ML082760408

Sacramento Municipal Utility District, Submittal of Revised Rancho Seco Quality Manual

ML082760408
Person / Time
Site:	Rancho Seco
Issue date:	09/24/2008
From:	Rosalyn Jones Sacramento Municipal Utility District (SMUD)
To:	John Hickman Document Control Desk, NRC/FSME
References
NQA 08-031
Download: ML082760408 (35)

Text

{{#Wiki_filter:"WSMUD SACRAMENTO MUNICIPAL ,UTILITY DISTRICT The Power To Do More. P.O. Box 15830, Sacramento, CA 95852-1830; 1-888-742-SMUD (7683) NQA 08-031 September 24, 2008 U.S. NRC Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Docket 50-312 Rancho Seco Nuclear Generating Station License DPR-54 REVISED RANCHO SECO QUALITY MANUAL Attention: John Hickman In accordance with 10 CFR 50.54(a)(3) and 10 CFR 50.4(b)(7)(i), the Sacramento Municipal Utility District is submitting a revision to portions of the previously accepted Rancho Seco Quality Manual (RSQM). Specifically, we are submitting RSQM Section XVIII, Revision 12 "Audits" and RSQM Appendix A, Revision 1 "Administrative Controls for Licensed Activities." Both of these RSQM sections were revised to reflect the long term monitoring organization that will go into effect after the MARSSIM Final Status Surveys (FSS) are completed. In addition, RSQM Section XVIII was revised to decrease certain audit frequencies to reflect long term monitoring conditions and to delete the requirement to perform trend analysis. The proposed decrease in audit frequencies. is as follows: Decrease the emergency preparedness audit frequency from once per year to once every two years. This frequency is consistent with 10 CFR 50.54(t)(1)(ii) which states that all' elements of the emergency preparedness program must be reviewed at least once every 24 months. Decrease the Physical Protection Program (PPP) audit frequency from once per year to once every two years. This frequency is consistent with 10 CFR 73.5 1(d)(12) which states that the PPP must be reviewed once every 24 months. Decrease the audit frequency of the 18 criteria in 10 CFR Part 50, Appendix B from once every 2 years to once every 5 years. With decommissioning activities completed, the principal activity on the 10 CFR Part 50 site will be the passive storage of Class B

       & C radioactive waste in the Interim Onsite Storage Building (IOSB). The spent nuclear fuel remains in dry storage at the Independent Spent Fuel Storage Installation (ISFSI). The 10 CFR Part 50, Appendix B programs are being reduced in scope to reflect the reduction in ongoing activities at the site. Accordingly, reducing the audit RANCHO SECO NUCLEAR PLANT

• 14440 Twin Cities Road, Herald,CA 95638-9799; (209) 333-2935

J. Hickman 2 NQA 08-031 frequency of the 18 criteria in 10 CFR Part 50, Appendix B from once every two years to once every five years is acceptable and is commensurate with the reduced activities at the site. RSQM Appendix A was revised to:

   " Delete the temporary procedure change process. The temporary procedure change process is no longer useful in the long term monitoring condition.
   " Reflect that radioactive effluents are no longer released from the site. There are no longer any radioactive liquid or gaseous effluents discharged from the site. The Offsite Dose Calculation Manual (ODCM) will be reduced in scope and the associated administrative and implementing procedures will be deleted. The ODCM will require that if radioactive effluents need to be released in the future, a program must be implemented that meets the requirements in 10 CFR 50.36a, 20.1301, 20.1302, 10 CFR Part 50, Appendix I, and any other applicable regulations Although there are no longer any radioactive effluents discharged from the site, we will continue to submit the Annual Radioactive Effluent Release Report until the NRC grants a specific exemption from 10 CFR 50.36a.

• Reflect that the REMP monitors only the direct radiation pathway. There are no longer any liquid or gaseous radioactive effluents discharged from the site. The radiation source term is limited to radioactive materials stored in the IOSB and the ISFSI. Accordingly, the only exposure pathway is by direct radiation.

The REMP will continue to require participation in an Inter-laboratory Comparison Program to ensure that independent checks on the precision and accuracy of the direct radiation measurements are performed as part of the quality assurance program for environmental monitoring.

• Delete the 10 curie limit for liquid hold-up tanks since these tanks no longer exist.
• Delete the requirement to maintain certain records for the duration of the operating licenses. In a letter dated December 23, 2004, (TAC No. L52635) the NRC granted Rancho Seco a partial exemption from the recordkeeping requirements in 10 CFR 50.71(c). This exemption allows the disposal of records, prior to termination of the license, that are associated with the operation, design, fabrication, erection, and testing of structures, systems, and components (SSCs) that are no longer quality related and/or important to safety or have been removed from the plant for disposal.

Accordingly, we are proposingto delete the requirement to retain the following records: 0 Records of reactor tests and experiments.

J. Hickman 3 NQA 08-031 0 Records of transient or operational cycles for those facility components designed for a limited number of transients or cycles.

• Records of in-service inspections previously performed pursuant to the Appendix A Technical Specifications
• Records of theenvironmental qualification of safety related electrical equipment previously generated pursuant to the Appendix A Technical Specifications.
• RecOrds of the service lives of all hydraulic and mechanical snubbers, including the date at which the service life commences, and associated installation and maintenance records.

The following records will be maintained for the 10 CFR Part 72 licensed ISFSI only

• Records and logs of principal maintenance activities, inspections, repair, and replacement of principal items-of equipment related to NUCLEAR SAFETY
• Records of changes made to Operating Procedures.

Based on the discussion above, and in accordance with 10 CFR 50.54(a), we conclude that this RSQM revision reduces the commitments in the RSQM that the NRC has previously accepted and therefore, prior NRC approval is required. provides a copy of the proposed RSQM Section XVIII, Revision 12 "Audits" and RSQM Appendix A, Revision 1 "Administrative Controls for Licensed Activities." includes a redline-strikeout version of the revised documents to facilitate NRC review. If you or members of your staff have any questions requiring additional information or clarification, please contact me at (916) 732-4843. Sincerely, Robert .Js Supervis*; uality Engineer Attachment Cc w/atch: NRC Region IV, Arlington, Texas

Attachment 1 Section XVIII, Revision 12 "Audits"' and RSQM Appendix A, Revision 1 "Administrative Controls for Licensed Activities"

MANUAL: RANCHO SECO QUALITY MANUAL RSQM-SECTION XVIII REVISION:12 TITLE: AUDITS PAGE 1 OF 5 LEAD DEPARTMENT: EFFECTIVE DATE: NUCLEAR QUALITY ASSURANCE REVISION

SUMMARY

1. Revised the audit frequencies to reflect the long term monitoring conditions.

2. Revised to reflect the long term monitoring organization.

3. Deleted the requirement to perform trend analysis.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 2 OF 5 XVIII. AUDITS 1.0 PURPOSE Describe the Rancho Seco Quality Assurance Program (QAP) measures that (1) establish a comprehensive system of planned and periodic audits, and (2) determine the effectiveness of the QAP at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS) licensed under 10 CFR Part 50 and the Independent Spent Fuel Storage Installation (ISFSI) licensed under 10 CFR Part 72. 2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XVIII, Audits 2.2 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.3 Reg. Guide 1.144/ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 2.4 Reg. Guide 1.146/ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 2.5 10 CFR 50.54(a), Conditions of Licenses 2.6 10 CFR 71.137, Audits 2.7 10 CFR 72.176, Audits 3.0 POLICY Procedures shall be established and implemented to assure that planned and periodic audits are conducted to verify compliance with all aspects of the QAP. 4.0 GENERAL REQUIREMENTS 4.1 Quality Assurance shall establish a schedule for auditing the activities affecting quality. The audit schedule shall be consistent with the audit requirements and frequencies specified herein. 4.2 The audit program shall be described in procedures that implement this RSQM section.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 3 OF 5 4.3 Audits shall be conducted to determine the adequacy and effectiveness of programs implemented for the design, procurement, modification, maintenance, and operational activities at the Rancho Seco nuclear facility. 4.4 Audit plans shall be developed that identify the audit scope, the requirements, activities to be audited, organizations to be notified, the applicable documents, and the audit schedule. 4.6 Audit reports shall be issued which identify the activity that was audited, the personnel that were contacted during the audit, and any conditions adverse to quality noted during the audit. 4.7 Process conditions identified as adverse to quality using the Rancho Seco Corrective Action Program. 4.8 Personnel conducting audits shall be trained and qualified in accordance with Reference 2.4. In addition, at least one individual participating in the Security audit will be knowledgeable and practiced in the access authorization program performance objectives. 4.9 Regularly scheduled audits shall be supplemented by special audits/surveillances when conditions that warrant special audits exist or when requested by SMUD management. 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section L ORGANIZATION. 5.1 Quality Assurance is responsible for:

a. Establishing a schedule for performance of required audits.

b. Reviewing audit results to evaluate the effectiveness of the QAP.

c. Implementation of the established audit program.

d. Training and qualification of audit personnel.

5.2 Each group is responsible for:

a. Supporting the audit activities.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 4 OF 5

b. Providing prompt response to any deviations from quality identified in the audit.

6.0 AUDITS AND AUDIT FREQUENCIES 6.1 Audits of Rancho Seco nuclear facility activities shall be performed under the cognizance of the Quality Assurance organization which reports to the Manager, Audit Services. The required audits and audit performance frequencies are as follows:

a. Conformance to the Rancho Seco nuclear facility Technical Specifications and associated license conditions at least once per year;

b. Performance and qualifications of the Rancho Seco nuclear facility technical staff at least. once every two years;

c. Actions taken to correct deficiencies occurring in facility structures, systems, components, or methods of operation associated with the safe operation of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) at least once every two years for those deficiencies not previously audited (Corrective Action Program audit);

d. Performance of activities required by the QAP to meet the 10 CFR 50, Appendix B criteria at least once every five years;

e. Rancho Seco nuclear facility Emergency Plan and implementing procedures at least once every two years;

f. 10 CFR 72 ISFSI Physical Protection Plan and implementing procedures at least once every two years;

g. Other areas of Rancho Seco nuclear facility operation that the Site Superintendent considers appropriate;

h. Compliance with fire protection requirements and implementing procedures at least once every two years;

i. Radiological Environmental Monitoring Program (REMP) and the results thereof at least once every two years;

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 5 OF 5

j. Off-site Dose Calculation Manual (ODCM) and implementing procedures at least once every two years;

k. Process Control Program (PCP) and implementing procedures for processing and packaging of.radioactive wastes from liquid systems at least once every two years;

1. Performance of activities required by the Quality Assurance Program for Effluent Control and Environmental Monitoring (Reg. Guide 4.15) at least once every two years; and

m. Radiation Protection Program content and implementation once per year.

6.2 Changes to these audits and audit frequencies are subject to the requirements contained in 10 CFR 50.54(a). In addition, frequencies specified in 10 CFR and related to the performance of specific audits may not be changed unless an exemption or waiver is obtained from the NRC. 6.3 The audit reports resulting from items "a". through "m". above shall be forwarded to the Site Superintendent, the Manager, Power Generation, and the management positions responsible for the areas reviewed. The report should be issued within 30 days after completion.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 1 OF 10 LEAD DEPARTMENT: EFFECTIVE DATE: NUCLEAR QUALITY ASSURANCE REVISION

SUMMARY

1. Revised to reflect the long term monitoring organization.

2. Deleted temporary procedure changes.

2. Revised to reflect that radioactive effluents are no longer released from the site.

3. Revised to reflect that the REMP monitors only the direct radiation pathway.

4. Deleted the 10 curie limit for liquid hold-up tanks since these tanks no longer exist.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 2 OF 10 1.0 10 CFR 50 ADMINISTRATIVE CONTROLS 1.1 Technical Review and Control

a. Procedures, plans, manuals, and programs required by Section 1.4 shall be prepared, reviewed and approved. Each such procedure, plan, manual, and program or change thereto shall be reviewed by an individual(s) other than the preparer, but who may be from the same organization as the preparer of the procedure, plan, manual and program or change thereto. Programs, plans, manuals, and procedures other than administrative procedures will be approved as delineated in writing by the Site Superintendent, but not lower than a direct report to the Site Superintendent. Such procedures, plans, marnuals and programs shall be reviewed periodically in accordance with administrative procedures.

The Site Superintendent will approve administrative procedures and Emergency Plan Implementing Procedures.

b. Proposed changes or modifications to systems or equipment described in the DSAR shall be reviewed by an individual(s) other than the individual(s) who designed the modification, but who may be from the same organization as the individual(s) who designed the modifications. Such modifications shall be approved by the Site Superintendent or his designee as delineated in writing, but not lower than a direct report to the Site Superintendent.

c. Individual(s), other than the individual(s) who prepare proposed tests or experiments shall review proposed tests and experiments that are not addressed in the DSAR. Such tests or experiments shall be approved by the Site Superintendent or his designee as delineated in writing, but not lower than a direct report to the Site Superintendent.

d. Individuals responsible for reviews performed in accordance with Section 1.1a, b, and c shall meet or exceed the.qualification requirements of Section 4, "Qualifications," of ANSI N18.1-1971, excluding Sections 4.5.2, "Technicians,"

and 4.5.3, "Repairmen." The Site Superintendent shall establish the list of qualified reviewers for the independent reviews described in a, b, and c above.

e. Events reportable pursuant to Section 1.5.5 and violations of Technical Specifications shall be investigated and a report prepared which evaluates the

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 3 OF 10 event and which provides recommendations to prevent recurrence. The Site Superintendent shall review these reports. 1.2 Audits (See RSQM Section XVIII) Specific audit requirements, including frequencies and administrative controls, are addressed in Rancho Seco Quality Manual (RSQM) Section XVIII, "Audits." 1.3 Licensee Event Report Action The following actions shall be taken for events that are reportable as Licensee Event Reports:

a. The Commission shall be notified and a report submitted per Section 1.5.5, pursuant to the requirements of 10 CFR 20.2203 and 50.73, and

b. Each Licensee Event Report shall be reviewed and approved by the Site Superintendent or designee.

1.4 Procedures, Plans, Manuals, and Programs 1.4.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained' covering the activities referenced below:

a. The applicable procedures recommended in Appendix "A" of Safety Guide 33, November 1972.

b. Emergency Plan implementation.

c. Fire Protection Program Plan implementation.

d. PCP implementation.

e. ODCM implementation.

f. REMP MANUAL implementation.

1 Note: These procedures, plans, manuals, and programs may coexist within a single document.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE - REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 4 OF 10

g. Quality Assurance Program for Effluent Control and Environmental Monitoring using the guidance of Regulatory Guide 4.15, Revision 1, February 1979.

h. Quality Assurance Program implementation.

g. Radiation Protection Program implementation.

1.4.2 Each procedure, plan, manual, and program of Section 1.4.1 above and changes thereto shall be reviewed and approved as set forth in Section 1.1. 1.4.3 The following programs shall be established, implemented, and maintained: 1.4.3.1 Radioactive Effluent Controls Program There are no longer any radioactive liquid or gaseous effluents discharged from the site. The Offsite Dose Calculation Manual (ODCM) has been reduced in scope and the associated administrative and implementing procedures have been deleted. The ODCM will require that if radioactive effluents need to be released in the future, a program must be implemented that meets the requirements in 10 CFR 50.36a, 20.1301, 20.1302, 10 CFR Part 50, Appendix I, and any other applicable regulations 1.4.3.2 Radiological Environmental Monitoring Program (REMP) There are no longer any liquid or gaseous radioactive effluents discharged from the site. The radiation source term is limited to radioactive materials stored in the Interim Onsite Storage Building (IOSB) and the Independent Spent Fuel Storage Installation (ISFSI). Accordingly, the only exposure pathway is by direct radiation. The REMP requires participation in an Inter-laboratory Comparison Program to ensure that independent checks on the precision and accuracy of the direct radiation measurements are performed as part of the quality assurance program for environmental monitoring. 1.4.4 The changes to the REMP shall be reviewed and approved as set forth in Sections 1.1 and 1.9. 1.5 Reporting Requirements

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 5 OF 10 1.5.1 Routine Reports In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the Region IV Office unless otherwise noted. 1.5.2 Annual Radiolo-gical Reports Annual reports covering the activities of the unit, as described below, for the previous calendar year shall be submitted as follows: 1.5.2.1 Annual Individual Monitorinq Results Report The Annual Individual Monitoring Results Report for the previous calendar year shall be submitted to the Commission by April 30 of each year in compliance with 10 CFR 20.2206. 1.5.2.2 Annual Exposure Report The Annual Exposure Report for the previous calendar year shall be submitted to the Commission within the first calendar quarter of each calendar year in accordance with the guidance contained in Regulatory Guide 1.16. 1.5.2.3 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the REMP Manual. 1.5.3 Annual Radioactive Effluent Release Report Although there are no longer any radioactive effluents discharged from the site, the Annual Radioactive Effluent Release Report, covering the operation of the unit during the previous 12 months, shall be submitted within 90 days after January 1 of each year. The report will continue to be submitted until the NRC grants a specific exemption from 10 CFR 50.36a.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 6 OF 10 1.5.4 Biennial Report A routine report consisting of shutdown statistics, narrative summary of shutdown experience, and tabulations of facility changes, tests or, experiments required pursuant to 10 CFR 50.59(d) shall be submitted at intervals not to exceed 24 months to the U. S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Office, postmarked no later than 30 days following the 24 month period covered by the report. 1.5.5 Licensee Event Report The typesof events listed in 10 CFR 20.2203 and 50.73 shall be the subject of Licensee Event Reports, submitted to the U.S. Nuclear Regulatory Commission (NRC), Document Control Desk, Washington, D.C. 20555, within the time requirements of 10 CFR 20.2203 and 50.73. An additional copy shall also be submitted to the Regional Administrator of the Region IV Office. The written report shall include a completed copy of a Licensee Event Report form, pursuant to 10 CFR 20.2203, 50.73 and the guidance of NUREG-1022, and a description of corrective actions and measures to prevent recurrence. Supplemental reports may be required to fully describe final resolution of the occurrence. For corrected or supplemental reports, a Licensee Event Report shall be completed and reference shall be made to the original report date, pursuant to the requirements of 10 CFR 20.2203 or 50.73, as appropriate. 1.5.6 Environmental Reports

a. When a change to the plant design or operation is planned which would have a significant adverse effect on the environment or which involves an environmental matter or question not previously reviewed and evaluated by the NRC, a report on the change will be made to the NRC prior to implementation. The report will include a description and evaluation of the change, including a supporting benefit-cost analysis.

b. Changes or additions to permits and certificates required by Federal, State, local and regional authorities for the protection of the environment will be reported. The request for permit and certificate changes or additions submitted to the concerned agencies for approval will also be submitted to the NRC. The submittal will be made for the reporting period during which the changes or additions occurred. The submittal will include an evaluation of the environmental impact of the change(s).

1.5.7 Special Reports Special reports shall be submitted to the Regional Administrator of the Region IV Office within the time period specified for each report.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 7 OF 10 1.6 Record Retention 1.6.1 The following records shall be retained for the duration of the 10 CFR Part 50 and 10 CFR Part 72 Operating Licenses:

a. Records and logs of facility operation covering time interval at each power level.

b. Records and logs of principal maintenance activities, inspections, repair, and replacement of principal items of equipment related to NUCLEAR SAFETY, as they relate to the 10 CFR Part 72 licensed facility.

c. Licensee Event Reports.

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e. Records of changes made to Operating Procedures, as they relate to the 10 CFR Part 72 licensed facility.

f. Records of radioactive shipments.

g. Records of sealed source leak tests and results.

h. Records of annual physical inventory of all sealed source material of record.

i. Records and logs of facility activities in the Permanently Defueled Mode.

j. Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Updated Safety Analysis Report.

k. Records of new and irradiated fuel inventory, fuel transfers and assembly burn-up histories.

I. Records of facility radiation and contamination surveys.

          *m. Records of radiation exposure for all individuals entering radiation control areas.

n. Records of gaseous and liquid radioactive material released to the environs.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 8 OF 10

o. Records of training and qualification for current members of the operating staff.

p. Records of quality assurance activities required by the RSQM.

q. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59 and 10 CFR 72.48.

r. Records of meetings of the PRC and MSRC.

s. Records for the Radiological Environmental Monitoring Program.

t. Records of reviews performed for changes made to the ODCM, REMP MANUAL, and the PCP.

u. Records of Plant Closure and decommissioning activities performed.

1.7 Radiation Protection Program Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 19 and 10 CFR 20, and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. 1.8 Process Control Program (PCP) Licensee-initiated changes to the PCP:

a. Shall be documented and records of reviews performed shall be retained as required by Section 1.6.1.t. This documentation shall contain:

1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and

2) A determination that the change will maintain the overall conformance of the processed waste product to existing requirements of Federal, State, or other applicable regulations.

b. Shall become effective after approval by the Site Superintendent.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 9 OF 10 1.9 Off-Site Dose Calculation And Radiological Environmental Monitoring Program Manuals Licensee-initiated changes to the ODCM or REMP Manual: shall be documented and records of reviews performed shall be retained as required by Section 1.6.1.t. This documentation shall contain sufficient information to support the change together with the appropriate analyses or evaluations justifying, the change. Changes to the REMP become effective after approval by the Site Superintendent and will be submitted to the Commission in the form of a complete, legible copy of the entire manual. 1.10 Liquid Hold-up Tanks There are no longer any liquid hold-up tanks. Accordingly, this section has been deleted. 1.11 Sealed Source Contamination Each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material shall be free of_> 0.005 microcuries of removable contamination. Applicability: At All Times Action: With a sealed source having removable contamination in excess of the above limits, immediately withdraw the sealed source from use and:

a. Either decontaminate and repair the sealed source, or

b. Dispose of the sealed source in accordance with NRC Regulations.

Surveillance Requirements: Test Requirements Each sealed source shall be tested for leakage and/or contamination by:

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 10 OF 10

a. The Licensee, or

b. Other persons specifically authorized by the NRC or an Agreement State.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample. Test Frequencies Each category of sealed sources shall be tested at the frequency described below.

a. For sources in use at least once every six months or all sealed sources containing radioactive material:

1. With a half-life greater than 30 days (excluding Tritium), and

2. In any form other than gas.

b. For stored sources not in use each sealed source shall be tested prior to use or transfer to another licensee unless tested within the previous six months.

Sealed sources transferred without a certificate indicating the last test date shall be tested prior to being placed into use.

Attachment 2 Redline-strikeout Version

SRSQM-SECTION XVIII TITLEAUDITS PAGE 1 OF 5. -- - .,!, LEAD DEPARTMENT: EFFECTIVE DATE: REVISION

SUMMARY

1. Revised the audit frequencies to reflect the long term monitoring conditions.

2. Revised to reflect the long term monitoring organization.

3. Deleted the requirement to perform trend analysis. ----- Formatted: Bullets and Numbering

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 2 OF 5 XVIII. AUDITS

         *R 1.-0.P O
                 . ...S P... ..... .... .....   .... .... .....   .... .... ..... .... ..... .... .........- .. .... ..... .... ..... ........ .....elet d...

Describe the Rancho Seco Quality Assurance Program (QAP) measures that (1) establish a comprehensive system of planned and periodic audits, and (2) determine the effectiveness of the QAP at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS) ,licensed under, 10 CFR Part 50, and the . Deleted: 2.0 Independent Spent Fuel Storage Installation (ISFSI)Jicensed under.O CFR Part 72.J.. REFERENCE DOCUMENTS Deleted: and undergoing decommissionin g pursuant to [...(Deleted:) 1

                                                                                                                                                , Deleted;:                         3 2.1         10 CFR 50, Appendix B, Criterion XVIII, Audits                                                                                 (Deleted: and operated pursuant to 3 Deleted:)                         3 2.2         Safety Guide 33/ANSI NI18.7, Administrative Controls for Nuclear Power Plants                                                 (Deleted:   ¶                       3 2.3        Reg. Guide 1.144/ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 2.4        Reg. Guide 1.146/ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 2.5         10 CFR 50.54(a), Conditions of Licenses 2.6         10 CFR 71.137, Audits 2.7         10 CFR 72.176, Audits POLICY-------------------................
                                              -                         ------------------------------                       -------.             Deleted:-¶-

Procedures shall be established and implemented to assure that planned and periodic audits are conducted to verify Compliance with all aspects of the QAP. ,4.0 GENERAL

          ,4:.0 E RA       L REQUIREMENTS
                      .....G R E N U IRE M E N TS                 ....................... ......... ..... ............ ....................
                                                                                                                                      -   I.-     O  'td '

Deleted:¶ 4.1 Quality Assurance shall establish a schedule for auditing the activities affecting quality. The audit schedule shall be consistent with the audit requirements and frequencies specified herein. 4.2 The audit program shall be described in procedures that implement this RSQM section.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 3 OF 5 4.3 Audits shall be conducted to determine the adequacy and effectiveness of programs implemented for the design, procurement, modification, maintenance, and operational activities at the Rancho Seco nuclear facility. 4.4 Audit plans shall be developed that identify the audit scope, the requirements, activities to be audited, organizations to be notified, the applicable documents, and the audit schedule, 4.5 Audits shall be performed using approved audit checklists, 4.6 Audit reports shall be issued which identify the activity that was audited, the personnel that were contacted during the audit, and any conditions adverse to quality noted during the audit. 4.7 Process conditions identified as adverse to quality using the Rancho Seco .c1o.....Formatted: Indent: Left: 0.5"', Corrective Action Program. iHanging: 0.5" Formatted: Bullets and Numbering 4.8 Personnel conducting audits shall be trained and qualified in accordance with Reference, 2.4., In addition, at least one individual participating- in the .Security.. Deleted: s audit will be knowledgeable and practiced in the access authorization program performance objectives. Formatted: Font: Times New

                                                                                                                        *Roman 4.9    Regularly scheduled audits shall be supplemented by special audits/surveillances                              Deetd when conditions that warrant special audits exist or when requested by SMUD m anagem ent.---------     ..... i................. ---------

I ........................................ Deleted: personnel 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION. 5.1 Quality Assurance is responsible for:

a. Establishing a schedule for performance of required audits.

b. Reviewing audit results to evaluate the effectiveness of the QAP.

c. Implementation of the established audit program.

d. Deleted: e. Preparation of trend

d. Training and qualification of audit personnel. analysis data.¶

. 5.2. Fach group is responsible for: ..... .....

                                                                   . .                                                     Deleted:

eltddpamn department

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 4 OF 5

a. Supporting the abdit activities.

b. Providing prompt response to any deviations from quality identified in the audit.

1 §7.6.0 AUDITS AND AUDIT FREQUENCIES (Deleted: ¶ 6.1 Audits of Rancho Seco nuclear facility activities shall be performed under the cognizance of the Quality Assurance organization,_which reports to t n Deleted: supervisor Audit Services. The required audits and audit performance frequencies are as follows:

a. Conformance to the Rancho Seco nuclear facility Technical Specifications and associated license conditions at least once per year;

b. Performance and qualifications of the Rancho Seco nuclear facility technical staff at least once every two years;

c. Actions taken to correct deficiencies occurring in facility structures, systems, components, or methods of operation associated with the safe operation of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) at least once every two years for those deficiencies not previously audited (Corrective Action Program audit);

d. Performance of activities required by the QAP to meet the 10 CFR 50, Appendix B criteria at least once every *fve. years; ............................ ...... Deleted: two

e. Rancho Seco nuclear facility Emergency Plan and implementing procedures at least once every two years;.............................. -- ................. Deleted: per

f. 10 CFR 72 ISFSI Physical Protection Plan and'implementing procedures at least once every tw o,,ears.; ....................... ---------- Deleted. pe

g. Other areas of Rancho Seco nuclear facility operation that the Site Superintendent considers appropriate;

h. Compliance with fire protection requirements and implementing procedures at least once every two years;

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-SECTION XVIII REVISION: 12 TITLE: AUDITS PAGE 5 OF 5

i. Radiological Environmental Monitoring Program (REMP) and the results thereof at least once every two years;

j. Off-site Dose Calculation Manual (ODCM) and implementing procedures at least once every two years;

k. Process Control Program (PCP) and implementing procedures for processing and packaging of radioactive wastes from liquid systems at least once every two years;

1. Performance of activities required by the Quality Assurance Program for .. {Formatted: Bullets and Numbering Effluent Control and Environmental Monitoring (Reg. Guide 4.15) at least once every two years; and

m. Radiation Protection Program content and implementation once per year. ..... Formatted: Numbered + Level: 1 +

Numbering Style: a, b, c, ... + Start at: 1 + Alignment: Left + Aligned at: 6.2 Changes to these audits and audit frequencies are subject to the requirements 1" + Tab after: 1.25"+ Indent at: contained in 10 CFR 50.54(a). In addition, frequencies specified in 10 CFR and 1.25" related to the performance of specific audits may not be changed unless an exemption or waiver is obtained from the NRC. 6.3 The audit reports resulting from items "a". through "m'. above shall be forwarded ..... ( Deleted: mr to the Site Superintendent, theManager, Power Generatior and the management .... Deleted: Plant positions responsible for the areas reviewed. The report should be issued within Deleted: the AGM, Energy Supply 30 days after completion.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 1 OF 10 LEAD DEPARTMENT: EFFECTIVE DATE: Ni I .I EAR Qi IAI ITY ASSI IRANCl. REVISION

SUMMARY

1. Revised to reflect the long term monitoring organization.

2. Deleted temporary procedure changes.

2. Revised to reflect that radioactive effluents are no longer released from the site.

3. Revised to reflect that the REMP monitors only the direct radiation pathway.

4. Deleted the 10 curie limit for liquid hold-up tanks since these tanks no longer exist.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 2 OF 10 1.0 10 CFR 50 ADMINISTRATIVE CONTROLS 1.1 Technical Review and Control

                                                                                                           --  Formatted: Line spacing: single

a. Procedures, plans, manuals, and programs required by Section 1.4 shall be prepared, reviewed and approved. Each such procedure, plan, manual, and program or change thereto shall be reviewed by an individual(s) other than the preparer, but who may be from the same organization as the preparer of the procedure, plan, manual and program or change thereto. Programs, plans, manuals, and procedures other than administrative procedures will be approved as delineated in writing by thesite Superintendent, but "not_!_o lower wer -- - Deleted: Manager, Plant Closure &

Decommissioning (Plant Manager) than a direct report to the Site Superintendent,_ ,Such procedures, plans ............ manuals and programs shall be reviewed periodically in accordance with

• Deleted: Plant Manager administrative procedures. Deleted:

The ,Site Superintendent will approve, administrative procedures and .... (Deleted: Plant Manager Emergency Plan Implementing Procedures. Deleted: plant proposed changes or modifications to,systems or equipment described in the

                                                                                                      ..... Deleted: . Two members of the plant management staff can approve DSAR shall be reviewed by an individual(s) other than the individual(s) who                            temporary procedure changes that designed the modification, but who may be from the same organization as the                            Icleary do not change the intent of the individual(s) who designed the modifications. Such modifications shall be                              approved procedure. The change approved by the Site Superintendent or his designee as delineated in writing,                   .      approved by the procedure's approval
                                                                                                    -          authority within 14 days of but not lower than a direct report to theSite Superintendent .-......................... --            implementation.¶

c. Individual(s), other than the individual(s) who prepare proposed tests or Deleted: p Mant ae experiments shall review proposed tests and experiments that are not Deleted: Plant Manager addressed in the DSAR. Such tests or experiments shall be approved by the Deleted: Plant Manager

       ,Site Superintendent or his designee as delineatedin writing; but not lower than a direct report to the          *erintendent.-                                                          SFormatted: Line spacing: single Deleted: Plant Manager

d. Individuals responsible for reviews performed in accordance with Section 1 la, Deleted: Plant Manager b, and c shall meet or exceed the qualification requirements of Section 4, "Qualifications," of ANSI N18.1-1971, excluding Sections 4.5.2, "Technicians,"

and 4.5.3, "Repairmen." ,The Site Superintendent shall establish the list of -- Deleted: Each such review shall qualified reviewers for the independent reviews described in a, b, and c above. include a determination of whether or not additional, cross-disciplinary review is necessary. If deemed

e. Events reportable pursuant to Section 1.5.5 and violations of Technical necessary, review personnel of the appropriate discipline shall perform Specifications shall be investigated and a report prepared which evaluates the this review.

Deleted: Plant Manager

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 3 OF 10 event and which provides recommendations to prevent recurrence. TheSite - Deleted: Plant Manager Superintendent shall review these reports. 1.2 Audits (See RSQM Section XVIII)

                                                                                            -DFormatted:      Line spacing: single Spo~c!ific audit requirements, including frequencies and administrative controls, are      -{Deleted:   ince s addressed in Rancho Seco Quality Manual (RSQM) Section XVII, "Audit" ..........              Deleted:

Deleted: the changed and retained audit program requirements resulting 1.3 Licensee Event Report Action from Rancho Seco nuclear facility 10 CFR 50 License Amendment Numbers 129 and 130 were placed in RSQM Section XVIII. The following actions shall be taken for events that are reportable as Licensee Event Reports: Formatted: Line spacing: single

a. The Commission shall be notified and a report submitted per Section 1.5.5, pursuant to the requirements of 10 CFR 20.2203 and 50.73, and

b. Each Licensee Event Report shall be reviewed and approved by the t ....... -f Deleted: Plant Manager Superintendent or designee.

1.4 Procedures, Plans, Manuals, and Programs

                                                                                            -f Formatted: Line spacing:     single      I 1.4.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained! covering the activities referenced below:

a. The applicable procedures recommended in Appendix "A"of Safety b.

Guide 33, November 1972. Emergency Plan implementation. IDeleted: $1

                                                                                                <#>Decommissioning Decontamination.¶l and             ]

c. Fire Protection Program Plan implementation. I Formatted: Bullets and Numbering 1

{ Formatted: Bullets and Numbering

d. PCP implementation.

e. ODCM implementation.

f. REMP MANUAL implementation. -j Formatted: Bullets and Numbering )

,1Note: These procedures, plans, manuals, and programs may coexist within a single -pFormatted: Font: (Default) Anal, 111 document.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 4 OF 10 g._,Quality Assurance Program for Effluent Control and Environmental Deleted: ¶ Monitoring using the guidance of Re-gulatory -Guide-4-.-1-5,-Revis-ion- 1, February 1979. Formatted: Bullets and Numbering Deleted: i.

h. quality Assurance Program implementation. Formatted: Indent: Left: 0.75",

Hanging: 0.38", Line spacing: single, Numbered + Level: 1 + g.gRadiation Protection Program implementation. Numbering Style: a, b, c, ... + Start at: 1 + Alignment: Left + Aligned at: 1.4.2 Each procedure, plan, manual, and program of Section 1.4.1 above and 0.75" + Tab after: 0" + Indent at: 1". changes thereto shall be reviewed and approved as set forth in Section 1.1. Formatted: Line spacing: single Formatted: Line spacing: single, 1.4.3 The following programs shall be established, implemented, and maintained: Numbered + Level: 1 + Numbering Style: a, b, c, ... + Start at: 7 + 1.4.3.1 Radioactive Effluent Controls Program Alignment: Left + Aligned at: 0.75"

                                                                                                                      + Tab after: 0" + Indent at: 1" Formatted: Line spacing: single

_There are no longer any radioactive liguid or gaseouseffluents ,4¸' Deleted: A program shall be

                   ,discharged from the site. ,TheOffsite Dose Calculation Manual                                     provided conforming to 10 CFR (ODCM) has been reduced in scope and the associated                                                50.36a for the control of administrative and implementing procedures have beeh deleted. The                                 Formatted: Font: Anal ODCM will require that if radioactive effluents need to be released in I

Formatted: Indent: Left: 1.38", the future, a program must be implemented that meets the First line: 0", Line spacing: single, Hyphenate, Tabs: Not at -0.5" + 0" requirements in 10 CFR 50.36a, 20.1301, 20.1302, 10 CFR Part 50, + 0.5" + 1" + 1.38" + 3" + 4" Appendix I, and any other applicable regulations.. Formatted: Font: Arial '1 Deleted: for maintaining the doses 1.4.3.2 Radiological Environmental Monitoring Program (REMP) to member(s) of the public from radioactive effluents as low as _There are no longer any liquid or gaseous radioactive effluents Formatted: Font: Arial discharged from the site. The radiation source term is limited to Deleted:, (2) shall be implemr radioactive materials stored in the Interim Onsite Storane Bijildlino Formatted: Font: Anial (IOSB) and the Independent Stent Fuel Storane Installation (ISFSi (I .. . B. ...... th

                                         ... ..... . .. . S.r-e n F uel.. S.. t r. c . ............. (IS...
                                                                                                      ..    . .      Formatted: Font: Anial Accordingly, the only exposure pathwav is bv direct radiation.

Formatted: Line spacing: single Deleted: . _The REMP requires ~articipation inanI_n_t_ne_r_-laboratory, Comparison Formatted r3-1 Program to ensure that independent checks on the precision and ,- .. accuracy of the direct radiation measurementsre_ performed as_part F Line spacing: single of the quality assurance program for environmental monitoring. Deleted. A program shall be F-.-1 1.4.4 The changes to the REMPshall be reviewed and approved as set forth in Formatted .. 5 Sections 1.1 and 1.9. Deleted: of radioactive materi...ý6 SFormatted: Line spacing: single Deee:Each program in Se.. l 1.5 Reporting Requirements Deleted: and changes thereto Formatted: Line spacing: single

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 5 OF 10 1.5.1 Routine Reports In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the Region IV Office unless otherwise noted. 1.5.2 Annual Radiological Reports Annual reports covering the activities of the unit, as described below, for the previous calendar year shall be submitted as follows: 1.5.2.1 Annual Individual Monitoring Results Report The Annual Individual Monitoring Results Report for the previous calendar year shall be submitted to the Commission by April 30 of each year in compliance with 10 CFR 20.2206. 1.5.2.2 Annual Exposure Report

            ,The AnnualExposure Report for the previous calendar        year shall be                       : Font: Arial               J
                                                            -calendar-quarter -of each submitted to- the -Commission with-in the fi-rst                                TLeft:

calendar year in accordance with the guidance contained in Regulatory Formatted : Body Text 2, Indent: 1" 1 I Guide 1.16. - Deleted:

                                                                                           -   Deleted:¶ 1.5*23                           nvironmen tlal Oeratina r        Report                     I¶ I¶ The Annual Radiological Environmental Operating Report covering the          V      1.5.2.3 operation of the unit during the previous calendar year shall be submitted       f Formatted:     Font: Times New Roman before May 1 of each year. The report shall include summaries, Formatted: Font: (Default) Times interpretations, and analysis of trends of the results of the Radiological        New Roman Environmental Monitoring Program for the reporting period. The material Formatted: Indent: Left: 0.5" provided shall be consistent with the objectives outlined in the REMP Manual.

1.5.3 Annual Radioactive Effluent Release Report Although there are no longer any radioactive effluents discharged from the site, the Annual Radioactive Effluent Release Report, covering the operation of the unit during the previous 12 months, shall be submitted within 90 days after January 1 of each year. The report will continue to be submitted until the NRC grants a specific exemption from 10 CFR 50.36a Deleted: shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section V.B.1 of Appendix I to 10 CFR 50

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 6 OF 10 1.5.4 Biennial Report A routine report consisting of shutdown statistics, narrative summary of shutdown experience, and tabulations of facility changes, tests or, experiments oto ..... required pursuant to 10 CFR 50.59()_ shall be su bmitted-a t _-intervals_not__t SDeleted: b exceed 24 months to the U. S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the Regional'Office, postmarked no later than 30 days following the 24 month period covered by the report. 1.5.5 Licensee Event Report Formatted: Keep lines together Formatted: Keep with next, Keep The types of events listed in 10 CFR 20.2203 and 50.73 shall be the subject of Licensee Event Reports, submitted to the U.S. Nuclear Regulatory I lines together Commission (NRC), Document Control Desk, Washington, D.C. 20555, within the time requirements of 10 CFR 20.2203 and 50.73. An additional copy shall also be submitted to the Regional Administrator of the Region IV Office. The written report shall include a completed copy of a Licensee Event Report form, pursuant to 10 CFR 20.2203, 50.73 and the guidance of NUREG-1022, and a description of corrective actions and measures to prevent recurrence. Supplemental reports may be required to fully describe final resolution of the occurrence. For corrected or supplemental reports, a Licensee Event Report shall be completed and reference shall be made to the original report date, pursuant to the requirements of 10 CFR 20.2203 or 50.73, as appropriate. 1.5.6 Environmental Reports

a. When a change to the plant design orp~perationis plan__ne.d-whichwouuld_ J Deleted: to the plant have a significant adverse effect on the environment or which involves an environmental matter or question not previously reviewed and evaluated by the NRC, a report on the change will be made to the NRC prior to implementation. The report will include a description and evaluation of the change, including a supporting benefit-cost analysis.

b. Changes or additions to permits and certificates required by Federal, State, local and regional authorities for the protection of the environment will be reported. The request for permit and certificate changes or additions submitted to the concerned agencies for approval will also be - Deleted: with the Biennial Report submitted to the NRC,,The submittal will be made for the reporting ........

period during which the changes or additions occurred. The submittal will include an evaluation of the environmental impact of the change(s). 1:1. (see Section 1.5.4) FDeleted: Deleted: in the Biennial Report 1.5.7 Special Reports

                                                                                                   '(Deleted:

Special reports shall be submitted to the Regional Administrator of the Region IV Office within the time period specified for each report.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 7 OF 10 1.6 Record Retention Formatted: Line spacing: single 1.6.1 The following records shall be retained for the duration of the 10 CFR Part 50 - Formatted: Indent: Left: 0", and 10 CFR Part 72 Operating Licenses, Hanging: 0.8", Line spacing: single Deleted: The following records shall be retained for at least five years:

a. Records and logs of facility operation covering time interval at each Formatted: Line spacing: single power level.

Formatted: Indent: Left: 1", Line spacing: single, Outline numbered +

b. Records and logs of principal maintenance activities, inspections, repair, Level: 3 + Numbering Style: a, b, c, and replacement of principal items of equipment related to NUCLEAR ... + Start at: 1 + Alignment: Right +

Aligned at: 1.38" + Tab after: 1.5" SAFETY, as they relate to the 10 CFR Part 72 licensed facility. + Indent at: 1.5", Tabs: 1.13", List tab + Not at 1.5"

c. Licensee Event Reports.

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

1I p._,Records of changes made to Operating_ _Procedu res, as they relate to the 10 CFR Part 72 licensed facility, "-- Itests Deleted: <#>Records of reactor and experiments.1

                                                                                                    =Formatted: Font: (Default)    =Anal

f. Records of radioactive shipments.

                                                                                               'I Deleted:.,                              j g.. Records of sealed source leak tests and results.

h. Records of annual physical inventory of all sealed source material Formatted: Line spacing: single, Outline numbered + Level: 3 +

of record. Numbering Style: a, b, c, ... + Start at: 1 + Alignment: Right + Aligned

i. Records and logs of facility activities in the Permanently Defueled Mode. at: 1.38" + Tab after: 1.5" + Indent at: 1.5"

                   .LRecord and drawing changes reflecting facility design modifications !,        Formatted: Indent: Left: 0", First line: 0", Line spacing: single made to systems and equipment described in the Updated Safety                Deleted: <#>1 .6.2. The following Analysis Report.                                                              records shall be retained for the duration of the 10 CFR 50 Facility Operating License:¶

k. -Records of new and irradiated fuel inventory, fuel transfers and assembly burn-up histories. Formatted: Line spacing: single, Outline numbered + Level: 3 +

Numbering Style: a, b, c, ... + Start I. -Records of.facility radiation and contamination surveys. at: 1 + Alignment: Right + Aligned at: 1.38" + Tab after: 1.5" + Indent

m. Records of radiation exposure for all individuals entering radiation at: 1.5" control areas. ','fDeleted: a.

                                                                                                '[Formatted: Indent: Left: 0.5", First line: 0,", Line spacing: single

n. Records of gaseous and liquid radioactive material released to the environs.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 8 OF 10

          ------------------- _ ---------..                                                                                                                                                                              Deleted: ¶

o. Records of training and qualification for current members of the.. ...-. I <#>Records of transient or

                                                                                                                                                                                                               - -       operational cycles for those facility operating staff.                                                                                                                                                                                       components designed for a limited number of transients or cycles,¶ pRecords of quality assurance activities required by the RSQM.                                                                                                                                              Deleted: plant Deleted: 9
                                                                                                                                                                                                                         <#>Records of in-service inspections Cl. Records of reviews performed for changes made to procedures or                                                                                                                                          previously performed pursuant to the equipment or reviews of tests and experiments pursuant to                                                                                                                                              Appendix A Technical Specifications.¶1
                 *10 CFR 50.59 and 10 CFR 72.48.

r. Records of meetings of the PRC and MSRC.

                                                                                                                                                                                                                       - Deleted: ¶
                                                                                                                                                                                                                         <#>Records of the environmental

s. Records for the Radiological Environmental Monitoring Program. qualification of safety related t._Aecords of reviews. performed for changees made to the 0DCM, REMP electrical equipment previously generated pursuant to the MANUAL, and the POP. Appendix A Technical Specifications.T Deleted: <#>Records of the service lives of all hydraulic and mechanical

u. Records of Plant Closure and decommissioning activities snubbers, including the date at which the service life commences, and performed. associated installation and

                                                                                                                                                                                                                    ,    maintenance records.na q¶ Formatted: Line spacing: single, 1.7    Radiation Protection Program                                                                                                                                                                                       Outline numbered + Level: 3 +

Numbering Style: a, b, c, ... + Start Procedures for personnel radiation protection shall be prepared consistent with the at: 1 + Alignment: Right + Aligned at. 1.38" + Tab after: 1.5" + Indent requirements of 10 CFR 19 and 10 CFR 20, and shall be approved, maintained and at: 1.5" adhered to for all operations involving personnel radiation exposure. FFormatted: Line spacing: single Formatted: Line spacing: single, Keep with next, Keep lines together 1.8 Process Control Program (PCP) For atted: Line spacing: single

                                                                                                                                                                                                              -..... "    Formatted: Line spacing: single Licensee-initiated changes to the PCP:

a. Shall be documented and records of reviews performed shall be retained as required by Section 1.6.1t._,This docu-mentation shall contaiin;:------- I------------------ Deleted: o Deleted:

1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and

2) A determination that the change will maintain the overall conformance of the processed waste product to existing requirements of Federal, State, or other applicable regulations.

b. Shall become effective after approval by the Site Superintendent.

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQMZAPPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 9 OF 10 Formatted: Indent: Left: 1" Formatted: Font: (Default) Arial 1.9 Off-Site Dose Calculation And Radiological Environmental Monitoring Deleted: ¶ Program Manuals ¶ a.. S

   ,Licensee-initiated changes to the ODCM or REMPManual:,Shall be documented                                         Formatted: Font: (Default) Arial and records of reviews performed shall be retained as required by Section 1 .61.__J                                Formatted: Normal, Indent: Left:

This documentation shall containsufficientinformationto support the change 0.25", First line: 0", Line spacing: single, Tabs: 0.25", Left together with the appropriate analyses or evaluations justifying the change., Deleted: 2

                                                                                                            *F,*,
                                                                                                            <         Deleted: o
   ,Channges to the REMP become effective after app r_0_va_ _by._the_-SteSuperintendent andwiil~be submitted to the Commission in the form of a complete, legible copy of                                  Deleted:

the entire Mnual-- Deleted: :¶ 1).S Deleted: (s) and¶ 1.10 Liquid Hold-up Tanks

2) A determination that the change will maintain the level of radioactive

_There are no Ion er any liquid hold-up tanks. Accordingly, this section has been effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR deleted. 50.36a, and Appendix I to 10 CFR 50 and not adversely impact the accuracy or reliability of effluent dose or setpoint calculations. 1.11 S_ea led_Sourcee C_0ontam -in-ati0on.. . . ........................................................ Formatted: Line spacing: single Deleted: b. Shall Each sealed source containing radioactive material either in excess of 4-,, Formatted: Indent: Left: 0.25", Formatted: Indent: Left: 0.25", 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha First line: 0", Line spacing: single emitting material shall be free of > 0.005 microcuries of removable contamination. Deleted: Plant Manager Deleted: . Applicability: At All Times 1Deleted: I

                                                                                                                  ,,* c... Shal Action:

Deleted. ODCM and/or REMP Ma With a sealed source having removable contamination in excess of the above limits, Deleted: as a part of or concurrent with the Annual Radioactive Effluent immediately withdraw the sealed source from use and: Release Report for the period 8

                                                                                                                    , Formatted: Line spacing: single

a. Either decontaminate and repair the sealed source, or Deleted: The quantity of radi EFormatted: Line spacing: single b.. Dispose of the sealed source in accordance with NRC Regulations.

Deleted: ¶ ... Surveillance Requirements: Formatted: Keep lines together Formatted Test Requirements Formatted Formatted: Line spacing: single Each sealed source shall be tested for leakage and/or contamination by: SFormatted: Line spacing: single

MANUAL: RANCHO SECO QUALITY MANUAL NUMBER: RSQM-APPENDIX A TITLE: ADMINISTRATIVE REVISION: 1 CONTROLS FOR LICENSED ACTIVITIES PAGE 10 OF 10

a. The Licensee, or

b. Other persons specifically authorized by the NRC or an Agreement State.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample. Test Frequencies Each category of sealed sources sha!_ be tested at the_ frequencydescribed below. Deleted: (excluding startup sources and fission detectors previously subjected to core flux)

a. For sources in use at least once every six months or all sealed sources containing radioactive material:

1. With a half-life greater than 30 days (excluding Tritium), and

2. In any form other than gas.

b. For stored sources not in use each sealed sourceshall be tested.prior to use or*- T Formatted: Indent: Left: 0.25",

Hanging: 0.38", Tabs: 0.63", Left + transfer to another licensee unless tested within the previous six months. 1.1", Left + 1.6", Left + 2.1", Left Sealed sources transferred without a certificate indicating the last test date - + 7.2", Left + Not at 1" shall be tested prior to being placed into use.-.............-. --..-----. i...Deleted: and fission detector Deleted: and fission detectors "Deleted: ¶}}