Text

Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 0
	ML24215A356
Person / Time
Site:	Palisades, Indian Point, Oyster Creek, Pilgrim, Big Rock Point
Issue date:	08/02/2024
From:	Fleming J; Holtec Decommissioning International
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	HDI PNP 2024-030, HDI BRP 2024-001, HDI-PIL-24-014, HDI-IPEC-24-033, HDI-OC-24-030
	Download: ML24215A356 (1)
	v • d • e

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 1 of 3 HDI PNP 2024-030 HDI BRP 2024-001 HDI-PIL-24-014 HDI-IPEC-24-033 HDI-OC-24-030 10 CFR 50.54(a)(3) 10 CFR 50.71(e)(4) 10 CFR 71.101(f) 10 CFR 71.106(b) 10 CFR 72.140(d)

August 2, 2024 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket No. 50-293 and 72-1044 Indian Point Nuclear Generating Unit Nos. 1,2, and 3 Provisional Operating License No. DPR-5 Renewed Facility License Nos. DPR-26 and DPR-64 NRC Docket Nos.50-003, 50-247, 50-286 and 72-051 Palisades Nuclear Plant Renewed Facility Operating License No. DPR-20 NRC Docket Nos. 50-255 and 72-007 Big Rock Point Plant Facility Operating License No. DPR-6 NRC Docket Nos. 50-155 and 72-043

Subject:

Update Report for Holtec Decommissioning International (HDI) Fleet Decommissioning Quality Assurance Program (DQAP) Revision 3 and Palisades Transitioning Quality Assurance Plan (TQAP) Rev 0 Holtec Decommissioning International (HDI) is submitting Revision 3 of the Decommissioning Quality Assurance Program, (DQAP) in accordance with Title 10 of the Code of Federal Regulations Part 50, Section 71, Maintenance of records, making of reports, paragraph (e)(4),

(10 CFR 50.71(e)(4)), and 10 CFR 71, Packaging and Transportation of Radioactive Material, Section 106, Changes to quality assurance program, paragraph (b), (10 CFR 71.106(b)).

HOLTEC DECOMMISSIONING INTERNATIONAL

HOLTEC Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 DECOMMISSIONING INTERNATIONAL Telephone (856) 797-0900 Fax (856) 797-0909 Palisades Nuclear Plant has submitted Palisades Energy Quality Assurance Program Manual (QAPM), Revision O (Reference 1) which is under NRC review. With the need for Palisades to increase commitments as the site transitions back to an operating status. The Quality Assurance Plan for Palisades was moved to a standalone Transitioning Quality Assurance Plan (TQAP)

(Enclosure 3). This was needed to address the increase in needed commitments particular to Palisades as site transitions back to an operating status. provides a copy of DQAP Revision 3, which includes a synopsis of the changes associated with Revision 3. provides the Decommissioning Quality Control Program Change Evaluation Forms associated with Revision 3 of DQAP. provides a copy of Palisades' TQAP Revision 0. provides the Transitional Quality Control Program Change Evaluation Forms associated with Revision O of TQAP.

This letter contains no new regulatory commitments.

Should you have any questions or require further information, please contact William Naval, at (856) 797-0900 X 3587.

Respectfully, 9-- (l_,4,.,,,0 Jean A. Fleming Vice President, Licensing and Regulatory Affairs Holtec International

Reference:

[1] HDI letter to NRC, tilted Supplement to Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments, Proposed Power Operations Quality Assurance Program Manual, Revision O (ADAMS Accession Number ML24144A106), dated May 23, 2024

Enclosure:

1. Decommissioning Quality Assurance Program (DQAP) Revision 3

2. Decommissioning Quality Control Program Change Evaluation Form for Rev 3

3. Palisades' Transitional Quality Assurance Plan (TQAP) Revision O

4. Transitional Quality Control Program Change Evaluation Forms for Rev 0 H DI PNP 2024-030 H DI BRP 2024-001 H DI-PIL-24-014 HDI-IPEC-24-033 H DI-OC-24-030 2 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 3 of 3 HDI PNP 2024-030 HDI BRP 2024-001 HDI-PIL-24-014 HDI-IPEC-24-033 HDI-OC-24-030 cc:

USNRC Director - Nuclear Reactor Regulation (NRR)

USNRC Director - Nuclear Material Safety and Safeguards (NMSS)

USNRC Region I - Regional Administrator USNRC Region III - Regional Administrator USNRC Inspector(s) - Palisades Nuclear Plant, Big Rock Point, Oyster Creek, Pilgrim and Indian Point.

USNRC Project Manager(s), NMSS - Palisades Nuclear Plant, Big Rock Point, Oyster Creek, Pilgrim and Indian Point.

HOLTEC DECOMMISSIONING INTERNATIONAL

Decommissioning Quality Assurance Program (DQAP) Revision 3

Page 1 of 35 CD-020 Decommissioning Quality Assurance Program (DQAP)

Revision 03 Effective August 2, 2024 HOLTEC DECOMMISSION I NG INTERNATIONAL

Holtec Decommissioning International DQAP Page 2 of 35 Holtec Decommissioning International Site Listing Oyster Creek Nuclear Generating Station Docket No. 50-219 Renewed Facility Operating License No. DPR-16 Docket No. 72-0015 Docket No. 71-0964 Pilgrim Nuclear Power Station Docket No. 50-293 Renewed Facility Operating License No. DPR-35 Docket No. 72-1044 Docket No. 71-0963 Indian Point Energy Center Indian Point 1 Nuclear Power Plant Docket No.50-003 License No. DPR-05 Docket No. 72-51 Docket No.: 71-0240 Indian Point 2 Nuclear Power Plant Docket No. 50-247 License No. DPR-26 Docket No. 72-51 Docket No.: 71-0240 Indian Point 3 Nuclear Power Plant Docket No. 50-286 License No. DPR-64 Docket No. 72-51 Docket No.: 71-0240 Big Rock Point Nuclear Plant - Independent Spent Fuel Storage Installation Docket No. 50-155 License No. DPR-6 Docket No. 72-43 Docket No. 71-0937

Holtec Decommissioning International DQAP Page 3 of 35 Letter #: N/A

Subject:

Removal of Palisades Nuclear Power Plant (PAL) from Holtec Decommissioning International (HDI)

Decommissioning Quality Assurance Plan (DQAP) Revision 03. Palisades was moved to a Transition Quality Assurance Plan for restart activities.

(TQAP) Revision 0 Section I Revision Concurrence and Agreement to Issue DQAP Revision 03 POSITION / NAME Action (concurrence, certification, etc.)

Signature (sign, interoffice memo, e-mail, or telecom)

HDI-Regulatory Assurance Director/ William Noval Preparer HDI - Manager, Quality Assurance/ Kevin Block Preparer Holtec VP Licensing and Regulatory Affairs / Jean Fleming Reviewer Holtec VP Quality Assurance / Mark Soler Approver COMMENTS

NOTE: Individuals signing above confirm their review and concurrence with revision of the HDI DQAP and the completeness and accuracy of the information contained within in it.

Holtec Decommissioning International DQAP Page 4 of 35 Revision Summary Revision Number Location Description of Changes 03 Cover Page

a. Updated revision number from 02 to 03.

b. Effective date updated to August 2, 2024.

HDI Site List

a. Removed Palisades facility Docket information.

Signature Page

a. Changed title; Holtec VP Licensing and Regulatory Affairs

b. Added a second preparer and reviewer 1.2.3

a. Updated VP of QA reports to CNO, matrix reporting to Holtec President.

Whole Document

b. Updated Page Numbering

c. Updated title change, HDI President to Holtec President

d. Updated title changes, Holtec President and CEO to Holtec CEO and Executive Chairman Table of Contents

a. Updated Page Numbering

Page 5 of 35 TABLE OF CONTENTS Policy Statement.

6 1.0 Organization...... 7 2.0 Quality Assurance Program...

11 3.0 Design Control.

13 4.0 Procurement Document Control 16 5.0 Instructions, Procedures, and Drawings..

17 6.0 Document Control 18 7.0 Control of Purchased Material, Equipment, and Services.

19 8.0 Identification and Control of Materials, Parts, and Components..

22 9.0 Control of Special Processes.

23 10.0 Inspection..

24 11.0 Test Control..

25 12.0 Control of Measuring and Test Equipment..

26 13.0 Handling, Storage, and Shipping..

27 14.0 Inspection, Test, and Operating Status....

28 15.0 Nonconforming Material, Parts, or Components.....

29 16.0 Corrective Action..

30 17.0 Quality Assurance Records...

31 18.0 Audits.

32 Appendix A General Administrative Requirements..

33 Appendix B Site Specific Administrative Requirements.

35

Page 6 of 35 Policy Statement The Decommissioning Quality Assurance Program (DQAP), is the highest tiered document that assigns major functional responsibilities for decommissioning facilities owned and operated by Holtec International and Holtec Decommissioning International respectively (referred to as HDI in this document). Implementing documents assign more specific responsibilities and define the organizational interfaces involved in conducting safety significant (term used in this DQAP to identify both safety related and important to safety) activities within the scope of this DQAP.

These requirements apply to those organizations and positions, which manage and perform activities within its scope.

The HDI organization is structured on the basis that the attainment of the objectives of this Program relies on those who manage, perform, and support the performance of activities within the scope of the DQAP. Assurance of this attainment relies on those who have no direct responsibility for performing the activity.

HDI will maintain the decommissioning facilities in a manner that will ensure the health and safety of the public and the workers. All facilities shall, at a minimum, be in compliance with the applicable requirements of the Code of Federal Regulations, NRC Licenses, and the laws and regulations of the state and local governments.

Page 7 of 35

1.

ORGANIZATION HDI is responsible for the establishment and execution of the DQAP at the decommissioning facilities owned by Holtec and maintained by HDI. These decommissioning facilities have submitted a Certification of Permanent Cessation of Operations and Certification of Permanent Removal of Fuel to the Nuclear Regulatory Commission (NRC) per 10 CFR 50.82(a)(1)(i) and (ii), respectfully. The titles of managers used in the DQAP are generic, or functional titles and their formal titles may vary. Unless otherwise specifically prohibited, responsibilities of managers described in the DQAP may be delegated to, and be performed by, other qualified individuals.

1.1.

Responsibilities 1.1.1. The authorities and duties of persons and organizations performing activities within the scope of this DQAP are established and delineated in writing.

1.1.2. All personnel who work directly, or indirectly for HDI are responsible for the achievement of quality in their work. Accordingly, all HDI personnel and its contractors engaged in supporting decommissioning activities shall comply with the requirements of this DQAP.

1.1.3. The overall responsibility for operation, maintenance, inspection, test, modification, decommissioning, and storage of spent fuel resides with the Holtec President and is overseen by the Holtec CEO and Executive Chairman. The HDI Site Vice President at each decommissioning facility is responsible for the administration and implementation of the DQAP at the applicable facility.

1.1.4. The DQAP is reviewed and approved by the Holtec Vice President of Quality Assurance. The management position responsible for Quality Assurance/Nuclear Oversight is responsible for periodically reporting to the Chief Nuclear Officer (CNO) and Holtec President on the effectiveness of the DQAP implementation and immediately apprising them of significant problems affecting quality.

1.1.5. Management of line organizations at the decommissioning facilities are responsible to ensure that the quality of work and activities meets the requirements set forth in the NRC licenses including the site technical specifications, this DQAP, and implementing procedures.

1.2.

Corporate Organizations 1.2.1. The Holtec President has the overall responsibility for the safety, operation, and decommissioning of the nuclear sites maintained by HDI including oversight of the decommissioning activities performed by HDI. This is the

Page 8 of 35 senior executive responsible for providing strategic direction to the HDI organization and to the senior leadership of the decommissioning facilities maintained by HDI. This position is responsible for providing management direction, oversight and support to the site organizations and for setting and implementing policies, objectives, expectations, and priorities to ensure activities are performed in accordance with the DQAP and other requirements.

1.2.2. The Holtec CEO and Executive Chairman provides oversight of all HDIs nuclear activities including decommissioning of the nuclear sites maintained by HDI.

1.2.3. The Holtec Vice President of Quality Assurance reports to the CNO and has a matrix reporting structure to Holtec President. The position provides quality assurance oversight for the decommissioning facilities maintained by HDI. In addition, this position is responsible for verifying the DQAP is effectively implemented, that Quality Assurance (QA) personnel have sufficient authority and organizational freedom to identify quality problems and to verify implementation of corrective actions, and that QA personnel have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and safety considerations. Functional responsibilities include:

Managing the performance of periodic audits and quality verification inspections to verify that activities within the scope of this DQAP have been correctly performed.

Establishing quality assurance practices and policies.

Authority and obligation to raise any conditions adverse to quality to the CNO and HDI President for resolution, as necessary.

Reporting on oversight activities to the Holtec Senior Vice President of Business Development and Holtec President.

Authority to stop work when quality is adversely affected.

1.2.4. The following management positions report to and/or receive direction from the Holtec President with respect to their assigned roles and responsibilities associated with the execution of this DQAP:

The Vice President of Licensing and Regulatory Affairs is responsible for providing licensing oversight for the decommissioning facilities maintained by HDI. This position is responsible for overseeing and guiding development and submission of licensing, regulatory and environmental actions. This position also conducts routine assessments of the regulatory activities at each of the decommissioning facilities and supports the interface between the site and nuclear regulators while also taking a lead role on generic issues in decommissioning.

Page 9 of 35

Additional support organizational activities such as Emergency Preparedness, calibrations, procurement, training, legal, communications, records and document control, information technology, business operations, and human resources may be provided by the decommissioning facility or by the corporate organizations.

1.3.

Decommissioning Facility Management The following are HDI decommissioning facility management positions and associated DQAP functional responsibilities which may be delegated to others as established in this document. These individuals may report through an additional layer of management but shall maintain sufficient authority and organizational freedom to implement assigned responsibilities.

1.3.1. The HDI Site Vice President for each decommissioning facility maintained by HDI is responsible for providing day-to-day on-site leadership and direction to the associated decommissioning facility to assure the safe decommissioning, maintenance, and regulatory compliance of the station including control over those onsite activities necessary for safe storage and maintenance of spent nuclear fuel, including maintaining the facility within the constraints of applicable regulatory requirements, licenses, Technical Specifications dry storage system Certificate of Compliance and training. The HDI Site Vice President, or specified designee, shall approve, prior to implementation, all tests, experiments, and modifications to systems or equipment that affect the safe storage and maintenance of spent nuclear fuel. The following positions report to the HDI Site Vice President:

A management position responsible for operational activities necessary for safe storage and maintenance of spent fuel including maintaining the facility within the constraints of applicable regulatory requirements and the decommissioning facility licenses.

A management position responsible for radiation protection, ALARA planning, chemistry, and environmental activities.

A management position responsible for supporting the VP of Licensing and Regulatory Affairs in maintaining an interface between the station and federal, state, and local regulators. Also, responsible for Emergency Preparedness, the Corrective Action Program, and document control and records management functions.

A management position responsible for managing decommissioning projects within the constraints of the decommissioning facility licenses and regulatory requirements.

A management position responsible for engineering support activities, development and maintenance of engineering programs, policies, procedures, and providing engineering services in accordance with the

Page 10 of 35 DQAP.

A management position responsible for the execution of maintenance and modification activities.

A management position responsible for implementation of the decommissioning facility security plan.

This following position may be included in the decommissioning facility management or in the corporate organization.

A management position responsible for material management and decommissioning facility supply, which coordinates, evaluates, and procures materials for the decommissioning facility.

Page 11 of 35

2. QUALITY ASSURANCE PROGRAM 2.1.

The Quality Assurance (QA) Program for HDI decommissioning facilities as described in this DQAP provides control over activities affecting quality to an extent consistent with their importance to safety and compliance. The DQAP includes specific monitoring activities which are measured against acceptance criteria in a manner sufficient to provide HDI management assurance that the activities affecting quality are performed in an acceptable manner. The DQAP requirements apply to (i.e. the following are in the scope of the DQAP) structure, system, or components (SSCs) designated as safety significant, applicable regulatory programs, and for other applicable activities and SSCs identified in either the facility-specific Decommissioning Safety Analysis Report (DSAR) or Appendices of this DQAP.

2.2.

The DQAP satisfies the requirements of 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants, 10 CFR 71 Subpart H, Quality Assurance for Packaging and Transportation of Radioactive Material, and 10 CFR 72 Subpart G, Quality Assurance for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste. HDI also commits to NUREG/CR-6407, Classification of Transportation Packaging and Dry Fuel Storage System Components According to Important to Safety (2/1996).

Implementation of this 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 activities within the scope of this DQAP for which they are responsible.

2.3.

Activities affecting quality 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 cleanliness; and assurance that all prerequisites for the given activity have been satisfied. The DQAP 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 where required.

2.4.

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

2.5.

Program Control and Authority 2.5.1. The Holtec VP of Quality Assurance is responsible for ensuring that the applicable portions of the DQAP are properly documented, approved, and implemented before an activity within the scope of the DQAP is executed.

Page 12 of 35 2.5.2. Additional requirements for specific programs are described in the Administrative Controls section of the applicable decommissioning facility Technical Specifications or in the DSAR, with the exception of security requirements which are contained in the applicable facility Physical Security Plan; and Emergency Plan requirements which are contained within the applicable facility Site Emergency Plan. Fire Protection Program requirements are addressed in Appendix A of this DQAP.

2.6.

Program Review 2.6.1. The status and effectiveness of the DQAP and its implementation is periodically reviewed by the management of the organization responsible for its execution.

2.7.

Personnel Training and Qualifications 2.7.1. Formal indoctrination and training programs for personnel performing or verifying activities within the scope of this DQAP are established and maintained. The indoctrination and training programs are established by on-site and/or off-site organizational units responsible for the performance or verification of activities within the scope of this DQAP.

2.7.2. Personnel shall have sufficient qualifications, as applicable, to perform their assigned duties. Implementing procedures provide the criteria utilized for determining and assessing appropriate staff qualifications. Indoctrination, training, and qualification programs are established such that:

Personnel performing and/or verifying activities affecting quality are trained and qualified, as applicable, in the principles, techniques, and requirements of the activity being performed.

Formal training and qualification program documentation includes the objective, content of the program, attendees, and date of attendance.

Proficiency tests are given as applicable to those personnel performing and verifying activities affecting quality.

A certificate of qualification, as applicable, clearly delineates the specific quality assurance functions personnel are qualified to perform and the criteria used to qualify personnel in each function.

Page 13 of 35 3.0.

DESIGN CONTROL 3.1.

Measures are established to assure that the designs, including applicable regulatory requirements and design bases, technical and quality requirements are correctly translated to design documents which include specifications, drawings, procedures, and instructions. HDI has overall responsibility for design and design control activities including preparing, reviewing, approving, and verifying design documents related to the facility's structures, systems, and components (SSCs) within the scope of the DQAP.

3.2.

Design changes to SSCs within the scope of this DQAP shall be properly controlled using design control measures commensurate with those applied to the original design as appropriate. Design changes are reviewed and approved by the same design groups cognizant in the discipline affected by the change that reviewed and approved the original documentation unless alternative design groups are designated. Design activities associated with the decommissioning facility changes or modifications may be performed by HDI or qualified contractors. Design groups shall have access to background information, shall be competent in the specific area of design interest, and shall understand the requirements and intent of the original design.

3.3.

Measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to SSCs that have current safety significant functions. Design control implementing procedures shall define responsibility for the following:

Design Input

Design Performance

Design Interface Control

Design Verification

Design Change 3.4.

Design inputs shall be identified, documented, and correctly used to derive design outputs. Design inputs shall be specified to a level of detail necessary to allow the design activities to be carried out in a controlled manner.

Page 14 of 35 3.5.

The design organization shall prescribe and document the design activities to the level of detail necessary to permit the design process to be completed in a correct manner which permits verification that the design meets requirements. Design documents shall support facility design, construction, safe storage and handling of spent fuel, and decommissioning projects.

Appropriate quality standards shall be identified and documented, and their selection reviewed and approved. Deviations from original design standards shall be reviewed to ensure that the designated quality requirements remain in the design of SSCs as applicable.

3.6.

Design control measures shall be applied to those SSCs within the scope of this DQAP. Design analyses shall be sufficiently detailed such that a person technically qualified in the subject can review and understand the analyses and verify the adequacy of the results without additional input.

3.7.

Design interfaces for SSCs within the scope of this DQAP shall be identified and controlled. Interface controls shall include the assignment of responsibility and the establishment of procedures among participating design organizations. Controls shall be established for the review, approval, release, distribution, and revision of documents involving design interfaces.

Design information transmitted across interfaces shall be documented and controlled.

3.8.

Changes or modifications to designated SSCs shall be approved by the Design Authority or designee. Procedures for implementing design changes and field changes shall assure that the impact of the change is considered, required actions documented, and information concerning the change transmitted to affected persons or organizations. Applicable regulatory change process criteria (e.g., 10 CFR 50.59, 10 CFR 50.82(a), or 10 CFR 72.48) shall be used to determine if NRC approval is required prior to implementation of a design change. For SSCs within the scope of this DQAP, these changes shall be subject to design control measures commensurate with those applied to the original design.

3.9.

Design verification for SSCs within the scope of this DQAP shall provide assurance that the final design is correct and has been performed in accordance with approved procedures for the design reviews.

Documentation to be reviewed for this design work includes the necessary calculations and/or analysis, design criteria specifications, drawings, procedures, and instructions as applicable to permit a comprehensive review.

3.10. Design verification may be accomplished through design reviews, alternate calculations, or qualification testing. These methods of design verification are defined in design procedures as applicable. The results of the design verification activities shall be documented with the identification of the verifier clearly documented. Design verification shall be performed by competent individual(s) other than those who performed the original design but may be

Page 15 of 35 from the same organization. This verification may be performed by the originators supervisor, provided the supervisor did not specify a singular design approach, rule out certain design considerations, did not establish the design inputs used in the design, or the supervisor is the only individual in the organization competent to perform the verification. Cursory supervisory reviews do not satisfy the intent of design verification. Design verification shall be completed prior to relying upon the SSC to perform its safety significant function.

3.11. Nonconforming activities such as deviations, errors, or deficiencies in the approved design documents, including design methods (e.g., computer codes), shall be identified, documented, and controlled. Computer programs used to calculate or develop data for safety significant activities shall be subject to validation and verification.

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

Page 16 of 35 4.0.

PROCUREMENT DOCUMENT CONTROL 4.1.

Measures are established for the preparation, review, and approval of procurement documents for those items and activities within the scope of this DQAP. Procurement documents include or reference the appropriate regulatory, technical, and quality requirements necessary to assure adequate quality for those materials, equipment, and services that are within the scope of this DQAP. Measures are established to assure that, to the extent necessary, contractors or subcontractors provide a QA Program consistent with the provisions of 10 CFR 50 Appendix B, 10 CFR 71 Subpart H, or 10 CFR 72 Subpart G, and 10 CFR 21, as applicable.

4.2.

HDI maintains an Approved Vendor List (AVL) for those vendors qualified to perform safety significant work. The qualification requirements for vendors on the AVL are described in controlling procedures except for procurement from other licensees that have an NRC approved quality program. Vendor qualification processes use a graded approach based on the qualification level of the vendor.

4.3.

Procurement document control applies to SSCs within the scope of this DQAP and any spare or replacement parts for those SSCs. Procurement documents shall include those requirements necessary to assure that the items and services to be provided meet the specified technical and quality requirements. Specifically, the procurement system assures that the appropriate technical and quality requirements are specified for procurement of items and services considering the safety significant function, complexity of the design, manufacturing, degree of inspection/testability upon receipt and other factors which affect the quality of products and services. In addition, procurement documents will, as applicable, require vendors to a) invoke applicable requirements on their vendors; b) allow for right of access for further evaluations as needed.

4.4.

Procedures that implement procurement document control shall describe the organizational responsibilities for procurement planning, preparation, review, approval and control of procurement documents, and vendor selection.

4.5.

Procedures shall be established to review the adequacy of the technical and QA requirements specified within procurement documents. Personnel who have access to pertinent information and who have an adequate understanding of the requirements and intent of the procurement documents shall perform reviews required to ensure the adequacy of the technical and QA requirements. Changes to procurement documents shall be subject to the same controls as the original documents.

Page 17 of 35 5.0.

INSTRUCTIONS, PROCEDURES AND DRAWINGS 5.1.

Measures are established to assure that quality activities are prescribed by and performed in accordance with documented instructions, procedures, or drawings. Documented and approved instructions, procedures, and drawings are required to accomplish work on SSCs within the scope of this DQAP.

5.2.

These instructions, procedures, and drawings include, as appropriate, quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished. The activities shall be described to a level of detail commensurate with the complexity of the activity and the need to assure consistent and acceptable results.

5.3.

Controls are established which ensure that instructions, procedures, and drawings are current and accurately reflect decommissioning facility design and regulatory requirements.

Page 18 of 35 6.0.

DOCUMENT CONTROL 6.1.

Measures are established to control the issuance of documents, such as instructions, procedures, drawings, including changes thereto, which prescribe activities affecting quality and activities within the scope of this DQAP. These measures assure that documents, such as procedures, instructions and drawings, are reviewed for adequacy by qualified personnel other than the personnel that prepared the document, approved for release and use, and available at the location where the activity is performed. Written procedures shall define the type of documents to which the document control system applies. These procedures also define the process for controlling the preparation, review, approval, issuance, and distribution.

6.2.

Documents and changes to documents that prescribe or verify activities within the scope of this DQAP shall be controlled in a manner that precludes the use of inappropriate or outdated documents.

6.3.

Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval unless another qualified organization has been designated. Administrative controls shall 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, and the time period during which they may be used. Minor changes to documents, such as inconsequential editorial corrections, shall not require that the revised documents receive the same review and approval as the original documents. To avoid a possible omission of a required review, the type of minor changes that do not require such a review and approval and the persons who can authorize such a decision shall be clearly delineated.

Page 19 of 35 7.0.

CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1.

Measures are established for the control of purchased material, equipment (identified as items), and services to assure they conform to the procurement documents as they apply to activities within the scope of this DQAP. These measures provide for the following as appropriate: source evaluation and selection, evaluation of objective evidence of quality furnished by the vendor, source inspection, audit, and examination of items or services. Procedures shall describe each organization's responsibilities for the control of items and services, including the interfaces between all affected organizations.

Documentation of acceptance of items shall be available prior to installation or acceptance for use.

7.2 Verification that a vendor can meet the specified technical and quality requirements shall be documented. HDI maintains an Approved Vendor List (AVL) for those vendors qualified to perform safety significant work. The qualification requirements for vendors on the AVL are described in controlling procedures. Vendor qualification processes use a graded approach based on the qualification level of the vendor.

7.3 This DQAP considers that other 10 CFR Part 50 licensees, Authorized Nuclear Inspection Agencies, National Institute of Standards and Technology, or other State and Federal agencies which may provide items or services to the facility are not required to be evaluated or audited.

7.4 Commercial grade calibration and/or testing services may be procured from domestic and international commercial calibration and/or testing laboratories based on the laboratory's accreditation to ISO/IEC-17025:2017 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) provided all of the following are met:

7.4.1 A documented review of the vendors accreditation is performed and includes a verification of the following:

The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encompasses ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

For procurement of calibration services, the published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.

For procurement of testing services, the published scope of accreditation for the test laboratory covers the needed testing services including test methodology and tolerances / uncertainty.

Page 20 of 35 7.4.2. The purchase documents require that:

The service must be provided in accordance with their accredited ISO/IEC-17025:2017 program and scope of accreditation.

As found calibration data must be reported in the certificate of calibration when calibrated items are found to be out-of-tolerance. (For calibration services only)

The equipment /standards used to perform the calibration must be identified in the certificate of calibration. (For calibration services only)

The customer must be notified of any condition that adversely impacts the laboratorys ability to maintain the scope of accreditation.

Additional technical and quality requirements, as necessary, based upon a review of the procured scope of services, which may include, but are not necessarily limited to, tolerances, accuracies, ranges, and industry standards.

Supplier shall not sub-contract the service to any other supplier.

7.4.3. It is validated, at receipt inspection, that the laboratory's documentation certifies that:

The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation; and

The purchase order's requirements are met.

7.5.

The effectiveness of contractors and vendors s QA program shall be assessed at intervals consistent with the importance, complexity, and quantity of the item or service. Vendor performance and compliance with procurement documents are monitored by source verification, receipt inspection, audit, or a combination to ensure continued acceptable vendor performance. Receiving inspection shall verify, by objective evidence, the acceptability of items in accordance with decommissioning facility procedures. Accepted items are appropriately marked and located in a controlled storage area until use. Documentary evidence shall be retained in accordance with decommissioning facility requirements and applicable regulatory requirements and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications, met by the purchased items.

Page 21 of 35 7.6.

For acquiring of services only, such as: third-party inspection, engineering and consulting services; auditing and installation; and repair, overhaul, or maintenance work, from vendors whose QA Program has not been reviewed or accepted, those vendors may be used provided additional controls such as technical verification of data produced, surveillance and/or audit of the activity, or review of objective evidence are employed. Additional controls will be approriately identified and implemented.

7.7.

Spare and replacement parts are procured such that their performance and quality are at least equivalent to those of the parts that will be replaced, as determined by engineering where applicable.

7.8.

Designated quality personnel or other personnel with appropriate qualifications are responsible for assuring source inspections, surveys, or audits of vendors are performed as necessary.

Page 22 of 35 8.0.

IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS 8.1.

Measures are established for the identification and control of material, parts, and components, including partially fabricated assemblies and consumables (identified as items), to assure that only correct and accepted items are used or installed. Identification is maintained on the items or in documents traceable to the items, and physical identification shall be used to the maximum extent possible. If physical identification is either impractical or insufficient for proper control, HDI controls an item by physical separation, procedural control, or other appropriate means.

8.2.

Markings are applied using materials and methods that are clear, legible and do not detrimentally affect the function or service life of the items that are marked. Markings are transferred to each part of an identified item prior to being subdivided. Markings are not obliterated or masked by surface treatments or coatings unless alternative identification methods are established.

8.3.

Provisions are made in procedures for maintenance or replacement of markings or identification due to damage from handling or aging, excessive deterioration due to environmental exposure, and for updating records while in storage.

8.4 Items having limited shelf or operating life are controlled to preclude use after the shelf life or operating life has expired.

Page 23 of 35 9.0.

CONTROL OF SPECIAL PROCESSES 9.1.

Measures are established to assure that special processes that require interim process controls to assure quality, such as welding, heat treating, and nondestructive examination, are controlled. These provisions include assuring, as applicable, that special processes are accomplished by qualified personnel using instructions, procedures, drawings, checklists, or other appropriate means. Personnel are qualified and special processes are performed in accordance with applicable codes, standards, specifications, criteria or other specially established requirements. Special processes are those where the results are highly dependent on the control of the process or the skill of the operator, or both, and for which the specified quality cannot be fully and readily determined by inspection or test of the final product.

Records are maintained, as appropriate, for the qualified personnel, processes, and equipment.

Page 24 of 35

10.

INSPECTION 10.1. Measures are established for inspection of activities within the scope of this DQAP by or for the organization performing the activity, to verify conformance with approved instructions procedures, drawings, and specifications for accomplishing the task.

10.2. A comprehensive program of inspections shall be established and implemented to verify conformance of an item or activity with the specified requirements. Inspections shall be performed by qualified individuals other than those who perform or directly supervise the activity being inspected.

10.3. Where mandatory hold or witness points are required for witness or inspection activities by designated personnel, the designated hold points shall be indicated in appropriate documentation. Work shall not progress beyond the point of an assigned hold point unless the inspection is complete or consent to waive the hold point is given by the designated organization.

10.4. Inspections shall be planned to ensure the characteristic to be inspected and the methods used to perform the inspection and acceptance criteria are documented. If inspection of items is impractical, monitoring of the processing method and equipment shall be utilized. Process monitoring shall be performed by qualified personnel or a qualified automated process.

Inspection and process monitoring shall both be used if quality control is inadequate without both.

10.5. Inspection records shall identify the item inspected, date of inspection, inspectors identity, and results of inspection.

10.6. Unacceptable inspection results shall be evaluated and resolved in accordance with approved procedures. Any modifications, repairs, and replacements are re-inspected to the same standard or method to verify acceptability of the items.

Page 25 of 35

11.

TEST CONTROL 11.1. Measures are established for a documented test program in accordance with applicable Technical Specifications, license conditions, and design documents to assure that all required testing demonstrate that the SSCs within the scope of this DQAP will perform satisfactorily in service. The test program shall ensure that design and performance criteria have been satisfied and that the testing does not adversely affect the safety significant SSCs.

11.2. The test program shall include criteria for determining when testing is required, such as proof tests prior to installation, preoperational tests, and operational tests of SSCs. The procedures that implement testing shall specify the appropriate prerequisites for the test (e.g., personnel qualification requirements, environmental conditions, equipment requirements), sufficient instruction for the performance of the testing, hold or witness points, acceptanceIrejection criteria and limits, and the required test documentation.

11.3 Test results are evaluated by the responsible organization to determine compliance with established acceptance criteria. Test results which do not meet acceptance criteria, shall be documented and evaluated to determine the appropriate corrective actions.

11.4 The test program shall require that modifications, repairs, and replacement of items that have a current safety significant function be tested, utilizing the same criteria as the original items to the extent applicable to the current safety significant function. If alternative tests are required, the alternative tests must be reviewed and approved by the same organization that established the original requirements unless the applicable manager designates another responsible organization. Test records shall be maintained in accordance with approved procedures.

Page 26 of 35

12.

CONTROL OF MEASURING AND TEST EQUIPMENT 12.1. Measures are established to assure those tools, gauges, instruments, and other measuring and test equipment (M&TE), used for activities within the scope of this DQAP, are controlled, calibrated and adjusted in order to maintain accuracy within necessary limits and to ensure M&TE traceability to calibration test data. For the purposes of this section, M&TE is considered to include both portable and permanently installed instrument and control devices.

12.2. Organizational responsibilities are delineated for establishing, implementing, and assuring the effectiveness of the calibration program for M&TE.

Reference standards used to determine the acceptability of items and activities, are of appropriate type, and maintained within prescribed accuracy limits, suitable range and accuracy in order to verify conformance to specified requirements.

12.3. Procedures for the control and calibration of M&TE that are within the scope of this DQAP shall specify identification requirements (labeling, codes, or other documented control system), the recall process and calibration process and frequencies (including documented pre-calibration checks) of the M&TE to nationally recognized standards. Calibration methods are documented and performed by competent personnel in an environment that does not adversely affect the calibration. The calibration procedures shall specify recording of as-found conditions.

12.4. The calibration procedures shall delineate special controls where applicable, for usage, handling, and storage required for environmental conditions such as temperature, humidity, cleanliness, or radiation to maintain accuracy and operating characteristics of the M&TE.

12.5. Calibration reference standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shall be documented.

Special calibration and control measures are not required when normal commercial practices provide adequate accuracy (e.g. rulers, tape measures, levels, and other such devices).

12.6. M&TE which is found to be damaged, out-of-calibration or for which accuracy is suspect, shall be tagged and segregated and processed in accordance with approved procedures. When M&TE is found to be out-of-tolerance, an evaluation is made of its previous uses to determine corrective action.

Page 27 of 35

13.

HANDLING, STORAGE, AND SHIPPING 13.1. Measures are established to control the handling, storage, shipping, packaging, cleaning and preservation of items within the scope of this DQAP in order to prevent damage or deterioration.

13.2. Special coverings, equipment and protective environments shall be specified and provided where necessary for the protection of items from damage and deterioration. Special protective measures are specified and provided when required to maintain acceptable quality. When special protective features are required, their existence shall be verified and monitored as necessary to assure that the special protective features continue to serve their intended function. Special handling tools and equipment shall be provided, where necessary, to ensure items can be handled safely and without damage.

13.3. Controls for hoisting, rigging, and transporting shall be established to protect SSCs within the scope of this DQAP as applicable. Markings or labeling shall be used to indicate the presence of special environments, or the need for special controls. Provisions shall be described for the storage of chemicals, reagents (including control of shelf life), lubricants and other combustible materials. Cleanliness controls shall be implemented to protect applicable SSCs from the introduction of foreign material and maintain system cleanliness as applicable throughout maintenance and modification activities.

Page 28 of 35

14.

INSPECTION, TEST, AND OPERATING STATUS 14.1. Measures are established for indicating the status of items within the scope of this DQAP undergoing inspections and tests to prevent the inadvertent bypassing or altering the sequence of such inspections or tests and avoid inadvertent operation. Where necessary to preclude inadvertent bypassing of inspections or tests, or to preclude inadvertent operation, these measures require the inspection, test, or operating status be verified before release, fabrication, receipt, installation, test or use. These measures also establish the necessary authorities and controls for the application and removal of status indicators or labels.

14.2. In addition, temporary design changes (temporary modifications), such as temporary bypass lines, electrical jumpers and lifted wires, and temporary trip-point settings, are controlled by procedures that include requirements for appropriate installation and removal, independent/concurrent verifications where necessary, and status tracking.

14.3. The operating status of nonconforming, inoperable or malfunctioning SSCs shall be identified and documented to prevent inadvertent operation.

Page 29 of 35

15.

NONCONFORMING MATERIAL, PARTS, OR COMPONENTS 15.1. Measures are established for the identification, evaluation, segregation (when practical), disposition of nonconforming items, and for notification to affected organizations. Items (including applicable services) that do not conform to specified requirements shall be controlled to prevent inadvertent installation or use.

15.2. Measures are established to require that the individual (or designee),

discovering a nonconformance, identify, describe, and document the nonconformance in accordance with the requirements of the corrective action program. Actions taken to address nonconforming items shall be documented.

15.3 Controls are provided to address conditional release of nonconforming items for use on an at-risk basis prior to resolution and disposition of the nonconformance, including maintaining identification of the item and documenting the basis for such release. Conditional release of nonconforming items for installation in the decommissioning facility requires the approval of the designated management.

15.4 Nonconformances are corrected or resolved prior to depending on the item to perform its intended safety significant function. Nonconformances to design requirements dispositioned as repair or use-as-is are subject to design control measures commensurate with those applied to the original design.

Significant trends in nonconformances are reported to management in accordance with applicable procedures, regulatory requirements, and industry standards.

15.5. Nonconforming items that are being used for training must be controlled (e.g.,

administratively controlled, permanently identified, marked, obliterate Material ID Tag or Q level indicators) to prevent inadvertent or inappropriate use of the item.

Page 30 of 35

16.

CORRECTIVE ACTION 16.1. Measures are established to promptly identify, control, document, classify, and correct conditions adverse to quality. Procedures assure that corrective actions are documented and initiated following the determination of conditions adverse to quality in accordance with regulatory requirements and applicable quality standards. Procedures require personnel to identify known conditions adverse to quality. When a complex issue arises where it cannot be readily determined if a condition adverse to quality exists, measures shall be established for documentation and timely evaluation of the issue. Significant conditions adverse to quality are documented and reported to responsible management. In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken and followed up on to verify implementation.

16.2. In the case of vendors performing activities within the scope of this DQAP the applicable manager may delegate specific responsibilities for corrective actions but maintains responsibility for the effectiveness of corrective action measures.

Page 31 of 35

17.

QUALITY ASSURANCE RECORDS 17.1. Measures are established which define the requirements and responsibilities for identification, generation, collection, compilation, storage, maintenance, retention, and retrieval of records necessary to provide objective evidence that activities within the scope of this DQAP are in compliance with the regulations and decommissioning facility implementing procedures.

17.2. Distribution of records shall be controlled in accordance with written procedures. Measures are established for replacement, restoration, or substitution of lost or damaged records.

17.3. Records are legible, accurate, complete, identifiable, and retrievable.

Records are considered valid and complete when dated and stamped, initialed, signed, or otherwise authenticated. Corrections, revisions, or supplements to completed records are reviewed and approved by an authorized individual in the originating organization. Such changes are dated and stamped, initialed, signed, or otherwise authenticated including the use of electronic approval and authorization as applicable.

17.4 Record storage facilities are established and maintained in a manner that minimizes the risk of damage or destruction. Records may be kept by vendors and maintained on an available basis for a specified period of time.

Records may be stored in electronic media provided that the process for managing and storing data is documented in procedures that comply with applicable regulations, including NRC guidance in RIS 2000-18 and as recognized in NIRMA (Nuclear Information Records Management Association) technical guides TG-11, TG-15, TG-16, and TG-21.

17.5 The program includes provisions for the use of various record storage media to maintain QA records. Procedures are developed to implement the regulatory guidance associated with the media used. The NRC Generic Letter 88-18 Plant Record Storage on Optical Disk is implemented for optical disk media. The Regulatory Issue Summary 2000-18 Guidance on Managing QA Records in Electronic Media is implemented for electronic media.

17.6. Record retention periods are established to meet regulatory, UFSAR/DSAR, DQAP, and License requirements. The most stringent retention period is implemented when multiple requirements exist. Records are dispositioned at the end of the prescribed retention period.

Page 32 of 35

18.

AUDITS 18.1. Measures are established for a system of planned and documented audits to verify compliance with all aspects of the DQAP and determine the effective implementation of programs covered by the DQAP.

18.2 Internal and vendor audits are conducted in accordance with written procedures or checklists. Audit personnel shall not have direct responsibilities in the areas to be audited.

18.3. The internal audit program is conducted on a performance driven frequency that is commensurate with the status and importance of the activity to be completed but does not exceed 24-months, unless otherwise required by regulation. Audits may be extended beyond their originally scheduled due date based on the following criteria:

A. Audits shall be performed at the intervals designated and the schedules are based on the month in which the audit starts.

B. A maximum extension not to exceed 25 percent of the audit interval is allowed unless restricted by regulation.

18.4 The vendor audit program is conducted on a performance driven frequency that is commensurate with the status and importance of the activity to be completed but does not exceed 36-months, unless otherwise required by regulation.

A. A maximum extension not to exceed 25 percent of the audit interval shall be allowed except that a total combined time interval for any three consecutive audit intervals should not exceed 3.25 times the specified audit interval, unless otherwise required by regulation.

18.5 When an audit interval extension greater than one month is used, the next audit for that particular audit area is scheduled from the original anniversary month rather than from the month of the extended audit.

18.6 Audit scheduling, preparation, personnel selection, personnel qualification, 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, activities being performed, regulatory requirements, and/or experience with the organization being audited. An audit schedule shall be maintained, reviewed, and revised as necessary at least annually, to ensure that programs receive necessary audits to support regulatory compliance.

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

Page 33 of 35 Appendix A Page 1 of 2 GENERAL ADMINISTRATIVE REQUIREMENTS A.1 Fire Protection 10 CFR 50.48(f) requires that licensees that have submitted the certification required under 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials. The quality assurance program established for these fire protection SSCs ensures that design, procurement, instruction, procedures, drawings, inspection, installation, testing, maintenance, operations, nonconforming Items, corrective action, records, audits and administrative controls meet the applicable quality assurance guidelines as described in the applicable edition of Branch Technical Position (BTP) 9.5-1 for each facility during decommissioning and permanent shutdown. Engineering determines what fire protection SSCs are required to prevent fires, rapidly detect, control, and extinguish fires that do occur and could result in a radiological hazard and, minimize the risk the public, environment, and decommissioning facility personnel resulting from fires that could result in a release of radioactive materials.

Engineering also establishes the requirements for the design, procurement, fabrication, installation and/or modification of these fire protection SSCs.

All other fire protection equipment and supplies will be of commercial quality, in accordance with National Fire Protection Association (NFPA) guidelines.

A.2 Transport of Radioactive Waste A.2.1 When HDI contracts with vendors to transport radioactive waste in NRC approved shipping packages, the contract is written such that the requirements of 10 CFR 71, Subpart H and Regulatory Guide 7.10, Revision 3 (6/15), Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material are met. HDI assures that this service is procured from an organization with a QA program and if applicable, includes a NRC licensed transport system. Loading, surveying, closure, placarding, and inspections are conducted in accordance with written procedures and instructions. Transport casks and trailers are inspected before release in accordance with Department of Transportation (DOT) 49 CFR. Shipping manifests, including final radiation surveys, are completed and retained. Radioactive waste shipments not meeting the requirements for NRC approved packaging, shall meet the requirements of DOT 49 CFR.

Page 34 of 35 Appendix A Page 2 of 2 GENERAL ADMINISTRATIVE REQUIREMENTS A.3.

Services A.3.1. HDI procures services from qualified vendors. It is not necessary that these vendors have a quality assurance program approved by the licensee, however, vendors should provide a quality assurance program that includes the quality assurance program elements presented in Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations)

- Effluent Streams and the Environment, and routinely provide program data summaries sufficiently detailed to permit evaluation of the program for the following areas:

Meteorology.

Offsite Dose Calculation Manual.

Radiological environmental monitoring.

A.4.

License Renewal A.4.1. Consistent with the requirements of 10 CFR 54.21(a)(3), HDI implements the requirements of DQAP Section 1 through 18 for aging management activities related to safety significant SSCs as described by licensing documents for those systems that remain active.

A.4.2. Additionally, to manage the aging effects of non-safety significant SSCs that were determined to be within the scope of License Renewal, HDI implements the administrative controls, corrective actions and confirmation processes described in DQAP Sections 6, 16 and the applicable requirements of this appendix.

A.5.

Safety Review Committee A.5.1. The Safety Review Committee (SRC) serves the HDI President as an on-site review body that performs procedure and program reviews for decommissioning activities and ISFSI operation as necessary on matters of Nuclear Safety. Details regarding the membership, quorum, agenda, and meeting schedule are contained in implementing procedures.

Page 35 of 35 Appendix B Page 1 of 1 SITE SPECIFIC ADMINISTRATIVE REQUIREMENTS B.1.

Regulatory Guide 1.33 B.1.1. Written procedures applicable to safe storage of nuclear fuel recommended in Appendix A of Regulatory Guide 1.33, shall be established, implemented, and maintained.

B.2 Regulatory Guide 1.88 B.2.1 Procedures for the collection, storage, and maintenance of decommissioning facility quality assurance records will be consistent with Regulatory Guide 1.88 Revision 2, dated October 1976. (Collection, storage, and maintenance of decommissioning facility quality assurance records).

B.3.

Independent Spent Fuel Storage Installation (ISFSI) SSC B.3.1. ISFSI quality assurance program requirements are performed in accordance with the applicable 10 CFR 72.212 report which invokes the portions of the NRC approved 10 CFR 50 Appendix B quality assurance program as described in this DQAP, commensurate with the safety classification of the component and quality requirements specified in the cask vendor Final Safety Analysis Report (FSAR) or decommissioning facility ISFSI specific license.

B.3.2 Radioactive Material Transport Packages (10 CFR 71)

Radioactive Material Transport Packages subject to the provisions of 10 CFR 71, Subpart C, General Licenses are Important-to-Safety and subject to the applicable requirements of the DQAP.

Decommissioning Quality Control Program Change Evaluation Form for Rev 3

DQAP CHANGE EVALUATION FORM Sheet 1 of 5 Holtec Decommissioning Quality Assurance Program Manual (DQAP) Rev~

LBDCR NO:

-Hl,lr-

'L\\.f-00.S-DQAP Change Evaluation NOTE - The basis for the answers should be of sufficient depth and detail to support the conclusions reached and allow for independent review. Simply stating the change does not decrease the effectiveness without stating why is not acceptable.

Editorial corrections (i.e., spelling, punctuation, typographical or grammatical errors, and incorrect cross-references) are not considered changes and therefore, a Quality Assurance Program Regulatory Review is not required. All boxes should be checked "N/A" and proceed to signature page of the evaluation form.

YES, NO, or N/A

1. Is this change an editorial change as defined in 1 0 CFR 50.54(a)(3)

YES and 10 CFR 71.106? (If yes, provide basis, mark remaining questions "N/A" and state "not a reduction in commitment") Proceed to approval page of attachment.

Basis for Answer: The change for the proposed Revision 3 of the DQAP is editorial only. The change is specific to the removal of references to the Palisades Nuclear Power Plant (Docket No. 50-225, License No. DRP-20, Docket No.72-007, and Docket No. 71-0937) from the Licensee listino oaoe.

2. For any YES answer in the 10 CFR 50.54(a) Screening or for the QA-N/A initiated change, does the proposed change represent a reduction in commitment or process(es) described or established in the approved QA Program?

Basis for Answer: N/A

3. If item 2 above is YES, is the proposed change limited to the use of a N/A quality assurance alternative or exception approved by the NRC Safety Evaluation Report (SER}, for which the bases of the NRC approval are applicable to HDI?

If YES, explain how all of the NRC approval bases from the SER are incorporated or covered by the HDI QA Program.

This exemption is not allowed under 10 CFR 71.106 and cannot be used to reduce commitments under part 71.