ML24229A047
| ML24229A047 | |
| Person / Time | |
|---|---|
| Site: | 07100327, Trojan |
| Issue date: | 08/27/2024 |
| From: | Rodriguez H NRC/NMSS/DFM/IOB |
| To: | Felton B Portland General Electric Co, Trojan Independent Spent Fuel Storage Facility |
| Shared Package | |
| ML24229A045 | List: |
| References | |
| EPID L-2021-LLQ-0005 PGE-8010 | |
| Download: ML24229A047 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Benjamin F. Felton Executive Vice President, and Chief Operating Officer Portland General Electric Company Trojan ISFSI 71760 Columbia River Hwy Rainier, OR 97048
SUBJECT:
SAFETY EVALUATION REPORT FOR REVISION 31 TO PGE-8010, TROJAN QUALITY ASSURANCE PROGRAM AND FORM 311 APPROVAL NUMBER. 0327 REVISION 18 APPROVAL
Dear Benjamin Felton:
By letter dated September 14, 2023, Portland General Electric Company (PGE) submitted proposed revision 31 to PGE-8010, Trojan Nuclear Quality Assurance Program, for U.S.
Nuclear Regulatory Commission (NRC) review and approval under Title 10, Code of Federal Regulations (10 CFR) Part 72. (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23272A032), supplemented by responses to NRC requests for additional information dated February 26, 2024 (ML24061A021), March 4, 2024 (ML24066A049), May 13, 2024, (ML24115A254), June 6, 2024 (ML24173A306), and July 25, 2024 (ML24212A342) respectively.
As a result of staffs review of the proposed Trojan Independent Spent Fuel Storage Installation (ISFSI) quality assurance program (QAP), revision 31, the staff prepared a Safety Evaluation Report (SER) to document the independent verification against the requirements of 10 CFR Part 72. The SER in Enclosure 1 contains information regarding the scope of the staffs review and our conclusions for the QAP. The staffs review found that the Trojan ISFSI QAP continues to meet the requirements of 10 CFR Part 72, subpart G, Quality Assurance.
In addition, revision 18 of NRC Form 311 for approval 0327 documents NRC approval of proposed revision 31 to PGE-8010, Trojan Nuclear Quality Assurance Program for governing activities that must adhere to the requirements of 10 CFR Part 71, Packaging and Transportation of Radioactive Material. The revised NRC Form 311 has been included in Enclosure 2.
Upon final PGE approval of PGE-8010 revision 31, please send the NRC an approved copy with its effective date.
August 27, 2024
B. Felton 2
If you have any questions regarding this approval of the QAP, please contact me at Hector.Rodriguez-Luccioni@nrc.gov or Raju Patel at raju.patel@nrc.gov.
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 EPID ID: L-2021-LLQ-0005
Enclosures:
1.Safety Evaluation Report 2.NRC Form 311 Signed by Rodriguez-Luccioni, Hector on 08/27/24
B. Felton 3
SUBJECT:
SAFETY EVALUATION REPORT FOR REVISION 31 TO PGE-8010, TROJAN QUALITY ASSURANCE PROGRAM AND FORM 311 APPROVAL NUMBER. 0327 REVISION 18 APPROVAL DATE:
August 27, 2024 EPID: L-2021-LLQ-0005 DISTRIBUTION:
DFM r/f NMSS r/f
- GWarnick, RidsRgn4MailCenter Resource ADAMS ACCESSION NOs. ML24229A045 (Pkg), ML24229A047 (Ltr and SER)
ML24229A046 (Form 311)
OFFICE:
NMSS/DFM NMSS/DFM NMSS/DFM NAME:
RPatel WWheatley HRodriquez DATE:
8/16/2024 8/19/2024 8/27/2024 OFFICIAL RECORD COPY UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT Docket No. 72-17 REVISION 31 TO PGE-8010, TROJAN QUALTY ASSURANCE PROGRAM (QAP) 1.
INTRODUCTION By letter dated September 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23272A032), Portland General Electric Company (PGE, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC, the Commission), for review and approval, a revision to the PGE Independent Spent Fuel Storage Installation (ISFSI) Quality Assurance Program (QAP) PGE-8010, revision 31 in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 72.140(b) and (c), and 10 CFR 71.101(b) and (c), and 10 CFR 71.106(a).
Trojans QAP PGE-8010 is associated with special nuclear material license number SNM-2509, and docket number 07200017 for the ISFSI at the Trojan site. The QAP is a standalone description of the Trojan ISFSI QAP which meets the requirements of Part 72, subpart G.
The NRC staff (the staff) reviewed the application, including relevant supplemental information in response to the NRC request for additional information (RAIs), using the guidance in NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, section 12, Quality Assurance Evaluation, dated March 2000 (ML003686776). Based on the statements and representations in the QAP as supplemented, the staff concludes that the Trojan ISFSI QAP, revision 31, meets the requirements of 10 CFR Part 72, subpart G.
2.
REGULATORY BASIS The NRCs regulation 10 CFR 72.24(n) has requirements for each application for a license under Part 72 to include a description of the Quality Assurance (QA) program that satisfies the requirements of subpart G. In addition, 10 CFR 72.56 requires, in part, whenever a holder of a specific license desires to amend the license (including a change to the license conditions), an application for an amendment shall be filed with the Commission fully describing the changes desired and the reasons for such changes.
Section 72.140, Quality Assurance Requirements, of subpart G, establishes the QA requirements for the design, purchase, fabrication, handling, shipping, storing, cleaning assembly, inspection, testing, operation, maintenance, repair, modification of structures, systems, and components, and decommissioning that are important to safety. Section 72.144, Quality Assurance Program, of subpart G, establishes requirements for indoctrination, and training of personnel. Section 72.144 states, in part, that, The licensee, applicant for licensee, certificate holder, and applicant for a Certificate of Compliance shall
2 provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
3.
TECHNICAL EVALUATION The purpose of this evaluation is to review and evaluate the proposed changes made in revision 31 to Trojan ISFSI PGE-8010 to assess whether the Trojan ISFSI QAP as written continues to comply with the requirements of 10 CFR Part 72, subpart G.
The following sections include the staffs evaluation in the areas related to the review.
A. Revised section 1.0, Organization, to reflect the current ISFSI operation and functional reporting chains. The organization chart was moved to appendix A of the Trojan ISFSI QAP.
B. Deleted subsection 1.2.2, ISFSI Safety Review Committee (ISRC), and replaced with subsection 1.2, Independent Management Assessments, function. The Independent Management Assessment (IMA) function reports to the Corporate Executive Responsible for Trojan. The Corporate Executive Responsible for Trojan shall periodically have an IMA performed to evaluate the effectiveness and implementation of the Trojan QA program.
PGE stated that IMAs shall be performed by individuals designated by the Corporate Executive Responsible for Trojan, independent of the Trojan ISFSI operations and QA program and have the appropriate level of expertise in activities being assessed. The periodic IMAs shall be performed no less frequently than every 24-months with a 90-day grace period. The IMA results shall be communicated in a written report in a timely manner to the Corporate Executive Responsible for Trojan to ensure effective corrective actions are implemented commensurate with their safety significance and will be reported to the PGE President.
In PGEs submittal letter for proposed Trojan ISFSI QAP, revision 31, the licensee stated that the Trojan ISFSI QAP will transition ISRC function to an IMA process within two years of the approval of the Trojan QAP revision 31.
C. Deleted subsection1.2.3.1 ISRC Member Responsible for Managing Nuclear Oversight Resources, and replaced with subsection 1.4, QA Manager, with detail description of the QA managers roles and responsibilities, and reporting to the Corporate Executive for Trojan. The QA Manager is responsible for independent oversight of the implementation of the Trojan ISFSI QA program and has indirect reporting responsibilities to the ISFSI Manager in the context of day-to-day ISFSI operation but does not execute line organization work. They have the authority, direct access to the responsible levels of management, organizational freedom, and access to work to perform these duties including independence of cost and schedule considerations when opposed to safety function considerations. If disagreements that cannot be resolved between the QA Manager and ISFSI Manager, then they are referred to the Corporate Executive responsible for Trojan for resolution.
NRC staff in their email dated July 18, 2024, (ML24213A247), to PGE requested to provide the experience and qualification requirements for the QA Manager. PGE in their response letter (ML24212A343 and ML24212A344), to staffs RAI, revised section 1.4 by
3 including a detail description of the minimum qualification and experience requirements of the QA Manager responsible for oversight of the Trojan QA Program.
Based on review of PGEs response to revise section 1.4 of the Trojan ISFSI QAP, the staff concluded that PGEs response to be acceptable and the changes in the QAP meets the guidance in the Standard Review Plan (SRP) section 12.4.1.3, Organization for Performing QA Function.
D. Added section 1.6, Delegation of Work, providing detail description of delegation of work.
PGE retains and exercises the responsibility for the scope and implementation of this QAP. Positions identified in this QAP may delegate all or part of the activities of planning, establishing, and implementing the program for which they are responsible to others, but retain the responsibility for compliance with program requirements. The responsibility for implementing certain elements of the QAP may be delegated to other organization duly qualified to perform such activities. However, the ultimate responsibility for compliance with and effective implementation of the QA program requirements remains with PGE via acceptance process for procured items and services.
E. Added section 1.7, Interface Control, providing detail interface control between internal organization and when between multiple organizations involved in the execution of activities, the responsibilities, interfaces, and authority of each organization shall be clearly defined and documented.
F. Added section 1.8, Storage Cask and Transportation Package Designer, that describes the responsibilities of the Storage Cask and Transportation Package Designers.
G. Added section 1.9, Other Engineering Services, that describes the use of different engineering firms for engineering, analysis, and design activities on as-needed basis under their respective QA programs reviewed and approved by PGE through procurement process.
H. Added section 1.10, Authority to Stop Work, that describes the authority of all employees to stop work when unsatisfactory work or unsafe conditions exist that pose an immediate threat to the health and safety of the public and report to their supervisor, ISFSI Manager or QA Manager for investigation and evaluation.
I.
Section 2.0, of the Trojan ISFSI QAP was re-written to include detailed information regarding Trojan ISFSI QAP commitment to guidance in Regulatory Guide (RG) 7.10, revision 3. In this section PGE added subsections on responsibilities, program summary, QAP change control, Important to Safety Activities, periodic review of the QAP, applicability of 10 CFR Part 21. Further, PGE expanded section on Training, to include detailed information regarding personnel indoctrination and training, qualification requirements, and training records.
J.
Added subsection 2.6, Applicability of 10 CFR Part 21, that describes that PGE maintains a written program for identifying and reporting of potential defects in accordance with 10 CFR Part 21. PGE proposed that it limits the applicability of 10 CFR Part 21 to important to safety (ITS)-A items and services, based on a determination that only ITS-A items and services meet the definition of basic component, in 10 CFR 21.3 as applicable to a Part 72-licensed facility.
4 K. Revised section 6, Document Control, to include detail description of the process for controlling documents and storage of documents electronically.
L.
Revised section 7, Control of Purchased Items and Services, to include the method of acceptance of items and services. PGE added the method of evaluating and acceptance of audits performed by third-party organizations to ensure the scope and adequacy of the audits meets PGE requirements. Further, PGE stated that it may use industry programs such as those applied by American Society of Mechanical Engineers, Nuclear Procurement Issues Corporation or other utility groups as input or basis for supplier qualification.
M. Revised section 9, Control of Special Processes, to include a statement that a special process may be delegated to other organizations, but PGE shall retain overall responsibilities for the quality of work and its acceptance.
N. Revised section 10.0, Inspection, to include inspector qualification program requirements. Described in implementing procedures.
O. Revised section 12.0, Control of Measuring and Test Equipment, to include the use of guidance for procurement of calibration services for portable measuring and test equipment (M&TE) from a commercial-grade supplier that meet the guidance in Nuclear Energy Institute (NEI)14-05A Guidelines for the Us of Accreditation in Lieu of Commercial-Grade Surveys for Procurement of Laboratory Calibration and Test Services, revision 1. This includes any applicable limitations in the NRCs SER endorsing the NEI guidance. For installed ITS M&TE calibration services shall be procured as an ITS service.
The staff reviewed the QA measures to be implemented by PGE in Trojan ISFSI QAP section 12.0 and concluded that the changes in the QAP continue to meet the guidance in SRP section 12.4.12, Calibration of Measuring and Test Equipment.
P. In section 18.1, Audits, of the Trojan ISFSI QAP, PGE proposed to perform audits every 24-months with a 90-day grace period. The licensee stated that the use of all, or part of the grace period will not impact the established 24-month cycle for the assessment.
Further, the licensee proposed to take exception to the annual audit frequency from the RG 7.10, Establishing Quality Assurance Programs for Packaging Used in the Transportation of Radioactive Material, revision 3.
In the letter dated May 13, 2024, (ML24115A254), to PGE, staff requested for additional information to either remove 24 months with a 90-day grace period audit frequency or provide reasonable justification for taking exception to the audit frequency from RG 7.10, revision 3 as well as a 90-day grace period.
In the response letter dated June 6, 2024, (ML24173A306), to the staff RAI, PGE stated that the 24-month is an appropriate audit frequency for ISFSI-only sites such as Trojan, which have a much lower public health and safety risk profile than operating plants. The comparatively lower risk at the standalone ISFSI is attributable to the spent fuel storage cask system being passive in design and they operate at a very low pressure (less than 40 psig). PGE in their justification stated that the Trojan ISFSI is a standalone ISFSI site, unlike from 10 CFR Part 71 certificate of compliance holders and NRC licensees that may package and ship radioactive material under Part 71 and operating reactor licensees where the facility conducts a much larger number of activities subject to the QA program
5 oversight. Trojan has completed movement of all spent fuel to the ISFSI and the only activities subject to QA program controls largely involve routine maintenance of the ISFSI pad and spent fuel casks as well as aging management inspections. Further, PGE stated that section 2.2 of the Trojan ISFSI QAP requires biennial self-assessment of the QA program implementation by the line organizations and additional assessment by newly created IMA process will also be conducted no less frequently than every 24 months.
PGE in their justification for the use of a 90-day grace period, stated that the 90-days would allow flexibility to slightly exceed the 24-month audit frequency in case of unforeseen delays in performing audits. PGE clarified that the use of the grace periods are not expected to be a routine occurrence and will not extend the due date of the subsequent audit. PGE proposed to revise section 18.1 of the QAP to include the proposed response and added the statement, or more likely as performance dictates, after every 24-months.
Based on review of PGEs response, the staff determined PGEs justification for deviating the audit frequency of RG 7.10 revision 3, from 12-months to 24-months to be reasonable and acceptable for a standalone ISFSI facility like Trojan that has limited QA program control activities involving routine maintenance of the ISFSI pad and spent fuel casks and aging management and poses very low public health and safety risk. Further, the staff determined PGEs proposed justification for the use of a 90-day grace period in case of unforeseen delays in performing audits and would not expect to be a routine occurrence and will not extend the due date of the subsequent audit to be reasonable and acceptable for a standalone ISFSI facility like Trojan.
4.
EVALUATION FINDINGS The staff reviewed and evaluated the QAP and concluded that it satisfied the requirements of 10 CFR Part 72, subpart G.
The staff assessed that:
i.
The applicant established and delineated the responsibilities, authorities, and duties of persons, and organizations performing activities affecting quality.
ii.
The applicants description of the QA program describes organizations and persons performing QA functions, indicating that sufficient independence and authority should exist to perform their functions without undue influence from those directly responsible for costs and schedules.
iii.
The QA plan provided control over activities affecting quality and ensured conformance to the approved design of structures, systems, and components that are important to safety.
iv.
The QA plan defined requirements, procedures, and controls that, when properly implemented, will comply with the requirements of 10 CFR Part 72, subpart G.
v.
The QA plan satisfied the requirements of 10 CFR 72.24(n).
6 5.
REFERENCES Portland General Electric Company letter Revision 31 to PGE-8010, Trojan Nuclear Quality Assurance Program dated September 14, 2023 (ML23272A032).
NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, Section 12, Quality Assurance Evaluation, dated March 2000 (ML003686776).
NRC approval of NEI 14-05-A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated February 9, 2015 (ML14322A535).
6.
CONCLUSION Based on the statements and representations contained in the application, the staff concluded that changes under revision 31 to PGE-8010, Trojan Nuclear Quality Assurance Program are acceptable and in conformance with the applicable requirements of subpart G to 10 CFR Part 72.