs, design and nuclear fuel management Engineering Oversight will have design authority 1 0 Organization Changed reporting structure for Admin1strat1ve changes to reflect N Station Management Manager responsible for Rad1at1on orgarnzat1onal changes due to current state of p 7 Protection who now reports through decomm1ss1oning organization All previously the Manager responsible for accepted commitments / respons1b1ht1es Decomm1ss1oning retained 1

Summary of Changes to the Decomm1ss1onmg Quality Assurance Program (DQAP)

Rev1s1ons 4 & 5 1 O Organization Incorporated 'Emergency Editorial change to relocate appropriate N Station Management Preparedness' (relocated from page respons1b1ht1es All previously accepted p 7 8) and 'ensures all act1v1t1es are commitments / respons1b1ht1es retained consistent with QA program requirements ' into respons1b1ht1es for the Plant Manager 1 0 Organization Removed redundant 1nformat1on Admin1strat1ve changes to remove redundant N Station Management regarding the line organizations 1nformat1on regarding reporting of line p 8 which report to the Plant Manager organizations to the Plant manager All previously defined on page 7 previously accepted commitments /

respons1b1ht1es retained 15 0 Nonconforming Changed noun name - 'Action Editorial change to replace noun name with N Materials, Parts or Request' to 'corrective action more generic nomenclature for corrective Components and document' action documents 16 O Corrective Action p 26 & 27 Appendix A Updated Organization Chart to Adm1rnstrat1ve changes to reflect N Organization Chart reflect changes due to orgarnzat1onal changes due to current state of p 29 decomm1ss1oning restructuring decomm1ss1ornng organization All previously accepted commitments / respons1b1ht1es retained Appendix H DQAP Added Contractor Oversight Adm1rnstrat1ve add1t1on of Contractor Oversight N Implementing procedure to DQAP Implementing procedure Programs/Procedures Procedures 11st within 7 0, Control of p 39 Purchased Material, Equipment and Services 2

Summary of Changes to the Decomm1ss1onmg Quality Assurance Program (DQAP)

Rev1s1ons 4 & 5 Rev1s1on S-Adm1rnstrat1ve changes (orgarnzat1onal changes and Appendix H implementing procedure combining) 1 0 Organization p 6 Changed reporting structure for S1mplify1ng the VP title has no impact on the N CNO to reflect SCE President who DQAP since the CNO remains as the ultimately 1s responsible Removed responsible 1nd1v1dual for the 1mplementat1on

'reports through the Senior Vice of the DQAP President Power Supply' Adm1rnstrat1ve changes to reflect orgarnzat1onal changes for alignment with the current state of the decomm1ss1ornng organization All previously accepted commitments / respons1b11it1es retained p7 Separated Decomm1ss1ornng Adm1rnstrat1ve changes to reflect an add1t1on manager respons1b11it1es into two to executive management ISFSI Engineering

'Decomm1ss1ornng Projects' and included within Plant Manager reporting chain

'Decomm1ss1ornng Oversight' All previously accepted commitments /

management respons1b11it1es retained Added ISFSI Engineering to the Plant Manager reporting chain 2 0 Quality Assurance Added 10CFR71 106 to the Adm1rnstrat1ve add1t1on to align with the N program p 9 paragraph which describes how requirements contained 1n 10CFR71 106 for changes to the DQAP will be changes to the Quality Assurance Plan implemented All previously accepted commitments /

respons1b11it1es retained Appendix A p 29 Changed orgarnzat1onal chart to Change to the orgarnzat1onal chart to add an N reflect the following add1t1onal layer of executive management

• add1t1on of Adm1rnstrat1ve change to reflect orgarnzat1onal

'Decomm1ss1ornng Projects' changes for alignment with the current state of Director the decomm1ss1ornng organization

• Separated Corrective Action All previously accepted commitments I Program from Maintenance respons1b11it1es retained as a result of restructuring

• Removed Work Control from title as program 1s controlled by Maintenance 3

Summary of Changes to the Decomm1ss1onmg Quality Assurance Program (DQAP)

Rev1s1ons 4 & 5 Appendix H DQAP Procedures have been combined or Adm1nrstrat1ve changes due to the combining N Implementing added The following changes have of procedures These changes have been Programs/Procedures been made to the implementing reviewed by Nuclear Oversight personnel as p 38-39 procedures listed in Appendix H* required by section 6 0 Document Control of

• S0123-Xl-8, "Supplier the DQAP to ensure regulatory requirements Evaluation and Qualtf1cat1on" have been retained _

was voided Venf1cat1on by All previously accepted commitments /

Engineering and NO respons1b11it1es retained determined requirements retained w1th1n S0123-Xll-18 19 and S0123-XXXll-2 1 to process voiding of Xl-8

• S0123-Vl-28 was combined and superseded with S0123-Vl-29

• S0123-XV-77 and S0123-XV-77 1 both contain requirements for software QA documentation retention 1n eDMRM (records repository) and NIRMA commitment (NIRMA TG16-2011) S0123-XV-77 1 WIii be credited as the implementing procedure for software purchased or developed and used at SONGS The following QA implementing Review of rev1s1on 5 revealed four add1t1onal N procedures have been added QA procedures should be listed in Appendix

• Section 1 - S0123-Xll-2 3, H Procedural add1t1ons are considered Stop Work Procedure admin1strat1ve for alignment with DQAP Procedure rev1s1ons were previously approved 1

by NOD staff 4

Summary of Changes to the Decomm1ss1onmg Quality Assurance Program (DQAP)

Rev1s1ons 4 & 5

• Section 2 - S0123-Xll-2 26, These add1t1ons-are n9t considered reduction Changmg the DQAP and m commitment to the previously accepted QA UFSAR Chapter 17 plan All previously accepted commitments /

• Section 6 - S0123-Xll-5 6, respons1b1ht1es retained Rev,ew/Approval of Procedures and Instructions

\

• Section 7 -S0123-Xll-7 12, Source Venflcat,on or Surveillance Act1v1tJes '~

5