ML21242A184

Independent Spent Fuel Storage Installation - Decommissioning Quality Assurance Plan

ML21242A184
Person / Time
Site:	Robinson, San Onofre
Issue date:	08/24/2021
From:	Bauder D Southern California Edison Co
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML21242A184 (42)

Text

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n HDTSON TNTHRNATIONAU* Company U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 August 24, 2021

Subject:

Docket Nos. 50-206, 50-361, 50-362, and 72-041 Decommissioning Quality Assurance Plan Douglas R. Bauder Vice President Decommissioning &

Chief Nuclear Officer San Onofre Nuclear Generating Station 10 CFR 50.54(a) 10 CFR 71.106(b)

San Onofre Nuclear Generating Station, Units 1, 2, and 3 and Independent Spent Fuel Storage Installation

Reference:

Letter from D. Bauder (SCE) to NRC Document Control Desk, dated August 27, 2019,

Subject:

Decommissioning Quality Assurance Plan, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation - (ADAMS Accession No. ML19241A245)

Dear Sir or Madam:

In accordance with the requirements of 10 CFR 50.54(a) and 10 CFR 71.106(b), Southern California Edison hereby submits the biennial update to the Decommissioning Quality Assurance Program (DQAP) for San Onofre Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation.

(Attachment 1 ). During the most recent biennial period (August 2019 -August 2021 ), four revisions (Revisions 6, 7, 8 and 9) to the DQAP were issued. Revision 8 of the DQAP implemented changes that had received prior NRC approval and was a complete replacement to previous revisions. As a result, many changes included in previous revisions were superseded by Revision 8.

A summary of the changes to the DQAP from Revisions 6, 7, 8 and 9 is provided in Attachment 2.

There are no commitments contained in this letter or its attachments.

Should there be any questions regarding this submittal, please contact Mr. Albert Bates, Manager, Regulatory Affairs, at (949) 368-7024.

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I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 24. 2021 (Date)

Sincerely, : Decommissioning Quality Assurance Program (DQAP) Revision 9 : Summary of Changes in the Decommissioning Quality Assurance Program.

Revisions 6, 7. 8 and 9 cc: S. A. Morris Regional Administrator, NRC Region IV A. M. Snyder, NRC Project Manager, SONGS Units 1, 2 and 3 Decommissioning Quality Assurance Program (DQAP)

Revision 9

DECOMMISSIONING QUALITY ASSURANCE PROGRAM (DQAP)

Revision 9 Southern California Edison (SCE)

San Onofre Nuclear Generating Station (SONGS) 1

SONGS DQAP Revision 9 j Southern California Edison San Onofre Nuclear Generating Station Decommissioning Quality Assurance Program (DQAP)

Approvals Manager, Nuclearerslght

{ate Date 2

. Introduction Southern California Edison (SCE) announced plans on June 7, 2013, to permanently retire Units 2 and 3 at the San Onofre Nuclear Generating Station (SONGS). On June 12, 2013 SONGS submitted a Certification of Permanent Cessation of Power Operations to the Nuclear Regulatory Commission (NRC), certifying that SCE had permanently ceased power operations of SONGS Units 2 and 3. To address this changing environment at SONGS, a Decommissioning Quality Assurance Program (DQAP) has been developed to support station activities) and the operation of the Independent Spent Fuel Storage Installation (ISFSI).

The SONGS DQAP reflects the quality activities pertaining to a decommissioning nuclear site through compliance with established regulatory requirements set forth by the NRC. The DOAP ensures the protection of the public health and safety through performance-based assessments and compliance-based auditing utilizing implementing procedures and instructions. The DQAP describes the responsibilities for implementing important to safety requirements, establishing and maintaining the OQAP, and assessing the performance of activities subject to the DQAP.

The implementation of the SON~S DQAP is performed in a graded approach commensurate with the items and activities importance to safety.

Appendix D, Section B contains a subset of administrative controls that were relocated from the Units 1, 2 and 3 Technical Specifications following the removal of all the Spent Fuel from the Spent Fuel Pools and its transfer to the ISFSI. However, the inclusion of these administrative controls does not increase the scope of SSC's or activities to which the requirements of the Quality Assurance Program apply.

The SONGS DQAP includes a general description of the organizational structure and functional responsibilities of station management regarding the implementation of important to safety activities and key facility activities at SONGS. The DQAP also outlines the key responsibilities for the Quality Assurance (QA) staff and program expectations for the associated station organizations. The DQAP satisfies the requirements of 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants, 1 0CFR71, Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material, and 10CFR72, Subpart G, Quality Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste. Additional regulatory commitments are listed within Appendix C of the DQAP.

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Table of Contents Approvals Introduction 1.0 Organization 2.0 Quality Assurance Program 3.0 Design Control 4.0 Procurement Document Control 5.0 Instructions, Procedures and Drawings 6.0 Document Control 7,0 Control of Purchased Material, Equipment and Services 8.0 Identification and Control of Material, Parts and Components 9.0 Control of Special Processes 10.0 Inspection 11.0 Test Control 12.0 Control of Measuring and Test Equipment 13.0 Handling, Storage and Shipping 14.0 Inspection, Test and Operating Status 15.0 Nonconforming Materials, Parts and Components 16.0 Corrective Action 17.0 Quality Assurance Records 18.0 Audits Appendix A: Organization Chart Appendix B: Important to Safety (ITS) Structures, Systems and Components Appendix C: Regulatory Requirements and Commitments Appendix D: Administrative Controls 4

. SONGS DQAP Revision.9 I Page 2

3 5

7 8

10 11 11 11 12 12 12 13 13 14 14 14 15 15 16 17 18 19 20

SONGS DOAP Revision 9 I Organization 1.0 Organization Southern California Edison (SCE) is responsible for the establishment and execution of the QA Program for the San Onofre Nuclear Generating Station (SONGS). The SCE organizational structure of functions involved with implementing the SONGS DQAP, as well as associated interfaces is described below with a high level functional organizational structure presented in Appendix A. The titles of managers used in the DQAP are generic, their functional titles and their formal titles may vary. Unless otherwise specifically prohibited, responsibilities of managers described in the DQAP may be delegated to, and performed by, other qualified individuals.

The ultimate responsibility for operation, maintenance, inspection, test, modification, decommissioning, and storage of spent fuel resides with the SCE President. The executive officer ultimately reports to the SCE President and has the overall responsibility for the establishment and execution of the SONGS DQAP.

Responsibilities The authorities and duties of persons and organizations performing activities affecting the important to safety functions of the Structures, Systems, and Components (SSC) defined in Appendix B are established and delineated in writing. These activities include both the performing functions of attaining quality objectives and the QA functions.

The executive officer is responsible for spent fuel safety, decommissioning of the station and nuclear oversight. The DQAP is reviewed and approved by the Manager responsible for Nuclear Oversight, and the executive officer.

The executive officer is responsible for apprising management of the effectiveness of the DQAP implementation and is the arbitrator for non-conformances of unusual complexity. The executive officer also directs actions to be taken based on reports and trending of quality issues submitted by the Manager responsible for Nuclear Oversight. Direction for implementing the DQAP activities is provided by the executive officer through the manager-responsible for Nuclear Oversight.

Management of line organizations at SONGS are responsible to ensure that the quality of organizational work and activities meets the requirements set forth in the DQAP and SONGS implementing procedures.

Nuclear Oversight The manager responsible for Nuclear Oversight reports to the executive officer and shall not be assigned responsibilities that would prevent the required attention to important to safety matters. Although reporting to the executive officer with other line organizations, the manager responsible for Nuclear Oversight shall have the necessary independence from other line management to ensure effective oversight for all organizations. The manager has the following responsibilities:

Management of day-to-day oversight of implementation of the DQAP for all important to safety activities Authority and obligation to raise any conditions adverse to quality to the executive officer for resolution 5

l

~ONGS. DQAP. Revision 9 I Assuring important to safety activities at SONGS are performed in accordance with implementing procedures Managing the performance of audits, assessments, and inspections in order to verify that important to safety activities have been correctly performed Reporting on oversight activities to the executive officer Authority to stop work when quality is adversely affected Nuclear Oversight personnel report directly to the manager responsible for Nuclear Oversight and implement the relevant provisions of the DQAP utilizing written implementing procedures. They perform independent oversight of line functions and activities. A member of the Nuclear Oversight organization shall not perform oversight of activities for which the member has been directly responsible. Further, they have the responsibility and authority to stop work when quality is adversely affected and immediately raise concerns to the manager responsible for Nuclear Oversight.

Nuclear Oversight personnel shall have sufficient authority and organizational freedom to identify any quality problems and to verify implementation of corrective actions. Additionally, Nuclear Oversight personnel shall have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and nuclear safety considerations.

Station Management The manager responsible for decommissioning oversight reports to the executive officer and is responsible for managing all decommissioning project activities being performed at SONGS.

A manager that is responsible for the operation of the ISFSI, with responsibility for ISFSI engineering, and emergency planning, reports to the executive officer.

Managers who are responsible for oversight of technical areas, such as engineering, and radiation protection report to the manager responsible for decommissioning projects The Independent Safety Reviewer (ISR) performs independent safety reviews as defined in Appendix D.

Other facility staff shall follow the requirements of Appendix D, Administrative Controls.

Other Corporate SCE Organizations e

Supply Chain Management is responsible for procurement of materials, equipment and services,,

and for preparation, negotiations, and administration of procurement contracts for SONGS reporting to SCE Corporate Management.

Corporate Records Center reports to SCE Corporate Management and is responsible for storage and retrieval of company records (including nuclear records) placed in their custody. They interface with SONGS staff related to long term storage of nuclear records.

Delegation of Quality Assurance Work SCE may delegate the execution of work under the DQAP to others such as contractors, agents, or consultants; however, SCE retains overall responsibility for those activities and the DQAP. Delegation is 6

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clearly identified in documentation and SCE retains the right to verify compliance with SCE quality requirements and regulatory requirements applicable to that organization's QA Program.

Reporting SCE management is involved with QA matters on a continuing basis. Periodic reports summarizing the quality of SONGS activities are reviewed and approved by the manager responsible for Nuclear Oversight. These reports contain status of program adherence to the DQAP, issues identified, unresolved items, and/or other items of interest. These reports are submitted to the executive officer and other SONGS management as deemed appropriate.

The executive officer shall periodically have an Independent Management Assessment (IMA) performed to evaluate the effectiveness of the SONGS QA Program. The details of the IMA are described in Appendix D under Independent Reviews.

Quality Assurance Program 2.0 Quality Assurance Program The QA Program for San Onofre Nuclear Generating Station (SONGS) is described in the Decommissioning Quality Assurance Program (DQAP). This DQAP provides control over important to safety and selected decommissioning activities to an extent consistent with their importance to ensure safety and compliance as defined in procedures. The DQAP includes specific monitoring activities which are measured against acceptance criteria in a manner sufficient to provide SONGS management assurance that the important to safety activities are performed in an acceptable manner. The SONGS DQAP requirements apply to SSCs designated as important to safety defined in Appendix 8. Those regulatory programs in Appendix D are addressed as noted in the Appendix.

The DQAP satisfies the requirements of 10 CFR 50 Appendix B Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants, 1 0CFR71, Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material, and 10CFR72, Subpart G, Quality Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste. Additional regulatory commitments are listed within Appendix C of the DQAP. Implementation of the SONGS DQAP is controlled through separately issued procedures, instructions and drawings. Each organization is responsible for the establishment and implementation of procedures and instructions prescribing the important to safety activities for which they are responsible.

Important to safety activities shall be accomplished under suitably controlled conditions. Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanness: and assurance that all prerequisites for the given activity have been satisfied. The QA program takes into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification of quality by inspection and test.

Changes to the DQAP will be implemented in accordance with 10 CFR 50.54(a) and 10 CFR 71.106.

Program Control and Authority The manager responsible for Nuclear Oversight is responsible for ensuring that the applicable portions of the DQAP are properly documented, approved and implemented (with trained staff, necessary materials 7

and approved procedures available) before an activity within the scope of the DQAP is executed. Disputes arising between departments or organizations on any QA matter that cannot be resolved at a lower level of management will be referred to the executive officer.

Additional requirements for specific programs are described in Appendix D, Administrative Controls.

Personnel Training and Qualifications Individual managers are responsible for ensuring that personnel working under their cognizance are provided with the necessary indoctrination training and resources to accomplish assigned activities which fall under the scope of the DQAP.

Members of the SONGS staff (including audit and inspection personnel) shall have the appropriate qualifications necessary to perform their assigned duties defined in implementing procedures. These implementing procedures provide the criteria utilized for determining and assessing appropriate staff qualification. Additionally, Appendix D cites references that stipulate the use of specific industry standards addressing qualifications. Training programs are established and implemented to ensure that personnel achieve and maintain suitable proficiency. Personnel training and qualification records are maintained in accordance with approved procedures.

QA Lead Auditors are qualified and certified by the manager responsible for Nuclear Oversight in accordance with approved procedures. Training methods, minimum experience requirements, and certification practices are In accordance with established procedures and based on criteria set forth in QA implementing procedures. Proficiency evaluations are performed and documented as defined in approved procedures Records Records of the implementation for staff indoctrination and training, as well as records for Lead Auditor, Auditor, Technical Specialist and Inspection Personnel qualification shall be maintained in accordance with approved procedures and show the appropriate documentary evidence of training completion.

PerformanceNerification

a.

Personnel performing work activities such as design, engineering, procurement, installation, maintenance, modification, operation, and decommissioning are responsible for achieving acceptable quality.

b.

Personnel performing independent verification activities are responsible for verifying the achievement of acceptable quality and are different personnel than those who performed the work.

c.

Work is accomplished and verified using instructions, procedures, or other appropriate means that are of a detail commensurate with the activity's complexity and importance to safety.

d.

Criteria that define acceptable quality are specified, and quality is verified against these criteria.

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soN<;;'s bq,AP Revision 9 I Design Control 3.0 Design Control The program will ensure that the activities associated with the design of important to safety structures, systems and components and modifications thereto, are executed in a planned, controlled, and orderly manner.

The program utilizes the guidance of NUREG/CR-6407 to classify structures, systems and components such that appropriate quality requirements are identified and documented on drawings, component lists, or procurement documents, as applicable.

The program includes provisions to control design inputs, processes, outputs, changes, interfaces, records, and organizational interfaces.

Design inputs (e.g., performance, conditions of the facility license, quality, and quality verification requirements) shall be correctly translated into design outputs (e.g., specifications, drawings, procedures, and instructions).

The final design output shall relate to the design input in sufficient detail to permit verification.

The design process shall ensure that materials, parts, equipment and processes are selected and independently verified consistent with their importance to safety to ensure they are suitable for their intended application.

Changes to final designs (including field changes and modifications) and dispositions of non-conforming items to either use-as-is or repair shall be subjected to design control measures commensurate with those applied to the original design and approved by the organization that performed the original design or a qualified designee. The original design organizations for the SCE ISFSI are identified in Appendix 8.

Subsequent changes to the original design can be made by SCE as defined in the design control process.

Interface controls (internal and external between participating design organizations and across technical disciplines) for the purpose of developing, reviewing, approving, releasing, distributing, and revising design inputs and outputs shall be defined in procedures.

Design documentation and records, which provide evidence that the design and design verification process was performed in accordance with the OAP, shall be collected, stored, and maintained in accordance with documented procedures. This documentation includes final design documents, such as drawings, and specifications, and revisions thereto and documentation which identifies the important steps, including sources of design inputs that support the final design.

Design Verification The program wm verify the acceptability of design activities and documents for the design of items. The selection and incorporation of design inputs and processes, outputs and changes are verified.

Verification methods include, but are not limited to, design reviews, alternative calculations, and qualification testing. The extent of this verification will be a function of the importance to safety of the item, the complexity of the design, the degree of standardization, the state of the art, and the similarity with previously proven designs.

When a test program is used to verify the acceptability of a specific design feature, the test program will demonstrate acceptable performance under conditions that simulate the most adverse design conditions that are expected to be encountered.

Independent design verification is to be completed before design outputs are used by other organizations for 9

• :soNGS bq.AP Revision 9 I design work and before they are used to support other activities such as procurement, manufacture, or construction. When this timing cannot be achieved, the unverified portion of the design is to be identified and controlled. In all cases, the design verification is to be completed before relying on the item to perform its Important to safety function.

Individuals or groups responsible for design reviews or other verification activities shall be identified In procedures and their authority and responsibility shall be defined and controlled. Design verification shall be performed by any competent individuals or groups other than those who performed the original design but who may be from the same organization. The designer's immediate supervisor or manager may perform the design verification and controls for this are defined in approved procedures.

Design verification procedures are to be established and implemented to ensure that an appropriate verification method is used, the appropriate design parameters to be verified are chosen, the acceptance criteria is identified, the verification is satisfactorily accomplished and the results are properly recorded.

Procurement Document Control 4.0 Procurement Document Control The program will ensure that purchased items and services are of acceptable quality.

The program includes provisions for evaluating prospective suppliers and ensuring that selected suppliers continue to provide acceptable products and services.

The program includes provisions for taking corrective action with suppliers (qualified or otherwise) whose products and services are not considered acceptable.

The program includes provisions for source verification (inspection, audit, etc.) for accepting purchased items and services identified as important to safety when determined necessary.

The program includes provisions for invoking applicable technical, regulatory, administrative, and reporting requirements (e.g., specification, codes, standards, tests, inspections, special processes, records, certifications, 10 CFR 21) applicable to the procurement to be specified in procurements documents.

The program includes provisions for ensuring that documented evidence of an item's conformance to procurement requirements is available at the site before the item is placed in service or used unless otherwise specified in procedures.

The program includes provisions for ensuring that procurement, inspection, and test requirements have been satisfied before an item is placed in service or used unless otherwise specified in procedures.

The procurement of components, including spare and replacement parts, is subject to quality and technical requirements suitable for their intended service.

The program includes provisions for the identification of critical characteristics and methods of acceptance for the dedication or a commercial grade item or seivice for its use in an important to safety function(s).

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Instructions. Procedures and Drawings 5,0 Instructions, Procedures and Drawings Measures are established to assure that quality activities are prescribed by and performed in accordance with documented instructions, procedures, or drawings. These instructions, procedures, and drawings include, as appropriate, quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished. Controls are established which ensure that instructions, procedures, and drawings are current and accurately reflect the facility design and regulatory requirements.

Changes or deviations from established Instructions, procedures or drawings for SSCs and other quality activities that have current important to safety functions, require the same review and approval as the original document. Instructions, procedures and drawings, including changes and deviations subject to the SONGS DQAP, shall be maintained as required by administrative procedures.

Administrative controls may be established that provide the methods by which temporary changes can be made to procedures which are approved, including the designation of persons authorized to approve such changes.

Document Control 6.0 Document Control The program will control the development, review, approval, issue, use, and revision of documents.

The scope of the document control program includes, but is not limited to:

a. Safety Analysis Report(s);

b. NRC License Documents, including Technical Specifications;

c.

Design Documents and Drawings;

d. Procurement Documents;

e. Procedures, Manuals, Plans, Directives, Policies, Instructions, etc.;

f.

Corrective Action Documents; and

g. Other documents as defined in procedures.

Revisions of controlled documents are reviewed for adequacy and approved for release by the same organization that originally reviewed and approved the documents or by a designated organization that is qualified and knowledgeable.

Copies of controlled documents are distributed to and used by the person performing the activity.

The distribution of new and revised controlled documents is in accordance with procedures. Superseded documents are.controlled to prevent inadvertent use.

Control of Purchased Materials. Equipment and Services 7.0 Control of Purchased Materials, Equipment and Services The program will verify the quality of purchased items and services at intervals and to a depth consistent with the Item's or service's importance to safety, complexity and quality of the item or service. Control of items and services for important to safety applications are clearly and adequately specified in 11

procurement documents.

The program is executed in all phases of procurement. As necessary, this may require verification of activities of suppliers below the primary supplier of the item or service.

Procedures shall describe each organization's responsibilities for the control of purchased material, equipment and services including the interfaces between all affected organizations.

Controls for the audits or surveys of suppliers providing important to safety items and services are provided for in Section 18.

Controls for the inspection (source verification/surveillance/inspection) of suppliers providing important to safety items and services are provided for in Section 10.

Identification and Control of Materials. Parts and Components 8.0 Identification and Control of Materials, Parts and Components The program will identify and control important to safety items to prevent the use of incorrect or defective items.

Identification of each item is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Traceability is maintained to an extent consistent with the item's importance to safety.

Control of Special Processes 9.0 Control of Special Processes This program will ensure that special processes identified as important to safety are properly controlled.

The criteria that estat;,lish which processes are special are described in procedures. The following are examples of special processes:

a. Welding;

b. Heat treating;

c.

NDE (Non-Destructive Examination);

d. Chemical cleaning; and

e. Unique fabricating or test processes which require in-process controls.

Special processes are accomplished by qualified personnel, using appropriate equipment, and procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

Inspection 10.0 Inspection The program will ensure inspections of important to safety activities are planned, executed and documented in order to verify conformance with instructions, procedures and drawings for accomplishing the activity.

Provisions to ensure inspection planning is properly accomplished are to be established. Planning activities shall identify the characteristics and activities to be inspected, the inspection techniques, the acceptance criteria, and the organization responsible for performing the inspections.

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SONGs:OafiPRevisio_n,9_j Provisions to identify inspection hold points, beyond which work is not to proceed without the consent of the inspection organizations are to be defined.

Inspection results are to be documented by the inspector and reviewed by qualified personnel.

Unacceptable inspection results shall be evaluated and resolved in accordance with procedures.

Inspections are performed by qualified personnel other than those who performed or directly supervised the work being inspected. While performing the inspection activity, inspectors functionally report to the nuclear oversight manager.

Test Control 11.0 Test Control The program will demonstrate that items will perform satisfactorily in service using approved test procedures.

The test control program includes, as appropriate, proof tests before installation, pre-operational tests, post-maintenance tests, post-modification tests, and operational tests.

Test procedures shall be developed which include:

a.

Instructions and prerequisites to perform the test;

b.

Use of proper test equipment;

c.

Acceptance criteria; and

d.

Mandatory inspections, as required.

Test results are evaluated and documented to assure that test objectives and inspection requirements have been satisfied.

Unacceptable test results shall be evaluated and documented for impact on safety and reportability.

Control of Measuring and Test Equipment 12.0 Control of Measuring and Test Equipment The program will control the calibration, maintenance and use of measuring and test equipment consistent with activities important to safety to ensure accuracy.

Calibration reference standards shall be based on traceability to nationally recognized standards. Where national standards do not exist, M& TE is calibrated against standards that have an accuracy of at least four (4) times the required accuracy of the equipment being calibrated, or when this is not possible have an accuracy that ensures the equipment being calibrated will be within the required tolerance. Special calibration and control measures are not required when normal commercial practices provide adequate accuracy (e.g. rulers, tape measures, level, and other such devices).

The types of equipment covered by the program (e.g., instruments, tools, gages, and reference and transfer standards) are defined in procedures.

Measuring and test equipment is calibrated at specified intervals or immediately before use on the basis of the item's required accuracy, intended use, frequency of use, stability characteristics and other conditions 13

. *SONGS DQAP Revisi_on 9 [

affecting its performance.

Measuring and test equipment is labeled, tagged, or otherwise controlled to indicate its traceability to calibration test data.

Measuring and test equipment found damaged or out of calibration is tagged or segregated. The acceptability shall be determined of items measured, inspected, or tested with a damaged or out-of-callbration device.

Handling, Storage and Shipping 13.0 Handling, Storage and Shipping The program will control the handling, storage, shipping, cleaning, and preserving of items to ensure the items maintain acceptable quality.

Special protective measures (e.g., containers, shock absorbers, accelerometers, inert gas atmospheres, specific moisture content levels and temperature levels, etc.) are specified and provided when required to maintain acceptable quality.

Specific procedures shall be developed and used for cleaning, handling, storage, packaging, shipping and preserving items when required to maintain acceptable quality.

Items are marked and labeled during packaging, shipping, handling, and storage to identify, maintain, and preserve the item's integrity and identify the need for any special controls.

Inspection, Test and Operating Status 14.0 Inspection. Test and Operating Status The program will ensure that required inspections and tests and the operating status of items important to safety is verified before release, fabrication, receipt, installation, test, and use, as applicable. This verification is to preclude inadvertent bypassing of inspections and tests and to prevent inadvertent operation of controlled equipment. Operating status is identified by the use of tags, markings, stamps, or other suitable means.

Items whose required inspections and tests are incomplete or inconclusive may be released for further processing. Controls are provided in procedures for establishing limitations on the release, applying status indications and documenting the basis for the conditional release of the item and any limitations.

The application and removal of inspection, test, and operating status indicators are controlled in accordance with procedures Non-conforming Materials, Parts or Components 15.0 Nonconforming Materials. Parts or Components SCE establishes measures to control important to safety materials, parts and components which do not conform to requirements. The measures used to control nonconforming materials, parts and components are described by approved procedures.

Management at all levels and each individual working at the facility is responsible for promptly identifying and reporting the identification of nonconforming materials, parts and components.

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sc)N GS DQAP Revision 9: I The corrective action program will be used to ensure the prompt identification, documentation, and correction of nonconforming materials, parts and components as described in Section 16.0.

Nonconforming items are properly controlled by approved procedures describing the identification, documentation, segregation requirements disposition and notification to the affected organizations to prevent their inadvertent installation or use. Nonconforming items are reviewed and either accepted, rejected, repaired, or reworked in accordance with approved procedures.

Corrective Action 16.0 Correcthre Action Each individual working at the facility is responsible for promptly identifying and reporting conditions adverse to quality. Management at all levels encourages the identification of conditions that are adverse to quality.

Significant conditions adverse to quality shall require cause determination, a corrective action that should prevent recurrence, and be documented and reported to appropriate levels of management. Follow-up action shall be taken to verify effective implementation of the required corrective actions to prevent recurrence and to verify that they are effectively implemented, Specific responsibilities within the corrective action program may be delegated, but SCE maintains responsibility for the program's effectiveness.

Reports of conditions that are adverse to quality are analyzed to identify negative performance trends.

Significant conditions adverse to quality and significant trends are reported to the appropriate levels of management, Quality Assurance Records 17.0 Quality Assurance Records The program will ensure that sufficient records of important to safety items and activities affecting quality (e.g. design, engineering, procurement, manufacturing, construction, inspection and test, installation, pre-operation, startup, operations, maintenance, modification, decommissioning, and audits) are generated and maintained to reflect the completed work.

Controls for the administration, identification, receipt, storage, preservation, safekeeping, retrieval, and disposition of records are provided in procedures.

Management of the electronic storage of records will utilize the guidance provided in the following industry standards as described in approved procedures:

NIRMA TG 11-2011, Authentication of Records and Media

• NIRMA TG 15-2011, Management of Electronic Records NIRMA TG 16-2011, Software Quality Assurance Documentation and Records NIRMA TG 21-2011, Required Records Protection, Disaster Recovery and Business Continuation Records generated for SSCs that were once classified as safety-related or quality-related but no longer have a safety function do not need to be retained for purposes of the DQAP (but may need to be retained for other purposes, such as compliance with 10 CFR 50.75(g), other regulations, or for business reasons).

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• _ SONGS DQAP Revision 9 I Audits 18.0&!!fil!

SCE establishes measures for a system of planned and documented audits in order to verify compliance with all aspects of the DQAP and determine the effective implementation of programs covered by the DQAP. QA internal and supplier audits are planned and performed by qualified auditors utilizing approved written procedures and/or checklists. External audits by licensees / utilities, Contractors, or Consultants acting for SCE to satisfy SCE audit requirements shall have the results evaluated by SCE to ensure acceptability.

Lead Auditors shall have experience, training or qualifications commensurate with the scope and complexity of their audit responsibility. Individuals performing audits shall not have direct responsibilities in the areas being audited.

Scheduling, preparation, personnel selection, performance, reporting, response, follow-up, and records management for audits are performed in accordance with written procedures. Audit scopes and schedules are based upon the status of work progress, important to safety activities being performed, regulatory requirements. Internal audits for the SONGS Decommissioning Quality Assurance Plan (DQAP) shall continue on a 24-month cycle with a 25% grace period. Grace periods are not intended to be used repetitively, merely as an administrative convenience to extend audit intervals. Therefore, the next performance due date is based on the originally scheduled date.

When specific audits are identified as requiring a more frequent periodicity, the shortest.periodicity will be adhered to for activities covered by those specific regulatory requirements. The frequency of internal audits will be prescribed by the plant implementing procedure which governs the conduct of QA audits.

External audits of suppliers providing important to safety materials, parts, equipment or seivices are scheduled and performed based on the importance of the activity and to confirm implementation of the supplier's QA Program at a frequency of not more than three (3) years with a 25% grace period. A total combined interval for any three (3) consecutive inspection or audit intervals does not exceed 3.25 times the specified inspection or audit interval. The supplier audit requirement shall not apply to standard off-the-shelf items and bulk commodities where required quality can adequately be determined by receipt inspection or post-installation test.

Audit reports shall be prepared, reviewed, approved and distributed in accordance with approved procedures.

Results of audits are reviewed with the management of the organization. Responsible management in the areas audited shall implement the necessary corrective actions required to address deficiencies. These actions are documented and reviewed periodically and, if needed, re-examined during re-audits of the subject area to verify deficient areas have completed corrective actions.

Audit records shall be retained in accordance with approved implementing procedures 16

Decommissioning Oversight Radiation Protection Manager Functional Organization Chart Appendix A: Organization Chart SCE president Executive Officer I

ISFSI Operation All positions are not defined and ultimate reporting is to the SCE President 17 SONGS DQAP"~evision 91 j

Nuclear Oversight

""***.. $0.NGS C>QAP Revision 9 I A ppendix B: Important to Safety (ITS) Structures, Systems and Components ertinent quality assurance requirements of 10CFR50 Appendix 8, 10CFR 71 Subpart Hand 10 CFR 72 Thep Subp asso art G will be applied, as a minimum, to all quality activities affecting important to safety (ITS) SSCs dated with spent fuel storage and transportation packages. (Notes 1 & 4)

NOTE e safety classification of SSCs at SONGS may be revised based on engineering evaluations and a Th rev ac the an ision to the SONGS engineering classification documentation. These modifications are controlled in cordance with the design control process and are not considered a reduction in the commitments to DQAP. Such changes are subject to regulatory review processes in accordance with 10 CFR 50.59 d 72.48.

SCs associated with spent fuel storage and radioactive material transportation packages are detailed in ITSS then oted engineering classification and include:

A.

B.

Dry Spent Fuel Storage (10 CFR 72)

Hi-Purpose Dry Storage Canisters (Note 2)

Mu Ca IS nister Overpack (Note 2)

FSI Pad {Holtec Pad Only)

SSC Transport of Spent Fuel and GTCC Waste (10 CFR 71)

Fuel SSC Mu Tr

!ti-purpose Storage Canister Transportable ansport Cask GTCC Waste SSC GT CC Waste Canister (Note 3)

Radioactive Material Transport Packages (10 CFR 71) oactive Material Transport Packages other that the GTCC canisters noted above are also subject to the

c.

Radi provi appli slons of 10 CFR 71, Subpart C, "General Licenses" are "Important-to-Safety" and subject to the cable requirements of the DOAP.

NOT

1.

2.

ES:

Administrative Controls are used to define the quality category, which is currenUy the Q-List.

Identified SSC's p art of Transnuclear and Holtec Stora e S stem g

y

3.

The storage of GTCC Waste Container does not have to be addressed under 1 0CFR72 per NRC Interim Staff Guidance (ISG-17).

4.

For the definition of Quality Categories A, B, and C refer to NUREG/CR-6407.

18 I

Appendix C - Regulatory Requirements and Commitments Regulatory Requirements

1.

10 CFR 50 Appendix 8, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants.

2.

10 CFR 71 Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material.

3.

10 CFR 72, Subpart G, Quality Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste.

Regulatory Commitments:

1. Regulatory Guide 7.10, "Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material" (Revision 2 - March 2005), with exception to the annual audit frequency. SONGS is on a 24-month audit frequency in accordance with implementing plant procedures.

2, NUREG/CR-6407, Classmcation of Transportation Packaging and Dry Fuel Storage System Components According to Important to Safety (2196).

Alternatives Suppliers providing commercial grade calibration and testing services, who are accredited by a nationally recognized accrediting body, as described in Nuclear Energy Institute (NEI) 14-05 guidelines, may be used without additional qualification, provided the conditions of the associated NRC Safety Evaluation are met. Controls shall be established in applicable procedures to ensure the requirements of the NRC Safety Evaluation are satisfied prior to acceptance.

19

Appendix D: Administrative Controls A. INDEPENDENT REVIEWS 1.0 Independent Management Assessment (IMA)

The executive officer shall periodically have an IMA performed to evaluate the effectiveness of the SONGS QA Program. These IMAs are performed by individual(s) designated by the executive officer who are independent of SONGS oversight activities and who have the appropriate level of expertise in the activities assessed. These periodic IMAs shall be performed on a 24 month frequency with a 90 day grace period, which is not to impact the established 24 month cycle for the assessment. The !MA results are communicated via a written report in a timely manner to a level of management having the authority to execute effective corrective action. In addition, these results are reported to the SCE President through the SONGS executive officer.

2.0 Independent Safety Review (ISR)

Independent Safety Reviewers perform ISRs of proposed changes, tests and experiments to important to safety SSCs, activities, program documents and procedures that are subject to the SONGS DQAP requirements. Independent Safety Reviewers shall be individuals without direct responsibility for the performance of activities under review and shall be competent and knowledgeable in the subject area being reviewed. Independent Safety Reviewers shall have at least 5 years of professional experience and either a Bachelor's Degree in Engineering or the Physical Sciences or shall have equivalent qualifications in accordance with ANSI N18.1-1971. Independent Safety Reviews must be completed prior to implementation of proposed activities. The manager responsible for the overall operational activities (or designee) shall document the appointment of Independent Safety Reviewers as defined in procedures.

B. INTEGRATED REQUIREMENTS RELOCATED FROM TECHNICAL SPECIFICATIONS This subsection contains a subset of controls that were relocated from the Units 1, 2 and 3 Technical Specifications, Section 5, Administrative Controls following the removal of all the Spent Fuel from the Spent Fuel Pools and its transfer to the ISFSI. However, the inclusion of these administrative controls in this Appendix does not increase the scope of SSC's or activities to which the requirements of the Quality Assurance Program apply.

1.0 Responsibility 1.1 The executive officer with direct responsibility for the facility shall be responsible for overall management of the San Onofre Nuclear Generating Station and all site support functions. The individual shall delegate in writing the succession to this responsibility during their absence.

2.0 Organization 2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility activities and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safe storage of the nuclear fuel.

a.

Lines of authority, responsibility and communication shall be established and defined for the highest management levels through intermediate levels to and including all organizational positions responsible for the safe storage of nuclear fuel. These relationships shall be documented and updated as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These relationships, including 20

the site-specific titles of those personnel fulfilling the responsibilities for the positions delineated in Appendix Dare documented in the SONGS 1 Defueled Safety Analysis Report (DSAR) or the SONGS 2 and 3 UFSAR.

b.

The executive officer with direct responsibility for the facility shall be responsible for the overall safe storage of the nuclear fuel and shall have control over those onsite activities necessary to ensure the ongoing safe storage of the nuclear fuel.

c.

A specified executive officer shall have corporate responsibility for overall facility nuclear safety and shall take any measures needed to ensure acceptable performance of the staff to ensure the safe management of nuclear fuel.

d.

The individuals who carry out radiation protection and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

3.0 Facility Staff Qualifications 3.1 Facility staff responsible for the safe storage of nuclear fuel and selected decommissioning activities shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions as defined in approved procedures except: a) the radiation protection manager who shall meet or exceed the qualifications of Regulatory guide 1.8, September 1975.

4.0 Procedures, Programs and Manuals 4.1 Procedures 4.1.1 Scope Written procedures shall be established, implemented, and maintained covering the following activities:

a.

Quality assurance for effluent and environmental monitoring using the guidance in Regulatory Guide 4.15, Revision 1, 1979;

b.

Fire Protection Program Implementation; and

c.

The following other Programs:

1) Off site Dose Calculation Manual (ODCM)

2) Radioactive Effluent Control Program (RECP)

3) Storage Tank Radioactivity Monitoring Program 21 Summary of Changes in the Decommissioning Quality Assurance Program, Revisions 6, 7, 8 and 9

DQAPsecfion Summary of Changes to the Decommissioning Quality Assurance Program (DQAP)

Revisions 6 Biennial Update Basjs/Justification

• • Reduction? Y/N Revision 6 - Administrative changes - (Historical)

NOTE: NRC approved DQAP issued August 10, 2020, superseded most of these changes. Appendix H was removed. The Nuclear Oversi ht Manager chan e has remained within the document and re ortin structure has not chan ed within Revision 9.

ppendix A Organization Chart Page 2 Approvals ppendix H DQAP Implementing Programs/Procedures.

The proposed change in Revision 6, The addition of a Nuclear Oversight manager ppendix A Organization Chart of the ithin the DQAP strengthens the DQAP is made to reflect the independence of Nuclear Oversight which organizational change that removed continues to report up through the Chief the Nuclear Oversight function from Nuclear Officer (CNO) and ultimately to the the NRA Manager and transfers the President of SCE. There is no impact on the responsibility to a newly assigned DQAP since the CNO remains as the independent Manager of Nuclear responsible individual for the implementation o Oversight.

the DQAP. Administrative controls included The change to Appendix A ithin the quality procedures defined in Organization Chart aligns with the ppendix H have not changed.

text specified in section 1.0 dded Nuclear Oversight procedure SO123-Organization which requires no 11-2 Assessment Program which provides change.

direction for Nuclear Oversight personnel to Page 2 of Revision 6 changed the titleperform Assessments in support of DQAP.

from the Manager Regulatory Affairs This change has been evaluated as non-and Nuclear Oversight to Manager of reduction in commitment to the previously NR Nuclear Oversight.

approved DQAP.

dded procedure SO123-Xll-2 ssessment Program to Appendix H:

DQAP Implementing Programs/Procedures.

N 1

DQAP section Summary of Changes to the Decommissioning Quality Assurance Program (DQAP)

Revisions 6 Biennial Update Change(s)

Basis/Justification Reduction? Y/N Revision 7 - Incorporation of Technical Specification (TS) from the License Amendment submitted (prior to approval) to the NRC and conforming changes. (Historical)

NOTE: The incorporation of the Technical Specifications Administrative Controls were added prior to creation of the ISFSI only DQAP submittal to the NRC in order to retain document control. Approval of the changes, as noted by the Safety Evaluation approval dated January 9, 2018, resulted in incorporation of portions of the U1 and U 2/3 Technical Specifications into DQAP Appendix Gin this revision with four corresponding changes to the body as noted below. This document was used as a transition document for the preparation of the DQAP submitted and subsequently approved by Safety Evaluation on September 24, 2018. These changes remain within the current document (Revision 9). The revision was processed separately from Revision 8 due to the timing of approvals for the LAR and the subsequent ISFSI only submittal of the DQAP for NRC approval. Revision 7 and Revision 8 were implemented sequentially on August 10, 2020. These changes remain within the current revision (Revision 9).

1.0 Organization P. 8

~ corresponding change is being

!This is considered a corresponding N

2.0 Quality Assurance Program P. 9 & 10 made to Section 1.0 to modify a administrative change to ensure accuracy of reference to the Technical the information provided in the DQAP. This Specifications to refer to Appendix G change is being made to reflect the relocation of the DQAP. This reflects the of the administrative requirements from the relocation of the Technical

!Technical Specifications to the DQAP Specifications administrative controls ~ppendix G. There are no reductions in to the DQAP Appendix G. Also, an commitments to the previously approved editorial punctuation DQAP from this change. LAR approved correction was made.

January 9, 2018.

Corresponding changes are being IThese are considered administrative changes made to Section 2.0 to modify a to ensure accuracy of the information provided reference to the Technical in the DQAP. These corresponding changes Specifications to refer to Appendix G are being made to reflect the relocation of the of the DQAP. This reflects the administrative requirements from the Technical relocation of the Technical Specifications to the DQAP Appendix G. There Specifications administrative controls are no reductions in commitments to the to the DQAP Appendix G.

previously approved DQAP from this change. LAR approved January 9, 2018.

N 2

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

Revisions 6 Biennial Update DQAP se:ctior Change(s) -- _

Basis/Justification -

Reduction? Y/N.

4.0 Procurement Document ~ corresponding change is being This is considered a corresponding Control P. 12 made to Section 4.0 to modify a administrative change to ensure accuracy of 17.0 Quality Assurance Records P. 27 reference to the Technical the information provided in the DQAP. This Specifications to refer to Appendix G change is being made to reflect the relocation of the DQAP. This reflects the of the administrative requirements from the relocation of the Technical Technical Specifications to the DQAP Specifications administrative controls Appendix G. There are no reductions in to the DQAP Appendix G.

commitments to the previously approved DQAP from this change. LAR approved January 9, 2018.

Corresponding changes are being These are considered administrative changes made to Section 17.0 to modify a to ensure accuracy of the information provided reference to the Technical in the DQAP. These corresponding changes Specifications to refer to Appendix G are being made to reflect the relocation of the of the DQAP. This reflects the administrative requirements from the Technical relocation of the Technical Specifications to the DQAP Appendix G. There Specifications administrative controls are no reductions in commitments to the to the DQAP Appendix G.

previously approved DQAP from this change. LAR approved January 9, 2018.

N N

3

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

Revisions 6 Biennial Update DQAP section

~ppendix G -

~dministrative Controls P.

38-39 Change(s)

Basis/Justification This change is being made to reflect This change to the DQAP is being made to the relocation of the administrative reflect the requested relocation of controls from the Unit 1 and Unit 2 & administrative controls from the Unit 1 and Unit 3 Technical Specifications as 2 & 3 Technical Specifications as described in described in the LAR submitted to the the LAR submitted to the NRC on December NRC on December 15, 2016.

15, 2016. This change is considered Corresponding changes are being administrative and does not reduce made to the language to modify commitments to the previously approved references to the Technical DQAP. LAR approved January 9, 2018.

Specifications and to add the specific programs that were relocated to the Licensee Controlled Specifications.

Reduction? Y/N N

Additional requirements are added to Appendix G to reflect the LAR approval.

Revision 8 - Incorporation of NRC approved SER dated September 24, 2018 - changes to organization - clarifications (Historical)

NOTE: Changes reflected in this revision incorporate the NRC approved DQAP and additional administrative changes to the organization which occurred after submittal of the DQAP to the NRC for approval on May 1, 2018. In addition, clarifications were added as a result of the Safety Evaluation provided by the NRC. These changes remain within the current revision (Revision 9).

Approvals P. 2 Changed descriptive title from 'Vice

~dministrative changes in accordance with

. N President of Decommissioning and 1 0CFR50.54(a)(3)(iv)

Chief Nuclear Officer' to functional Changes are reflective of DQAP approval by title 'executive officer' NRC SER 9/24/18 Changes do not reduce commitments to the NRC approved DQAP 4

Introduction P. 3 Summary of Changes to the Decommissioning Quality Assurance Program (DQAP)

Revisions 6 Biennial Update Basis/Justificatfon..

• Reduction? Y:/N Changes to the first, second and fourth paragraph clarify language.

Term 'Important to safety' replaces

'quality' throughout the document.

Editorial change to add/remove text for readability. Appendix identifier changed.

~ddition of the third paragraph is clarification of the DQAP scope specific to ITS SSCs specific to

~ppendix D, Section A. 4.0 for procedures relocated from the Technical Specifications.

Changes are reflective of DQAP approval by NRC SER 9/24/18 Editorial improvements in accordance with 1 0CFR50.54(a)(3)

Clarification for scope of DQAP to inserted

[Technical Specifications in Appendix D, Section A. 4.0. In the SER, dated September 24, 2018 (ML18101A231), the NRC states, (in part) "In addition, the NRC has previously approved this type of change for other decommissioning nuclear facilities... The SONGS DQAP adequately describes the provisions to meet the quality assurance requirements of 1 0 CFR Part 71, 1 0 CFR Part 72, and Appendix B to 10 CFR Part 50 for activities that are important to safety for a focility that has moved all its spent fuel from

~he spent fuel pools to the ISFSI."

~lthough not a commitment, some Quality

~ssurance controls used to implement ITS activities are also applied in a graded approach to regulatory activities, such as

~hose listed in Appendix D, Section A. 4.0. This strategy is utilized to ensure quality considerations are applied to decommissioning the facility and will be y

N 5

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

Revisions 6 Biennial Update DQAP *sectidn Change(s)

Basis/J1:1stificatipn Reductio,n? YIN Table of Contents P. 4 1.0 Organization P. 5 1.0 Organization -

Responsibilities P. 5 controlled/defined in Administrative procedures in a graded approach.

Changes are reflective of DQAP approval by NRC SER 9/24/18 for DQAP applicability to ITS SSCs for a facility that has moved all its spent fuel from the spent fuel pools to the ISFSI.

This type of change is allowed under 10CFR50.54(a)(3)

Changes to the size/content of the.

Editorial changes in accordance with document as a result of the approved 1 0CFR50.54(a)(3)

DQAP reduction.

Changes are reflective of DQAP approval by Changes to current appendices NRC SER 9/24/18 identifiers and removal of AppendicesChanges do not reduce commitments to the E-F NRC approved DQAP Changed the first paragraph to clarify Changes are reflective of DQAP approval by the organizational structure as high-NRC SER 9/24/18 level functional descriptions.

Administrative changes in accordance with Second paragraph changed CNO to 1 0CFR50.54(a)(3)(iv) executive officer. Continued Changes do not reduce commitments to the throughout the document.

NRC approved DQAP Defined high level executive officers' Changes are reflective of DQAP approval by responsibilities reflective of NRC SER 9/24/18 organizational changes and replaced ~dministrative changes in accordance with CNO with executive officer.

1 0CFR50.54(a)(3)(iv)

Changes do not reduce commitments to the NRC approved DQAP N

N N

6

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

Revisions 6 Biennial Update DOAP section

• • '?hange( s)

Basis/Justification,:

Reduction? YIN

1. 0 Organization - Nuclear oversight P. 5 & 6 1.0 Organization - Station Management P.6 Replaced CNO with executive officer. lA.dministrative changes in accordance with Replaced quality affecting with 1 0CFR50.54(a)(3)(iv) important to safety. Added 'nuclear' Changes are reflective of DQAP approval by to clarify safety considerations.

NRC SER 9/24/18 Station management is described using high level, functional relationships. Plant Manager has been replaced by an ISFSI manager who will be responsible for the operating ISFSI staff.

Maintenance was added to show reporting structure.

Changes do not reduce commitments to the NRC approved DQAP Administrative changes in accordance with 1 0CFR50.54(a)(3)(iv)

Independent Safety Reviewer (ISR)

Conforming change to the addition of ISR responsibilities relocated to Appendix responsibilities relocated to Appendix D, D, Administrative Controls and is

~dministrative Controls referenced.

Changes are reflective of DQAP approval by NRC SER 9/24/18

~ppendix D, Administrative Controls identifier changed.

~dministrative changes in accordance with 1 0CFR50.54(a)(3)

Changes are reflective of DQAP approval by NRC SER 9/24/18 N

N N

N 7

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

DQAP section

• 1.0 Organization - Other Corporate SCE Organizations P. 6 1.0 Organization -

Reporting P. 7 & 8 Revisions 6 Biennial Update

• Basis/Justification

• Changes do not reduce commitments to the NRC approved DQAP Supply Chain Management no longer ~dministrative changes in accordance with performs material shipping.

1 0CFR50.54(a)(3) to define organization after Information Technology is managed FTO complete by SONGS.

Records Management department Administrative changes in accordance with has been incorporated into Business 1 0CFR50.54(a)(3) to define organization after Services. Title changed to generic FTO complete identifier 'SONGS staff' Conforming changes to describe the Independent Management Assessment (IMA) for the evaluation of the QA Program as described in Appendix D. Administrative Controls

- Independent Reviews Administrative improvements for readability. Replace CNO with executive officer Changes do not reduce commitments to the NRC approved DQAP Changes are reflective of DQAP approval by NRC SER 9/24/18 Administrative changes in accordance with 1 0CFR50.54(a)(3)

Editorial improvements in accordance with 1 0CFR50.54(a)(3)

.. R~di.Jction? YIN N

N N

N 8

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

. Revisions 6 Biennial Update

~OAP section Records 2.0 - Quality Assurance Program P. 7

• change(s)

. Basis/Justification

.,:c' Conforming change to the addition of Administrative changes in accordance with the IMA as defined in Appendix D -

1 0CFR50.54(a)(3)

Independent Reviews - Records Changes are reflective of DQAP approval by section deleted to addition in NRG SER 9/24/18 Appendix D - Independent Reviews Changes do not reduce commitments to the NRG approved DQAP Conforming changes within this Changes are reflective of DQAP approval by section to align with: scope for NRG SER 9/24/18 important to safety and selected

!Administrative changes in accordance with decommissioning activities; changes 1 0CFR50.54(a)(3) to Appendices.

Conforming change to define regulatory programs for the addition within Appendix D, Administrative Controls, B - Integrated Requirements Relocated from Technical Specifications Clarification change in accordance with 1 0CFR50.54(a)(3)

Clarifications for the application of the DQAP

~o Appendix D A.4 for regulatory programs not important to safety.

Clarification for scope of DQAP for inserted Technical Specifications in Appendix D A.4. In

~he SER, the NRG states in part, "The primary changes proposed in Revision 6 of the SONGS DQAP include: Limiting the application of the SONGS DQAP to only important to safety SSCs and associated activities." In the conclusion, the NRG stated "The SONGS DQAP adequately describes the provisions to meet the quality assurance requirements of 10 CFR Part 71, 10 CFR Part 72, and Appendix B to 10 CFR Part 50 for activities that are important to N

y N

9

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

Revisions 6 Biennial Update QQAP se~tion Basis/Justification

.....Reduction? YIN

~.

safety for a facility that has moved all its spent fuel from the spent fuel pools to the ISFSI."

Although not a commitment, some Quality Assurance controls used to implement ITS activities are also applied in a graded approach to regulatory activities, such as those listed in Appendix D A.4. This strategy is utilized to ensure quality considerations are applied to decommissioning the facility and will be controlled in administrative procedures.

Changes are reflective of DQAP approval by NRC SER 9/24/18 2.0 Quality Assurance Changed Appendix designator.

Administrative changes in accordance with Program - Program Control Clarification for applicability of DQAP 10CFR50.54(a)(3) and Authority P. 8 to Appendix D for additional Changes are reflective of DQAP approval by requirements for specific programs NRC SER 9/24/18 2.0 Quality Assurance Program - Personnel Training and Qualifications P.8 2.0 Quality Assurance Program -

Removed Security, Emergency Preparedness and Fire Protection Removed Appendix H; changed appendix designator; denoted requirements for proficiency evaluations controlled in approved procedures Added Performance Verification attributes to the document Changes are reflective of DQAP approval by NRC SER 9/24/18 Changes do not reduce commitments to the NRC approved DQAP Changes are reflective of DQAP approval by NRC SER 9/24/18 Changes do not reduce commitments to the NRC approved DQAP

~ddition to document; however, the addition is reflective of DQAP approval by NRC SER 9/24/18 N

y y

N 10

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

Revisions 6 Biennial Update DQAP section Change(s)

Basis/ Justification Reduction? Y/N Performance/Verification Changes do not reduce commitments to the P.9 NRC approved DQAP 3.0 Design Control P. 9 Rewritten in its entirety Changes are reflective of DQAP approval by y

NRC SER 9/24/18 Changes do not reduce commitments to the NRC approved DQAP 4.0 Procurement Document Rewritten in its entirety Changes are reflective of DQAP approval by y

Control P. 1 0 NRC SER 9/24/18 Changes do not reduce commitments to the NRC approved DQAP 5.0 Instructions, Procedures Changes made within this section Changes are reflective of DQAP approval by N

and Drawings include removal of redundant NRC SER 9/24/18 P. 11 information (second sentence deleted Editorial changes in accordance with as is redundant to first sentence) 1 0CFR50.54( a)(3)

Periodic review removed.

Changes are reflective of DQAP approval by y

Procedures, Instructions and NRC SER 9/24/18 drawings will be reviewed during the audit process Temporary changes to procedures Changes are reflective of DQAP approval by y

language has changed.

NRC SER 9/24/18 Contractor documents for Changes are reflective of DQAP approval by y

performance of site activities no NRC SER 9/24/18 11

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

Revisions 6 Biennial Update DQAP section*..

Change(s).

Basis/J ystification Reduction? YIN n'

longer require review/approval by SCE.

6.0 Document Control P. 11 Rewritten in its entirety Changes are reflective of DQAP approval by y

NRC SER 9/24/18 7.0 Control of Purchased Rewritten in its entirety Changes are reflective of DQAP approval by y

Materials, Equipment and NRC SER 9/24/18 Services P. 11 8.0 Identification and Rewritten in its entirety Changes are reflective of DQAP approval by y

Control of Materials, Parts NRC SER 9/24/18 and Components P. 12 9.0 Control of Special Rewritten in its entirety Changes are reflective of DQAP approval by y

Processes P. 12 NRC SER 9/24/18 10.0 Inspection P. 12 Rewritten in its entirety Changes are reflective of DQAP approval by y

NRC SER 9/24/18 Changed 'nuclear safety manager' to ~dministrative change in accordance with N

correctly identify nuclear oversight 1 0CFR50.54(a)(3) manager for functional reporting when performing inspections 11.0 Test Control P. 13 Rewritten in its entirety Changes are reflective of DQAP approval by y

NRC SER 9/24/18 12.0 Control of Measuring Rewritten in its entirety Changes are reflective of DQAP approval by y

and Test Equipment P. 13 NRC SER 9/24/18 12

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

Revisions 6 Biennial Update DQAP section Change(s)

Basis/Justification Reduction? Y/N 13.0 Handling Storage and Rewritten in its entirety Changes are reflective of DQAP approval by-y Shipping P. 14 NRC SER 9/24/18 14.0 Inspection, Test and Rewritten in its entirety Changes are reflective of DQAP approval by y

Operating Status P. 14 NRC SER 9/24/18 15.0 Non-conforming Rewritten in its entirety Changes are reflective of DQAP approval by y

Materials, Parts or NRC SER 9/24/18 Components P. 14 16.0 Corrective Action Rewritten in its entirety Changes are reflective of DQAP approval by y

Program P. 15 NRC SER 9/24/18 17.0 Quality Assurance Rewritten in its entirety Changes are reflective of DQAP approval by y

Records P. 15 NRC SER 9/24/18 18.0 Audits P. 16 Designated qualified auditors rather Changes are reflective of DQAP approval by y

than departmental identifier for NRC SER 9/24/18 performance of audits subject to the DQAP.

Removed 'and prior experience with Administrative changes in accordance with N

the organization being audited' 1 0CFR50.54(a)(3) redundant to previous paragraph in part, 'Lead auditors shall have experience, training, or qualifications... "

13

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

Revisions 6 Biennial Update DQAP section Change(s)*

. Basis/Ju~tification

• Reductioii?Y/N

,~.,

Removed Emergency Preparedness Changes are reflective of DQAP approval by y

and Safeguards from audits requiring NRC SER 9/24/18 a more frequent periodicity.

Removed requirement to maintain Changes are reflective of DQAP approval by y

and revise audit schedule. Audit NRC SER 9/24/18 schedules will be maintained in accordance with approved procedures Section for communication of audit Changes are reflective of DQAP approval by y

results and audit records were NRC SER 9/24/18 simplified.

Removed redundant word 'audited' Editorial change in accordance with N

(7th paragraph, first sentence) after 1 0CFR50.54(a)(3) organization

~ppendix A - Organization High level functional organization Administrative changes in accordance with N

Chart P. 17 identified 1 0CFR50.54(a)(3)(iv)

Changes are reflective of DQAP approval by NRC SER 9/24/18 Changes do not reduce commitments to the NRC approved DQAP.

Appendix B t\\dded to the document to identify Addition to the DQAP; however, addition of the N

- Important to Safety (ITS) SSCs applicable to the DQAP. The appendix is reflective of DQAP approval by Structures, Systems and SONGS Q-list will maintain specific NRC SER 9/24/18 Components (SSCs) classification of equipment.

P. 18 Changes were made to Section A.

Clarification added specific to applicability for N

Dry Spent Fuel Storage (10 CFR 72) ISFSI Pad classification for ITS; Holtec ISFSI to add/remove note 2 Pad classified as ITS; Transnuclear Pad classified as NITS 14

Summary of Changes to the Decommissioning Quality Assurance Program {DQAP)

Revisions 6 Biennial Update QQAP SE}Ction Change{~).

Basis/Justification*

. Reductib11?Y/N

• Changes do not reduce commitments to the NRC approved DQAP.

Appendix B renamed to Re formatted the appendix to reflect Changes are reflective of DQAP approval by y

Appendix C: Regulatory Regulatory Requirements and NRC SER 9/24/18 Requirements and Regulatory Commitments; removed Commitments P. 19 RG 1.191, NRC RIS, the Exception and added an Alternative for suppliers providing commercial grade calibration services

~ppendix C: Quality Removed Appendix C: QA program Changes are reflective of DQAP approval by y

~ssurance Program for Fire for Fire Protection NRC SER 9/24/18 Protection Deleted

~ppendix D: List of Removed Appendix D: List of Changes are reflective of DQAP approval by y

~cronyms

~cronyms NRC SER 9/24/18 Deleted

~ppendix E: References Removed Appendix E: References Changes are reflective of DQAP approval by y

Deleted NRC SER 9/24/18 Appendix F: Definitions Removed Appendix F: Definitions Changes are reflective of DQAP approval by y

Deleted NRC SER 9/24/18 Appendix D (renamed):

Added Independent Reviews for Changes are reflective of DQAP approval by y

Administrative Controls P.

Independent Management NRC SER 9/24/18 20 & 21 Assessment (replaced Nuclear Oversight Board) and Independent Safety Review (replaced Onsite Review Committee) 15

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

Revisions 6 Biennial Update DQAP section Change(s)

Basis/ Justification Reduction? Y/N Added clarifying language to section Clarification of the application of the DQAP to N

B. Integrated requirements relocated ITS SSCs as referenced in the SONGS SER from Technical Specification for dated September 24, 2018 applicability to DQAP specific to ITS SSCs as approved.

Consolidated U1, and U 2/3 Changes are reflective of DQAP approval by y

Technical Specifications NRC SER 9/24/18 Approval of Technical Specification changes (Safety Evaluation) Dated January 9, 2018 brought into the DQAP in Revision 7 Revision 9-Changes to Audits Grace Period; two minor administrative changes as described below. (Current) 1.0 Organization P. 6 DQAP 1.0 Organization Station

!Administrative changes in accordance with N

Management 1 0CFR50.54(a)(3)

Changed the third paragraph by Clarification to Station Management (within inserting the words "oversight of" Section 1.0, Organization) responsibilities for

~echnical areas such as engineering and radiation protection.

18.0 Audits P. 16 DQAP 18.0 Audits Changes are reflective of approval by NRC for N

Changed the 90-day grace period Oyster Creek Nuclear Generating Station's specified in Section 18.0 Audits, to a (OCNGS) Quality Assurance Program (QAP) 25% grace for external and Internal by SER dated June 27, 2018 (ADAMS audits.

~ccession No.

ML18165A136) as allowed by 1 0CFR50.54(a)(3).

16

D01:\\P section 18.0 Audits P. 16 Summary of Changes to the Decommissioning Quality Assurance Program (DQAP)

Revisions 6 Biennial Update Change(s)

• Basis/.Justificatiori Reduction? YIN Regarding external audits only, Change Due to the national COVID-19 additional text included. "A total pandemic, NUPIC audits are scheduled combined interval for any three (3) outside of the currently established 90-day consecutive inspection or audit grace period. Change will allow a 25% grace intervals does not exceed 3.25 times period to be applied.

the specified inspection or audit interval."

DQAP 18.0 Audits

'.Added administrative change from not less than to not more than three (3) years between External Audits.

~dministrative changes in accordance with 1 OCFR50.54(a)(3) for clarity in audit requency.

N 17