ML24115A254

Request for Additional Information for Trojan Docket No. 72-0017, PGE-8010, Trojan ISFSI Quality Assurance Program, Revision 31

ML24115A254
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/13/2024
From:	Rodriguez H NRC/NMSS/DFM/IOB
To:	Felton B Portland General Electric Co
References
Download: ML24115A254 (1)

Text

Benjamin F. Felton Executive Vice President and Chief Operating Officer Portland General Electric Company Trojan ISFSI 71760 Columbia River Hwy Rainer, OR 97048

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR TROJAN DOCKET NO.

7217, PGE-8010, TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION QUALITY ASSURANCE PROGRAM, REVISION NO. 31

Dear Benjamin Felton:

By letter dated September 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23272A032), Portland General Electric Company (PGE) submitted proposed Revision No. 31 to PGE-8010, Trojan ISFSI Quality Assurance Program, for U.S.

Nuclear Regulatory Commission (NRC) review and approval under Title 10, of the Code of Federal Regulations (10 CFR) Part 72 and 10 CFR Part 71.

In connection with the staffs review, the NRC needs information identified in the enclosure to this letter. This request for additional information (RAI) is listed by chapter number and title in the applicants quality assurance program. The RAI describes the information needed by the staff to complete the review of the submittal and to determine whether the applicant has demonstrated compliance with the regulatory requirements.

NUREG 2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities,"

was used by the staff for the review of the submittal.

The staff is available to clarify these questions, and if necessary, to meet, and discuss your proposed responses.

In accordance with 10 CFR Part 2, Agency Rules of Practice and Procedure, a copy of this communication will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m.

eastern time (ET), Monday through Friday, except Federal holidays.

May 13, 2024 B. Felton 2 If you have any questions regarding this RAI, please contact me at (301) 415-6004 or Raju B. Patel at (301) 415-3511.

Sincerely, Hector Rodriguez, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket Nos. 72-17 and 71-0327

Enclosure:

Request for Additional Information Signed by Rodriguez-Luccioni, Hector on 05/13/24

B. Felton 3

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR TROJAN DOCKET NO.

7217 PGE-8010, TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION QUALITY ASSURANCE PROGRAM, REVISION NO. 31

DATE: May 13, 2024

DISTRIBUTION:

DFM r/f NMSS r/f RidsRgn2MailCenter Resource RidsRgn4MailCenter Resource GWarnick RIV

ADAMS Accession Nos.: ML24115A254 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM/BC

NAME RPatel WWheatley HRodriguez

DATE 4/25/2024 4/25/2024 5/13/2024 OFFICIAL USE ONLY Request for Additional Information Trojan

Docket No. 72-17

PGE-8010, TROJAN ISFSI QUALITY ASSURANCE PROGRAM, REVISION NO. 31

Section 18.1, Audit Program

18.1 Revise section 18.1 of the quality assurance program (QAP) to remove a description that allow the internal audit interval to be performed every 24 months with a 90-day grace period or provide reasonable justification for taking exception to the annual audit frequency from Regulatory Guide (RG) 7.10, Revision 3, as well as for the 90-day grace period. The NRC RGs documents that endorse the American Society of Mechanical Engineers (ASME)

Nuclear Quality Assurance-1 (NQA-1) took exception to the statement that the interval may be extended up to 2 years.

The Trojan QAP section 18.1, Audit Program, states in part, that audits shall be performed every 24 months with a 90-day grace period. Further, section 18.1 goes on to state that use of all, or parts of the 90-day grace period does not impact the established 24-month cycle for the assessment.

Further, in Appendix B, Trojan ISFSI Regulatory Requirements and Commitments, of Trojan QAP, the licensee in their commitment to RG 7.10, Revision 3, took an exception to the annual audit frequency. Further, the licensee stated that the Trojan Independent Spent Fuel Storage Installation (ISFSI) is on a 24-month audit frequency in accordance with implementing plant procedures.

This language is consistent with the ASME NQA-12008 and NQA-1a-2009 Addenda, Requirement 18. However, in the NRC RG 7.10, Revision 3, and RG 1.28, Revision 4, Quality Assurance Program Criteria (Design and Construction), which endorsed NQA 2008, and NQA-1a-2009 Addenda, Requirement 18, provide a regulatory position that all applicable QAP elements shall be audited at least once each year or at least once during the life of the activity, whichever is shorter. The NRC RGs took exception to the statement that the interval may be extended up to 2 years based on the results of an annual evaluation and objective evidence that the activities are being satisfactorily accomplished.

This information is needed to demonstrate compliance with Title 10, of the Code of Federal Regulations Section 72.176.

Enclosure