Text

Smud, Revised Rancho Seco Quality Manual Request for Approval
	ML21230A269
Person / Time
Site:	07200011, 07100489
Issue date:	08/02/2021
From:	Gacke B; Sacramento Municipal Utility District (SMUD)
To:	Shana Helton; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Division of Fuel Management
References
	DPG 21-104
	Download: ML21230A269 (127)
	v • d • e

Powering forward. Together.

DPG 21-104 August 2, 2021 Attn: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket 72-11 Rancho Seco Independent Spent Fuel Storage Installation Renewed License SNM-2510 Docket 71-0489 Rancho Seco Quality Assurance Program Approval for Radioactive Material Packages QA Program Approval No. 71-0489 REVISED RANCHO SECO QUALITY MANUAL REQUEST FOR APPROVAL Attention: Shana Helton In accordance with 10 CFR 72.140(d), 10 CFR71.106(a)(1) and NRC Information Notice 2002-35: Changes To 10 CFR Parts 71 and 72 Quality Assurance Programs, the Sacramento Municipal Utility District (SMUD) is submitting a revision to the previously accepted Rancho Seco Quality Manual for approval. Specifically, we are submitting RSLBD-010, Rancho Seco Quality Manual (RSQM), Revision 5, which reflects title changes associated with a corporate reorganization of SMUD's executive management. RSQM, Revision *5 will not go into effect until such time as this request is approved by the NRC.

Attachment 1 discusses the proposed changes and the justification for making those changes. Attachment 2 provides al'clean" copy of the proposed RSQM, Revision 5. Attachment 3 includes a "red line-strikeout" version of the proposed revisions to the RSQM.

If you or members of your staff have any questions requiring additional information or clarification, please contact me at (916) 732-4812.

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Sincerely, Brad Gacke Manager, Rancho Seco Assets Attachments (3) cc w/attachment:

Scott Morris; NRC Region IV William "Chris" Allen RIC: 1F.099

Attachment 1 Proposed Changes to the RSQM Based on 10 CFR 72.140(d), 10 CFR 71.106 (a)(1) and NRC Information Notice 2002-35: Changes To 10 CFR Parts 71 and 72 Quality Assurance Programs, the following changes to the RSQM require prior NRC approval:

1. Quality Assurance Policy Item Ill is being revised to reflect the change in the executive delegating the responsibility and authority for developing and executing the Quality Assurance Policy to the Director, Power Generation.

The Chief Zero Carbon Officer is the new executive who makes this delegation, replacing the Chief Energy Delivery Officer.

2. Criterion I, Section 4.1 is being changed to reflect a position title change in the Chief Executive with corporate responsibility for overall safe operation of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI). The title changed from General Manager to Chief Executive Officer & General Manager.

3. Criterion I, Section 4.1 is being changed to reflect the change in the executive with corporate responsibility for overall safe operation of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI). The Chief Zero Carbon Officer is the new executive with this responsibility. A clarification is also added that the Director, Power Generation (to whom the Manager, Rancho Seco Assets reports) reports to the Chief Zero Carbon Officer.

The Chief Zero Carbon Officer is the new executive designated by the Chief Executive Officer & General Manager (CEO & GM) to have corporate responsibility for overall safe operation of the Rancho Seco ISFSI and to take any measures needed to ensure acceptable performance of the staff in providing long term monitoring of the spent fuel. The Chief Zero Carbon Officer is an executive of equivalent level as the Chief Energy Delivery Officer in the current Rancho Seco Quality Assurance Program, reports directly to SMUD's CEO & GM, and has sufficient authority to fulfill the responsibilities assigned by the CEO & GM.

These changes do not represent a reduction in commitment in the Rancho Seco Quality Assurance Program. The changes simply modify position titles to align with the 2021 SMUD organizational re-alignment.

Attachment 2 Proposed RSQM, Revision 5

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 1 OF 61 EFFECTIVE DATE: Upon NRC Approval REASON FOR CHANGE:

Update to reflect title change from General Manager to Chief Executive Officer & General Manager

Update to reflect the 2021 SMUD corporate reorganization. The responsibility for the Rancho Seco ISFSI was moved from the Chief Energy Delivery Officer to the Chief Zero Carbon Officer.

REVISION

SUMMARY

Quality Assurance Policy Item Ill changed from the Chief Energy Delivery Officer to the Chief Zero Carbon Officer.

Section 4.1 changed position title from the General Manager to Chief Executive Officer & General Manager.

Section 4.1 changed position from the Chief Energy Delivery Officer to the Chief Zero Carbon Officer.

Section 4.1 added clarification that the Director, Power Generation reports to the Chief Zero Carbon Officer.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION;. 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 2 OF 61

QUALITY'ASSURANCE POLICY The Sacramento Municipal Utility District's (SMUD) policy regarding quality assurance at the Rancho Seco ISFSI, licensed and operated in accordance with 10 CFR 72, is as follows:

I. Organizations involved in QA Important to Safety activities and the other Program Activity Areas specified in Rancho Seco Quality Manual (RSQM)Section II, Attachment 11-1, shall be structured, managed, and operated to provide compliance with the RSQM.

Procedures shall be prepared that implement the activities required to safely operate the Rancho Seco ISFSI and achieve the following objectives: *

a. Comply with government regulations and established SMUD management policies, applying a systematic, disciplined, and uniform approach to quality assurance.

b. Provide facilities designed, modified, constructed, tested and operated in accordance with specified requirements with reasonable assurance that failures or malfunctions will not cause undue risk to public health and safety.

c. Ensure prompt identification and resolution of actual and potential problems in design, procurement, construction, testing, operations, maintenance, and modification of the structures, systems, and components associated with QA Important to Safety activities or other applicable Program Activity Areas specified in RSQM Section II, Attachment 11-1 ..

II. The RSQM and implementing procedures constitute the Rancho Seco Quality Assurance Program (QAP). The QAP applies to activities, plans, and programs affecting the operation and the quality of structures, systems, components, and services addressed in the RSQM. The QAP will be implemented by organizations responsible for achieving and verifying quality assurance.

Ill. The Chief Zero Carbon Officer has delegated the responsibility and authority for developing and executing the QAP to the Director, Power Generation. Any conflicts or questions involving interpretation of the requirements or resulting .from the .

implementation of the QAP must be referred to the Director, Power Generation.

Ross Gould Lora Anguay Director, Power Generation Chief Zero Carbon Officer

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLB,D-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 3 OF 61 Table of Contents I. ORGANIZATION.*.......................................................................................................:. 7 1.0 PURPOSE ..................................... :......................................................................7 2.0 REFERENCE DOCUMENTS .................................................... ~ ....... : .................... 7

3.0 POLICY ........*................... ,....... ~ .............. *...............*.....*........ *...*........................ ;........ 7.

4.0 ORGANIZATION AND REQUIREMENTS ............... :...... :....._.................................. 8 5.0 GENERAL RESPONSIBILITIES ........................................................................... 9 II. QUALITY ASSURANCE PROGRAM ........................................ ~ .. ;........................... 10 1.0 PURPOSE .......................................................................................................... 10

2.0 REFERENCES

.................................................................................................... 10 3.0 POLICY ............................................... ,............................................................... 10 4.0 GENERAL-REQUIREMENTS ................................ ,............................................ 10 5.0 RESPONSIBILITIES ............................... .,............................................................. 12 6.0 ATTACHMENTS ......................*................ :.......................................................... 12 Ill. DESIGN CONTROL .........................................................*......................................... 17 1.0 PURPOSE ............................................... :....... :....................................*............... 17

2.0 REFERENCES

................................................................................. :.................. 17 3.0 POLICY ........*........................................................................................................ 17 4.0 4.0 GENERAL REQUIREMENTS ......................... : .. *............................................ 17 5.0 RESPONSIBILITIES ........................................................................................... 19 IV. PROCUREMENT DOCUMENT CONTROL .............................................................21 1.0 PURPOSE ................... *................. .-.....................................................................21 2.0 REFERENCE DOCUMENTS ..............................................................................21 3.0 POLICY ...................................................................-.............. *.. .- ........................... 21 4.0 GENERAL REQUIREMENTS .............................................................................21 5.0 RESPONSIBILITIES ...........................................................................................23 V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS ............................................. 24 1.0 PURPOSE ......... :*:~ ..........*.... ;................................ :.,..'.. :.*.: ....................................... 24 2.0 REFERENCE DOCUMEN'tS .. .':'... .' ......................................................................24 3.0 POLICY .........................................................................................,..................... 24

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE4.OF 61 4.0 GENERAL REQUIREMENTS ............................................................................. 24 5.0 RESPONSIBILITIES ...........................................................................................24 VI. DOCUMENT CONTROL ...................................................................*......................26 1.0 PURPOSE ..........................................................................................................26 2.0 REFERENCE DOCUMENTS ............................................................................ .-.26 3.0 POLICY ...............................................................................................................26 4.0 GENERAL REQUIREMENTS ..............................................................................26 5.0 RESPONSIBILITIES ...........................................................................................27 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES .......... 28 1.0 PURPOSE .........................................................................................................:28 2.0 REFERENCE DOCUMENTS ..... ,........................................................................28 3.0 POLICY ...............................................................................................................28 4.0 GENERAL REQUIREMENTS ...................................................... ., ..................... 28 5.0 RESPONSIBILITIES ...........................................................................................29 VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, & COMPONENTS

... ********************************************** ......................................................................................31 1.0 PURPOSE ...........................................................................................................31 2.0 REFERENCE DOCUMENTS ......................................................................... ,.... 31 3.0 POLICY ...............................................................................................................31 4.0 GENERAL REQUIREMENTS ............................................................................. 31 5.0 RESPONSIBILITIES ...........................................................................................32 IX. CONTROL OF SPECIAL PROCESSES ..................................................................33 1.0 PURPOSE ..........................................................................................................33 2.0 REFERENCE DOCUMENTS .............................................................................. 33 3.0 POLICY ...............................................................................................................33 4.0 GENERAL REQUIREMENTS ............................................................................. 33 5.0 RESPONSIBILITIES *.************************ .................................................................. 33 X. INSPECTION ...........................................................................................................35 1.0 PURPOSE ............................................................... ,.......................................... 35 2.0 REFERENCE DOCUMENTS ........................................................................... :.. 35 3.0 POLICY ***********************************************************.*******************,*********************************35

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL *. *PAGE 5 OF 61 4.0 GENERAL REQUIREMENTS ............................ *....................... :.. *..... : ... :.. :...... :.. :35 5.0 RESPONSIBILITIES ........................................................................................ :.. 36 XI. TEST CONTROL......................................................................................................38 1.0 PURPOSE ...........................................................................................................38 2.0 REFERENCE DOCUMENTS ..............................................................................38 3.0 POLICY*..................................-......................................*........................ '. ................ 38 4.0 GENERAL REQUIREMENTS ................................ :.. ~ .......... ,.:.. : ....... '. ...... :.......... 38 5.0 RESPONSIBILITIES .................................................... .'.,.*:.;... '. .. :..... *.. *.............. *..... 39 XII. CONTROL OF MEASURING AND TEST EQUIPMENT ......... ~ ...............................40 1.0 PURPOSE ....................................................................................... :............... : ... 40 2.0 REFERENCE DOCUMENTS ................................................................... :......... .40 3.0 POLICY ............ :............................................................*........................................ 40 4.0 GENERAL REQUIREMENTS ...................................... ,........................... ,......... .40 5.0 RESPONSIBILITIES .......................*......................................................*............. 40 XIII. HANDLING, STORAGE, AND SHIPPING ..*:..........................................................42 1.0 PURPOSE ...................................*.......................................................................42 2.0 REFERENCE DOCUMENTS ............................................................................. .42 ;

3.0 POLICY ...............................................................................................................42 4.0 GENERAL REQUIREMENTS .............................................................................42 5.0 RESPONSIBILITIES ...........................................................................................42 XIV. INSPECTION, TEST, AND OPERATING STATUS ...................................... :........ 44 1.0 PURPOSE .......*.......................................................... :........................................44 2.0 REFERENCE DOCUMENTS ............................................................................. .44 3.0 POLICY ..........................................................................*..................................... 44 4.0 GENERAL REQUIREMENTS ............................................................................ .44 5.0 RESPONSIBILITIES ....................*.......................................................................44 XV. NONCONFORMING MATERIALS, PARTS, OR COMPONENTS ......................... 46 1.0 PURPOSE ..................................... :....................................................................46 2.0 REFERENCED DOCUMENTS .... :...................................................................... .46

. 3.0 POLICY ...................... :......................................... .' ..............................................46

. 4.0 GENERAL REQUIREMENTS ............................................................................. .46

RANCHO SECO"LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 6 OF 61 5.0 RESPONSIBILITIES ...........................................................................................46 XVI. CORRECTIVE ACTION ****************:*.**************************.*********************************************48 1.0 PURPOSE ...................................*:.*: ....................................................................48 2.0 REFERENCE DOCUMENTS ............................................................................. .48 3.0 POLICY ..........................*.................................... ,................................................48 4.0 GENERAL REQUIREMENTS ............................................................................ .48 5.0 RESPONSIBILITIES ........................................................................ ,.... *.............. 48 XVII. QUALITY ASSURANCE RECORDS ....................................................................50 1.0 PURPOSE ..........................................................................................................50 2.0 REFERENCE DOCUMENTS ..............................................................................50 3.0 POLICY .............................*.................................................................................. 50 4.0 GENERAL REQUIREMENTS .............................................................................50 5.0 RESPONSIBILITIES .................................................... ,...................................... 51 XVIII. AUDITS ..............................................:.................................................................52 1.0 PURPOSE ..........................................................................................................52 2.0 REFERENCE DOCUMENTS .................... :......................................................... 52 3.0 POLICY ...............................................*................................................................ q2 4.0 GENERAL REQUIREMENTS ................................................................. :........... 52 5.0 RESPONSIBILITIES .*................................................................ ,......... :............... 53 6.0 AUDITS AND AUDIT FREQUENCIES ...................................... :......................... 53 APPENDIX A ..........................................................................................;...................... 55

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 7 OF 61 I. ORGANIZATION 1.0 PURPOSE This section describes the Sacramento Municipal Utility District (SMUD) organization and personnel responsible for establishing, implementing, and verifying the Quality Assurance Program (QAP) at the Rancho Seco ISFSI licensed under 10 CFR Part 72.

2.0 REFERENCE DOCUMENTS 2.1 Rancho Seco Quality Manual, Appendix A 2.2 10 CFR 71.103, Quality Assurance Organization 2.3 10 CFR 72.142, Quality Assurance Organization 3.0 POLICY 3.1 The establishment and implementation of the Rancho Seco QAP, which is comprised of this Rancho Seco Quality Manual (RSQM) and implementing procedures, shall be SMUD's responsibility. Some QAP functions may be delegated to other SMUD approved external organizations, but overall responsibility for the QAP remains with SMUD.

3.2 Definitive lines of authority, responsibility, and communication shall be established for those organizations involved in the QAP.

3.3 The Power Generation personnel assigned to perform quality functions at the Rancho Seco ISFSI have defined responsibilities and organizational freedom to identify problems that affect quality; to initiate, recommend, or provide solutions; and to verify implementation of solutions. They have the authority te initiate action to stop unsatisfactory work pending implementation of necessary corrective action to bring the unsatisfactory conditions into conformance.

3.4 The organizational structure and functional responsibility assignments shall be such that attainment of program objectives is accomplished by individuals or groups who inspect, examine, audit or otherwise verify conformance to established requirements, and who are independent of the individuals or groups who performed the original activity.

RANCHO SECO LICENSING BASIS DOGUMENT **.NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGES OF 61 4.0 ORGANIZATION AND REQUIREMENTS 4.1 The position of Chief Executive Officer & General Manager (CEO & GM) through the Chief Zero Carbon Officer shall have corporate responsibility for overall safe operation of the Rancho Seco ISFSI and shall take any measures needed to ensure acceptable performance of the staff in providing long term monitoring of the spent nuclear fuel. The Director, Power Generation reports to the Chief Zero Carbon Officer.

4.2 The Man~ger, Rancho Seco Assets reports directly to the Director, Power Generation. The Manager, Rancho Seco Assets ensures that the Rancho Seco ISFSL is properly staffed and adequately budgeted to ensure staff can safely carry out their responsibilities.

The Manager, Rancho Seco Assets is responsible for the safe and reliable operation of the Rancho Seco ISFSI, pursuant to 10 CFR Part 72. The Manager, Rancho Seco Assets has the responsibility and authority to implement the QAP and ensure optimum quality performance of the Rancho Seco ISFSI.

The Manager, Rancho Seco Assets shall maintain continuing involvement in quality matters and shaH.assess the scope, status, implementation, and effectiveness of the QAP through the review of Quality Assurance Audits and Surveillances.

4.3 The Program Manager, Regulatory Compliance - Power Generation is responsible for the Rancho Seco nuclear audit program. The Regulatory Compliance - Power Generation group is independent from operating pressures or other lines of authority, and ensures an active QAP is implemented at the Rancho Seco ISFSI in accordance with regulatory requirements. The Regulatory Compliance - Power Generation group has the authority to take any issue concerning the quality of operations at the Rancho Seco ISFSI to the Director, Power Generation.

4.4 The Regulatory Compliance - Power Generation group shall have sufficient authority and organizational freedom to identify problems that affect quality, recommend solutions, and verify implementation of solutions, as appropriate. Commensurate with this responsibility is the authority to initiate action to stop unsatisfactory work pending correction of the unsatisfactory condition.

Corporate and on-site organizational responsibilities are described in greater detail in Rancho Seco Nuclear Administrative Procedure RSNAP-001. Specific duties and responsibilities for organizations whose activities affect quality are described in RSQM Sections II through XVIII and Appendix A.

7I i

RANCHO SEGO- LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL*.

PAGE 9'OF 61 The Manager, Rancho Seco Assets advises the Director, Power Generation on matters related to the safety of operations at the Rancho Seco ISFSI. .

The Manager, Rancho Seco Assets performs safety reviews and provides onsite management oversight of Rancho Seco ISFSI activities.

The Manager, Rancho Seco Assets is responsible for reviewing all Potential Deviations from Quality (PDQ) to determine if a condition is a Deviation from Quality (DQ) and requires determination of the cause, extent, remedial corrective actions, and actions to prevent recurrence.

The Manager, Rancho *seco Assets reviews and approves DQ dispositions and assigns corrective acti_ons identified in DQ dispositions.

The Manager, Rancho Seco Assets also determines whether a PDQ is pote11tially reportable pursuant to 10 CFR 21.

5.0 GENERAL RESPONSIBILITIES -

The nuclear organization is involved in the long term monitoring of the Rancho Seco ISFSI and is responsible for describing and clearly defining the duties and authority of individuals whose work affects quality. RSNAP-001 defines the Rancho Seco ISFSI organization and the responsibilities associated with each onsite work group.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-01.0 REVISION: 5 TITLE: . RANCHO SEGO QUALITY MANUAL- PAGE 10 OF 61 II. QUALITY ASSURANCE PROGRAM 1.0 PURPOSE The purpose of this section is to describe the Rancho Seco Quality Assurance Program (QAP) implemented at the Rancho Seco ISFSI, licensed and operated pursuant to 10 CFR Part 72.

2.0 REFERENCES

2.1 10 CFR 71, Subpart H, Quality Assurance Requirements for Packaging and Transportation of Radioactive Material 2.2 10 CFR 72, Subpart G, Quality Assurance Requirements for the Independent Storage of Spent Nuclear Fuel.

2.3 NRC Form 311, Quality Assurance Approval for Radioactive Material Packages,ApprovalNo. 0489 3.0 POLICY The QAP is designed to ensure compliance with the requirements of 10 CFR Part 72, Subpart G "Quality Assurance.". The QAP is also designed to fulfill the quality requirements for the use of radioactive material transport packages (e.g.,

the MP187 Cask) in accordance with 10 CFR Part 71, Subpart H "Quality Assurance."

4.0 GENERAL REQUIREMENTS 4.1 Th_e Rancho Seco Quality Manual (RSQM) is organized to present the 18 quality criteria in the order they are. addr~ssed in 10 CFR Part 72, Subpart G. The RSQM states the Rancho Seco policy for each criterion and describes how controls pertinent to each criterion are to be carried out.

4.2 The QAP is implemented by organizations responsible for achieving quality and by organizations responsible for verifying quality .

4.3 Manager, Rancho Seco Assets identifies the Quality Assurance (QA) classification of structures, systems, and component~ (SSCs) commensurate to their importance to safety.

4.4 Quality Assurance classification Important to Safety is assigned to SSCs that are considered Important to Safety in accordance viiith 10 CFR Part 72, Subpart G: * '. .

RANCHO SEGO LICENSING BASIS DOCUMENT

NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL *- PAGE 11 OF 61 4.4.1 The Important to Safety assignment includes 10 CFR 72 (ISFSI) and 10 CFR71 (Transportatio*n Package) SSCs as specified in RSAP-0302.

4.4.2 All 18 elements of the 10 CFR Part 72, Subpart G quality criteria apply to activities affecting lmportantto Safety SSCs during operation, maintenance, testing, and modifications.

4.5

Some 10 CFR Part 72, Subpart G quality criteria apply to non-Important to Safety programs and activities such as radiation protection, emergency preparedness, ISFSI operations, environmental monitoring, security, training, and 10 CFR 71/72 important-to-safety, as indicated in RSQM-Section II, Attachment 11-1.

4.5.1 The Manager, Rancho Seco Assets identifies the 10 CFR 71 and 10 CFR 72 SSCs that are Important-to-Safety in accordance with RSAP-0302 Configuration Identification."

4.5.2 SMUD activities performed*under 10 CFR 71 shall be limited to procurement, maintenance, repair, and use as authorized by the NRG Quality Assurance Program Approval for Radioactive Material Packages (NRG Form 311; Approval Number 0489).

4.6 Attachment 11-1 indicates the minimum QAP criteria that must be applied to specific Program Activity Areas.

4.7 Attachments 11-2 and 11-3 tabulate the NRG regulatory guides and ANSI standards, with exceptions and applicable revisions, that SMUD is committed to meeting as part of its QAP.

4.8 Activities associated with the safe operation of the Rancho Seco ISFSI are accomplished under controlled condition*s. - Preparations for such activities include confirmation that prerequisites have been met.-

4.9 Development, control, and use of computer programs associated with the design and safe operation of the Rancho Seco ISFSI are subject to appropriate controls. -

4.10 Training programs shall be established to ensure personnel responsible for performing and verifying activities that affect quality have the required proficiency and qualificati~ns to perform the assigned tasks.

4.11 QAP Policy/Procedures/Instructions:

a. The QAP is documented in written policies, procedures, and instructions. The overall policies and general requirements are outlined in the RSQM. Specific details related to implementation of the

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 12 OF 61 established QAP policies are contained in Rancho Seco Implementing Procedures (RSIPs) and Rancho Seco Nuclear Administrative Procedures (RSNAPs). Organizations responsible for performing QAP functions shall prepare additional implementing procedures as necessary. RSIPs and RSNAPs are reviewed appropriately to ensure RSQM requirements are accomplished in a controlled manner.

b. Manager, Rancho Seco Assets is responsible for RSQM preparation, issuance, and control. The RSQM, including any changes, supplements, or attachments, is issued and maintained as a controlled document.

c. Manager, Rancho Seco Assets shall review and approve proposed RSQM changes.

4.12 Resolution of Differences:

RSQM requirements take precedence over differing quality requirements specified in other work group procedures until the Manager, Rancho Seco Assets evaluates the issue and determines which requirements must be modified.

Questions or disputes involving RSQM interpretation or implementation must be referred to the Manager, Rancho Seco Assets for resolution. The Manager, Rancho Seco Assets may elect fo confer with other individuals or groups within SMUD, or senior SMUD management for resolution.

4.13 Packaging and Transportation of Radioactive Material:

The QAP shall be applied to packaging and transportation of radioactive material as specified in References 2.1 and 2.3.

5.0 RESPONSIBILITIES General organizational responsibilities are described in RSQM Section I,.

ORGANIZATION 6.0 ATTACHMENTS 11-1 Application of Rancho Seco Quality Assurance Program Criteria 11-2 Regulatory Commitments 11-3 Exceptions

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 13 OF 61 Attachment 11-1 APPLICATION OF RANCHO SECO QUALITY ASSURANCE PROGRAM (QAP) CRITERIA (A. s. ci (A) An 'X' means application of the RSQM requirements associated with the QAP Criteria is required.

(B) No 'X' means application of the RSQM requirements associated with the QAP Criteria is optional.

(C) RSQM Impementmg

. I . deta,*1 s are prov,"d ed .m th e RSAP s an d 0 th er QAP .Imp1emen I fmg procedures.

QAP CRITERIA <11 Program Activity Areas ..

.j, I !! ill IV ':!.. VI VII VIII IX ~ XI XII XIII XIV xv XVI XVII XVIII References 10 CFR 71 /72 Important-to- ISFSI TS 5.4.1 k Safety, Category A X X X X X X X X X X X X X X X X X X RSQM, APP. A, 10 CFR 72, Subpart G RSAP-0302, ATT. 6 ISFSI Operations (License ISFSI TS 5.4.1 k Condition and Tech. Spec. X X X X X X X X x: *x X RSQM Section XVIII Compliance) 10 CFR 72 License ISFSI TS 5.4.1k Radiation Protection X X x<21 X X X X X X 10 CFR 20 RSQM,APP.A Radiological Environmental ISFSI TS 5.4.1k ""

Monitoring Program (REMP) c3> X X XC4> X X* X X X x. X Reg: Guide;-'4.15 RSQM,APP.A ISFSI TS 5.4.1k Security X X X X X X X X 10 CFR 72.44 & 186<

10 CFR 73 ISFSI TS 5.4.1k Emergency Preparedness X X X X X x. X X RSQM,APP.A ISFSI TS 5.4.1k Training X X X X X x* X X 10 CFR 72.190 RSQM APP.A 10 CFR 71172 Important-to- ISFIS TS 5.4.1 k Safety, Category B & C c51 X X X X X X X X X X X X. X X RSAP-0302, ATT. 6 .

10 CFR 72.3 & 72.140 10 CFR 71.101

RANCHO .SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: . RANCHO SECO QUALITY MANUAL PAGE 14 OF 61 Footnotes:

(1) 10 CFR Part 72, Subpart.G, Quality Criteria and corresponding RSQM section titles: ?

I. Organization II. Quality Assurance Criteria Ill. Design Control IV. Procurement Document Control V. Instruction, Procedures, and Drawings VI. Document Control VII. Control of Purchased Material, Equipment, and Services VIII. -Identification and Control of Materials, Parts, and Components IX. Control of Special Processes X. Inspection XI. Test Control XII. Control of Measuring and Test Equipment XIII. Handling, Storage, and Shipping XIV. Inspection, Test, and Operating Status XV. Nonconforming Materials, Parts, or Components XVI. Corrective Action XVII. Quality Assurance Records XVIII. Audits (2) Design Control as applied to permanent protective shielding.

(3) Rancho Seco applies the NRC Regulatory Guide 4.15 QA/QC program to the REMP. This Regulatory Guide 4.15 program meets the applicable QA/QC program requirements.

(4) As applied to environmental monitoring laboratory analysis services.

(5) As applied to 10 CFR 71 activities authorized pursuant to NRC Form 311,.

"Quality Assurance Approval for Radioactive Material Packages,"

Approval No. 0489. (Refer to RSQM Section II, Steps 4.4.1 and 4.5.2)

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: . RANCHO SEGO QUALITY MANUAL PAGE 15-OF 61 Attachment 11-2 REGULATORY COMMITMENTS SMUD commits to the requirements of the regulations and industry standards listed below with any exceptions identified in Attachment 11-3.

Document Revision/Date Title

1. Regulatory Guide 9/75 *

Personnel Selection and Training 1.8 Per ISFSI Tech. Spec. 5:3

2. Regulatory Guide 8/85 Supplementary Requirements for Quality 1.28 1983 Assurance Records (See Attachment ANSI/ASME NQA- 11-3, Exception No. 1)

Supplement 17S-1

3. Regulatory Guide 1/79 Auditing of Quality Assurance Programs 1.144 1977 for Nuclear Power Plants ANSI N45.2.12

4. Regulatory Guide 8/80 Qualification of Quality Assurance 1.146 1978 Program Audit Personnel for Nuclear ANSI N45.2.23 Power Plants

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 16 OF 61 Attachment 11-3 EXCEPTION EXCEPTION: Regulatory Guide 1.28/NQA-1, Supplement 17S-1 SMUD complies with the recommendations of this regulatory guide with the following clarifications:

With regard to Section 2.4 of Supplement 17S-1 titled Index: The phrase "an index" is clarified to mean* a collection of documents or indices which, when taken together, supplithe information attribut~_q to "an index" in the standard.

The specific location of a record "within a storage area" may not be delineated (e.g., the specific location within a computer record file may not be constant; further, SMUD may utilize a computer assisted random access filing system where such location could not be readily "documented," or would such a location be "relevant.") The storage location will be delineated, but where file locations change with time, the specific. location of a record within that file. may not always be documented.

With regard to Section 4.3, Supplement 17S-1 titled Safekeeping: Routine general office and nuclear site security systems and access controls are provided: No special security systems are required to be established for record storage areas.

With regard to Section 4.4, Supplement 17S-1, titled Facility: This Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: "Records completed but not yet transferred for permanent storage may be temporarily stored in one-hour fire rated file cabinets. In general, records shall not be maintained in such temporary storage for more than four months after completion without being microfilmed or placed in permanent storage. Open-ended documents revised or updated on a more-or-less continuing basis over an extended period of time (e.g.

personnel qualification and training do~uments, equipment history cards) which are cumulative in nature (e.g. nonconforming item logs and control room log books) shall become QA records_whem they are issued as a specific revision (e.g.

the master audit schedule); when they are filled-up or discontinued (e.g. log books or equipment history cards); on a predefined periodic basis when the completed portion of the ongoing document shall be transferred td records control as a "record (e.g. training and q1,.1alification records) ..

RANCHO SECO LICENSING BASIS DOCUMENT' NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHOSECO QUALITY MANUAL , PAGE 17 OF 61 Ill. DESIGN CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for control of design activities affecting applicable structures, systems, and components at the Rancho Seco ISFSI, licensed under 10 CFR Part 72.

In addition, this section defines the requirements for developing and .

implementing control measures thc;tt ensure design functions affecting the performance of operational, construction, and modification activities are carried out in a planned, controlled, and orderly manner and are in compliance with applicable regulatory commitments.

2.0 . REFERENCES

2.1 10 CFR 72.48, Changes, Tests, and Experiments 2.2 10 CFR 71.107, Package Design Contror 2.3 10 CFR 72.146, Design Control 3.0 POLICY The requirements specified in this section apply to all organizations performing design functions for modifications, changes, replacement or addition of structures, systeml;>, or components at the Rancho Seco ISFSI. .

4.0 4.0 GENERAL REQUIREMENTS Procedures shall be established and executeq to control design activities.

Procedures covering design control activities shall include the following requirements: *

4.1 Applicable design inputs such as design bases, regulatory requirements, codes and standards, methodology,_ and all assumptions with appropriate justifications are identified, documented, and correctly translated into design output documents.such as specifications, drawings, procedures, or instructions.

4.2 Exceptions, waivers to or deviations from engineering requirements are documented and controlled.

4.3 Methods are specified for the selection and classification of suitable materials, parts, equipment, and processes used in meeting applicable requirements for structures, systems, and components.

RANCHO SECO LICENSING BASIS DOCUMENT

NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL .. PAGE 18 OF 61 Materials, parts, components, and equipr:nent that are standard, commercial (off the shelf), or.which have been.previously approved for other similar, applications are reviewed for suitability and appr_opriately classified.

4.4 Systematic methods are established for communicating and controlling the flow of related design information across the external and internal design interfaces, including any changes to the design information as the work progresses.

4.5 Interfaces between Engineering and other participating design organizations (either internal or external to SMUD) are identified and documented: This identification includes those organizations providing design inputs, design analyses, design specifications, and design verification for operational, construction and modification design activities.

4.6 Participating design organizations establish and describe the controlled methods for preparation, review, approval, release, distribution, and revision of documents (such as design analyses, specifications, drawings, reports) involving design interfaces.

4.7 Design control measures shall provide for verifying or checking the adequacy of design modifications or design changes. Acceptable verification methods include, but are not limited to, design reviews, alternate calculations, or qualification testing. If a test program is used to verify the adequacy of a design, it must include qualification testing of a prototype unit under the most adverse design conditions.

4.8 Computer program codes used for design calculations are certified for use and their use is specified.

4.9 Design verification is to be performed by competent individuals or groups other than those who performed the original design, but who may be from the same organization. The results of the design verification efforts must be documented with the identification of the verifier clearly provided.

4.10 Provisions are specified for the control of design analyses such as accident analyses; compatibility of materials; accessibility for maintenance and repair; and delineation of acceptance criteria for inspections and tests.

4.11 Design problems that are identifi~d during field installation or testing activities shall be documented and forwarded to the Manager, Rancho Seco Assets for evaluation and resolution.

4.12 Design and specification changes, iricluding field changes, receive the same degree of control and approval as the original design unless another qualified, responsible organization is specifically designated.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 19 OF 61 4.13 Errors and deficiencies in the design process, including computer programs that could adversely affect structures, systems, or components are documented *and corrective action is taken to preclude repetition.

4.14 Proposed modifications or design changes which involve an Unreviewed Safety Question or a change to Rancho Seco ISFSI License or Technical Specifications are handled in accordance with 10 CFR 72.48 or 10 CFR 71.107(c), as appropriate.

4.15 Modifications are reviewed by plant personnel for effect on plant operation prior to making the modification operational.

4.16 Design documents are reviewed for accessibility of equipment and components for tests, maintenance, or modifications.

4.17 Design and/or test documentation must be obtained from all suppliers on procurements of ASME code components used for replacement or .

modification to the Rancho Seco ISFSI.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for implementing a design control process per this section and to:

a. Provide and control design change packages.

b. Ensure integrity and regulatory conformance of configuration control.

c. Provide plant configuration control including establishing and maintaining baseline documents.

d. Provide engineering support for ISFSI computers.

e. Perform probabilistic analysis in support of plant design, when necessary.

f. Provide engineerin*g *sllpport to the Rancho Seco nuclear organization. *

g. Provide and maintain engineering procedures, standards and specifica,tions_ and drawings.

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PAGE-20 OF 61 I

h. Review and concur with design control procedures.

j. Monitor implem-entation of the design control program.

k. Ensure that audits of the design control program are conducted in accordance with RSQM Section XVIII,

RANCHO SECO LICENSING BASIS DOCUMENT .. NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 21 OF 61 W.PROCUREMENTDOCUMENTCONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to control procurement documents for material, equipment, and services at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.109, Procurement Document Control 2.2 10 CFR 72.148, Procurement Document Control 3.0 POLICY Procurement documents for applicable Rancho -Seco ISFSI materials, equipment, components/spares, or services shall include applicable technical requirements, quality requirements, regulatory requirements, and other provisions necessary to ensure that purchased items and services are adequately described to the supplier.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established and implemented to control the preparation, review, approval and issuance of procurement documents.

4.2 Procurement documents shall include provisions for the following, as applicable:

a. Description of item or service.

b. Identification of design specifications and technical requirements by reference to specific drawings, codes, regulations, industry standards, or other documentation, including the applicable revision thereto that describe the items or services to be furnished.

c. Identification of test, inspection, and acceptance requirements, and any special instructions and requirements for activities such as design, fabrication, identification, cleaning, erecting, packaging, handling, shipping, and extended storage.

d. Identification of applicable QAP criteria.

e. Applicability of 10 CFR Part 21.

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f. , Identification of the documentation, such as drawings, specifications, procedures, fabrication and inspection plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test reports to be prepared and maintained by the supplier or contractor, and the requirement to submit this documentation to SMUD for review and approval.

g. Identification of those records to be retained, controlled, and maintained by the supplier or contractor and those to be delivered to SMUD at the time of shipment of the procured item.

h.

SMUD's right of access to the supplier's facilities and records for inspection and audits. *

i. Extension of applicable requirements to lower tier subcontractors and suppliers, including SMUD's right of access to facilities and records.

j. Supplier submittal of nonconforming items and SMUD approval for "Accept as is" or "Repair" dispositions of non-conformances.

k. SMUD's right to hold shipment if procurement document requirements, including those for documentation, have not been fulfilled.

4.3 Technical and quality review by qualified personnel and approval by designated individuals shall be performed prior to issuance of the procurement document. The review and approval shall be- documented and available for verification.

4.4 Review and concurrence by qualified personnel shall be performed to ensure adequacy of quality requirements and to verify that the

requirements.are correctly stated, inspectable, and controllable; that there are adequate, acceptance and rejection criteria; and that the procurement documents have been prepared, reviewed, and approved in accordance with the requirements of the established procedures.

4.5 , Revisions to procurement documents shall receive an equivalent review and approval as the original documents. Exceptions to this include changes in quantity, estimated price, cost codes, taxes, format or editorial changes that do not affect the quality of the item or service.

4.6 Procurement documents for spare or replacement parts for Important to Safety structures, systems, or components shall specify procurement controls at least equivalent to those required for purchase of the original equipment.

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NUMBER: RSLBD.:.010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 23 OF 61

4. 7 . Methods shall be established to ensure thatthe items received are traceable to procurement documents.***

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:: _ ,

a. Purchase items in conformance with procurement documents.

b. Purchase Important to Safety items from .approved suppliers.

c. Arrange for suppliers to be placed on an Approved Suppliers List (ASL). Refer to RSQM Section VII, Step 4.2 regarding ASL.

d. Arrange for source inspection when specified on the procurement documents.

e. Designate qualified engineer&. (SMUD or Contract) to provide technical and quality requirements for,purchasing Important to Safety) items.

f. Developing and maintaining the ASL.

g. Review and concurrence of material management procedures.

h. Review and concurrence of procurement documents for Important to Safety items.

i. Ensuring audits of the procurement document control program are conducted in accordance with RSQMSection XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT * ,NUM.BER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 24 OF 61 V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that activities affecting the quality or safety of the Rancho Seco ISFSI are described and accomplished in accordance with documented instructions, procedures, drawings, or other documents appropriate to the circumstances.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.150, Instructions, Procedures, and Drawings 2.2 10 CFR 72.111, Instructions, Procedures, and Drawings 3.0 POLICY Activities affecting quality performance or operational safety at the Rancho Seco ISFSI shall be described and implemented in accordance with documented instructions, procedures, and drawings.

4.0 GENERAL REQUIREMENTS 4.1 Written instructions, procedures, drawings, or other documents appropriate to the circumstances shall be prepared to provide measures for complying with the provisions of the QAP.

4.2 Instructions, procedures, or drawings shall include applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished.

4.3 Procedures shall be established for the review, approval, issuance, change, and use of documents that specify quality requirements such as instructions, procedures, drawings, and other documents that implement the QAP.

4.4 Activities affectfng quality shall be accomplished in accordance with approved instructions, procedures, and drawings.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for ensuring activities that affect quality are described in instructions, procedures, and drawings.

RANCHO SEGO LICENSING BASIS DOClfrv1ENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL.* : . PAGE 25 OF 61 5.2 The Manager, Ranch.a SetoAssets is.responsible for ensuring that audits are conducted in accordance with RSQI\/I Section XVIII.

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NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 26 OF 61 VI. DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the issuance and control of documents that control activities affecting quality at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.113, Document Control 2.2 10 CFR 72.152, Document Control 3.0 POLICY Applicable documents, including changes thereto, that prescribe activities affecting the quality operation at the Rancho Seco ISFSI shall be issued and controlled in a manner that precludes the use of inappropriate or outdated documents.

4.0 GENERAL REQUIREMENTS 4.1 The Manager, Rancho Seco Assets shall establish procedures that define responsibilities and delineate the sequence of actions to be accomplished in preparation, review, approval, and control of instructions, procedures, or drawings, or changes thereto.

4.2 Procedures that establish document control measures shall include:

a. Identification of documents to be controlled;

b. Identification of individuals or organizations responsible for the review, approval, issuance, and revision of documents;

c. Criteria to ensure that adequate technical and quality requirements are incorporated prior to implementation;

d. Review of changes to documents by the same organizations that performed the initial review and approval or by the organizations designated in accordance with the applicable procedures.

4.3 Controlled documents, including changes, shall be issued and distributed to organizations noted on distribution lists so that proper and current documents are available as required, and obsolete or superseded documents are identified and not used for prescribed activities.

RANCHO SECO LICENSING BASIS ooclJME'tfr: -;NUMBER: RSLBD-010 REVISION: 5 TITLE: - RANCHO SEGO QUALITY MANUAL PAGE27 OF.61 4.4 Master lists or ,equivalent means* shall. be* used to identify the current revision of controlled documents and made available at work locations, as appropriate.

5.0 RESPONSIBILITIES.

General organizational responsibilities are.described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Developing and implementing a document control program in accordance with this section. *

b. Complying with document review, approval, and revision authority defined in plant administrative procedures.

c. Ensuring qualified personnel review documents with quality' assurance related aspects, as appropriate. *

d. Reviewing and con~urring with document control procedures.

e. Reviewing ano concurring with procedure~, instructions, or documents that implement the QAP to. ensure compliance with applicable RSQM provisions.

f. Ensuring that audits of the document control program are conducted in accordance with RSQM Section XVI 11.

RANCHO SEGO LICENSING BASIS DOClJMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 28 OF 61 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND

sERVICES 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure thatmaterial, equipment, and services purchased for the Rancho Seco ISFSI conform to the procurement documents.

2.0 REFERENCE DOCUMENTS 2.1 10CFR 71.115, Control of Pur~hased Material, Equipment, and Services 2.2 10 CFR 72.154, Control of Purchased Material, Equipment, and Services 3.0 POLICY Measures shall be established to ensure that material, equipment, and services conform to the specified requirements of the related procurement documents.

4.0 GENERAL REQUIREMENTS 4.1 Control of purchased material, equipment, and services shall include the following, as appropriate:

a. Source evaluation and selection of suppliers.

b. Objective evidence of quality furnished by the supplier.

c. Source inspection, audit, and/or surveillance activities.

d. Examination of items or services upon delivery or completion.

4.2 Results of source evaluation and selection of suppliers shall be documented and retained on file.

4.3 Procedures for control of materials, equipment, and services shall address the following:

a. Responsibilities of departments performing supplier technical and quality evaluations, and the method of evaluation.

b. Inspection activities that specify the characteristics or processes to be witnessed, inspected or verified;-the method of verification and the extent of documentation required; .and the organization responsible for implementing the inspection.

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c. Auditing to verify conformance and implementation to requirements of this policy. Source inspection and audits may not be necessary when conformance of an item to procurement requirements can be verified by receipt inspection, review of test reports, certified reports or other means specified by qualified personnel.

d. Receipt inspection of supplier furnished items to ensure: (1) the proper identification of items on the receiving documentation, (2) that the items are inspected and judged acceptable.in accordance with predetermined instructions prior to installation or use, (3) that inspection records or certificates of conformance are available at the plant sit~ prior to installation or use of the items, ,and (4) that items accepted and released are identified as to their inspection status prior to storage or use.

e. Review, acceptance, and maintenance of records to ensure adequacy of documentation that identifies the purchased item, and that specific procurement requirements (e.g., codes, standards, specifications) have* been met or satisfied. *

f. Review and approval of documentation required to be submitted by the procurement documents (CMTR's, Certificate of Compliance, Procedures, Specifications, etc.).

g. Procurement control of spare or replacement parts for Important to Safety systems to ensure compliance with requirements that are (1) equivalent to the original requirements or (2) specified by a properly reviewed and approved revision to the original requirements.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION. . .

5.1

The Manager, Rancho Seco Assets is responsible for:

a. Ensuring quality and qualifications of parts and materials by (1) developing quality specifications and (2) storing parts and materials in accordance with regulatory requirements and in coordination with appropriate nuclear organization groups.

b. Ensuring regulatory compliance of materials and parts by managing procurement documentation and reviewing (and implementing, as appropriate) NRC and related parts/materials bulletins.

c.. Examining items .or services upon delivery or completion, as deemed necessary to supplement .or replace formal inspection activities.

d. Developing and maintaining the ASL.*

e. Performing required inspections, evaluations, and audits.

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f. The review and. concurrence with material management procedures.

g. Ensuring that audits -of the control of purchased material, equipment, and services are conducted in accordance with RSQM Section XVIII.

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NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL. *

PAGE 31 OF 61 VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, &

COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the identification and control of material, parts, and components for the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.117, Identification and Control of Materials, Parts, and Components 2.2 10 CFR 72.156, Identification and Control of Materials, Parts, and Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts,

. or components are properly identified and controlled to preclude the use of incorrect or nonconforming items.

4.0 GENERAL REQUIREMENTS 4.1 Materials, parts, or components, including partially fabricated subassemblies and consumables, shall be identified so they can be related to their applicable drawing, specification, purchase document, and inspection records at any stage from initial receipt through fabrication/construction, installation, repair, modification, or use.

4.2 Identification controls, implementation procedures, and documentation shall be used to ensure that only correct and accepted items are used during all stages. of construction, installation, and operation.

4.3 Unique identification of items is required (e.g., by part number, serial number, heat number, drawing identification number, or other traceable coding methods).

4.4 Identification is required to be maintained either on the item or on records traceable to the item. Physical identification such as by marking or tagging shall be used to the maximum extent practical.

4.5 When specified by codes, standards, procurement documents, or other requirements, identification is required such that items are traceable to appropriate documentation (e.g., specifications, drawings, purchase

RANCHO SECO LICENSING BASIS DO_QUMENT. NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 32 OF 61 orders, manufacturing and inspection documents, nonconformance reports, physical or chemical mill test reports).

4.6 Where identification marking is employed, the marking is required t6 be clear, unambiguous and .indelible, and shall be applied such as not to affect the fit, function, or quality of the item.

4.7 Markings shall be transferred to each part of an item, if subdivided. The markings shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted.

\

4.8 Procedures are required to provide for the verification arid documentation of correct identification of items prior to release for use. Items may be conditionally released under adequate procedural controls.

4.9 Bulk consumables (such as weld rod, chemicals, reagents, gases, resins, lubricating oil and grease, fuel oil, cleaning solvents, etc.) must be identified and controlled in accordance with approved procedures that specify the applicable requirements for identification and use of the consumables.

4.10 In the event the identification or traceability of an item is lost, it shall be handled in accordance with RSQM Section XV.

5.0 RESPONSIBILITIES General organizational responsibilities are.described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Identification and control of items from procurement through withdrawal from the warehouse.

b. Maintaining identification and control of items from withdrawal from the warehouse through installation.

c. Review and concurrence of procedures for controlling material, parts, and components from procurement through storage, issuance, and installation.

d. Ensuring that audits of the process for identification and control of materials, parts, and components* are conducted in accordance with RSQM Section XVIII.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 33 OF 61 .

. IX. CONTROL OF SPECIAL PROCESSES 1.0 PURPOSE

This section describes the Rancho Sec~ Quality Assmance* Program (QAP) measures established to control special processes used at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 ASME Section V and IX 2.2 10 CFR 71.119, Control of Special* Processes 2.3 10 CFR 72.158, Control of Special Processes 3.0 POLICY Prior to performing any special processes*,* procedures shall be established and implemented to ensure that special processes and equipment are controlled and that qualified personnel and procedures accomplish required activities.

4.0 GENERAL REQUIREMENTS*

4.1 Prior to performing any special processes, procedures shall be prepared to provide for proper control of special processes, which include welding, heat treating, chemical cleaning, application of protective coatings, and nondestr~ctive examination (NOE).

4.2 Controls shall be e*stablished to ensure that only approved materials and equipment are used to perform special processes.,

4.3 Personnel who perform special processes shall be qualified in accordance with *industry standards.

4.4 Special process requirements shall be prescribed in the controlling specifications, drawings, procurement documents, or procedures.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Specifying the special processes on design documents governing maintenance/modification activities.

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b. Developing, qualifying, and maintaining special process procedures in accordance with Step 4.1 of this RSQM section.

c. Qualifying personnel or approving contract personnel to perform special processes identified in Step 4.1 of this RSQM section.

d. Performing NOE or approving contract personnel to perform NOE.

e. Review and concurrence of special process procedures.

f. Ensuring that audits of the special process progrpm a,re conducted in .

accordance with RSQM Section XVIII.

RANCHO SEGO LICENSING BASIS DOCWMENT NUMBER: RSLBD-010 REVISION: 5 TITLE:

RANCHO*SECO QUALITY MANUAL. PAGE 35 OF 61 X. INSPECTION' 1.0 PURPOSE .

This section describes the* Rancho Seco 6u~lity Assura.nce Program (OAP) measures established to provide for the inspection of material, parts, and components for the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.121, Internal Inspection 2.2 10 CFR 72.160, Licensee Inspection 3.0 POLICY Procedures shall be established and implemented to ensure that inspections are performed to verify compliance with specified requirements at the Rancho Seco ISFSI.

4.0 GENERAL REQUIREMENTS 4.1 *inspections shall be applied to receiving, maintenance, and modification activities to veri.fy that items and activities conform to specified requirements.

4.2 Inspection planning documents shall be prepared or reviewed by Quality Assurance in accordance with established procedures. Inspection planning documents shall identify the following as applicable:

a. Characteristics and activities to be inspected;

b. Inspection organization;

c. Accept/reject criteria;

d. Hold points and/or witness points;

e. Inspection Methods;

f. Provisions for recording objective evidence of inspection results; and

g. Measuring and test equipment of the necessary accuracy for performing inspection.

4.3 Process monitoring may be used where direct inspection alone is impractical or inadequate. Both inspection and process monitoring are performed when control is inadequate without both.

4.4 Training and qualification of personnel, who perform inspections including NOE, shall be performed in accordance with approved procedures.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 36 OF 61 4.5. Hold points are designated .as mandatory inspection points when confirmation is needed that the work at the point is acceptable before additional work can proceed. Authorized personnel perform hold point inspections and release work for further processing or use.

4.6 Inspections, including any required hold points, are performed and documented in accordance with written procedures. Inspection results are documented and evaluated by qualified personnel to verify acceptability.

4.7 Qualified personnel perform inspections of receiving, maintenance, and modification activities.

4.8 Inspection records shall contain the following where applicable:

a. Item inspected;

b. The date of the inspection;

c. Inspector or data recorder identification;

d. Identification of M&TE used to perform inspections;

e. Type of observation;

f. Results or acceptability; and

g. Reference to information on action taken on non-conformances to resolve any discrepancies noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Ensuring that Quality Control Inspectors are qualified.

b. Preparing or reviewing inspection-planning documents for modification/maintenance activities.

c. Performing inspections per inspection plans.

d. Ensuring that audits of the inspection program are conducted in accordance with RSQM Section XVI 11.

e. Ensuring that inspections are performed as required by inspection planning.

f. Ensuring that work does not proceed beyond inspector signoffs for hold points.

g. Supporting inspection activities.

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h. Providing prompt corrective action to any:deficiencies found during the inspection. , -

RANCHO SEGO LICENSING BASIS DOCUMENT . NUMBER: RSLBD-010 REVISION: 5 TITLE: . RANCHO SEGO QUALITY MANUAL PAGE 38 OF 61 XI. TEST CONTROL 1.0 PURPOSE This section describes the Rancho* Seco Quality-Assurance Program (QAP) measures established to provide for acceptance and surveillance test control at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.123, Test Control 2.2 10 CFR72.162, Test Control 3.0 POLICY Procedures shall be established and implemented to ensure that required testing to demonstrate that structures, systems, and components will perform satisfactorily in service is identified, performed and documented.

4.0 GENERAL REQUIREMENTS 4.1 Tests shall be performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

a. Qualification tests, as applicable, to verify design adequacy.

b. Tests of equipment and components to ensure their proper operation prior to delivery or pre-operational tests;

c. Pre-operational tests to ensure proper and safe operation of systems and equipment prior to startup tests or operations;

d. Startup tests to ensure proper and safe operation of ~ystems and equipment. *

e. Surveillance tests to ensure continuing proper and safe operation of systems and equipment.

f. Maintenance tests after preventive or corrective. maintenance.

4.2 Test procedures and instructions shall include provisions for the following, as applicable:

a. The requirements and acceptance limits contained in the applicable design and procurement documents;

b. Test prerequisites such as calibrated instrumentation, required test equipment, degree of completeness of the item to be tested, suitable

RANCHO SECO LICENSING BASIS DOCUMENT*::-* NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY.MANUAL* - PAGE 39 OF61 and controlled environmental conditions, and provisions for data collection and storage; * * * *

c. Verifying that test prerequisites have been met;

d. Instructions for performing the test;

e. Any inspection points;

f. Acceptance criteria;

g. Documenting or recording test data and results; and

h. Verification of completion.

4.3 Test procedures and instructions-shall be reviewed by the applicable organizations for technical content.

4.4 Test results shall be documented and evaluated by responsible authorities to ensure that test requirements have been satisfied.

4.5 Test records shall contain the following information where applicable:

a. Item tested and type of observation;

b. The date and results of the test;

c. Information related to ~eviatfOns or non~conformances;

d. Identification of person recording the data;

e. Evidence as to the acceptability of the results; and

f. . Action taken to resolve any deviations and non-conformances noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Establishing the procedure for acceptqnce and surveillance testing.

b. Providing personnel to perform the testing and acceptance evaluations.

c. Ensuring that audits of the test control program are conducted in accordance with RSQM Section XVIII.

RANCHO SEGO LICENSING BASIS DOCUMENT - NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE40 OF 61 XII. CONTROL OF MEASURING AND TEST EQUIPMENT 1.0 PURPOSE This section describes the Rancho* Seco Quality Assurance Program (QAP)

. measures established_to provide for the control of measuring and test equipment at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR-71.125, Control of Measuring and Test Equipment 2.2 10 CFR 72.164, Control of Measuring and Test Equipment 3.0 POLICY Procedures shall be established and implemented to ensure that measuring and testing devices used in finalacceptance of activities affecting quality are properly controlled, calibrated, and adjusted at specified intervals to maintain the desired accuracy.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for calibration, maintenance, and control of measuring and test equipment utilized in the operation, measurement, inspection, or monitoring of items.

4.2 Measuring and Test Equipment (M&TE) shall be calibrated at specified intervals. These intervals are based on the amount of use, stability, characteristics and other conditions that could adversely affect the required measurement accuracy. Reference and secondary calibration standards shall be traceable to nationally recognized standards where they exist. Where national standards do not exist, provisions shall be established to document the basis for calibration.

4.3 M&TE used for calibrating plant process instrumentation (Pl) shall have calibration ranges, precision, and accuracy's such that the Pl can be calibrated from M&TE with an accuracy ratio of at least two-to-one (M&TE to Pl). Calibration accuracy ratios of less than two but equal to or better than one shall be acceptable when equipment to meet specified requirements is not commercially available. The basis of acceptance in these cases shall be documented.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO' SEGO QUALITY MANUAL PAGE 41 OF 61 5.1 The Manager, Rancho Seco Assets, is responsible for:

a. Establishing methods for control of measuring and test equipment.

b. Determining the need for calibrated instruments and measuring devices in Rancho Seco ISFSI activities.

c. Providing administrative procedures that address the requirements for calibration. *

d. Control of measurement devices to ensure their use and accuracy.

e. Ensuring that audits of the control of measuring and test equipment program are conducted in accordance with RSQM Section XVIII.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: .RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL. PAGE42 OF61 XIII. HANDLING; STORAGE, AND SHIPPING 1.0 PURPOSE This section describes theRancho Seco Quality Assurance Program (QAP) measures established to provide for the handling,, storage, shipping, cleaning, and preservation of material and equipment at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.127, Handling, Storage, and Shipping 2.2 10 CFR 72.166, Handling, Storage, and Shipping 3.0 POLICY Procedures shall be established and implemented to ensure that materials and equipment are properly handled, stored, shipped, cleaned, and preserved to prevent damage or deterioration.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for assuring that proper handling, storage, .shipping, and preservation instructions are included in applicable drawings and/or specifications.

4.2 When required for specific items, special protective environments, such as inert gas atmosphere, specific moisture content levels, and temperature levels, shall be specified.

4.3 A shelf life program shall be in effect and monitored to prevent usage after the expiration date without re-certification for extension of shelf life.

4.4 Special material handling and preservation instructions shall be developed when required by applicable drawings and/or specifications.

4.5 Materials used for packaging, shipment, and, storage of items that have the potential for causing contamination or radiation exposure require marking and labeling to indicate the need for special radiological controls.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

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a. Establishing methods and procedures to ensure that applicable drawings and/or specifications include handling, storage, shipping, and preservation requirements.

b. Establishing methods for special handling, storage, and preservation during maintenance activities.

c. Providing administrative procedures that specify the required controls.

d. Maintaining material and warehousing control of items and equipment that require sp*ecial handling and storage.

e. Ensuring that audits of conformance to the handling, storage, and shipping program are conducted in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT . NUMBER: RSLBD-010 REVISION: 5 TITLE:

RANCHO SECO QUALITY MANUAL PAGE44 OF 61 XIV. INSPECTION, TEST, AND OPERATING STATUS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a system to identify the inspection, test, and operating status of individual items at the Rancho ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.129, Inspection, Test and Operating Status 2.2 10 CFR 72.168, Inspection, Test and Operating Status 3.0 POLICY Procedures shall be established and implemented to ensure that measures are provided to indicate the status of inspections, tests, and operations.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall specify the degree of control required for the indication of inspection and test status of items required for modification activities.

4.2 The sequence of inspections, tests, and other operations, and changes thereto, shall be controlled by procedures.

4.3 Procedures shall provide methods for identifying the nonconforming items, inoperable systems and components by tags, markings, labels, etc. to prevent inadvertent use ..*

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Facilities Maintenance is responsible for Clearance Program procedures to ensure:

a. Safety of personnel and equipment during maintenance and testing activities.

b. Installation and removal of test and operating status indicators.

c. Identifying the quality status of applicable material, parts, and components.

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d. , Ensuring that audits,,of the inspecti.on, test; *and operating status program are conducted in accordance with RSQM Section XVIII.

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XV- NONCONFORMING MATERIALS, PARTS, OR*COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for controlling material, components, parts, or systems that are not in conformance to specified requirements at the Rancho Seco ISFSI .

2.0 REFERENCED DOCUMENTS 2.1 10 CFR 71.131, Nonconforming Materials, Parts or Components 2.2 10 CFR 7t 170, Nonconforming Materials, Parts or Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components that do not conform to specified requirements are controlled to prevent their inadvertent use or *installation.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be developed for controlling, documenting, and resolving items, services, or activities identified as nonconforming.

4.2 Marking, tagging, segregating, or other means shall identify nonconforming items.

4.3 Non-conformances shall be documented, processed, controlled and retained to provide records of the actions taken to resolve the nonconforming condition.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions. (Refer to RSQM Section XVI regarding corrective action program)

b. Establishing methods for controlling and documenting non-conformances.

c. Ensuring expertise is available to disposition non-conformances.

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d .. Developing safety-analyses that add res~ the nonconforming condition,

. if required. . .

e. Auditing the nonconforming materials, parts, or components program per RSQM Section XVII I.

f. Taking appropriate action to ensure operation of the plant in conformance to license requirements when a nonconformance identifies a condition prohibiting components, structures, or systems from returning to an acceptable condition._

g. Determining the safety significance of the nonconforming condition on the status of the plant. *

h. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions.

i. Ensuring expertise is available to disposition non-con~ormances.

j. Developing safety analyses that address the nonconforming condition, if required.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL . PAGE 48 OF 61 XVI*. CORRECTIVE ACTION 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a corrective action program to ensure that conditions adverse to quality are promptly identified and corrected at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 72, Subpart D, Records, Reports, Inspections, and Enforcement.

2.2 10 CFR 71.133, Corrective Action 2.3 10 CFR 72.172, Corrective Action 3.0 . POLICY Procedures shall be established and implemented to ensure that significant conditions adverse to quality are identified and that corrective action is taken to preclude repetition.

4.0 GENERAL REQUIREMENTS 4.1 Controls shall ensure conditions adverse to quality such as malfunctions, errors, deficiencies or non-conformances are identified, documented and appropriate corrective action taken. The controls shall ensure that the corrective action is implemented in a timely manner.

4.2 For significant conditions adverse to quality, corrective action includes determining the cause and extent of the condition, taking corrective action to remedy the condition and taking action to prevent recurrence. These actions shall be reported to management personnel for review and assessment.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Formulating appropriate corrective actions.

b. Implementing proposed corrective actions.

c. Ensuring that proposed corrective action is effective.

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d. Ensuring that.audits of the Corrective.Action Program are conducted in accordance with RSQM Section XVI 11.

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XVII. QUALITY ASSURANCE RECORDS 1.0 PURPOSE This section describes the Ranct:o Seco Quality Assurance Program (QAP) measures established for the storage and maintenance of Quality Assurance Records that provide the documentary evidence of activities affecting quality performed at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 Regulatory Guide 1.28/ANSI/ASME, NQA-1-1983, Supplement 17S-1, Supplementary Requirements for Quality Assurance Records, with exceptions as noted in RSQM Section II, Attachment 11-3.

2.2 Rancho Seco Quality Manual, Appendix A 2.3 10 CFR 71.135, Quality Assurance Records 2.4 10 CFR 72.174, Quality Assurance Records 3.0 POLICY Procedures shall be established and implemented to ensure storage and maintenance of records that represent evidence of activities described in RSQM Section II, Step 4.3.

4.0 GENERAL REQUIREMENTS 4.1 Quality Assurance records shall be permanently stored in a facility that meets the requirements of Reference 2.1 and 2.2.

4.2 Quality Assurance records shall be protected during interim storage in accordance with Reference 2.1.

4.3 Documents that furnish evidence of the quality of items and services are generated and controlled in accordance with the procedures that govern those activities. Such documents are considered Quality Assurance Records upon completion. Quality Assurance Records are considered completed when they have been stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated.

4.4 The record system shall provide for identification and retrievability of the records to the extent that information can be obtained in a reasonable amount of time.

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NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL,,* ,, PAGE 51 O"F 61 4.5 The records program shaH address reco{ds. :cl.assification (retention period), storage location a*nd responsibility for 'retention and retrievability.

4.6 A records retention schedule shall be established which addresses the requirements in References 2 ..1 and 2.2 ..

5.0 RESPONSIBILITIES . .

General organizational responsibilities are described in Section I, ORGANIZATION 5.1 The Manager, Rancho* Seco Assets is responsible, for:

a. Establishing methods for control of records.* *

b. Providing administrative procedures that define the reco~ds storage program and provide for ready retrievability.

c. Transmitting completed records to Records Management.

d. Providing interim storage in accordance with Step 4.2 above and Reference 2.1, prior to transmittal*to Records Management.

e. Ensuring that audits of the records management system to ensure conformance to specified requirements are conducted in accordance with RSQM Section XVIII.

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XVIII. AUDITS,._

1.0 PURPOSE

Describe the Rancho Seco Quality Assurance Program (QAP) measures that (1) establish a comprehensive system of planned.and periodic audits, and (2) determine the effectiveness of the QAP at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 Regulatory Guide 1.144/ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 2.2 Regulatory Guide 1.146/ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit 1?ersonnel for Nuclear Power Plants 2.3 10 CFR 71.137, Audits 2.4 10 CFR 72.176, Audits 3.0 POLICY Procedures shall be established and implemented to ensure that planned and periodic audits are conducted to verify compliance with all aspects of the QAP.

4.0 GENERAL REQUIREMENTS 4.1 The Program Manager, Regulatory Compliance - Power Generation shall establish a schedule for auditing the activities affecting quality. The audit schedule shall be consistent with the audit requirements and frequencies specified herein.

4.2 The audit program shall be described in *procedures that implement this RSQM section.

4.3 Audits shall be conducted to determine the adequacy and effectiveness of programs implemented for the design, procurement, modification, maintenance, and operational activities at the Rancho Seco ISFSI .

4.4 Audit plans shall be developed that identify the audit scope, the requirements, activities to be audited; organizations to be notified, the applicable documents, and the augit schedule.

4.5 Audit reports shall be issued which identify the activity that was audited, the personnel that were contacted during the audit, and any conditions adverse to quality noted during the audit **

RANCHO SEGO LICENSING BASIS DOCUMENT*, *>. , NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SE:CO QUALITY MANUAL . PAGE 53 OF 61 4.6 Process conditions ide:ntified as adverse to quality using the Rancho Seco Corrective Action Program.

4.7 Personnel conducting audits shall be trained and qualified in accordance with Reference 2.2. In addition, at least one individual participating in the Security audit will be knowledgeable and practiced in.the access authorization program performance* objectives.*

' 4.8 Regularly scheduled audits shall be supplemented by special audits/surveillances when conditions that warrant special audits exist or when requested by SMUD management.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section, I, ORGANIZATION.

5.1 The Program Manager, Regulatory Compliance - Power Generation is responsible for:

a. Establishing a schedule for performing required audits.

b. Reviewing audit results to evaluate the effectiveness of the QAP.

c. Implementation of the established audit program.

d. Training and qualification of audit personnel.

5.2 The Manager, Rancho Seco Assets is responsible for:

a. Supporting the audit activities.

b. Providing prompt response*to any deviations from quality identified in the audit.

6.0 AUDITS AND AUDIT FREQUENCIES 6.1 Audits of Rancho Seco ISFSI activities shall be performed under the cognizance of the Program Manager, Regulatory Compliance - Power Generation who reports to the Director, Power Generation. The required audits and audit performance frequencies are as follows:

a. Conformance to the Rancho Seco ISFSI Technical Specifications and associated license,~6nditions at least once per year;

b. Performance and qu~lifications of the Rancho Seco ISFSI technical staff at least once every two years;

. c. . Actions taken to correct deficiencies occurring in structures, systems, components, or.methods of operation associated with the safe operation of the Rancho Seco ISFSI at least once every two years for

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d. Performance of activities required by the QAP to meet the 10 CFR af 72, Subpart G criteria' least once every five years;

e. Rancho Seco ISFSI Emergency Plan and implementing procedures at least once every two years;

f. 10 CFR 72 ISFSI Physical Protection Plan and implementing

. procedures at least once every two years; *

g. Other areas of Rancho Seco ISFSI operation that the Manager, Rancho Seco Assets considers appropriate;

h. : Rad'ioiogical Environmental Monitoring Program (REMP) and the results thereof at leas~ once every two years; .

i. Performance of activities required by the Quality Assurance Program for Effluent Control and Environmental Monitoring (Regulatory Guide 4.15) at least once every two years; and

j. Radiation Protection Program content and implementation once per year.

6.2 Changes to these audits and audit frequencies are subject to the requirements specified in 10 'CFR 72, Subpart G and related to the performance of specific audits may not be changed unless an exemption or waiver is obtained

. from the. NRC.

6.3 The audit reports resulting from items "a" through "j" above shall be forwarded to the Manager, Rancho Seco Assets; the Director, Power Generation; and the management positions responsible for the areas reviewed: The report should be issued within 30 days after completion.

RANCHO SECO LICENSING BASIS DOCIJMENT ; * -. NUMBER:. RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 55 OF 61 Appendix A 1.0 10 CFR PART 72 ADMINISTRATIVE CONTROLS 1.1 Technical Review and Control

a. Procedures, plans, manuals, and programs required by Section 1.4 shall be prepared, reviewed, and. approved. Each such procedure, plan, manual, and program or change thereto shall be reviewed by an individual(s) other than the preparer, but who may be from the same organization as the preparer of the procedure, plan, manual and program or change thereto.* .Programs, plans, manuals, and procedures other than administrative procedures will be approved as delineated in writing by the Manger, Rancho Seco Assets; but not lower than a direct report to the Manager. Such procedures, plans, manuals and programs shall be reviewed periodically in accordance with administrative procedures.

The Manager, Rancho Seco Assets will approve administrative procedures and Emergency Plan Implementing Procedures.

b. Proposed changes or modifications to systems or equipment described in the ISFSI Final Safety Analysis Report (IFSAR) shall be reviewed by an individual(s) other than the individual(s) who designed t.he modification, but who may be from the same organization as the individual(s) who designed the modifications. Such modifications shall be approved by the Manager, Rancho Seco Assets or his designee as delineated in writing, but not lower than a direct report to the Manager.

c. lndividual(s), other than the individual(s) who prepare proposed tests or experiments shall review proposed tests and expe,riments that are not addressed in the IFSAR. Such tests or experiments shall be approved by the Manager, Rancho Seco Assets or his designee as delineated in writing, but not lower than a direct report to the Manager.

d. Individuals responsible for reviews performed in accordance with Section 1.1 a, b, and c shall meet or exceed the qualification requirements of Section 4, "Qualifications," of ANSI N18.1-1971, excluding Sections 4.5.2 "Technicians" and 4.5.3 "Repairmen." The Manager, Rancho Seco Assets_shall establish the list of qualified reviewers for the independent reviews described in a, b, and c above.

e. Events reportable pursuant to Section 1.5 and violations of Technical Specifications shall .be investigated and a report prepared which evaluates the event and which provides recommendations to prevent recurrence. The Manager, Rancho Seco Assets shall review these reports.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMB~R: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 56 OF 61 1.2 Audits (S~e RSQM Sectiqn XVIII.)

Specific audit requirements, including frequencies and administrative controls, are addressed in Rancho Seco Quality Manual (RSQM)Section XVIII, "Audits."

1.3 Reporting Requirements for Specific Events and Conditions The Commission shall be notified and a report submitted per Section 1.5, pursuant to the requirements of 10 CFR 72. 75, 10 CFR 20.2203, and 10 CFR Part 73, Appendix G. Each report required by this section shall be reviewed and approved by the Manager, Rancho Seco Assets, or designee.

1.4 Procedures, Plans, Manuals, and Programs .

1.4.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained covering the activities referenced below:

a. Emergency Plan implementation.

b. REMP MANUAL implementation.

c. Quality Assurance Program for Effluent Control and Environmental Monitoring using the guidance of Regulatory Guide 4.15, Revision 1, February 1979. * , ..

d. Quality Assurance Program implementation.

e. Radiation Protection Program impiementation.

1.4.2 Each procedure, plan, manual, and program of Section 1.4.1 above and changes thereto shall be reviewed and approved as set forth in Section 1 .1 .

1.4.3 The following programs shall be established, implemented, and maintained:

1.4.3.1 Radiological Environmental Monitoring Program (REMP)

There are no longer any liquid or gaseous radioactive effluents discharged from the site. The radiation source term is limited to radioactive materials stored at the ISFSI. Accorc;:lingly, the only

.exposure pathway is by djrectradiation.

With the completion of decommissioning, the direcfradiation pathway is the only pathway still monitored by the REMP. Accordingly, there is no longer any requirement to participate, in an Inter-laboratory Comparison Program (ICP). The vendor supplying the direct radiation monitoring devices must be certified under a National Voluntary Laboratory Accreditation Program (NVLAP). The National Institute of Standards and Technology (NIST) administers the NVLAP, which provides third-party accreditation to testing and calibration laboratories.

RANCHO SECO LICENSING BASIS DOCUMENT * < *NUMBER: RSLBD-010 REVISION: 5 TITLE: _ RANCHO SECO QUALITY MANUAL ' . ' _PAGE 57 OF61 1.4.4 The changes to the REMP shall be reviewed and* approved as set forth in

Sections 1.1 and 1.9.

1.5 Reporting Requirements 1.5.1 Routine Reports

In.addition to the applicable reporting requirements of Title 10, Code of Federal-Regulations, the following reports shall be.submitted to the _

Regional Administrator of the Region IV Office unless otherwise noted.

1.5.2 Annual Radiological Reports Annual reports covering the activities of the unit, as described below, for the previous calendar year shall be submitted as follows:

1.5.2.1 Annual Individual Monitoring Results Report The Annual Individual Monitoring Results R'eport for the previous calendar year shall be submitted to the Commission by April 30 of each year in -compliance with 10 CFR 20.2206.

1.5.2.2 Annual Radiological Envirorimental'Operating Report The Annual .Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries, interpretations, and analysis of tre~ds of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the REMP Manual.

1.5.3 Biennial Report A routine report consisting of shutdown statistics, narrative summary of shutdown experience, and tabulations of changes, tests or, experiments required pursuant to 10 *cFR 72.48(d) shall be submitte,d at intervals not to exceed *24 months tci the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, n.c. 20555, with a copy to the Regional Office, postmarked no later than 30 days following the 24 month period covered by the report.

1.6 Reports for Specific Everits. and Conditions The types of events listed in -10 CFR 72.75, 10 CFR 20.2203, and 10 CFR Part 73, Appendix G. shall, be submitted to the U.S. Nuclear Regulatory Commission (NRC), ATTN: Document Control Desk, Washington, D.C.

20555-0001, within the time-.requirements of 10 CFR72.75, 10 CFR 20.2203, and 10 CFR Part 73, Appendix G. An additional copy shall also be

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 58 OF 61 submitted to the Regional Administrator of the Region IV Office. The written report shall include the information required by 10 CFR 72.75, 10 CFR 20.2203, or 10 CFR Part 73, Appendix G, as appropriate. Supplemental reports shall be submitted in accordance with the requirements in 10 CFR 72.75, 10 CFR 20.2203, orJ,0 CFR Part 73, Appendix G.,. as appropriate.

1.6.1 Environmental Reports

a. When a change to the plant design or operation is planned which would have a significant adverse effect on the environment or which involves an environmental matter or question not previously reviewed and evaluated by the NRC, a report on the change will be made to the NRC prior to implementation. The report will include a description and evaluation of the change, including a supporting benefit-cost analysis.

b. Changes, or additions to permits and certificates required by Federal, State, locai and regional authorities for the protection of the environment will be reported. The request for permit and certificate changes or additions submitted to the conc~rned agencies for approval will also be submitted to the NRC. The submittal will be made for the reporting period during which the changes or additions occurred. The submittal will include an.evaluation of the environmental impact of the change(s). * *

1.6.2

Special Reports Special reports shall be submitted to the Regional Administrator of the Region IV Office within the time period specified for each report.

1.7 Record Retention

1. 7 .1 The following records shall be retained for the duration of the 10 CFR Part 72 Operating Licenses:

a. Records and logs of principal maintenance activities, inspections, repair, and replacement of principal items of equipment related .to NUCLEAR SAFETY, as they relate to the 10 CFR Part 72 licensed ISFSI.

b. Reports for Specific Events and Conditions

c. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

d. Recordsof changes made to Operating Procec;tures, as they relate to the 10 CFR Part 72 licensed ISFSI. . . .

e. Records of sealed source leak tests and results.

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f. Records of annual'physical inventory of all sealed source material of record.

g. Records and logs of ISFSI activities.

h. Record and drawjng changes reflecting ISFSI design modifications made to systems and equipment described in the ISFSI SAR.

i. Records of new and irradiated fuel inventory, fu~I transfers and assembly

burn-up histories.

j. Records of ISFSI radiation and contamination surveys ..

k. Records of radiation exposure for all individuals entering radiation control areas. .

I. Records of training and qualification for current members *of the operating

staff. *

m. Records of quality assurance activities required by the RSQM.

n. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 72.48.

o. Records for the Radiological Environmental Monitoring Program.

p. Records of reviews performed for changes made to the REMP MANUAL.

q. Records of ISFSI decommissioning activities performed.

1.8 Radiation Protection Program Procedures for personnel radiation protection shall be_prepared*consistent with the requirements of 10 CFR 19 and 10 CFR 20, and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

1.9 Radiological Environmental Monitoring Program Manual

Licensee-initiated charigeido:the-~EMP Manual shall be documented and records of reviews performed shall be retained as required by Section 1.6.1.o.

RANCHO SECO LICENSING BASIS DOCUMENT. NUMBER: RSLBD-010 REVISION: 5 TITLE: RAMCHO SECO QUALITY MANUAL - -PAGE 60 OF 61 This documentation shall contain sufficient information to support the change together with the appropriate analyses or evaluations justifying the change.

Changes to the REMP become effective after approval by the Manager, Rancho Seco Assets and will be submitted to the Commission in the form of a complete, legible copy of the- entire manuaL

1.10 Sealed Source Contamination Each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material shall be free of.:::. 0.005 microcuries of removable contamination.

Applicability: At All Times Action:

With a sealed source having removable contamination in excess of the above limits, immediately withdraw the sealed source from use and:

a. Either decontaminate and repair,the sealed source, or

b. Dispose of the sealed source in accordance with NRC Regulations.

Surveillance Requirements:

Test Requirements Each sealed source shall be tested for leakage and/or contamination by:

a. The Licensee, or

b. Other persons specifically authorized by the NRC or an Agreement State.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample.

Test Frequencies Each category of sealed sources shall be tested at the frequency described below.

a. For sources in use at least once every six months or all sealed sources containing radioactive material:

1. With a half-life greater than 30 days (excluding Tritium), and

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2. In any form other than gas*. * ,

b.

For stored sources not in use each sealed source shall be tested prior to use or transfer to another licensee unless tested within the previous six months. Sealed sources transferred without a certificate indicating .the last test date shall be tested prior to being placed into use.

Attachment 3 Proposed RSQM, Revision 5 Redline-strikeout Version

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 1 OF 61 EFFECTIVE DATE: Upon NRC Approval REASON FOR CHANGE:

Update to reflect title change from General Manager to Chief Executive Officer & General Manager.

Update to reflect the 2021 SMUD corporate reorganization. The responsibility for the Rancho Seco ISFSI was moved from the Chief Energy Delivery Officer to the Chief Zero Carbon Officer.

REVISION

SUMMARY

Quality Assurance Policy Item Ill changed from the Chief Energy Delivery Officer to the Chief Zero Carbon Officer.

Section 4.1 changed position title from the General Manager to Chief Executive Officer and General Manager.

Section 4.1 changed position title from the Chief Energy Delivery Officer to the Chief Zero Carbon Officer.

Section 4.1 added clarification that the Director, Power Generation reports to the Chief Zero Carbon Officer.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL . PAGE 2 OF 61 QUALITY ASSURANCE POLICY The Sacramento Municipal Utility District's (SMUD) policy regarding quality assurance at the Rancho Seco ISFSI, licensed and operated in accordance with 10 CFR 72, is as follows:

I. Organizations involved in QA Important to Safety activities and the other Program Activity Areas specified in Rancho Seco Quality Manual (RSQM)Section II, Attachment 11-1, shall be structured, managed, and operated to provide compliance with the RSQM.

Procedures shall be prepared that implement the activities required to safely operate the Rancho Seco ISFSI and achieve the following objectives:

a. Comply with government regulations and established SMUD management policies, applying a systematic, disciplined, and uniform approach to quality assurance.

b. Provide facilities designed, modified, constructed, tested and operated in accordance with specified requirements with reasonable assurance that failures or malfunctions will not cause undue risk to public health and safety.

c. Ensure prompt identification and resolution of actual and potential problems in design, procurement, construction, testing, operations, maintenance, and modification of the structures, systems, and components associated with QA Important to Safety activities or other applicable Program Activity Areas specified in RSQM Section II, Attachment 11-1.

II. The RSQM and implementing procedures constitute the Rancho Seco Quality Assurance Program (QAP). The QAP applies to activities, plans, and programs affecting the operation and the quality of structures, systems, components, and services addressed in the RSQM. The QAP will be implemented by organiza~ions responsible for achieving and verifying quality assurance. * *

Ill. The Chief Energy DeliveryZero Carbon Officer has delegated the responsibility and authority for developing and executing the QAP to the Director, Power Generation. Any

.conflicts or questions involving interpretation of the requirements or resulting from the implementation of the QAP must be referred to the Director, Power Generation .

Ross Gould . Frankie MeDermottLora Anguay Director, Power Generation Chief Energy De.'i'leryZero Carbon Officer

RANCHO SEGO LICENSING BASIS DOCUMENT . NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO' QUALITY MANUAL PAGE 3 OF 61 Table of Contents I. ORGANIZATION ..........................................................................................................7 1.0 PURPOSE ............................................................................................................7 2.0 REFERENCE DOCUMENTS ................................................................................7

3.0 POLICY ...............................*.......................... :.............. :............... -......................... 7 4.0 ORGANIZATION AND REQUIREMENTS .................................... :........................ 8 5.0 GENERAL RESPONSIBILITIES ........................................................................... 9 II. QUALITY ASSURANCE PROGRAM ................................ :.: .................. ~ ................. 10 1.0 PURPOSE .......................................................................................................... 10

2.0 REFERENCES

.................................................................................................... 10 3.0 POLICY ................................................................................................................. 10 4.0 GENERAL REQUIREMENTS ............................................................................. 10 5.0 RESPONSIBILITIES .................,. ......................................................................... 12 6.0 ATTACHMENTS ............... ,........................ ,........................................................ 12 Ill. DESIGN CONTROL ..........................................................-....................................... 17 1.0 PURPOSE .......................................*.................................................................. 17

2.0 REFERENCES

.................................................................................................... 17 3.0 POLICY .......................... ,..................................................................................... 17 4.0 4.0 GENERAL REQUIREMENTS ........................................................................ 17 5.0 RESPONSIBILITIES .: ......................................................................................... 19 IV. PROCUREMENT DOCUMENT CONTROL ............................................................. 21 1.0 .PURPOSE ................................. .'. .......................... .-................................... *......... 21 2.0 .REFERENCE DOCUMENTS .....................................-.......... ;.............................. 21 3.0 POLICY ............................ :.................................................. -........... :........... :........ 21 4.0 GENERAL REQUIREMENTS ............................................................................. 21 5.0 RESPONSIBILITIES ...........................................................................................23 V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS ............................................. 24 1.0 PURPOSE .......................... i ....................................... , ..... ; ................................. 24 2.0 REFERENCE DOCUMENTS ..............................................................................24 3.0 POLICY ...............................................................................................................24

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 4 OF 61

. 4.0 GENERAL REQUIREMENTS .............................~,; .............................................. 24

5.0 RESPONSIBILITIES .................................................................,.:........................... 24 VI. DOCUMENT CONTROL ................................................. ,.............. ;......................... 26 1.0 PURPOSE .............................................................................. :........................... 26 2.0 REFERENCE DOCUMENTS ................................ '. .............................................. 26

3.0 POLICY .....................................................................................................,......... 26 4.0 GENERAL REQUIREMENTS ................................................................. ,........... 26 5.0 RESPONSIBILITIES ........................................................................................:.. 27 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES .......... 28 1.0 PURPOSE ........................... :..............................................................................28 2.0 REFERENCE DOCUMENTS ...............................................................................28 3.0 POLICY ...............................................................................................................28 4.0 GENERAL REQUIREMENTS ................................. ;.. ,........................................ 28 5.0 RESPONSIBILITIES ...........................................................................................29 VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, & COMPONENTS

.....................................................................................................................,................. 31 1.0 PURPOSE ..........................................................................................................31 2.0 REFERENCE DOCUMENTS .............................................................................. 31 3.0 POLICY ............................................................................................................~ .. 31 4.0 GENERAL REQUIREMENTS ............................................................................. 31 5.0 RESPONSIBILITIES .......................... , ..................... ,........................................... 32 IX. CONTROL OF SPECIAL PROCESSES ..................................................................33 1.0 PURPOSE ................. :........................................................................................33 2.0 REFERENCE DOCUMENTS .............................................................................. 33 3.0 POLICY .............................. :................................................... '. ................... ;......... 33 4.0 GENERAL REQUIREMENTS ............................................................................. 33 5.0 RESPONSIBILITIES .................................................... :............ ,........................... 33 X. INSPECTION ...........................................................................................................35 1.0 PURPOSE ..................................................................., .......................................

35 2.0 REFERENCE DOCUMENTS ..............................................................................35 3.0- POLICY .....................................................................................*........................... 35

RANCHO SECO LICENSING BASIS DOCUMENT * .** . NUMBER: RSLBD-010 REVISION: 5 TITLE: . RANCHO SECO QUALITY MANUAL * ,,

PAGE 5 OF 61 4.0 GENERAL REQUIREMENTS ........................................ :............................. :...... 35 5.0 RESPONSIBILITIES ................................*............................... :............................ :.. 36 XI. TEST CONTROL ................... ;........................................... :.. ~ ... ~ .... :.............. :........ ~ .. 38 1.0 PURPOSE ..........................................................................................................38 2.0 REFERENCE DOCUMENTS ..............................................................................38 3.0 POLICY ............................................................................*.................... '. .............. 38 4.0 GENERAL REQUIREMENTS ....................................................... :.'. ................... 38 5.0 RESPONSIBILITIES .... ,........................... :: ................... '. ........... :... :.... :...*............. 39 XII. CONTROL OF MEASURING AND TEST EQUIPMENT .......... ;.:.. ;.......................... 40 1.0 PURPOSE ...................................................................*.................................... :... 40 2.0 REFERENCE DOCUMENTS ............................................ ~ ................................ .40 3.0 POLICY .................................................................................................:............. 40 4.0 GENERAL REQUIREMENTS ................................... :............. :.......................... .40 5.0 RESPONSIBILITIES ...........................................................................................40 XIII. HANDLING, STORAGE, AND SHIPPING ..............*....... ~ ........ ~.~ ...... ~ .................... ~42 1.0 PURPOSE ... ~ ......................................... .' ............................................................42 2.0 REFERENCE DOCUMENTS ............................................................................. .42 3.0 POLICY ...............................................................................................................42 4.0 GENERAL REQUIREMENTS ............................................................................ .42 5.0 RESPONSIBILITIES ...........................................................................................42 XIV. INSPECTION, TEST, AND OPERATING STATUS ...............................................44 1.0 PURPOSE

.......................................................................................................... )

44 2.0 REFERENCE DOCUMENTS ............................................................................. .44 3.0 POLICY .......... .'............... *..........................................................*........................... 44 4.0 GENERAL REQUIREMENTS ........... :................................................................ .44 5.0 RESPONSIBILITIES ...........................................................................................44 XV. NONCONFORMING MATERIALS, PARTS, OR COMPONENTS ......................... 46 1.0 PURPOSE ............................................. :........ .' ...................................................46 2.0 REFERENCED DOCUMENTS.: ......................................................................... .46 3.0 POLICY ..................... .' ... .' .....*............................ *.~ ... ::.* .. :......*.... *............................... 46 4.0 GENERAL REQUIREMENTS ... :........................................................................ .46

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 6 OF 61 5.0 RESPONSIBILITIES ...........................................................................................46 XVI. CORRECTIVE ACTION .........................................................................................48 1.0 PURPOSE ............................. :....-........................ :*...............................................48 2.0 REFERENCE DOCUMENTS ............................................................................. .48 3.0 POLICY .....................................-.............................. -.-............................................48 4.0 GENERAL REQUIREMENTS ............................................................................. .48 5.0 RESPONSIBILITIES ...........................................................................................48 XVII. QUALITY ASSURANCE RECORDS ....................................................................50 1.0 PURPOSE ..........................................................................................................50 2.0 REFERENCE DOCUMENTS ...... ~ ....................................................................... 50 3.0 POLICY ........................................., ................. :-....._.................... :......................... 50 4.0 GENERAL REQUIREMENTS .... ,........................................................................50 5.0 RESPONSIBILITIES ............. :.............................................................................51 XVIII. AUDITS ................................................................................................................52 1.0 PURPOSE ....... ,........... .-.:: .......... -.':..... -.....-.:.: .. ,......... :.............................................. 52 2.0 REFERENCE DOCUMENTS .... .-..-.: .......................... :..........................................'52 3.0 POLICY ..................-........................,..................... ;............................................... 52 4.0 GENERAL REQUIREMENTS .. -....................................... ~ ................................... 52 5.0 RESPONSIBILITIES ...........................................................................................53 6.0 AUDITS AND AUDIT FREQUENCIES .......... :...... :.............................................. 53 APPENDIX A l . *****~*************************11 **********1!**********11*.*****.**************************55

RANCHO SECO LICENSING BASIS DOCl.lMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL * *' PAGE 7 OF 61 I. ORGANIZATION 1.0 PURPOSE Tliis section describes the Sacramento Municipal Utility District (SMUD) organization and personnel responsible for establishing, implemen_ting, and verifying the Quality Assurance Program (QAP) at the Rancho Seco ISFSI licensed under 10 CFR Part 72.

2.0 REFERENCE DOCUMENTS 2.1 Rancho Seco Quality Manual, Appendix A 2.2

10 CFR 71.103, Quality Assurance Organization 2.3 10 CFR 72.142, Quality Assurance Organization 3.0 POLICY 3.1 The establishment and implementation of the Rancho Seco QAP; which is comprised of this Rancho Seco Quality Manual (RSQM) and implementing procedures, shall be SMUD's responsibility. Some QAP functions may be delegated to other SMUD approved external organizations, but overall responsibility for the QAP remains with SMUD.

3.2 Definitive lines of authority, responsibility, and communication shall be established for those organizations involved in the QAP.

3.3 The Power Generation personnel assigned to perform quality functions at the Rancho Seco ISFSI have defined responsibilities and organizational freedom to identify problems that affect quality; to initiate, recommend, or provide solutions; and to verify implementation of solutions. They have the authority to initiate action to stop unsatisfactory work pending implementation of necessary corrective action to bring the unsatisfactory conditions into conformance.

3.4 The organizational structure and functional responsibility assignments shall be such that attainment of program objectives is accomplished by individuals or groups who inspect, examine, audit or otherwise verify conformance to established requirements, and who are independent of the individuals or groups who performed the original activity.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 8 OF 61 4.0 ORGANIZATION AND REQUIREMENTS 4.1 The position of Chief Executive Officer & General Manager (CEO & GM) through the Chief Energy DeliveryZero Carbon Officer shall have corporate responsibility fOi overall safe operation of the Rancho Seco ISFSI and shall take any measures needed to ensure acceptable performance of the staff in providing long term monitoring of the spent nuclear fuel. The Director, Power Generation reports to the Chief Zero Carbon Officer.

4.2 The Manager, Rancho Seco Assets rep9rts directly to the Director, Power Generation.. The Manager, Rancho Seco Assets ensures that the Rancho Seco ISFSI is properly staffed and adequately budgeted to ensure staff can safely carry out their responsibilities. ,

The Manager, Rancho Seco Assets is responsible for the safe and reliable operation of the Rancho Seco ISFSI, pursuant to 10 CFR Part 72. The Manager, Rancho Seco As~ets has the responsibility and authority to implement the QAP and ensure optimum quality performance of the Rancho Seco ISFSI.

The Manager, Rancho Seco Assets .sha!I maintain continuing involvement in quality matters and shall assess the scope, status, implementation, and effectiveness of the QAP through the review of Quality Assurance Audits and Surveillances.

4.3 The Program Manager, Regulatory Compliance - Power Generation is responsible for the Rancho Seco nuclear audit program. The Regulatory Compliance - Power Generation group is independent from operating pressures or other lines of authority, and ensures an active QAP is implemented at the Rancho Seco ISFSI in accordance with regulatory requirements. The Regulatory Compliance - Power Generation group has the authority to take any issue concerning the quality of operations at the Rancho Seco ISFSI to the Director, Power Generation.

4.4 The Regulatory Compliance - Power Generation group shall have sufficient authority and organizational freedom to identify problems that affect quality, recommend solutions, and verify implementation of solutions, as appropriate. Commensurate with this responsibility is the authority to initiate action to stop unsatisfactory work pending correction of the unsatisfactory condition.

Corporate and on-site organizational responsibilities are described in greater detail in Rancho Seco Nuclear Administrative Procedure RSNAP-001. Specific duties and responsibilities for organizations whose activities affect quality are described in RSQM Sections II through XVIII and Appendix A.

RANCHO SECO LICENSING BASIS DOCUMENT - -* NUMBER: RSLBD-010 REVISION: 5 TITLE:. RANCHO SECO QUALITY.MANUAL* PAGE 9 OF 61 The Manager, Rancho Seco Assets advises the Director, Power Generation on matters related to the safety of operations at the Rancho

Seco ISFSI.

The Manager, Rancho Seco Assets performs *safety reviews and provides onsite managerT)ent oversight of Rancho Seco _ISFSI activities.

The Manager, Rancho Seco Assets is responsible for reviewing all Potential Deviations from Quality (PDQ) to determine if a condition is a Deviation from Quality (DQ) and requires determination of the cause, extent, remedial corrective actions, and actions to prevent recurrence.

The Manager, Rancho Seco Assets reviews* and approves DQ dispositions and assigns corrective actions identified* in DQ* dispositions.

The Manager, Ran*cho Seco Assets also determines whether a PDQ is potentially reportable pursuant to 10 CFR 21.

5.0 GENERAL RESPONSIBILITIES The nuclear organization is involved in the long term monitoring of the Rancho Seco ISFSI and *is responsible for describing and clearly defining the duties and authority of individuals whose work affects quality. RSNAP-001 defines the Rancho Seco ISFSI organization and the responsibilities associated with each onsite work group.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 10 OF 61 II. -QUALITY ASSURANCE PROGRAM 1.0 PURPOSE The purpose of this section is to describe the Rancho Seco Quality Assurance Program (QAP) implemented at the Rancho Seco ISFSI, licensed and operated pursuant to 10 CFR Part 72.

2.0 REFERENCES

2.1 10 CFR 71, Subpart H, Quality Assurance Requirements for Packaging and Transportation of Radioactive Material 2.2 10 CFR 72, Subpart G, Quality Assurance Requirements for the Independent Storage of Spent Nuclear Fuel 2.3 NRC Form 311, Quality Assurance Approval for Radioactive Material Packages, Approval No. 0489 3.0 POLICY

. The QAP is designed to ensure compliance with the requirements of 10 CFR Part 72, Subpart G "Quality Assurance." The_ QAP is also designed to fulfill the quality requirements for the use of radioactive material transport packages (e.g.,

the MP187 Cask) in accordance with. 10 CFR Part 71, Subpart H "Quality Assurance."

4.0 GENERAL REQUIREMENTS 4.1 The Rancho Seco Quality Manual (RSQM) is organized to present the 18 quality criteria in the order they are addressed in 10 CFR Part 72, Subpart G. The RSQM states the Rancho Seco policy for each criterion and desciibes how controls pertinent to each criterion are to be carried out.

4.2 The QAP is implemented by organizations responsible for achieving quality and by organizations responsible for verifying quality.

4.3 Manager, Rancho Seco Assets iden_tifies the Quality Assurance (QA) classification of structures, systems, and components (SSCs) commensurate to their importance to safety.

4.4 Quality Assurance classification Important to Safety is assigned to SSCs that are considered Important to Safety iri accordance with 10 CFR Part 72, Subpart G. . '

RANCHO SEGO LICENSING BASIS DOCUMENT

NUMBER: RSLBD-010 REVISION: 5 TITLE: . RANCHO SEGO QUALITY MANUAL

PAGE 11 OF 61 4.4.1 The Important to Safety assignment includes 10 CFR 72 (ISFSI) and 1O CFH 71 (Transportation Package) *sscs as specified in RSAP-0302.

4.4.2 All 18 elements of the 10 CFR Part 72, Subpart G quality criteria apply to activities affecting Important to Safety SSCs during operation, maintenance, testing, and mqdifications.

4.5 Some 10 CFR Part 72, Subpart G quality criteria apply to non-Important to Safety programs and activities such as radiation protection, emergency preparedness, ISFSI operations, environmental monitoring, security, training, and 10 CFR 71/72 important-to-safety; as indicated in RSQM-Section II, Attachment 11-1.

4.5.1 The Manager, Rancho Seco Assets identifies the 10 CFR 71 and 10 CFR 72 SSCs that are* lmportant~to-Safety in accordance with RSAP-0302 Configuration* Identification."

4.5.2 SMUD activities performed* under 10 CFR 71 shall be limited'to . I I

procurement, maintenance; repair, and use as authorized by the NRC Quality Assurance Program Approval for Radioactive Material Packages (NRC Form 311; Approval Number 0489).

4.6 Attachment 11-1* indicates the minimum QAP criteria that must be applied to specific Program Activity Areas. * **

4.7 Attachments 11-2 and 11-3 tabulate'the NRC regulatory guides and ANSI standards, with exceptions and applicable revisions, that SMUD is committed to meeting as part of its QAP.

4.8 Activities associated with the safe operation of the Rancho Seco ISFSI are

accomplished under controlled conditions.

Preparations for such activities include confirmation

. that prerequisites have been met.

4.9 Development, control, and use of computer programs associated with the design and safe operation of the Rancho Seco ISFSI are subject to appropriate controls.

4.10 Training programs shall be established to ensure personnel responsible for performing and verifying activities that affect quality have the required proficiency and qualifications to perform the assigned tasks.

4.11 QAP Policy/Proced~res/lnstructions:

a .. The QAP is documented in.written poljcies: procedures, and instructions. The overall policies and general requirements are outlined in the RSQM. Specific details related to implementation of the

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 12 OF 61 established QAP policies are contained- ih Rancho Seco Implementing Procedures (RSIPs) and Rancho Seco Nuclear Administrative Procedures (RSNAPs). Organizations responsible for performing QAP functions shall prepare additional implementing procedures as necessary. RSIPs and RSNAPs are reviewed appropriately to ensure RSQM requirements are accomplished in a controlled manner.

b. Manager, Rancho Seco Assets is responsible for RSQM preparation, issuance, and control. The RSQM, including any changes, supplements, or attachments, is issued and maintained as a controlled document.

c. Manager,* Rancho Seco Assets shall review and approve proposed RSQM changes.

4.12 Resolution of Differences:

RSQM requirements take precedence over differing quality requirements specified in other work group procedures until the Manager, Rancho Seco Assets evaluates the issue and determines which requirements must be modified.

Questions or disputes involving RSQM interpretation or implementation must be referred to the Manager, Rancho Seco Assets for resolution. The Manager, Rancho Seco Assets may elect to confer with other individuals or groups within SMUD, or senior SMUD management for resolution.

4.13 Packaging and Transportation of Radioactive Material:

The QAP shall be applied to packaging and transportation of radioactive material as specified in References 2.1 and 2.3.

5.0 RESPONSIBILITIES General organizational responsibilities are described in RSQM Section I, ORGANIZATION 6.0 ATTACHMENTS 11-1 Application of Rancho Seco Quality Assurance Program Criteria 11-2 Regulatory Commitments 11-3 Exceptions

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE 13 OF 61 Attachment 11-1 APPLICATION OF RANCHO SECO QUALITY ASSURANCE PROGRAM (QAP) CRITERIA (A, 8 , c>

(A) An 'X' means application of the RSQM requirements associated with the QAP Criteria is required.

(B) No 'X' means application of the RSQM requirements associated with the QAP Criteria is optional.

(C) RSQ M.imp Iementino details are prov1"d ed.int he RSAP s an d 0 th er QAP.imp Iementino proced ures. ..

1>

QAP CRITERIA <

Program Activity Areas I

.j, I II Ill IV Y.. VI VII VIII IX ~ XI XII XIII XIV xv XVI XVII XVIII References*

10 CFR 71/72 Important-to- ISFSI TS 5.4..1 k Safety, Category A X X X X X X X X X X X X X X X X. X X . RSQM, APP. A, 10 c*FR 72, Subpart G RSAP-0302,ATT. 6 ISFSI Operations (License ISFSI TS 5.4.1 k Condition and Tech. Spec. X X X X X X X X X X X RSQM Section XVIII Compliance) *10 CFR 72 License ISFSI TS 5.4.1 k Radiation Protection X X x<2i X X . X X X X 10 CFR*20

'* RSQM,APP.A .*.

Radiological Environmental ISFSI TS 5.4.1 k

<3> X x<4>

0 Monitoring Program (REMP) X X X X X X* X X *Reg. Gu ide 4.15

- , RS9M.-APP:, A

' ISFSI TS 5.4.1 k Security X X X X X X X X 10 CFR 72.44 & 186 10 CFR 73 ISFSI TS 5.4.1k l Emeraencv Preoaredness X X X X X X X X RSQIVl,APP.A ISFSI TS 5.4.1k Training X X X X .X *x X X 10 CFR 72.190

.. RSQM,APP.A 10 CFR 71 /72 Important-to- ISFIS TS 5.4.1 k Safety, Category B & C < 5> X X X X X X X X X X X . x.. X X RSAP-0302, ATT. 6

. 10 CFR 72.3 & 72.140

.. 10 CFR 71.101

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 14 OF 61 Footnotes:

(1) 10 CFR Part 72, Subp~rtG, Quality Criteria and corresponding RSQM section titles:

I. Organization II. Quality Assurance Criteria Ill. Design Control IV. Procurement Document Control V. Instruction, Procedures, and Drawings VI. Document Control VII. Control of Purchased Material, Equipment, and Services VIII. Identification and Control of Materials, Parts, and Components IX. Control of Special Processes X. Inspection XI. Test Control XII. Control of Measuring and Test Equipment XIII.. Handling, Storage, and Shipping XIV. Inspection, Test, and Operating Status XV. Nonconforming Materials, Parts, or Components XVI. Corrective Action XVII. Quality Assurance Records XVIII. Audits (2) Design Control as applied to permanent protective shielding. *

(3) Rancho Seco applies the NRO Regulatory Guide 4.15 QA/QC program to the REMP. This Regulatory Guide 4.15 program meets the applicable QA/QC program requirements. *

(4) As applied to environmental monitoring laboratory analysis services.

(5) As applied to 10 CFR 71 activities authorized pursuant to NRG Form 311, "Quality Assurance Approval for Radioactive Material Packages,"

Approval No. 0489. (Refer to RSQM Section II, Steps 4.4.1 and 4.5.2)

RANCHO SECO LICENSING BASIS DOCUMENT ,, NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL* PAGE 15 OF 61 Attachment 11-2 REGULATORY COMMITMENTS SMUD commits to the requirements of the regulations and industry standards listed below with any exceptions identified in Attachment 11-3.

Document Revision/Date Title

1. Regulatory Guide 9/75 Personnel Selection and Training 1.8 Per ISFSI Tech. Spec. 5.3

2. Regulatory Guide 8/85 Supplementary Requirements for Quality 1.28 1983 Assurance Records (See Attachment ANSI/ASME NQA- 11-3, Exception No. 1)

Supplement 17S-1

3. Regulatory Guide 1/79

Auditing of Quality Assurance Programs 1.144 1977 for Nuclear Power Plants ANSI N45.2.12

4. Regulatory Guide 8/80 Qualification of Quality Assurance 1.146 1978 Program Audit Personnel for Nuclear ANSI N45.2.23 Power Plants

RANCHO SECO LICENSING BASIS DOCUMENT * ** NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 16 OF 61

. ,Attachment 11-'3 EXCEPTION EXCEPTION: Regulatory Guide 1.28/NQA-1, Supplement 17S-1 SMUD complies with the recommendations of this regulatory guide with the following clarifications:

With regard to Section 2.4 of Supplement 17S-1 titled Index: The phrase "an index"is clarified to rnean a collection of documents or indices which, when taken together, supplythe'information attributed to "an index" in the standard.

The specific location of a record "within a storage area" may not be delineated (e.g., the specific location within a computer record file may not be constant; further, SMUD may utilize a computer assisted random access filing system where such location could not be readily "documented," or would such a location be "relevant.") The storage location will be delineated, but where file locations change with time, the specific location of a record within that file may not always be documented. * *

With regard to Section 4.3, Supplement 17S-1 titled Safekeeping: Routine general office and nuclear site security systems and access controls are provided: No special security systems are required to be established for record storage areas.

With regard to Section 4.4, Supplement 17S-1, titled Facility: This Section provides no*distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: "Records completed but not yet transferred for permanent storage may be temporarily stored in one-hour fire rated file cabinets. In general, records shall not be maintained in such

temporary storage for more than four months after completion without being microfilmed or placed in permanent storage. *Open-ended documents revised or updated on a more-or-less continuing basis over an extended period of time (e.g.

personnel qualification and training documents, equipment history cards) which are cumulative in nature (e.g.* nonconforming item logs and control room log books) shall become QA records when they are issued as a specific revision (e.g.

the master audit schedul,e); when they are filled-up or di.scontinued (e.g. log books a

or equipment history cards); on predefined periodic basis when the completed portion of the ongoing document shall be transferred to records control as a "record" (e.g. training and qualification records).

RANCHO SEGO LICENSING BASIS DOCUMENT : NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL*" PAGE 17 OF 61 Ill.: DESIGN CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for control of design activities affecting applicable structures, systems, and components at the Rancho Seco ISFSI, licensed under 10 CFR Part 72.

In addition, this section defines the requirements for developing and .

implementing control. measures that ensure design functions _affecting the performance of operational, construction, and modific~tion activities are carried out in a planned, controlled, and orderly manner and are in compliance with applicable regulatory commitments.

2.0 REFERENCES

2.1 10 CFR 72.48, Changes, Tests, and Experi_ments .*

2.2 10.CFR 71.107, Package Design Control 2.3 10 CFR 72.146, _Design Control 3.0 POLICY The requirements specified in this section apply to all organizations performing design functions for modifications, changes, replacement or addition of structures, systems, or components at the Rancho Seco ISFSI.

4.0 4.0 GENERAL REQUIREMENTS Procedures shall be established ~nd executed to control design activities.

Procedures*covering design contrpl activities shall include the following requirements:

4.1 Applicable design inputs s*uch as design bases, regulatory requirements,

. codes and standards, methodology, and all assumptions with appropriate j~stifications are identified, documented, and correctly translated into design output documents such as specifi*cations, drawings, procedures, or instructions. . . .

4.2 Exceptions, waivers to or deviations from engin*eering requirements are documented and controlled.

4.3 Methods are specified for the selection and classification of suitable materials, parts, equipment, and processes used in meeting applicable requirements for structures, systems, and components.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 18 OF 61 Materials; parts, compor;,ents, and equipment that are standard, commercial (off _the shelf), or which have. been previously approved for other similar applications are reviewed.for suitability and appropriately classified.

4.4 Systematic methods are established for communicating and controlling the flow of related design information across the external and internal design interfaces, including any changes to the design information as the work progresses.

4.5 Interfaces between Engineering and other participating design organizations (either internal or external to SMUD) are identified and documented. This identification includes those organizations providing design inputs, design analyses, design specifications, and design verification for operational, construction and modification design activities.

4.6 Participating design organizations establish and describe the controlled methods for preparation, review, approval; release, distribution, and revision of documents (such as design analyses, specifications, drawings, reports) involving design interfaces.

4.7 Design control* measures shall provide for verifying or checking the adequacy of design modifications or design changes. Acceptable verification methods include, but are not limited to, design reviews, alternate calculations, or qualification testing. If a test program is used to verify the adequacy of a design, it must include qualification testing of a prototype unit under the most adverse design conditions.

4.8 Computer program codes used for design calculations are certified for use and their use is specified.

4.9 Design verification is to be performed by competent individuals or groups other than those who performed the original design, but who may-be from the same organization. The results of the design verification efforts must be documented with the identification of the verifier clearly provided.

4.1 O Provisions are specified for the control of design analyses such as accident analyses; compatibility of _materials; accessibility for maintenance and repair; and delineation of acceptance criteria for inspections and tests.

4.11 Design problems.that are identified during field installation or testing activities shall be documented and -forwarded to the Manager, Rancho Seco Assets for evaluation and resolution.

4.12 Design and specification changes;* including field changes, receive the same degree of control and approval as the original design unless another qualified, responsible organization is specifically designated.

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PAGE 19 OF 61 4.13

Errors and deficiencies in the design :p*rocess, including computer programs that could adversely affect structures, systems, or components are documented and* corrective action *is taken to preclude repetition.

4.14 Proposed modifications or design changes which involve an Unreviewed Safety Question or'a change to Rancho Seco- ISFSI License or Technical Specifications are handled in accordance with 10 CFR 72.48 or 10 CFR 71.107(c), as appropriate.

4.15 Modifications are reviewed by plant personnel for effect on plant operation prior to making the modification operational.

4.16 Design documents are reviewed for accessibility of equipment and components for tests, maint~nance, or modifications.

4.17 Design and/or test documentation must be obtained from all suppliers on procurements of ASME code components used for replacement or modification to the Rancho Seco ISFSI.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for implementing a design control process per this.section and to:

a. Provide and control design change packages.

b. Ensure integrity and regulatory conformance of configuration control.

c: Provide-plant configuration control including establishing and .

maintaining baseline documents ..

d. Provide engineering supp9rt for ISFSI computers.

e. Perform probabilistic *anaiysis in support of plant design, when necessary.*

f. Provide engineering support to the Rancho Seco nuclear organization. . .

g. Provide an_d maintain engineering procedures, standards and specifications and dr_awings. .

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PAGE 20 OF 61

h. Review and concur with design control procedures.

j. Monitor implementation of the de~ign control program.

k. Ensure that audits of the design control program are conducted in

accordance with RSQM Section XVII.I_

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NUMBER: RSLBD-010

REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL/:-'* .. * .PAGE 21 'OF 61 IV. PROCUREMENT DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance:Program (QAP) measures established to control procurement documents for material, equipment, and services at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.109, Procurement Document Control 2.2 10 CFR 72.148, Procurement Document Control 3.0 POLICY Procurement documents for applicable Rancho Seco ISFSI materials, equipment, components/spares, or services shall include applicable technical requirements, quality* requirements, regulatory requirements, and other provisions necessary to ensure that purchased items and services are adequately described to the supplier.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established and implemented to control the preparation, review, approval and issuance of procurement documents.

4.2 Procurement documents shall include provisions for the following, as applicable:

a. Description of item or service.

b. Identification of design specifications and technical requirements by reference to specific drawings, codes, regulations, industry standards, or other documentation, including the applicable revision thereto that describe the items or services to be furnished.

c. Identification of test, inspection, and acceptance requirements, and any special instructions and requirements for activities such as design, fabrication, identification, cleaning, erecting, packaging, handling, shipping, and extended storage.

d. Identification of applicable QAP criteria.

e. Applicability of 10 CFR Part 21.

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f. Identification of the documentation, S.L~ch as.:drawings, ~pecifications, procedures, fabrication. and inspectiori plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test reports to be prepared and maintained by the supplier or contractor, and the requirement to submit this documentation to SMUD for review and approval.

g. Identification of those records to be retained, controlled, and maintained by the supplier or contractor arid those to be delivered to SMUD at the time of shipment of the procured item.

h. SMUD's right of access to the supplier's facilities and records for inspectio*n and audits.

i. Extension of applicable requirements to lower tier subcontractors and suppliers, including SMUD's right -of access to facilities and records.

j. Supplier submittal .of nonconforming items and SMUD approval for "Accept as is" or "Repair" dispositions of non-conformances.

k. SMUD's right to hold shipment if procurement document requirements, including those for documentation, have not been fulfilled.

4.3 Technical and quality review by qualified personnel and approval by designated individuals shall be performed prior to issuance of the procurement document. The review and approval shall be documented and available for verification.

4.4 Review and concurrence by qualified personnel shall be performed to ensure adequacy of quality requirements and to verify that the requirements are correctly stated, .inspectable, and controllable; that there are adequate acceptance and- rejectior:, criteria; and that the procurement documents have been prepared, reviewed, and approved in accordance with the requirements of the established procedures.

4.5 Revisions to procurement documents shall receive an equivalent review and approval as the original documents. Exceptions to this include changes in quantity, estimated price, cost codes, taxes, format or editorial changes that do not affect the quality of the item or service.

4.6 Procurement documents for spare or replacement parts for Important to Safety structures, systems, or components shall specify procurement controls at least equivalent to those required for purchase of the original equipment.

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4. 7

Methods shall be* established to ensure thatthe item$ received are

traceable to procurement documents: *

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets*is responsible for:

a. Purchase items in conformance with procurement documents.

b. Purchase Important to Safety items from -approved suppliers.

c. Arrange for suppliers to be placed on an Approved Suppliers List (ASL). Refer to RSQM Section VII, Step 4.2 regarding ASL.

d. Arrange for source inspection when specified on the procurement documents.. . ** :1.~..

1

e. Designate qualified engineers ,(SMUD or Contract) to provide technical and quality requirements for purchasing Important to Safety) items.

f. Developing and maintaining.the ASL.

g. Review and concurrence of material management procedures.

h. Review and concurrence of procurement documents for Important to Safety items.

i. Ensuring audits of the procurement document control program are conducted in accordance with RSQM Section XVIII.

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V.. INSTRUCTIONS, PROCEDURES, AND DRAWINGS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that activities affecting the quality or safety of the Rancho Seco ISFSI are described and accomplished in accordance with documented instructions, procedures, drawings, or other documents appropriate to the circumstances.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.150, Instructions, Procedures, and Drawings 2.2 10 CFR 72.111, Instructions, Procedures, and Drawings 3.0 POLICY Activities affecting quality performance or operational safety at the Rancho Seco ISFSI shall be described and implemented in accordance with documented instructions, procedures, and drawings.

4.0 GENERAL REQUIREMENTS 4.1 Written instructions, procedures, drawings, or other documents appropriate to the circumstances shall be prepared to provide measures for complying with the provisions of the QAP.

4.2 Instructions, procedures, or drawings shall include applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished.

4.3 Procedures shall be established for the review, approval, issuance, change, and use of documents that specify quality requirements such as instructions, procedures, drawings, and other documents that implement the QAP.

4.4 Activities affecting quality shall be accomplished in accordance with approved instructions, procedures, and drawings.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for ensuring activities that affect quality are described in instructions, procedures, and drawings.

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PAGE 25 OF 61 5.2 The. Manager,*Rahcho Seco Assets is responsible for-ensuring that audits are conducted in accordance with.RSQM Section XVIII.

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VI. DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the issuance and control of documents that control activities affecting quality at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.113, Document Control 2.2 10 CFR 72.152, Document Control 3.0 POLICY Applicable documents, including changes thereto, that prescribe activities affecting the quality operation atthe Rancho Seco.lSFSI shall be issued and controlled in a manner that precludes the use of inappropriate or outdated documents.

4.0 GENERAL REQUIREMENTS 4.1 The Manager, Rancho Seco Assets shall establish procedures that define responsibilities and *delineate the sequence of actions to be accomplished in preparation, review, approval, and control of instructions, procedures, or drawings, or changes thereto.

4.2 Procedures that establish document control measures shall include:

a. Identification of documents to be controlled;

b. Identification of individuals or organizations responsible for the review, approval, issuance, and revision of documents;

c. Criteria to ensure that adequate technical and quality requirements are incorporated prior to implementation;

d. Review of changes to documents by the same organizations that performed the initial review and approval or by the organizations designated in accordance with the applicable procedures.

4.3 Controlled documents, including changes, shall be issued and distributed to organizations noted on distribution lists so that proper and current documents are available as required, and obsolete or superseded documents are identified and not used for prescribed activities.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: . RANCHO*SECO QUALITY MANUAL *....- PAGE 27 OF 61 4.4 Master lists or equivalent means i:;hall be-used Jo identify the current revision of controlled documents and made available at work locations, as appropriate.

5.0 RESPONSIBILITIES

General organizational responsibilities are describee:I in.S~ction I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Developing and implementing a document control program in accordance with this section. * *

b. Complying with document review, approval, and revision authority defined in plant administrative procedures.

c. Ensuring qualified personnel review d_6cuments with quality assurance related aspects, as appropriate.'* *

d. Reviewing and concurring with document control procedures.

e. Reviewing and concurring with procedures., instructions, or documents that implement the QAP to ensure compliance with applicable RSQM provisions.

f. Ensuring that audits of the document control program are conducted in accordance with RSQM Section XVI 11 ..

RANCHO SECO LICENSING BASIS DOCUMENT . NUMSER: RSLBD-010 REVISION: 5 TITLE: . RANCHO SECO QUALITY MANUAL PAGE 28 OF 61 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES.*

1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that material, equipment, c1nd services purchased for the Rancho Seco ISFSI conform to the procurement documents.

2.0 REFERENCE DOCUMENTS .

2.f 10 CFR 71.115, Control of Purchased Material, Equipment, and Services 2.2 10 CFR 72.154, Control of Purchased Material, Equipment, and Services 3.0 POLICY.

Measures shall be established to ensure that material, equipment, and services conform to the specified requirements of the related procurement documents.

4.0 GENERAL REQUIREMENTS 4.1 Control of pu.rchased material, equipment, and services shall include the following, as appropriate*: *

a. Source evaluation and selection of suppliers.

b. Objective evidence of quality furnished by the supplier.

c. Source inspection, audit, and/or surveillance activities.

d. Examination of items or services upon delivery or completion.

4.2 Results of source evaluation and selection of suppliers shall be documented and retained on file.

4.3 Procedures for control of materials; equipment, and services shall address the following:

a. Responsibilities of departments performing supplier technical and quality evaluations, and the method of evaluation. .

b.

Inspection activities that specify the characteristics or processes to be witnessed, inspected or verified; the method of verification and the extent of documentation required; and the organization responsible for implementing the inspection. * *

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REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL* !* PAGE29 OF 61 c *. : Auoiting*to verify.cqnformance and.implementation to requirements of

. this policy. Source inspection ai:,d audits may not be necessary when conformance of an item to procurement requirements can be verified by receipt inspection, review of test reports,* certified reports or other.

means specified by qualified personnel.

d. Receipt inspection *of supplier furnished items to ensure: (1) the proper identification of ltems on the receiving documentation, (2) that the

items are inspected and judged acceptable in accordance with predetermined instructions prior to installation or use, (3) that inspection records or certificates of conformanc*e are available at the plant site prior to instalJation or use of the items, and (4) that items accepted and released are identified as to their inspection status prior to storage or use.

e. Review, acceptance, and maintenance of records to ensure adequacy of documentation that identifies the purchased item, and tliat specific procurement requirements (e.g., codes, standards, specifications) have been met or satisfied. * *

f. Review and approval of documentation required to be submitted by the procurement documents (CMTR's, Certificate of Compliance, Procedures, Specifications, etc.).

g. Procurement control of spare pr replacement parts for Important to Safety systems to ensure compliance with requirements that are (1) equivalent to the original requirements or (2) specified by a properly reviewed and approved revision to the original requirements.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION. . .

5.1 The Manager, Rancho Seco Assets is responsible .for:

.a. Ensuring quality and qualifications .of parts and materials by (1) developing quality specifications and (2) storing parts and materials in accordance with regulatory requirements and in coordination with appropriate nuclear organization groups.

b. Ensuring regulatory compliance of materials and parts by managing procurement documentation and reviewing (and implementing, as appropriate) NRC and related parts/materials bulletins.

c. Examiningdtems or services upon delivery or completion, as deemed

. necessary to supplement or replace formal inspection activities.

d. Developing and ma.intaining the ASL

e. Performing required inspections, evaluations, and audits.

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f. The review and concurrence with niaterial management procedures.

.*' * /

1 ** *

g. Ensuring that audits of'fhe control of purchased material, equipment, and services are conducted in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL -* PAGE 31 OF 61 VIII. IDENTIFICATION AND. C'oNTROL OF MATERIALS. PARTS. &

.COMPONENTS-1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the identification and control of material, parts, and components for the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.117, Identification and Control of Materials, Parts, and Components 2.2 10 CFR 72.156, Identification and Control of Materials, Parts, and Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components are properly identified and controlled to preclude the use of incorrect or nonconforming items.

4.0 GENERAL REQUIREMENTS 4.1 Materials, parts, or components, including partially fabricated subassemblies and consumables, shall be identified so they can be related to their applicable drawing, specification, purchase document, and inspection records at any stage from initial receipt through fabrication/construction, installation, repair, modification, or use.

4.2 Identification controls, implementation procedures, and documentation shall be used to ensure that only correct and accepted items are used during all stages of construction, installation, and operation.

4.3 Unique identification of items is required (e.g., by part number, serial number, heat number, drawing identification number, or other traceable coding methods).

4.4 Identification is required to be maintained either on the item or on records traceable to the item. Physical identification such as by marking or tagging shall be used to the maximum extent practical.

4.5 When specified by codes, standards, procurement documents, or other requirements, identification is required such that items are traceable to appropriate documentation (e.g., specifications, drawings, purchase

RANCHO SECO LICENSING BASIS E>OCL)MENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL ...

PAGE 32 OF 61 orders, manqfacturing and inspection ,poc1,,1ments, nonconformance reports, physical*or chemical mill test repOrts) .. , .

4.6 Where identification marking is employed, the marking is required to be

clear, unambiguous and indelible, and shall be applied such as not to affect the fit, function, or quality of the iter.n, 4.7 Markings shall be transferred to each part of an item, if subdivided. The markings shall not be obliterated or hidden by s1,1rface treatment or

coatings unless other means of identification are substituted.

4.8 Procedures are required to provide for the verification and documentation of correct identification of items prior to release for use. Items may be conditionally released under adequate procedural controls.

4.9 Bulk consumables (such as weld rod, chemicals, reagents, gases, resins, lubricating oil and grease, fuel oil, cleaning solvents, etc.) must be identified and controlled in accordance with approved procedures that specify the applicable requirements for identification and use of the consumables ..

4.10 In the event the identification or traceability of an item is lost, it shall be handled in accordance with RSQM Section XV. -

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Identification and control of items from p'rocurement through withdrawal from the warehouse.

b. Maintaining identification and control of items from withdrawal from the warehouse through installation.

c. Review and concurrence of procedures for controlling_ material, parts, and components from procurement through storage, issuance, and installation.

d. Ensuring that audits of the process for identification and control of materials, parts, and components are conducted in accordanc~ with RSQM Section XVII I.

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IX~ CONTROL OF SPECIAL PROCESSES .

1.0 PURPOSE This section describes the Rancho Secb Quality Assurance Program (QAP) measures established to control special procE3sse*s used atthe Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 ASME Section V and IX 2.2 10 CFR 71.119, Control of Special Processes 2.3 10 CFR 72.158, Control of Special Processes 3.0 POLICY Prior to performing any special processes, procedures shall be.established and implemented to ensure that special processes and equipment are controlled and that qualified personnel and procedures accomplish required activities.

4.0 GENERAL REQUIREMENTS 4.1 Prior to performing any special processes, procedures shall be prepared to provide for proper control of special processes, which include welding, heat treating, chemical cleaning, application of protectiye coatings, and nondestructive examination (NOE).

4.2 Controls shall be established to ensure that only approved materials and equipment are used to perform special processes:

4.3 Personnel who perform special processes shall be qualified in accordance with industry standards: *

4.4 Special process requirements sh~II be prescribed in the controlling spe'cifications, d~awings, procurement documents, or procedures.

5.0 RESPONSIBILITIES General organizational respor;tsibilities. are described. in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Specifying the special processes on design documents governing maintenance/modification activities.

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b. Developing, qualifying, and maintainirm special process procedures in accordance with Step 4.1 *of this RSQM section.

c. Qualifying personnel or approving contract personnel to perform special processes identified in Step 4.1 of this RSQM section.

* * * ; I * *

d. Performing NOE or approving contr~ct personnel to perform NOE.

e. Review and concurrence of special process procedures.

f. Ensuring that audits of the special proces$ program are conducted in accordance with RSQM Section XVIII.

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.x~ *1NSPECTION.

1.0 PURPOSE This section de~ci-ibes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the inspection* of material, parts, and components for the Rancho Seco ISFSI . _

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.121, Internal Inspection 2.2 10 CFR 72.160, Licensee Inspection 3.0 POLICY Procedures shall be established and implemented to ensure that inspections are performed to verify compliance with specified requirements at the Rancho Seco ISFSI. .

4.0 GENERAL REQUIREMENTS 4.1 Inspections shall be applied to receiving, maintenance, and modification activities to verify that items and activities conform to specified requirements.

4.2 Inspection planning documents shall be prepared or reviewed by Quality Assurance in accordance with established procedures. Inspection planning documents shall identify the following as applicable:

a. Characteristics and activities to be inspected;

b. Inspection organization;

c. Accept/reject criteria;

d. Hold points and/or witness points;

e. Inspection Methods;

f. Provisions for recording objective evidence of inspection results; and

g. Measuring and test equipment of the necessary accuracy for performing inspection.

4.3 Process monitoring may be used where direct inspection alone is impractical or inadequate. Both inspection and process monitoring are performed when control is inadequate without both.

4.4 Training and qualification of personnel, who perform inspections including NOE, shall be performed in accordance with approved procedures.

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-4.5

Hold points are:designated as mandatory inspection points when confirmation is needed that the work at the point is ~cceptable before additional work can proceed. Authorized personnel perform hold point inspections and release work for further processing or use.

4.6 Inspections, including any required hold points, are performed and documented in accordance with written procedures. Inspection results are documented and evaluated _by qualified personnel to verify acceptability.

4.7 Qualified personnel perform inspections of receiving, maintenance, and modification activities.

4.8 Inspection records shall contain the following where applicable:

a. Item inspected;

b. The date of the inspection;

c. Inspector or data recorder identification;

d. Identification of M&TE used to perform inspections;

e. Type of observation;

f. Results or acceptability; and

g. Reference to information on action taken on non-conformances to resolve any discrepancies noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Ensuring that Quality Control Inspectors are qualified.

b. Preparing or reviewing inspection-planning documents for modification/maintenance activities.

c. Performing inspections per inspection plans.

d. Ensuring that audits of the inspection program are conducted in accordance with RSQM Section XVIII.

e. Ensuring that inspections are performed as required by inspection planning.

f. Ensuring that work does not proceed beyond inspector signoffs for hold points.

g. Supporting inspection activities.

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h. Providing prompt corrective action to any deficiencies-found during the

inspection. *.

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,XI. TEST CONTROL

1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for acceptance and surveillance test control at the Rancho Seco ISFSI . . .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.123, Test Control 2.2 10 CFR 72;162; Test Control 3.0 POLICY Procedures shall be established and implemented to ensure that required testing to demonstrate that structures, systems, and components will perform satisfactorily in service is identified, performed and documented.

4.0 GENERAL REQUIREMENTS 4.1 Tests shall be performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

a. Qualification tests, as applicable, to verify design adequacy.

b. Tests of equipment and components to ensure their proper operation prior to delivery or pre-operational tests;

c. Pre-operational tests to ensure proper and safe operation of systems and equipment prior to startup tests or operations;

d. Startup tests to ensure proper and safe operation of systems and equipment.

e. Surveillance tests to ensure continuing proper and safe operation of systems and equipment. *

f. Maintenance tests after preventive or corrective maintenance.

4.2 Test procedyres and instru~tions shall .include provisions for the following, as applicable:

a. The requirements and acceptance limits contained in the applicable design and procurement documents;

b. Test prerequisites such as calibrated instrumentation, required test equipment, degree of completeness of the item to be tested, suitable

RANCHO SECO LICENSING BASIS DOCUMENl NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL : PAGE 39 OF 61 and controlled envtronmen_taL'conditions, and provisions for data collection and storage*; ** *** *

c. Verifying that test prerequisites have been met;

d. lnstru.ctions:for performing the-test;

e. Any inspection points; *

f. Acceptance criteria;

g. Documenting or recording test data and results; and

h. Verification of completion.

4.3 Test procedures and instructions shall be reviewed by the applicable organizations for technical content.

4.4 Test results shall be documented and evaluated by responsible authorities to ensure that test requirements have been satisfied. .

4.5 Test records shall contain the following information where applicable:

a. Item tested and type of observation;

b. The date and results of the test;

c. Information related to deviations or non-conformances;

{

d. Identification of person recording the data;

e. Evidence as to the acceptability of the results; and

f. . Action taken to* resolve any deviations and non-conformances noted.

5.0 RESPONSIBILITIES General organizational responsibllities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Establishing the procedure for ,acceptance and surveillance testing.

b. Providing personnel to.perform the t~_sting a_nd acceptance evaluations.

c. Ensuring that audits ofthe* test d::mtrol*program are conducted in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 40 OF 61 XII. CONTROL OF MEASURING AND TEST EQUIPMENT .

1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the control of measuring and test equipment at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 GFR 71.125, Control of Measuring and Test Equipment 2.2 10 CFR 72.164, Control of Measuring and Test Equipment 3.0 POLICY Procedures shall be established and implemented to ensure that measuring and testing devices used in final acceptance of activities affecting quality are properly controlled, calibrated, and adjusted at specified intervals to maintain the desired accuracy.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for calibration, maintenance, and control of measuring and test equipment utilized in the operation, measurement, inspection, or monitoring of items.

4.2 Measuring and Test Equipment (M&TE) shall be calibrated at specified intervals. These intervals are based on the amount of use, stability, characteristics and other conditions that could adversely affect the required measurement accuracy. Reference and secondary calibration standards shall be traceable to nationally recognized standards where they exist. Where national standards do not exist, provisions shall be established to document the basis for calibration.

4.3 M&TE used for calibrating plant process instrumentation (Pl) shall have calibration ranges, precision, and accuracy's such that the Pl can be calibrated from M&TE with an accuracy ratio of at least two-to-one (M&TE to Pl). Calibration accuracy ratios of less than two but equal to or better than one shall be acceptable when equipment to meet specified requirements is not commercially available. The basis of acceptance in these cases shall be documented.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

RANCHO SEGO LICENSING BASIS DOCUMENT* NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL .. PAGE 41 OF 61 5.1 The Manager, Rancho s,eco Assets is responsi.ble for:

a. Establishing methods for control of measuring and test equipment.

b. Determining the need for calibrated instruments and measuring devices in Rancho *Seco ISFSI activities.*.

c. Providing administrative procedures that address the requirements for calibration.

d. Control of measurement devices to ensure their use and accuracy.

e. Ensuring that audits of the control of measuring and test equipment program are conducted in accordance with RSQM Section XVIII.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL .

PAGE42 OF 61 XIII. HANDLING,* STORAGE,' AND SHIPPING 1.0 PURPOSE This section describes the Rancho Seco Quality.Assurance Program (QAP) measures established to provide for the handling,.storage, shipping, cleaning, and preservation of material and equipment at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.127, Handling, Storage, and Shipping 2.2 10 CFR 72.166, Handling, Storage, and Shipping 3.0 POLICY Procedures shall be established and implemented to ensure that materials and equipment are properly handled, stored, shipped, cleaned, and preserved to prevent damage or deterioration.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for assuring that proper handling, storage, shipping, and preservation instructions are included in applicable drawings and/or specifications.

4.2 When required for specific items, special protective environments, such as inert gas atmosphere, specific moisture content levels, and temperature levels, shall be specified.

4.3 A shelf life program shall be in effect and monitored to prevent usage after the expiration date without re-certification for extension of shelf life.

4.4 Special material handling and preservation instructions shall be developed when required by applicable drawings and/or specifications.

4.5 Materials used for packaging, shipment, and, storage of items that have the potential for causing contamination or radiation exposure require marking and labeling to indicate the need for special radiological controls.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I,

-ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

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a. Establishing m_ethods and procedures to eo~ure that applicable drawings and/or s*pecifications include handling, storage, shipping, and preservation requirements.

b. Establishing methods for special handling, storage, and preservation during maintenance activities.

c. Providing administrative procedures that specify the required controls.

d. Maintaining material and warehousing control of items and equipment that require special handling-and storage.

e. Ensuring that audits of conformance to the handling, storage, and shipping program are conducted in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL * . , PAGE 44 OF 61 XIV. INSPECTION,*TEST~:AND*OPERATING STATUS

~. . . ' . ' .

1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a system to identify the inspection, test, and operating status of individual items at the Rancho ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 71.129, Inspection, Test and Operating Status 2.2 10 CFR 72.168, Inspection, Test and Operating Status 3.0 POLICY Procedures shall be established and implemented to ensure that measures are provided to indicate the status of inspections, tests, and operations.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall specify the degree of control required for the indication of inspection and test status of items required for modification activities.

4.2 The sequence of inspections, tests, and other operations, and changes thereto, shall be controlled by procedures.

4.3 Procedures shall provide methods for identifying the nonconforming items, inoperable systems and components by tags, markings, labels, etc. to prevent inadvertent use.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Facilities Maintenance is responsible for Clearance Program procedures to erisure:

a. Safety of personnel and equipment during maintenance and testing activities.

b. Installation and removal of test and operating status indicators.

c. Identifying the quality status of applicable material, parts, and components.

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d. Ensuring that.audits of the inspectiqn, *test, and op~rating status

program are conducted in accordance with RSQM Section XVIII.

RANCHO SEGO LICENSING BASIS DGCUMENT NUMBER: RSLBD-01.0 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGF46 OF61 XV. NONCONFORMING MATER~ALS, PARTS, OR*COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Ass*urance Program (QAP) measures established for controlling material, components, parts, or systems that are not in conformance to specified requirements at the Rancho Seco ISFSI .

2.0 REFERENCED DOCUMENTS 2.1 10 CFR 71.131, Nonco~forming Materiais, Parts or Components 2.2 1() CFR 72.170, Nonconforming Materials, Parts or Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components that do not conform to specified requirements are controlled to prevent their inadvertent use or installation.

4.0 GENERAL REQUIREMENTS .

4.1 Procedures shall be developed for controlling, documenting, and resolving items, services, or activities identified as nonconforming.

4.2 Marking, tagging, segregating, or other means shall identify nonconforming items.

4.3 Non-conformances shall be documented, processed, controlled and retained to provide records of the actions taken to resolve the nonconforming condition.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions. (Refer to RSQM Section XVI regarding corrective action program)

]

b. Establishing methods for controlling and documenting non-conformances.

c. Ensuring expertise is available to disposition non-conformances.

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d. ,Developing ~afetyanalysesJbat.addre~s. th~ nonconforming condition,

if required. * * ** * * * * * ** * * * -

e. Auditing the nonconforming materials, parts, or components program

per RSQM*Section XVIII.

f. Taking appropriate action to* ensure operation of the plant in conformance to license requirements when a nonconformance identifies a condition prohibiting components, structures, or systems from returning to an acceptable condition.

g. Determining the safety significance of the nonconforming condition on the status of the plant.

h. Reviewing identified conditions that are adverse to quality and the

. corrective action associated with those (?Onditi9ns ..

i. Ensuring expertise is available Jo disposition non-conformances.*

j. Developing safety analyses that address the non~onforming condition, if required.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE48 OF61 XVI. CORRECTIVE ACTION 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a corrective action program to ensure that conditions adverse to quality are promptly identified and corrected at the Rancho Seco ISFSI.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 72, Subpart D, Records, Reports, Inspections, and Enforcement.

2.2 10 CFR 71.133, Corrective Action 2.3 10 CFR 72.172, Corrective Action .

3.0 POLICY Procedures shall be established and implemented to ensure that significant conditions adverse to quality are identified and that corrective action is taken to preclud~ repetition.

4.0 GENERAL REQUIREMENTS 4.1 Controls shall ensure conditions adverse to quality such as malfunctions, errors, deficiencies or non-conformances are identified, documented and appropriate corrective action taken. The controls shall ensure that the corrective action is implemented in a timely manner.

4.2 For significant conditions adverse to quality, corrective action includes determining the cause and extent of the condition, taking corrective action to remedy the condition and taking action to prevent recurrence. These actions shall be reported to management personnel for review and assessment.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 The Manager, Rancho Seco Assets is responsible for:

a. Formulating appropriate corrective actions.

b. Implementing proposed corrective actions.

c. Ensuring that proposed corrective action is effective.

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PAGE 49 OF 61 d .. Ensuring th~t.audits of the Corr~ctive Action: Program are conducted in accordance with RSQM Section XVI 11. .

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 50 OF 61 XVII. QUALITY ASSURANCE-RECORDS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the storage and maintenance of Quality Assurance Records that provide the documentary evidence of activities affecting quality performed at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 Regulatory Guide 1.28/ANSI/ASME, NQA-1-1983, Supplement 17S-1, Supplementary Requirements for .Quality Assurance Records, with exc~ptions as noted in RSQM Section II, Attachment 11-3.

2.2 Rancho Seco Quality Manual, Appendix A 2.3 10 CFR 71.135, Quality Assurance Records 2.4 10 CFR 72.174, Quality Assurance Records 3.0 POLICY

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Procedures shall be established and implemented to ensure storage and

maintenance of records that represent evidence of activities described in RSQM Section II, Step 4.3.

4.0 GENERAL REQUIREMENTS 4.1 Quality Assurance records shall be permanently stored in a facility that meets the requirements of Reference 2.1 and 2.2.

4.2 Quality Assurance records shall be protected during interim storage in accordance with Reference 2.1.

4.3 Documents that furnish evidence of the quality of items and services are generated and controlled in accordance with the procedures that govern those activities. Such documents are considered Quality Assurance Records upon completion. Quality Assurance Records are considered completed when they have been stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated.

4.4 The record system shall provide for identification and retrievability of the records to the extent that information can be obtained in a reasonable amount of time.

RANCHO SEGO LICENSING BASIS DOCUMENT_.=,*. . NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 51 OF 61 4.5 The records p~9g~am shall addres$. records clc~ssification (retention period), storage location and responsibility for retention and retrievability.

4.6 A records retention schedule shall be established which addresses the requirements in References 2, 1 and2.2:

5.0 RESPONSIBILITIES.

General organizational responsibilities are described in Section I, ORGANIZATION 5.1 The Manager,. Rancho Seco Assets is responsible for:.

a. Establishing methods for control of 'records. *

b. Providing administrative procedures that define the records storage program and provide for ready retrievability.

c. Transmitting completed records to R.,ecords Management.

d. Providing interim storage in accordance with Step 4.2 above and Reference 2.1, prior to transmittal to Records Management.

e. Ensuring that audits of the records management system to ensure conformance to specified requirements are conducted in accordance with RSQM Section XVIII.

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PAGE 52 OF 61 XVIII.AUDITS':::

1.0 PURPOSE Describe the Rancho Seco QualityAssurance Program (QAP) measures that (1) establish a comprehensive system of planned and periodic audits, and (2) determine the effectiveness of the QAP at the Rancho Seco ISFSI .

2.0 REFERENCE DOCUMENTS 2.1 Regulatory Guide 1.144/ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 2.2 Regulatory Guide 1.146/ANSI N45.2.23-1978, Qualification of Quality Assura*nce Program Audit Personnel for Nuclear Power Plants 2.3 10 CFR 71.137, Audits 2.4 10 CFR 72.176, Audits 3.0 POLICY Procedures shall be established and implemented to ensure that planned and periodic audits are conducted to verify*conipliance with all aspects of the QAP.

4.0 GENERAL REQUIREMENTS 4.1 The Program Manager, Regulatory Compliance - Power Generation shall establish a schedule for auditing the activities affecting quality. The audit schedule shall be consistent with the audit requirements and frequencies specified herein.

4.2 The audit program shall be described in procedures that implement this RSQM section.

4.3 Audits shall be conducted to determine the adequacy and effectiveness of programs implemented for the design, procurement, modification, maintenance, and operational activities at the Rancho Seco ISFSI .

4.4 Audit plans shall bS' developed that identify the audit scope, the requirements, activities to be audited, organizations to be notified, the applicable documents, and the audit $Chedule.

4.5 Audit reports shall be issued which identify the activity that was audited, the personnel that were contacted' during the audit, and any conditions adverse to quality noted during the audit.

RANCHO SEGO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SEGO QUALITY MANUAL PAGE.53 OF 61 4.6 Process conditions identified as ad.verse to quality using the Rancho Seco Corrective Action Program. *

4. 7 Personnel conducting audits shall be trained and qualified in accordance with Reference.2.2. *In addition, at .least one individual participating in the Security .audit will be knowledgeable and practiced in the access authorization program performance objectives.

4.8 Regularly scheduled audits shall be supplemented by special audits/surveillances when conditions that warrant special audits exist or when requested by SMUD management.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Se_ction I, ORGANIZATION.

5.1 The Program Manager, Regulatory Compliance - Power Generation is responsible for:

a. Establishing a schedule for performing required audits.

b. Reviewing audit results to evaluate the effectiveness of the QAP.

c. Implementation of the established audit program.

d. Training and qualification of audit personnel.

5.2 The Manager, Rancho Seco Assets is responsible for:

a. Supporting the audit activities ..

b. Providing prompt response to any deviations from quality identified in the audit.

6.0 AUDITS AND AUDIT FREQUENCIES 6.1 Audits of Rancho Seco ISFSI activities shall be performed under the cognizance of the Program Manager, Regulatory Compliance - Power Generation who reports to-the Director, Power Generation. The required audits and audit performance frequencies are as follows:

a. Conformance to .the Rancho Seco ISFSI Technical Specifications and associated license conditions at least once per year;

b. Performance and qualifications of the Rancho Seco ISFSI technical staff at least once every two years; C. Actions taker,,to correct deficiencies occurring in structures, systems, components, or method~ of operation associated with the safe operation of the Rancho Seco ISFSI at least once every two years for

RANCHO $ECO LICENSING-BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL -. PAGE 54 OF 61 those deficiencies not previously audited (Corrective Action Program audit); .* .i . :,

d. Performance _of activities requJ~ed .by,t~e QAP to meet the 10 CFR 72, Subpart G criteria at least once every five years;

e. Rancho Seco ISFSI Emergency Plan and implementing procedures at least once every two years;

f. 10 CFR 72 ISFSI_ Physical Protection Plan and fmplementirig procedures at least once every two years;

g. Other areas of Rancho Seco ISFSI operation that the Manager, Rancilo*Seco Assets considers appropriate;

h. Radiological Environmental Monitoring Program (REMP) and the results thereof at least once every two years;

i. Performance of activities required by the Quality Assurance Program for Effluent Control and Environmental Monitoring (Regulatory Guide 4.15) at least on0e every two years; and

j. Radiation Protection Program content and implementation once per year.

6.2 Chang.es to the-se audits and audifffequencies are subject to the requirements specified in 10 CFR 72, Subpart G and related to the performance of specific audits may not be changed unless an exemption or waiver is obtained from the NRC.

6.3

The audit reports resulting from items "a" through "j" above shall be forwarded to the Manager, Rancho Seco Assets; the Director, Power Generation; and the management positions responsible for 'the areas reviewed. The report should be issued within 30 days afte!_ completion.

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PAGE 55 OF 61 Appendix A 1.0 10 CFR PART72 ADMINISTRATIVE CONTROLS 1.1 Technical*Review and Control

a. Procedures, plans, manuals, and programs required by Section 1.4 shall be prepared, reviewed, and approved. Each such procedure, plan, manual, and program or change thereto shall be reviewed by an individual(s) other than the preparer, but who may be from the same organization as the preparer of the procedure, plan, manual and program or change thereto .. Programs, plans, manuals; and procedures other than administrative pro,cedures will be approved as delineated in writing by the Manger, R,ancho SeGo Assets, b.ut not lower than a direct report to the Manager. Such procedures, plans, manuals and programs shall be reviewed periodically in accordance with administrative procedures.

The Manager, Rancho Seco Assets will approve administrative procedures and Emergency Plan ..

Implementing Procedures.

b. Proposed changes or modifications to systems or equipment described in the ISFSI Final Safety Analysis Report (IFSAR) shall be reviewed by an individual(s) other than the individual(s) who designed the modification, but who may be from the same organization as the individual(s) who designed the modifications. Such modifications shall be approved by the Mc}nager, Rancho Seco* Assets or his designee as delineated in writing, but not lower than a direct report to the Manager.

c. lndividual(s), other than the indivi.dual(s) who prepare proposed tests or

.experiments shali review proposed tests and experiments that are not addressed in the IFSAR. Such tests or experiments shall be approved by the Manager, Rancho Seco Assets or his designee as delineated in writing, but not lower than a direct report to the Manager.

d. Individuals responsible for reviews performed in accordance with Section 1.1 a, b, and c shall meet or exceed the qualification requirements of Section 4, "Qualifications," of ANSI N18.1-1971, excluding Sections 4.5.2 "Technicians" and 4.5.3 "Repairmen." The Manager, Rancho Seco Assets shall establish the list of qualified reviewers for the independent reviews described in a, b, and c above.

e. Events reportable pursuant to Section 1.5 and violations of Technical Specifications shall be investigated and a report prepared which evaluates the event and which provides recommendations to prevent recurrence. The Manager, Rancho Seco Assets shall revi.ew these reports.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL PAGE 56- OF 61 1.2 Audits (See RSQM Section XVIU) ..*

Specific audit requirements, including frequencies and administrative controls, are addressed in Rancho Seco Quality Manual (RSQM) Section XVIU,,"Audits."

1.3 Reporting Requirements for Specific Events and Conditions The Commission shall be notified and a report submitted per Section 1.5, pursuant to the requirements of10 CFR 72.75; 10 CFR 20.2203, and 10 CFR Part 73, Appendix G. Each report required by this section shall be reviewed and approved by the Manager, Rancho Seco Assets, or designee.

1.4 Procedures; Plans; Manuals, and Programs _

1.4.1 Written procedures, pfans, manuals, and programs shall be established, implemented and maintained covering the activities referenced below:

a. Emergency Plan implementation.

b. REMP MANUAL 'ir:npleq,entation.

c. Quality Assurance Program for Effluent c*oritrol and Environmental Monitoring using the guidance of Regl!latory Guide 4.15, Revision 1, February 1979. * '*' * *

d. Quality AssuranceProgram implementation.

e. Radiation Pr~tection Program implementation.

1.4.2 Each procedure, plan; manual, and program of Section 1.4.1 above and changes thereto shall be reviewed arid approved as* set forth in Section 1.1.

1.4.3 The following programs shall be establis.hed, implemented, and maintained:

1.4.3.1 Radiological Environmental Monitoring Program (HEMP)

There are no longer any liquid or gaseou~ radioactive effluents discharged from the site:_ The radiation source term is limited to

_radioactive m~terials sto,red at the. lSFSI. Accordingly, the only exposure pathway is by_pirect r~diation.

With the completion of decommissioning, the direct' radiation pathway is the only pathway still monitored by the REMP." Accordingly, there is no longer any requirement to. pprticipate in an Inter-laboratory Comparison P*rogram (ICP). The vendor supplying the direct radiation monitoring devices must be 1certified undera National Voluntary Laboratory Accreditation Program (NVLAP). The National Institute of Standards and:Technofogy (NIST) administers the

. NVLAP, which provides third..:party accreditation-to testing and calibration laboratories; .-. *; * :* *. *- * *

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1.4.4 The changes to the REMP shall be reviewed and approved as set forth in Sections 1.1 and 1.9.

1.5

Reporting Re*quirements 1.5.1 Routine Reports, ., , . _: *

In addition to the appl.icable reporting requirements _of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the Region IV Office unless otherwise noted.

1.5.2 Annual Radiological Reports Annual reports covering the activities- of the unit; as described below, for the previous calendar year shall be submitted as follows:

1.5.2.1- Annual Individual Monitoring Results Report The Annual Individual Monitori~g Results Report for the previous calendar year shall be submitted to the Commission by April 30 of each year in _compliance Vlfi~~J0 CFR .20.2206.

1.5.2.2 Annual Radiological Environ.rriental Operating *Report The Annual Radiological Environmental Operating Report covering the operation_ of the.LJ,11it _during the ,previous calenqar year shall be submitted before May f of each year. The report shall include summaries, interpretations, and analyl?iS. of, trends of the results of

. the Radioiogical Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the REMP Manual:

1.5.3 Biennial Report A routine report consisting of shutdown statistics, _narrative summary of shutdown* experience, and_tabula'tions of changes,*tests or, experiments requfred pursuant to 10. CFR 72.48(d) shall be submitted at intervals not to exceed 24 months to the U. S. Nudear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Office, postmarked no later than .30 days following the 24 month period covered by the report. . .

1.6 '

Reports for Specific Events ~rid Contlitions*

The types of eventsHsted.,in 10.CFR.72.75, 10 CF:R.20.2203, and 10 CFR Part 73, Appendi?C G. shall be-su,bmitted to the U.S .. Nuclear Regulatory Cqmmission (NRC), ATTN: Document Control Desk, Washington, D.C.

20555~0001, within the. time requirements of 10*CFR 72.75, 10 CFR 20.2203, and 10 CFR Part 73, AppendixJ3. An additional copy shall also be

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO SECO QUALITY MANUAL , PAGE 58 OF 61 submitted to the Regional Administrator of the Region IV Office. The written report shall include th,e information required.by 10 CFR 72.75,' 10 CFR 20.2203, or 10 CFR Part 73, Appendix G, as appropriate. Supplemental reports shall be submitted in accordance with the requirements in 10 CFR 72.75, 10 CFR 20.2203, or 10:CFR Part 73, Appendix G., as appropriate.

1.6.1 Environmental Reoorts

a. When a change to the plant design or operation is planned which would have a significant adverse effect on the environment or which involves an environmental matter or question not previously reviewed and evaluated by the NRC, a report on the change will be made to the NRC prior to implementation. The report will include a description and evaluation of the change, including a supporting benefit-cost analysis.

b. Changes or additions to permits and certificates required by Federal, State, local and regional authorities for the protection of the environment will be reported. The request for permit and certificate changes or additions submitted to the concerned agencies for approval will also be submitted to the NRC. The submittal will .be made for the reporting period during which the changes or additions occurred. The submittal will includ~ an.,evaluation o.f the environmental impact of the change(s). *. ** ,

1.6.2 Special Reports** '*~ ,.

Special reports shall be submitted to the Regional Administrator of the Region IV Office within the time period specified for each report.

1.7 Record Retention

1. 7 .1 The following records shall be retained for the duration of the 10 CFR Part 72 Operating Licenses:

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

NUCLEAR SAFETY, as they relate to the 10 CFR Part 72 licensed ISFSI.

b. Reports for Specific Events.and Conditions

c. Records of surveillance activities, inspections and calibrations required by these Technical,SpecificaUons. * .

d. Records of changes made t9 Op~rating Procedures, as they relate to the 10 CFR Part 72 licensed l~.FSL . ,.

e. Records of sealed source leak tests and results.

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f. Records of annual 'physical inverit6ry of al1 sealed source material of

.record. * .* * * ;* . .

g. Records and logs of ISFSI activities.

h. Record and drawing changes reflecting ISFSI design modifications made to systems and equipment described in the ISFSI SAR.

. i. Records of new and irradiated fuel inventory, fuel transfers and assembly burn-µp histories.

j. Recorqsof ISFSI radiation and contamination.surveys.

k. Records of radiation exposwe for all ihdi\/iduals *entering radiation control areas. . .

~,-

I. Records' of training and qualificatiorffor cu*rrent *members of the operating

m. Records of quality assurance activities required by the RSQM.

n. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to' 10 CFR 72,.48-. . * *. '

o. Records for the Radiological Environmental Monitoring Program.

p. Records of reviews performed for changes made to the REMP MANUAL. , *,* * .

q. Records of ISFSI decommissioning activities performed.

1.8 Radiation Protection Program Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 19 and 10 CFR 20, and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

1.9 Radiological Environmental Monitoring Program Manual

Licensee-initiated changes to'the RE:MP.*Manual shall be documented and records of reviews performed sh'all be retained as required by Section 1.6.1.o.

,,;,* ,,*' :,) ..... , ..

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 5 TITLE: RANCHO*SECO QUALITY MANUAL PAGE 60 OF 61 This documentation shall contain sufficient informationtoa:support the change together with the appropriate analyses or evaluations justifying the change.

_*_ -Changes to the REMP.become effective after. approval by,the Manager, Rancho Seco Assets and will be .submitted, to the Commission ,in the form of a complete,

.: legible copy ofthe entiremanuaL '..*,~,-- .. ,.

1.10 Sealed Source Contamination Each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material shall be free of~ 0.005 microcuries of removable contamination.

Applicability: At All Times Action:

With a sealed source having removable contamination in excess of the above limits, immediately withdraw the sealed source from use and:

a. Either decontaminate and repair the sealed source, or

. b. Dispose of the s~aled source in accordance with NRC Regulations:

Surveillance Requirements:

Test Requirements Each

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sealed source shall be tested for leakage and/or contamination by:

a. The Licensee, or

b. Other persons specifically authorized by the NRC or an Agreement State.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample.

Test Frequencies Each category of sealed source$ shall be tested at the frequency described below.

a. .For sources in use at least once every six months or all sealed sources containing radioactive material:

1. With a half-life greater than 30 days (excluding Tritium), and

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In any.form other than gas.-

b. For stored sources noUn,use each sealed source-shall be tested prior to

. use or transferto another*-licensee unless tested within-the previous six months. Sealed sources transferred withouta certificate indicating the last test date shall be tested prior to being placed into use.

ML21230A269

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