View source for HBL-86-006, Forwards Rev 1 to Safstor QA Program & Description of Rev

{{Adams
| number = ML20154Q042
| issue date = 03/14/1986
| title = Forwards Rev 1 to Safstor QA Program & Description of Rev
| author name = Shiffer J
| author affiliation = PACIFIC GAS &amp; ELECTRIC CO.
| addressee name = Berkow H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000133
| license number = 
| contact person = 
| document report number = HBL-86-006, HBL-86-6, NUDOCS 8603210014
| package number = ML20154Q047
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
}}

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PACIFIC                       GAS AND ELECTR,IC C O M PANY bbWIb                   ;     77 BEALE STREET . SAN FRANCISCO, CALIFORNIA 94106 . (415) 781 4211 . TM 910 372 6587 JAMES D. SHIFFE R vKE PRE 9 CENT mio -1.         ~.ma                                          March 14, 1986 PGandE Letter No.: HBL-86-006 Mr. Herbert N. Berkow, Director Special and Standardization Project Directorate Division of PHR Licensing-B U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit No. 3 Custodial SAFSTOR Facility Quality Assurance Plan, Revision 1

==Dear Mr. Berkow:==

PGandE hereby submits the enclosed changes to the Custodial SAFSTOR Facility Quality Assurance Plan, Revision 1, which was provided with PGandE letter HBL-85-059, dated December 13, 1985.
The changes are delineated in the enclosure and the modified pages are provided following the enclosure. Four pages are affected and are identified as being revised in March 1986. The affected pages are page 2 to Attachment A of HBL-85-059, and pages 1, 8 and the cover page to the Quality Assurance Plan, Revision 1.
Please substitute the enclosed pages for those originally submitted.
This plan provides for the implementation of a graded Quality Assurance Program based upon the appropriate criteria of 10 CFR 50, Appendix B, commensurate with the limited scope of activities proposed during SAFSTOR at HBPP-3.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely.
                     -8603210014 860314 3 PDR     ADOCK 0500 P
J.    . Shiffer Enclosure cc:       P. B. Erickson (2)                                           gol            N J. B. Martin                                                                      tp g,,d Humboldt Distribution                                        (i )                    i    g Service List (Decommissioning) 0747S/0042K/GHM/1739 m

PGandE Letter No.: HBL-86-006 e
ENCLOSURE 0747S/0042K

==Enclosure:==
Description of Revision The following changes clarify the sections concerning applicability of 10CFR50, Appendix B and 10CFR71.
Ref: Attachment A HBPP-3 QA Plan (Rev 1)
: 1. Page 2 Replace first paragraph with the following:
              " Analyses of potential accidents, assuming worse-case conditions, demonstrate that the HBPP-3 components, systems, and structures need not function to prevent or mitigate the radiological consequences to less than 10CFR100 limits. Thus, the components, systems,.and structures need not be classified and treated as safety-related.
Because (a) the components, systems, and structures need not be
>             classified and treated as satety-related, and (b) the activities during SAFSTOR are of such limited scope, PGandE concludes that, rather than a full-scale 10CFR50, Appendix B quality assurance program, a graded program based upon the appropriate criteria of Appendix B is appropriate for HBPP Unit 3 SAFSTOR activities."                                        ,
: 2. Page 2 paragraph 3.0 Change to read.
              " Containers may be used to transport radioactive materials during the HBPP-3 SAFSTOR period. Thus, the quality assurance requirements of Subpart H of 10CFR71 would be applicable for this activity."
Ref: HUMBOLDT BAY POWER PLANT UNIT 3 - SAFSTOR QUALITY ASSURANCE PLAN dated December 1985:
Paragraph 1.1
: 1) add new: "a) To establish and implement a graded program that is based upon the appropriate criteria of 10CFR50, Appendix B and is commensurate with the limited SAFSTOR activities and required function of the HBPP-3 components, systems, and structures.
: 2) Change old "a)" to "b)" and old "b)" to "c)"
Paragraph 3.3
: 1) Change 6th line to read
                      "--with the quality assurance requirements of Subpart H of 10CFR71- "
_ . _ _ . _ ~ _ . _ _ .      . . - _   -  . _ - _ _ . _ .         . _ . _

           .                Analyses of potential accidents, assuming worse-case conditions, demonstrate that the HBPP-3 components,' systems, and structures need not function to prevent or mitigate the radiological consequences to less than 10CFR100 limits. Thus, the components, systems, and structures need not be classified and treated as safety-related.
Because (a) the components, systems and structures need not be classified and treated as safety-related and (b) the activities during SAFSTOR are of such limited scope, PGandE concludes that i                           rather than a full-scale 10CFR50 Appendix B quality assurance program, a graded program, based upon the appropriate criteria of Appendix B is appropriate for the Unit 3 SAFSTOR activities.
3.0 APPLICABILITY OF 10CFR71 Containers may be used to transport radioactive materials during the HBPP-3 SAFSTOR period. Thus, the quality assurance j                           requirements of Subpart H of 10CFR71 would be applicable for this activity.
4.0 APPLICABILITY OF REGULATORY GUIDE 4.15
 !                          Radiological monitoring of gaseous and liquid affluents and the environment will be conducted in accordance with the HBPP-3 Technical Specifications. While the level of radioactivity to be potentially released during SAFSTOR operations is well within regulatory limits, it is still important to assure that the radiological monitoring measurements are valid. Thus, the quality assurance requirements of Regulatory Guide 4.15 are deemed applicable.
5.0 PLAN APPROACH Tne Plan first describes the quality assurance organization responsible for implementing the Plan. General quality assurance requirements common to the activities covered by the Plan are then described.
These requirements include:
                   .       >                                                e.
: a. Procedures, Instructions, and Drawings.
: b. Document Control.
: c. Nonconformance Control.
: d. Indoctrination and Training.
: e. Records.
: f. Audits.
With respect to the radiological monitoring of gaseous and liquid effluents, the plan requires compliance with USNRC Regulatory Guide 4.15 (Revision O, December 1977).
(Rev. 1)
(Revised 3/86) i
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