ML21231A147

Report of Changes Made to Quality Assurance Program for Radioactive Material Packages

ML21231A147
Person / Time
Site:	South Texas
Issue date:	08/19/2021
From:	Stone C South Texas
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
NOC-AE-21003822
Download: ML21231A147 (3)

Text

Nuclear Operating Company South 'ferns Project Elcc/ric Cc11cr11/in,g Sia/ion PO. Box 289 W,,dsworlh, Texas 77481 August 19, 2021 NOC-AE-21003822 10CFR71.106 ATTN : Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington , DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Report of Changes Made to Quality Assurance Program for Radioactive Material Packages

Reference:

Letter; P. Silva (USNRC) to D. L. Koehl ; "Revised Quality Assurance Program Approval Form for Radioactive Material Packages No. 0645, Revision 5 ;"

dated August 28, 2015 (ML15245A285).

In accordance with 10CFR 71 .1(a), 10CFR 71 .106(b), and the above referenced letter, STP Nuclear Operating Company (STPNOC) hereby submits a report of changes to the STPNOC Quality Assurance (QA) Program for Radioactive Material Packages (No. 0654, Revision 5) approved on August 28, 2015. The changes to the STPNOC QA Program for Radioactive Material Packages are documented in STPNOC procedure 0PGP03-ZR-0053, "Radioactive Material Control Program ," Revision 21, effective June 30, 2021 .

Attached is a summary of the changes to the subject procedure made since August 7, 2019.

The attachment documents that the changes are non-substantive in nature, involving administrative items and editorial type clarifications . The changes do not reduce commitments in the STPNOC QA Program for Radioactive Material Packages.

There are no commitments in this letter.

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If there are any questions regarding this matter, please contact Ali Alb aj at (361) 972-8949 or me at (361) 972-8168.

~/Nf'tlY ayton B. Stone Manager, Health Physics aa

Attachment:

Summary of Changes Made to the South Texas Project Nuclear Operating Company Quality Assurance Program for Rad ioactive Material Packages Since August 7, 2019 cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington , TX 76011-4511

NOC-AE-21003822 Attachment Page 1 of 2 Attachment Summary of Changes Made to the South Texas Project Nuclear Operating Company Quality Assurance Program for Radioactive Material Packages Since August 7, 2019 Changes to 0PGP03-ZR-0053, Rev. 21 (Effective June 30, 2021)

Step Description of Changes Regulatory Basis Changed Table of Removed Section 7.5 Removal of Material from 10CFR71.106(b):

Contents Radiologically Controlled Areas Administrative References to 0PRP04-ZR-0004, Release of Materials improvement from Radiologically Controlled Areas is now provided for guidance related to these activities.

Step 1.8 Removed hyphen from by-product material for 10CFR71.106(b):

consistency within the procedure. Spelling correction Step 2.15 Corrected Title to read Radiological Postings and 10CFR71.106(b):

Warning Devices Administrative improvement Inserted Revisions to this program are required to be reviewed in 10CFR71.106(b):

Caution accordance with 10 CFR 71.106. Changes to the Administrative Box prior program may be made provided the change does not improvement to Step reduce the commitments in the program previously 4.12 accepted by the NRC. Changes to the program that do reduce the commitments must be submitted to the NRC for review and approval prior to implementation.

Add step IF a change is desired to the program, THEN perform a 10CFR71.106(b):

4.12.1 review per the criteria in 10 CFR 71.106 Administrative improvement Add step IF it is determined the change does not reduce the 10CFR71.106(b):

4.12.2 quality program commitments previously accepted by Administrative the NRC, THEN NRC approval is not required prior to improvement implementation.

Add step IF the change reduces quality program commitments 10CFR71.106(b):

4.12.3 previously accepted by the NRC, THEN obtain NRC Administrative approval prior to implementation. improvement Add step IF NRC approval is required prior to implementation, 10CFR71.106(b):

4.12.4 THEN Administrative improvement

NOC-AE-21003822 Attachment Page 2 of 2 Changes to 0PGP03-ZR-0053, Rev. 21 (Effective June 30, 2021)

Step Description of Changes Regulatory Basis Changed Add step Provide written justification for the change to allow 10CFR71.106(b):

4.12.4.1 Licensing to request prior approval from the NRC Administrative improvement Add step Add an action to the CR tracking the change to verify 10CFR71.106(b):

4.12.4.2 that NRC approval is obtained Administrative improvement Note below Corrected reference to the title for 0PRP04-ZR-0015 10CFR71.106(b):

7.4 Radiological Postings and Warning Devices Administrative improvement Deleted Release of Materials from Radiologically Controlled 10CFR71.106(b):

Step 7.5 Areas Administrative improvement Deleted Waste materials unconditionally released from the 10CFR71.106(b):

Step 7.5.1 Radiologically Controlled Area SHALL be disposed of in Administrative accordance with 0PGP03-ZH-0003 (Packaging of non- improvement Radioactive Waste Materials for Disposal).

Step 7.5.3 Corrected the reference which should be 7.5.1. 10CFR71.106(b):

Administrative improvement Addendum Removed Addendum 2, Examples of RAM Labels/Tags. 10CFR71.106(b):

2 Addendum 2 is not referenced in the body of the Administrative procedure and the procedure directs to improvement 0PRP04-ZR-0015.