ML16014A137

ISFSI - Report of Changes to the Quality Assurance Program That Do Not Require Prior NRC Approval

ML16014A137
Person / Time
Site:	Rancho Seco, 07200011
Issue date:	01/07/2016
From:	Ronningen E Sacramento Municipal Utility District (SMUD)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DPG 16-002
Download: ML16014A137 (79)

Text

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January 7, 2016 DPG 16-002 U.S. NRC Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Docket 50-312 Rancho Seco Nuclear Generating Station License DPR-54 Docket 72-11 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510 REPORT OF CHANGES TO THE RANCHO SECO QUALITY ASSURANCE PROGRAM THAT DO NOT REQUIRE PRIOR NRC APPROVAL Attention: Jack Parrott and Chris Allen In accordance with 10 CFR 50.54(a)(3) and 10 CFR 50.4(b)(7), we are required to submit a copy of changes to the Rancho Seco Quality Manual (RSQM) that do not reduce commitments in the quality assurance program previously accepted by the NRC. Changes to the quality program that do not reduce commitments in the program can be made without prior NRC approval.

During calendar year 2015, we revised the RSQM to reflect changes to the corporate organization. Specific portions of the RSQM that were revised include:

1. Quality Assurance Policy

2. RSQM Chapter I "Organization"

3. RSQM Chapter II "Quality Assurance Program"

4. RSQM Chapter XVIII "Audits"

5. Appendix A "10 CFR 50 Administrative Controls" The safety evaluation associated with these changes concluded that these changes ¶ did not reduce any commitments and did not require prior NRC approval. The RSQM continues to implement the requirements of 10 CFR Part 50, Appendix B and 10 CFR Part 72, Subpart G. The individuals and organizations performing quality assurance functions continue to have sufficient authority, organizational freedom, and independence from cost and schedule issues.

/

Rancho Seco Nuclear Generating Station I14440 Twin Cities Road I Herald, GA 95638-9799 I 916.452.3211 Ismud.org *)Ppe'

DPG 16-002 The document is being provided in its entirety because it does not include a List of Effective Pages. However, changes are indicated by "revision bars" in the left margin to aid in review.

If you or members of your staff have any questions requiring additional information or clarification, please contact me at (916) 732-4817.

Sincerely,

.Einar T. Ronningen Manager, Rancho Seco Assets (RJIDTIBG)

Enclosures - (1) Rancho Seco Quality Manual, RSLBD-01O Rev.2 Cc: NRC, Region IV 2

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 1 OF 77 IEFFECTIVE DATE: 04/20/2015 REASON FOR CHANGE:

• Reflect current corporate organization and responsibilities REVISION

SUMMARY

• Revised QA policy Statement to Reflect current corporate organization and responsibilities

• Revised Section 4.0 of the RSQM to reflect new titles within the organization.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 2 OF 77 QUALITY ASSURANCE POLICY The Sacramento Municipal Utility District's (SMUD) policy regarding quality assurance at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72), is as follows:

I. Organizations involved in QA Class 1 activities and the other Program Activity Areas specified in Rancho Seco Quality Manual (RSQM)Section II, Attachment Il-1, shall be structured, managed, and operated to provide compliance with the RSQM. Procedures shall be prepared that implement the activities required to safely operate the Rancho Seco nuclear facility and achieve the following objectives:

a. Comply with government regulations and established SMUD management policies, applying a systematic, disciplined, and uniform approach to quality assurance.

b. Provide facilities designed, modified, constructed, tested and operated in accordance with specified requirements with reasonable assurance that failures or malfunctions will not cause undue risk to public health and safety.

c. Ensure prompt identification and resolution of actual and potential problems in design, procurement, construction, testing, operations, maintenance, and modification of the structures, systems, and components associated with QA Class 1 activities or other applicable Program Activity Areas specified in RSQM Section II, Attachment Il-i.

Ill. The RSQM and implementing procedures constitute the Rancho Seco Quality Assurance Program (QAP). The QAP applies to activities, plans, and programs affecting the operation and the quality of structures, systems, components, and services addressed in the RSQM. The QAP will be implemented by organizations responsible for achieving and verifying quality assurance.

IV. The Chief Generation and Grid Assets Officer has delegated the responsibility and authority for developing the QAP to the Director, Power Generation and executing the QAP to the Director, Audit Services. Any conflicts or questions involving interpretation of the requirements or resulting from the implementation of the QAP must be referred to the Director, Audit Services.

Chris Moffitt Claire Rogers Frankie McDermott Director, Power Generation Director, Audit Services Chief Generation and Grid Assets Officer

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 3 OF 77 Table of Contents I. ORGANIZATION 1.0 PURPOSE ................................................................. 9

2.0 REFERENCES

............................................................ 9 3.0 POLICY .................................................................... 9 4.0 ORGANIZATION AND REQUIREMENTS............................. 10 5.0 RESPONSIBILITIES .................................................... 11 II. QUALITY ASSURANCE PROGRAM 1.0 PURPOSE................................................................ 12

2.0 REFERENCES

........................................................... 12 3.0 POLICY................................................................... 12 4.0 GENERAL REQUIREMENTS........................................... 13 5.0 RESPONSIBILITIES .................................................... 15 6.0 ATTACHMENTS......................................................... 15 I1-1 Application of Rancho Seco Quality Assurance Program Criteria ........ 16 11-2 Regulatory Commitments................................................18 11-3 Exceptions .............................................................. 20 II1. DESIGN CONTROL 1.0 PURPOSE................................................................ 27

2.0 REFERENCES

........................................................... 27 3.0 POLICY................................................................... 27 4.0 GENERAL REQUIREMENTS........................................... 28 5.0 RESPONSIBILITIES .................................................... 30

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 4 OF 77 IV. PROCUREMENT DOCUMENT CONTROL 1.0 PURPOSE................................................................ 31

2.0 REFERENCES

........................................................... 31 3.0 POLICY................................................................... 31 4.0 GENERAL REQUIREMENTS....................................... 31 5.0 RESPONSIBILITIES .................................................... 33 V. INSTRUCTIONS, PROCEDURES. AND DRAWINGS 1.0 PURPOSE................................................................ 35

2.0 REFERENCES

........................................................... 35 3=0 POLICY ................................................................... 35 4.0 GENERAL REQUIREMENTS........................................... 35 5.0 RESPONSIBILITIES .................................................... 36 VI. DOCUMENT CONTROL 1.0 PURPOSE............................................................. 37

2.0 REFERENCES

........................................................... 37 3.0 POLICY................................................................... 37 4.0 GENERAL REQUIREMENTS........................................... 37 5.0 RESPONSIBILITIES .................................................... 38

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 5 OF 77 VII. CONTROL OF PURCHASED MATERIAL. EQUIPMENT. AND SERVICES 1.0 PURPOSE ........................................................... 39

2.0 REFERENCES

........................................................... 39 3.0 POLICY................................................................... 39 4.0 GENERAL REQUIREMENTS ......................................... 39 5.0 RESPONSIBILITIES .................................................... 41 VIII. IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. &

COMPONENTS 1.0 PURPOSE................................................................ 42

2.0 REFERENCES

........................................................... 42 3.0 POLICY................................................................... 42 4.0 GENERAL REQUIREMENTS........................................... 42 5.0 RESPONSIBILITIES .................................................... 43 IX. CONTROL OF SPECIAL PROCESSES 1.0 PURPOSE............................................................... 45

2.0 REFERENCES

........................................................... 45 3.0 POLICY................................................................... 45 4.0 GENERAL REQUIREMENTS........................................... 45 5.0 RESPONSIBILITIES .................................................... 46

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-01O REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 6 OF 77 X. INSPECTION 1.0 PURPOSE................................................................ 47

2.0 REFERENCES

................ ........................................... 47 3.0 PO LIC Y ......................... ...................................... 47 4.0 GENERAL REQUIREMENTS........................................... 47 5.0 RESPONSIBILITIES .................................................... 49 XI. TEST CONTROL 1.0 PURPOSE................................................................ 50

2.0 REFERENCES

........................................................... 50 3.0 POLICY................................................................... 50 4.0 GENERAL REQUIREMENTS........................................... 50 5.0 RESPONSIBILITIES .................................................... 52 XII. CONTROL OF MEASURING AND TEST EQUIPMENT 1.0 PURPOSE................................................................ 53

2.0 REFERENCES

........................................................... 53 3.0 POLICY................................................................... 53 4.0 GENERAL REQUIREMENTS........................................... 53 5.0 RESPONSIBILITIES .................................................... 54

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 7 OF 77 XIII. HANDLING. STORAGE. AND SHIPPING 1.0 PU R PO SE ................... ............................................. 55

2.0 REFERENCES

................ ........................................... 55 3.0 POLICY................................................................... 55 4.0 GENERAL REQUIREMENTS........................................... 55 5.0 RESPONSIBILITIES .................................................... 56 XIV. INSPECTION. TEST. AND OPERATING STATUS .

1.0 PU R PO SE ................... ............................................. 57

2.0 REFERENCES

........................................................... 57 3.0 PO LIC Y ..................... .............................................. 57 4.0 GENERAL REQUIREMENTS........................................... 57 5.0 RESPONSIBILITIES .................................................... 58 XV. NONCONFORMING MATERIALS. PARTS. OR COMPONENTS 1.0 PU RPO SE ................................................................ 59

2.0 REFERENCES

................ ........................................... 59 3.0 POLICY...................,................................................ 59 4.0 GENERAL REQUIREMENTS........................................... 59 5.0 RESPONSIBILITIES .................................................... 60

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 8 OF 77 XVI. CORRECTIVE ACTION 1.0 PU R POSE ................................................................ 61

2.0 REFERENCES

........................................................... 61 3.0 POLICY .............................................................. 61 4.0) GENERAL REQUIREMENTS........................................... 61 5.0 RESPONSIBILITIES ................................................ 62 XVII. QUALITY ASSURANCE RECORDS 1.0 PURPOSE ................................................................ 63

2.0 REFERENCES

........................................................... 63 3.0 PO LIC Y ..................... .............................................. 63 4.0 GENERAL REQUIREMENTS........................................... 63 5.0 RESPONSIBILITIES .................................................. 64 XVIII. AUDITS 1.0 PURPOSE ............................................................ 65

2.0 REFERENCES

........................................................... 65 3.0 PO LIC Y ..................... .............................................. 65 4.0 GENERAL REQUIREMENTS........................................... 65 5.0 RESPONSIBILITIES .................................................... 66 6.0 AUDITS AND AUDIT FREQUENCIES................................. 67 Appendix A 10 CFR 50 ADMINISTRATIVE CONTROLS ....................... 69

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 9 OF 77 I. ORGANIZATION 1.0 PURPOSE This section describes the Sacramento Municipal Utility District (SMUD) organization and personnel responsible for establishing, implementing, and verifying the Quality Assurance Program (QAP) at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS) licensed under 10 CFR Part 50 and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) licensed under 10 CFR Part 72.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion I, Organization 2.2 ANSI N45.2-1 971, Section 3, Organization 2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.4 Rancho Seco Quality Manual, Appendix A 2.5 10 CFR 71.103, Quality Assurance Organization 2.6 10 CFR 72.142, Quality Assurance Organization 3.0 POLICY 3.1 The establishment and implementation of the Rancho Seco QAP, which is comprised of this Rancho Seco Quality Manual (RSQM) and the RSQM implementing procedures, shall be SMUD's responsibility. Some QAP functions may be delegated to other SMUD approved external organizations, but overall responsibility for the QAP remains with SMUD.

3.2 Definitive lines of authority, responsibility, and communication shall be established for those organizations involved in the QAP.

3.3 Quality Assurance personnel assigned to the Rancho Seco nuclear facility have defined responsibilities and organizational freedom to identify problems that affect quality; to initiate, recommend, or provide solutions; and to verify implementation of solutions. They have the authority to initiate action to stop unsatisfactory work pending implementation of necessary corrective action to bring the unsatisfactory conditions into conformance.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 10 OF 77 3.4 The organizational structure and functional responsibility assignments shall be such that attainment of program objectives is accomplished by individuals or groups who inspect, examine, audit or otherwise verify conformance to established requirements, and who are independent of the individuals or groups who performed the original activity.

4.0 ORGANIZATION AND REQUIREMENTS 4.1 The General Manager (GM) through the Chief Generation and Grid Assets Officer shall have corporate responsibility for overall safe operation of the Rancho Seco nuclear facility and shall take any measures needed to ensure acceptable performance of the staff in providing long term monitoring of the remaining radioactive waste.

4.2 The Manager, Rancho Seco Assets reports directly to the Director, Power Generation. The Manager, Rancho Seco Assets ensures that the Rancho Seco nuclear facility is properly staffed and adequately budgeted to ensure,*

staff can safely carry out their responsibilities. The Manager, Rancho Sec0.

Assets also coordinates quality concerns with the Quality Assurance group.

The Manager, Rancho Seco Assets is responsible for the safe and reliable operation of RSNGS, pursuant to 10 CFR Part 50, and the ISFSI, pursuant to 10 CER Part 72. The Manager, Rancho Seco Assets has the responsibility and authority to implement the QAP and ensure optimum quality performance of the Rancho Seco nuclear facility...

The Manager, Rancho Seco Assets is responsible for the administrative  :

actions necessary to ensure that the QAP is implemented by the groups under his direction. To this extent, the Manager, Rancho Seco Assets shall maintain continuing involvement in quality matters and shall assess the scope, status, implementation, and effectiveness of the QAP through the review of Quality Assurance Audits and Surveillances.

4.3 The Director, Audit Services, through the Principal Quality Engineer, is responsible for the Rancho Seco nuclear quality assurance program. The Audit and Quality Services group is independent from operating pressures or other lines of authority, and ensures an active QAP is implemented at the Rancho Seco nuclear facility in accordance with regulatory requirements.

The Audit and Quality Services group has the authority to take any issue concerning the quality of operations at the Rancho Seco nuclear facility to the Director, Power Generation.

4.4 The Audit and Quality Services group shall have sufficient authority and organizational freedom to identify problems that affect quality, recommend

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 11 OF 77 solutions, and verify implementation of solutions, as appropriate.

Commensurate with this responsibility is the authority to initiate action to stop unsatisfactory work pending correction of the unsatisfactory condition.

Corporate and on-site organizational responsibilities are described in greater detail in Rancho Seco Administrative Procedure RSAP- 0101. Specific duties and responsibilities for organizations whose activities affect quality are described in RSQM Sections II through XVIII and Appendix A.

The Manager, Rancho Seco Assets advises the Director, Power Generation on matters related to the safety of operations at the Rancho Seco nuclear facility.

The Manager, Rancho Seco Assets performs safety reviews and provides onsite management oversight of Rancho Seco nuclear facility activities.

The Manager, Rancho Seco Assets is responsible for reviewing all Potential;:

Deviations from Quality (PDQ) to determine if a condition is a Deviation from?:

Quality (DQ) and requires determination of the cause, extent, remedial I corrective actions, and actions to prevent recurrence. The Manager, Rancho Seco Assets reviews and approves DQ dispositions and assigns corrective I actions identified in DQ dispositions. The Manager, Rancho Seco Assets also determines whether a PDQ is potentially reportable pursuant to 10 CFR 21.

5.0 GENERAL RESPONSIBILITIES The nuclear organization is involved in the long term monitoring of the Rancho

• Seco nuclear facility and is responsible for describing and clearly defining the duties and authority of individuals whose work affects quality. RSAP-01 01 defines the Rancho Seco nuclear facility organization and the responsibilities associated with each onsite work group. Each work group has the responsibility to ensure that their procedures implement QAP requirements.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD.-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 12 OF 77 i1. QUALITY ASSURANCE PROGRAM 1.0 PURPOSE The purpose of this section is to describe the Rancho Seco Quality Assurance Program (QAP) implemented at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR

50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCES

2.1 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program 2.2 ANSI N45.2-1971, Section 2, Quality Assurance Program ,

2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.4 10 CFR 71, Subpart H, Quality Assurance Requirements for Packaging and Transportation of Radioactive Material 2.5 10 CFR 72, Subpart G, Quality Assurance Requirements for, the Independent Storage of Spent Nuclear Fuel 2.6 NRC Form 311, Quality Assurance Approval for Radioactive Material Packages, Approval No. 0489 3.0 POLICY The QAP described herein is designed to ensure compliance with the requirements of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" including the requirements of applicable NRC Regulatory Guides and ANSI Standards.

Also, the QAP is designed to fulfill the quality requirements for (1) the use of radioactive material transport packages and (2) the operation of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) in accordance with 10 CFR 71.101(f) and 10 CFR 72.140(d), respectively.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 13 OF 77 4.0 GENERAL REQUIREMENTS 4.1 This Rancho Seco Quality Manual (RSQM) is organized to present the 18 quality criteria in the order they are addressed in 10 CFR 50, Appendix B. The RSQM states the Rancho Seco policy for each criterion and describes how controls pertinent to each criterion are to be carried out.

4.2 In accordance with 10 CFR 50.54(a), SMUD submits an annual report to the Nuclear Regulatory Commission (NRC) regarding RSQM changes that do not reduce the commitments previously accepted by the NRC. Also, in accordance with 10 CFR 50.54(a), SMUD submits RSQM changes that reduce commitments previously accepted to the NRC for their review and approval prior to implementation.

4.3 The QAP is implemented by organizations responsible for achieving quality and by organizations responsible for verifying quality.

4.4 Engineering identifies the Quality Assurance (QA) classification of structures, systenis, and components (SSCs) commensurate to their importance to safety.

4.5 Quality Assurance classification 1 (QA Class 1) is assigned to SSCs that are considered safety-related in accordance with 10 CFR 50, Appendix B.

4.5.1 The QA Class I assignment includes 10 CFR 72 (ISFSl) and 10 CFR 71 (Transportation Package) SSCs as specified in RSAP-0302.

4.5.2 All 18 elements of the 10 CFR 50, Appendix B quality criteria apply to activities affecting QA Class I SSCs during operation, maintenance, testing, and modifications.

4.6 Some 10 CFR 50, Appendix B quality criteria apply to non-QA Class 1 programs and activities such as radiation protection, emergency preparedness, radioactive waste handling and shipping, fire protection, facility operations, environmental monitoring, security, training, and 10 CFR 71/72 important-to-safety, as indicated in RSQM-Section II, Attachment Il-I.

4.6.1 Engineering identifies thel0 CFR 71 and 10 CFR 72 non-QA Class 1 SSCs that are important-to-safety in accordance with RSAP-0302.

RANCHO SEWO LIUL;NSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 14 OF 77 4.6.2 SMUD activities performed under 10 CFR 71 shall be limited to procurement, maintenance, repair, and use as authorized by the NRC Quality Assurance Program Approval for Radioactive Material Packages (NRC Form 311; Approval Number 0489).

4.7 Attachment Il-I indicates the minimum QAP criteria that must be applied to specific Program Activity Areas.

4.8 Attachments 11-2 and 11-3 tabulate the NRC regulatory guides and ANSI standards, with exceptions and applicable revisions, that SMUD is committed to meeting as part of its QAP.

4.9 Activities associated with the safe operation of the Rancho Seco nuclear facility are accomplished under controlled conditions.

Preparations for such activities include confirmation that prerequisites have been met.

4.11 Development, control, and use of computer programs associated-with the design and safe operation of the Rancho Seco nuclear facility are subject to appropriate controls.

4.12 Training programs shall be established to ensure personnel responsible for performing and verifying activities that affect quality have the required proficiency and qualifications to perform the assigned tasks.

4.13 QAP Policy/Procedures/Instructions:

a. The QAP is documented in written policies, procedures, and .

instructions. The overall policies and general requirements are outlined in the RSQM. Specific details related to implementation of the established QAP policies are contained in Rancho Seco Administrative Procedures (RSAPs). Organizations responsible for performing QAP functions shall prepare additional implementing procedures as necessary. Quality reviews RSAPs to ensure RSQM requirements are accomplished in a controlled manner.

b. Quality is responsible for RSQM preparation, issuance, and control.

The RSQM, including any changes, supplements, or attachments, is issued and maintained as a controlled document.

c. Quality and the Site Manager shall review and approve proposed RSQM changes.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 15 OF 77 4.14 Resolution of Differences:

RSQM requirements take precedence over differing quality requirements specified in other work group procedures until Quality evaluates the issue and determines which requirements must be modified.

Questions or disputes involving RSQM interpretation or implementation must be referred to Quality for resolution.

4.15 Packaging and Transportation of Radioactive Material:

The QAP shall be applied to packaging and transportation of radioactive material as specified in References 2.4 and 2.6.

5.0 RESPONSIBILITIES General organizational responsibilities are described in RSQM Section I, ORGANIZATION 6.0 ATTACHMENTS Il-I, Application of Rancho Seco Quality Assurance Program Criteria 11-2, Regulatory Commitments 11-3, Exceptions

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 16 OF 77 Attachment I1-1 (Page 1 of 2)

APPLICATION OF RANCHO SECO QUALITY ASSURANCE PROGRAM (QAP) CRITERIA (A, B,C)

An 'X' means application of the RSQM requirements associated with the QAP Criteria is required.

(A)

(B) No 'X' means application of the RSQM requirements associated with the QAP Criteria is optional.

(C) RSQM implementing details are provided in the RSAPs and other QAP implementing procedures._______

QAP'CRITERIA

Program Activity Areas_____ __efrn s 4,I I_1 Ill IV V VIl VIIJ VIIIl IX X Xl_ XIIl XIIIl XIV XV XV.I XVII XVIII References Safety Related / 10 CFR 71/72 ISFSI TS 5.4.1k Important-to-Safety, Category A X X X X X X X X X X X X X X X X X X RSQM, APP. A, (QA Class 1) 10 CFR 50, APP. B

____ ____RSAP-0302, Alr. 6 Facility Operations (License ISFSI TS 5.4.1k Condition and Tech. Spec. x x X x X X x X X Xx RSQM Section XVllI Compliance) ___10 CFR 50/72 Licenses ISF5l TS 5.4,1k Radiation Protection X X X(2 ) X X X X X X 10OCFR 20

_______ ___ _____RSQM, APP. A Radioactive Effluent Control ISFS1 TS 5.4.1k Program (RECP) (3) X X X X X X X X X X Reg. Guide 4.15 RSQM, APP. A

______________________ _____10 CFR 50, APP. I Radiological Environmental ISFSI TS 5.4.1k 14 Monitoring Program (REMP) (3) X X X ) X X X X X X X Reg. Guide 4.15

____________________RSQM, APP. A Radwaste Handling and ISF51 TS 5.4.1k Shipping (Including Process X X X X X X X X X X X X X 10 CFR 71 Control Program) ()10 CFR 20.2006(d)

RSAP-0302, ATT. 6

____________________RSQM, APP. A ISFSI TS 5.4.1k & 5.7 Fire Protection (6 X X X X X X X X RSQM, APP. A

__________________________Decommissioning Order ISFSI TS 5.4.1k Security (7) X X X X X X X X 10OCFR 72.44 &186 10 CFR 73 ISFSI TS 5.4.1k Emergency Preparedness X X X X X X X X 10 CFR 50.54(t) 10 CFR 50, APP. E

__________RSOM, APP. A ISFS1 TS 5.4.1k Training X X X X X X X X 10OCFR 72.190

____ RSQM, APP. A 10 CFR 71/72 Important-to- ISFIS TS 5.4.1k Safety, Category B &C 5( X X X X X X X X X X X X X X RSAP-0302,ATT. 6 (QA Class 2) 10 CFR 72.3 & 72.140

__________ ____ ___ _____ ___________10 CFR 71.101 Attachment I1-1 (Page 1 of 2)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 17 OF 77 Footnotes:

(1) 10 CFR 50, Appendix B, Quality Criteria and corresponding RSQM section titles:

I. Organization II. Quality Assurance Criteria III. Design Control IV. Procurement Document Control V. Instruction, Procedures, and Drawings VI. Document Control VII. Control of Purchased Material, Equipment, and Services VIII. Identification and Control of Materials, Parts, and Components IX. Control of Special Processes X. Inspection XI. Test Control XII. Control of Measuring and Test Equipment XIII. Handling, Storage, and Shipping XIV. Inspection, Test, and Operating Status XV. Nonconforming Materials, Parts, or Components XVI. Corrective Action XVII. Quality Assurance Records XVIII. Audits (2) Design Control as applied to permanent protective shielding.

(3) Rancho Seco applies the NRC Regulatory Guide 4.15 QA/QC program to the RECP and REMP. This Regulatory Guide 4.15 program meets the applicable 10 CFR 50, Appendix B QAIQC program requirements.

(4) As applied to environmental monitoring laboratory analysis services.

(5) As applied to 10 CFR 71 activities authorized pursuant to NRC Form 311, "Quality Assurance Approval for Radioactive Material Packages,"

Approval No. 0489. (Refer to RSQM Section II, Steps 4.3.2 and 4.4.2)

(6) No Fire Protection equipment or services falls under the QAP.

ATTACHMENT Il-1 (Page 2 of 2)

REGULATORY COMMITMENTS

.RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 18 OF 77 SMUD commits to the requirements of the regulations and industry standards listed below with any exceptions identified in Attachment 11-3.

Document Revision/Date Title 1 Regulatory Guide 9/75 Personnel Selection and Training 1.8 Per ISFSI Tech. Spec. 5.3 2 Safety Guide 28 6/7/72 Quality Assurance Requirements for ANSI N45.2 1971 Nuclear Power Plants 3 Regulatory Guide 8/85 Supplementary Requirements for Quality 1.28 1983 Assurance Records (See Attachment 11-3, ANSI/ASME NQA- Exception No. 1)

Supplement 17S-1 4 Safety Guide 30 8/11/72 Quality Assurance requirements for the ANSI N45.2.4 1972 installation, Inspection, and Testing of Instrumentation and Electrical Equipment (See Attachment I1-3, Exception No. 2) 5 Safety Guide 33 11/3/72 Administrative Controls for Nuclear Power Plants as Addressed in RSQM Appendix A 6Regulatory Guide 3/16/73 Quality Assurance Requirements for 1.37 1973 Cleaning Fluid Systems and Associated ANSI N45.2.1 Components of Water-Cooled Nuclear Power Plants (See Attachment 11-3, Exception No. 3) 7 Regulatory Guide 3/16/73 Quality Assurance Requirements for 1.38 1972 Packaging, Shipping, Receiving, Storage ANSI N45.2.2 and Handling of Items for Water-Cooled Nuclear Power Plants (See Attachment II-3, Exception No. 8) 8 Regulatory Guide 3/16/73 Housekeeping Requirements for Water-1.39 1973 Cooled Nuclear Power Plants (See ANSI N45.2.3 Attachment 11-3, Exception No. 4)

ATTACHMENT 11-2 (Page 1 of 2)

PANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 19 OF 77 9 Regulatory Guide 6/73 Quality Assurance Requirements for 1.54 1972 Protective Coatings Applied to Nuclear ANSI N101.4 Facilities 10 Regulatory Guide 9/80 Qualification of Nuclear Power Plant 1.58 1978 Inspection, Examination, and Testing ANSI N45.2.6 Personnel (See Attachment 11-3, Exception No. 5) 11 Regulatory Guide 10/73 Quality Assurance Requirements for the 1.64 1974 Design of Nuclear Power Plants (See ANSI N45.2.11 Attachment 11-3, Exception No. 6) 12 Regulatory Guide 2/74 Quality Assurance Terms and Definitions 1.74 1973 (See Attachment 11-3, Exception No. 7)

ANSI N45.2.10 13 Regulatory Guide Rev. 2 Quality Assurance Requirements for 1.94 1978 Installation, Inspection, and Testing of ANSI N45.2.5 Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants 14 Regulatory Guide 6/76 Quality Assurance Requirements for 1.116 1975 Installation, Inspection, and Testing of ANSI N45.2.8 Mechanical Equipment and Systems 15 Regulatory Guide 11/77 Fire Protection Guidelines for Nuclear 1.120 Power Plants 16 Regulatory Guide 7/77 Quality Assurance Requirements for 1.123 Control of Procurement Items and Services 1976 ANSI N45.2.13 for Nuclear Power Plants 17 Regulatory Guide 1/79 Auditing of Quality Assurance Programs 1.144 for Nuclear Power Plants 1977 ANSI N45.2.12 18 Regulatory Guide 8/80 Qualification of Quality Assurance Program 1.146 1978 Audit Personnel for Nuclear Power Plants ANSI N45.2.23 ATTACHMENT 11-2 (Page 2 of 2)

EXCEPTIONS:

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 20 OF 77 EXCEPTION NO. 1: Regulatory Guide 1.28/NQA-1, Supplement 17S-1 SMUD complies with the recommendations of this regulatory guide with the following clarifications:

With regard to Section 2.4 of Supplement 17S-1 titled Index: The phrase "an index" is clarified to mean a collection of documents or indices which, when taken together, supply the information attributed to "an index" in the standard.

The specific location of a record "within a storage area" may not be delineated (e.g., the specific location within a computer record file may not be constant; further, SMUD may utilize a computer assisted random access filing system where such location could not be readily "documented," or would such a location be "relevant.") The storage location will be delineated, but where file locations change with time, the specific location of a record within that file may not always be documented.

With regard to Section 4.3, Supplement 17S-1 titled Safekeepincq: Routine general office and nuclear site security systems and access controls are provided: No special security systems are required to be established for record storage areas.

With regard to Section 4.4, Supplement 17S-1, titled Facility: This Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: "Records completed but not yet transferred for permanent storage may be temporarily stored in one-hour fire rated file cabinets. In general, records shall not be maintained in such temporary storage for more than four months after completion without being microfilmed or placed in permanent storage. Open-ended documents revised or updated on a more-or-less continuing basis over an extended period of time (e.g.

personnel qualification and training documents, equipment history cards) which are cumulative in nature (e.g. nonconforming item logs and control room log books) shall become QA records when they are issued as a specific revision (e.g.

the master audit schedule); when they are filled-up or discontinued (e.g. log books or equipment history cards); on a predefined periodic basis when the completed portion of the ongoing document shall be transferred to records control as a "record" (e.g. training and qualification records).

ATTACHMENT 1I-3 ('Pacie 1 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 21 OF 77 EXCEPTION NO. 2: Regulatory Guide 1.30/ANSI N45.2.4-.72 Specific clarifications for ANSI N45.2.4-1 972 are indicated below by section:

Section 1.4 Definitions in this standard that are not included in ANSI N45.2.10 shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clarified in SMUD commitment to Regulatory Guide 1.74.

Section 2.1 Planninqi requirements, as determined by engineering, shall be incorporated into modification procedures.

Section 2.3 Procedures and Instructions shall be implemented as set forth in Sections II, III, V, X and Xl of this program and by compliance with the Rancho Seco Plant Technical Specifications and Regulatory Guide 1.33 (ANSI N18.7).

Section 2.4 Results will be implemented as set forth in Sections X, Xl, and XVII of this program and by compliance with ANSI N18.7 in lieu of the requirements set forth here.

Section 2.5.2 Calibration and Control covers three classes of instrumentation used by SMUD: (1)

M&TE (portable measuring instruments, test equipment, tools, gages, and non-destructive test equipment used in measuring and inspecting safety-related structures, systems, and components); (2) reference standards (primary, secondary, transfer, and working); and (3) permanently installed process instrumentation (PI).

With respect to the first sentence, M&TE and reference standards shall be included in calibration program and shall either be calibrated at prescribed intervals or shall be calibrated prior to use. With respect to the last sentence, personnel shall be trained and procedures shall require that the calibration sticker shall be reviewed to determine calibration status prior to use: This label shall be considered to clearly identify equipment that is out of calibration.

Lack of a sticker shall require record review and affixing a new sticker based on calibration data. M&TE and reference standards shall comply with sentences 2, 3, and 4.

ATTACHMENT II-3 (Paaie 2 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 22 OF 77 With respect to the third sentence, SMUD uniquely identifies each safety-related component of permanently installed process instrumentation. This identification provides traceability to calibration data. These actions are SMUD's alternative to the tagging or labeling of items to indicate the calibration date and the identity of the person who performed the calibration. Permanently installed process instrumentation shall comply with sentences 1, 2, and 5.

Section 3 Pre-construction Verification will be implemented as follows: (1) is required only for modifications, (2) no special checks are required to be made by the person withdrawing a replacement part from the warehouse equivalent controls are ensured by compliance with Regulatory Guide 1.38 (ANSI N45.2.2) as set forth in this table, and, (3) shall be complied with as determined by engineering, by individual technicians as part of the modification process.

Section 5.1 Inspections, including subsections 5.1.1, 5.1.2, and 5.1.3, will be implemented as set forth in Section X of this program. The inspection program will incorporate,= as determined by engineering and Quality those items listed in these subsections.

Section 5.2 Tests, including subsections 5.2.1 through 5.2.3, will be implemented as set forth in Sections IIl and Xl of this program. In some cases Surveillance testing may be used to meet the appropriate requirements of this section.

Section 6 Post Construction Verification is not generally considered applicable at operating facilities because of the scope of the work and the relatively short interval between installation and operation. Where considered necessary by engineering andl Quality, the elements described in this Section will be used in the development and implementation of inspection and testing programs as describe in Sections III, X, and Xl of this program.

Section 7 Data Analysis and Evaluation will be implemented as stated herein after adding the clarifying phrase "Where used" at the beginning of that paragraph.

ATTACHMENT 11-3 (Paae 3 of 7)

.RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 23 OF 77 EXCEPTION NO. 3: Regulatory Guide 1.37/ANSI N45.2.1-73 Specific clarifications for this Regulatory Guide and ANSI N45.2.1-1 973 are indicated below:

With regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for final flushing of fluid systems and associated components shall be at least equivalent to the quality of the operating system water, except for the oxygen and nitrogen content; but this does not infer that chromate's or other additives, normally in the system water, will be added to the flush water.

With regard to Paragraph 0.4 of Regulatory Guide 1.37: Expendable materials, such as inks and related products; temperature indicating sticks; tapes; gummed labels; wrapping materials (other than polyethylene); water soluble dam materials; lubricants; NDT penetrant materials and couplants, desiccants, which contact stainless steel or nickel alloy surfaces shall not contain lead, zinc, copper, mercury, cadmium and other low melting points metals, their alloys or compounds as basic and essential chemical constituents. No more than 0.1 percent (1,000 ppm) halogens will be allowed where such elements are leachable or where they could be released by breakdown of the compounds under expected environmental conditions.

With regard to Section 5 of ANSI N45.2.1-1 973 titled Installation Cleaning: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded, as determined by Engineering or Chemistry.

EXCEPTION NO. 4: Regulatory Guide 1.39/ANSI N45.2.3-73 .

Specific classifications for ANSI N45.2.3-73 are indicated for specific sections below:

Section 1.4 Definitions: Definitions in this standard that are not included in Regulatory Guide 1.74 (ANSI N45.2.10) will be used. All definitions that are included in ANSI N45.2.10 will be used as clarified in SMUD's commitment to Regulatory Guide 1.74.

Section 2.1 ..

Planning: SMUD may choose not to utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with program requirements in the areas of housekeeping, plant and personnel safety, and fire protection.

ATTACHMENT II-3 ('Pane 4 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 24 OF 77 Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented cleanliness inspections that will be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will be established when the reactor system is opened for inspection, maintenance, modification or repair.

Additional housekeeping requirements will be implemented as required for control of radioactive contamination.

Section 2.2 Procedures and Instructions: Appropriate procedures will be written and implemented.

Section 3.2 Control of Facilities: SMUD may choose not to utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with program requirements in the areas of housekeeping, plant and personnel safety, and fire protection.

Cleanliness will be maintained, consistent with the work being performed, 'so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented cleanliness inspections that will be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will be established when the reactor system is opened for inspection, maintenance, modification or repair.

Additional housekeeping requirements will be implemented as required for control of radioactive contamination.

EXCEPTION NO. 5: Regulatory Guide 1.58/ANSI N45.2.6 SMUD complies with the recommendation of the regulatory guide with the following clarification:

With regard to Paragraph C.5: The Level II1 function of inspection planning, reviewing and concurring with inspection, examination and testing procedures is performed by designated individuals from the Quality & Industrial Safety Department.

ATTFACHMENT II-3 (Paae 5 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 25 OF 77 EXCEPTION NO. 6: Regulatory Guide 1.64/ANSI N45.2.11 SMUD complies with the recommendation of the regulatory guide with the following clarification:

With regard to Paragraph C.2: In exceptional circumstances, the designer's immediate supervisor can perform design verification, provided:

1. The supervisor is the only technically qualified individual available.

2. The need is individually documented and approved in advance by the supervisor's management.

3. QA audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.

EXCEPTION NO. 7: Regulatory Guide 1.74/ANSI N45.2.10-73 SMUD complies with the recommendations of this regulatory guide with the following clarifications:

SMUD reserves the right to define additional words or phrases that are not included in this Standard. Such additional definitions will be documented in appropriate procedures.

In addition to the Standard's definition of "Inspection," SMUD will use the following definition when referring to activities that are NOT performed by QC personnel:

Examining, viewing closely, scrutinizing, looking over or otherwise checking activities.

Personnel performing these functions are not necessarily certified to Regulatory Guide 1.58 (ANSI N45.2.6).

When SMUD intends for Inspection to be performed in accordance with the QA Program by personnel certified as required by that program and for activities defined by "inspection" in ANSI N45.2.10, appropriate references to the plant QC organization or the procedures to be used for performing the activity will be made. If such references are NOT made, inspections are to be considered under the additional definition given above.

"Independent Verification": Verification by an individual other than the person who performed the operation or activity being verified that required actions have been completed. Such verification may not necessarily require confirmation of the action at the physical location if adequate remote indication of completion of action is available. In determining the acceptability of remote verification, the consequences of the action not being 100% completed and the validity of the remote indication for ATTACHMENT 11-3 (Pagje 6 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 26 OF 77 confirming the completion of the desired action will be considered. Examples include, but are not limited to: Verification of a breaker opening by observed remote breaker indication lights; verification of a set point (made with a voltmeter or ammeter for example) by observing the actuation of status or indicating lights at the required panel-meter indicated value; verification that a valve has been positioned by observing the starting or stopping of flow on meter indications or by remote valve positions indicating lights.

"Will": (Not defined in any ANSI Standard) - Means the same as "shall" except when used to denote simple futurity. When used to denote futurity, "will" is normally followed by "be".

EXCEPTION NO. 8: Regulatory Guide 1.38/ANSI N45.2.2 Section 2.7 Classification of Items - SMUD may choose not to utilize the four levels of item' classification, but will address packaging and storage requirements for. items based on the needs of individual items and manufacturers recommendation.

ATTACHMENT 11-3 (Pa~ie 7 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 27 OF 77 III. DESIGN CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for control of design activities affecting applicable structures, systems, and components at the Rancho Seco nuclear station, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

In addition, this section defines the requirements for developing and implementing control measures that ensure design functions affecting the performance of operational, construction, and modification activities are carried out in a planned, controlled, and orderly manner and are in compliance with applicable regulatory commitments.

2.0 REFERENCES

2.1 10 CER 50, Appendix B, Criterion Ill, "Design Control" 2.2 10 CFR 50.59, Changes, Tests and Experiments 2.3 Regulatory Guide 1.64/ANSI N45.2.1 1, 1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (with exceptions noted in RSQM Section II) 2.4 ANSI N45.2, Section 4, Design Control 2.5 10 CFR 72.48, Changes, Tests, and Experiments 2.6 10 CFR 71.107, Package Design Control 2.7 10 CFR 72.146, Design Control 3.0 POLICY The requirements specified in this section apply to all organizations performing design functions for modifications, changes, replacement or addition of structures, systems, or components at the Rancho Seco nuclear facility.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 28 OF 77 4.0 GENERAL REQUIREMENTS Procedures shall be established and executed to control design activities.

Procedures covering design control activities shall include the following requirements:

4.1 Applicable design inputs such as design bases, regulatory requirements, codes and standards, methodology, and all assumptions with appropriate justifications are identified, documented, and correctly translated into design output documents such as specifications, drawings, procedures, or instructions.

4.2 Exceptions, waivers to or deviations from engineering requirements are documented and controlled.

4.3 Methods are specified for the selection and classification of suitable materials, parts, equipment, and processes used in meeting applicable requirements for structures, systems, and components.

Materials, parts, components, and equipment that are standard, commercial (off the shelf), or which have been previously approved for other similar applications are reviewed for suitability and appropriately classified.

4.4 Systematic methods are established for communicating and controlling the flow of related design information across the external and internal design interfaces, including any changes to the design information as the work progresses.

4.5 Interfaces between Engineering and other participating design organizations (either internal or external to SMUD) are identified and documented. This identification includes those organizations providing design inputs, design analyses, design specifications, and design verification for operational, construction and modification design activities.

4.6 Participating design organizations establish and describe the controlled methods for preparation, review, approval, release, distribution, and revision of documents (such as design analyses, specifications, drawings, reports) involving design interfaces.

4.7 Design control measures shall provide for verifying or checking the adequacy of design modifications or design changes. Acceptable verification methods include, but are not limited to, design reviews, alternate calculations, or qualification testing. If a test program is used to verify the adequacy of a

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 29 OF 77 design, it must include qualification testing of a prototype unit under the most adverse design conditions.

4.8 Computer program codes used for design calculations are certified for use and their use is specified.

4.9 Design verification is to be performed by competent individuals or groups other than those who performed the original design, but who may be from the same organization. The originator's supervisor may perform this verification provided the supervisor is the only technically qualified individual available and meets the appropriate clarification provisions of Reference 2.4. The results of the design verification efforts must be documented with the identification of the verifier clearly provided.

4.10 Provisions are specified for the control of design analyses such as; reactor physics, stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for in-service inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests.

4.11 Design problems that are identified during field installation or testing activities shall be documented and forwarded to Engineering for evaluation and resolution.

4.12 Design and specification changes, including field changes, receive the same degree of control and approval as the original design unless another qualified, responsible organization is specifically designated.

4.13 Errors and deficiencies in the design process, including computer programs that could adversely affect structures, systems, or components are documented and corrective action is taken to preclude repetition.

4.14 Proposed modifications or design changes which involve an Unreviewed Safety Question or a change to Rancho Seco nuclear facility Licenses or Technical Specifications are handled in accordance with 10 CFR 50.59, 10 CFR 72.48, and 10 CFR 71.107(c), as appropriate.

4.15 Modifications are reviewed by plant personnel for effect on plant operation prior to making the modification operational.

4.16 Design documents are reviewed for accessibility of equipment and components for in-service inspection, tests, maintenance or modifications.

4.17 Design and/or test documentation must be obtained from all suppliers on procurements of ASME code components used for replacement or modification to the Rancho Seco nuclear facility.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 I REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 30 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Engineering is responsible for implementing a design control process per this section and to:

a. Provide and control design change packages.

b. Ensure integrity and regulatory conformance of configuration control.

c. Provide plant configuration control including establishing and maintaining baseline documents.

d. Provide engineering support for facility computers.

e. Perform probabilistic analysis in support of plant design, when necessary.

f. Provide engineering support to the Rancho Seco nuclear organization.

g. Provide and maintain engineering procedures, standards and specifications and drawings.

h. Prepare and maintain the Master Equipment List (MEL) described in RSQM Section I1.

5.2 Quality Assurance is responsible for:

a. Review and concurrence of design control procedures.

b. Monitoring implementation of the design control program.

c. Auditing the design control program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 31 OF 77 IV. PROCUREMENT DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to control procurement documents for material, equipment, and services at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion IV, Procurement Document Control 2.2 ANSI N45.2-1 971, Section 5, Procurement Document Control 2.3 Regulatory Guide 1.123/ANSI N45.2.13-1976, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants 2.4 10 CFR 71.109, Procurement Document Control 2.5 10 CFR 72.148, Procurement Document Control 3.0 POLICY Procurement documents for applicable Rancho Seco nuclear facility materials, equipment, components/spares, or services shall include applicable technical requirements, quality requirements, regulatory requirements, and other provisions necessary to ensure that purchased items and services are adequately described to the supplier.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established and implemented to control the preparation, review, approval and issuance of procurement documents.

4.2 Procurement documents shall include provisions for the following, as applicable:

a. Description of item or service.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 32 OF 77

b. Identification of design specifications and technical requirements by reference to specific drawings, codes, regulations, industry standards, or other documentation, including the applicable revision thereto that describe the items or services to be furnished.

c. Identification of test, inspection, and acceptance requirements, and any special instructions and requirements for activities such as design, fabrication, identification, cleaning, erecting, packaging, handling, shipping, and extended storage.

d. Identification of applicable QAP criteria.

e. Applicability of 10 CFR Part 21.

f. Identification of the documentation, such as drawings, specifications, procedures, fabrication and inspection plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test reports to be prepared and maintained by the supplier or contractor, and the requirement to submit this documentation to SMUD for review and approval.

g. Identification of those records to be retained, controlled, and maintained by the supplier or contractor and those to be delivered to SMUD at the time of shipment of the procured item.

h. SMUD's right of access to the supplier's facilities and records for inspection and audits.

i. Extension of applicable requirements to lower tier subcontractors and suppliers, including SMUD's right of access to facilities and records.

j. Supplier submittal of nonconforming items and SMUD approval for "Accept as is" or "Repair" dispositions of non-conformances.

k. SMUD's right to hold shipment if procurement document requirements, including those for documentation, have not been fulfilled.

4.3 Technical and quality review by qualified personnel and approval by designated individuals shall be performed prior to issuance of the procurement document. The review and approval shall be documented and available for verification.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 33 OF 77 4.4 Review and concurrence by Quality Assurance shall be performed to ensure adequacy of quality requirements and to verify that the requirements are correctly stated, inspectable, and controllable; that there are adequate acceptance and rejection criteria; and that the procurement documents have been prepared, reviewed, and approved in accordance with the requirements of the established procedures.

4.5 Revisions to procurement documents shall receive an equivalent review and approval as the original documents. Exceptions to this include changes in quantity, estimated price, cost codes, taxes, format or editorial changes that do not affect the quality of the item or service.

4.6 Procurement documents for spare or replacement parts for QA Class 1 structures, systems, or components shall specify procurement controls at least equivalent to those required for purchase of the original equipment.

4.7 Methods shall be established to ensure that the items received are traceable to procurement documents.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 General Services is responsible for:

a. Purchase items in conformance with procurement documents.

b. Purchase safety-related (QA Class 1) items from approved suppliers.

c. Arrange for suppliers to be placed on an Approved Suppliers List (ASL). (Refer to RSQM Section VII, step 4.2 regarding ASL)

d. Arrange for source inspection when specified on the procurement documents.

5.2 Engineering is responsible for:

Maintain a staff of qualified engineers who provide technical and quality requirements for purchasing safety-related (QA Class 1) items.

5.3 Quality Assurance is responsible for:

a. Review and concurrence of material management procedures.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010

+I REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 34 OF 77

b. Review and concurrence of procurement documents for safety-related (QA Class 1) items.

c. Auditing the procurement document control program per RSQM Section XVIII.

d. Developing and maintaining the ASL.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 35 OF 77 V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that activities affecting the quality or safety of the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72), are described and accomplished in accordance with documented instructions, procedures, drawings, or other documents appropriate to the circumstances.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings 2.2 ANSI N45.2-1 971, Section 6, Instructions, Procedures, and Drawings 2.4 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.4 10 CFR 71.150, Instructions, Procedures, and Drawings 2.5 10 CFR 72.111, Instructions, Procedures, and Drawings 3.0 POLICY Activities affecting quality performance or operational safety at the Rancho Seco nuclear facility shall be described and implemented in accordance with documented instructions, procedures, and drawings.

4.0 GENERAL REQUIREMENTS 4.1 Written instructions, procedures, drawings, or other documents appropriate to the circumstances shall be prepared to provide measures for complying with the provisions of the QAP.

4.2 Instructions, procedures, or drawings shall include applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished.

4.3 Procedures shall be established for the review, approval, issuance, change, and use of documents that specify quality requirements such as

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 36 OF 77 instructions, procedures, drawings, and other documents that implement the QAP.

4.4 Activities affecting quality shall be accomplished in accordance with approved instructions, procedures, and drawings.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Rancho Seco management is responsible for ensuring activities that affect quality are described in instructions, procedures, and drawings.

5.2 Quality Assurance is responsible for performing audits to verify that any activities affecting quality are described in instructions, procedures and, drawings. Audits shall be conducted in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 37 OF 77 VI. DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the issuance and control of documents that control activities affecting quality at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed pursuant to 10 CFR

50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion VI, Document Control 2.2 ANSI N45.2-1 971, Section 7, Document Control 2.3 ANSI N45.2.1 1-1 974, Section 7, Document Control 2.4 10 CFR 71.113, Document Control 2.5 10 CFR 72.152, Document Control 3.0 POLICY Applicable documents, including changes thereto, that prescribe activities affecting the quality operation at the Rancho Seco nuclear facility shall be issued and controlled in a manner that precludes the use of inappropriate or outdated documents.

4.0 GENERAL REQUIREMENTS 4.1 The responsible organization shall establish procedures that define responsibilities and delineate the sequence of actions to be accomplished in preparation, review, approval, and control of instructions, procedures, or drawings, or changes thereto.

4.2 Procedures that establish document control measures shall include:

a. Identification of documents to be controlled;

b. Identification of individuals or organizations responsible for the review, approval, issuance, and revision of documents;

PANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 38 OF 77

c. Criteria to ensure that adequate technical and quality requirements are incorporated prior to implementation;

d. Review of changes to documents by the same organizations that performed the initial review and approval or by the organizations designated in accordance with the applicable procedures.

4.3 Controlled documents, including changes, shall be issued and distributed to organizations noted on distribution lists so that proper and current documents are available as required, and obsolete or superseded documents are identified and not used for prescribed activities.

4.4 Master lists or equivalent means shall be used to identify the current revision of controlled documents and made available at work locations, as appropriate.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Site Document Control (SDC) is responsible for developing and implementing a document control program in accordance with this section.

5.2 Rancho Seco management is responsible for:

a. Complying with document review, approval, and revision authority defined in plant administrative procedures.

b. Ensuring Quality Assurance review of documents with quality assurance related aspects, as appropriate.

5.3 Quality Assurance is responsible for:

a. Reviewing and concurring with document control procedures.

b. Reviewing and concurring with prOcedures, instructions, or documents that implement the QAP to ensure compliance with applicable RSQM provisions.

c. Auditing the document control program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 39 OF 77 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that material, equipment, and services purchased for the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72), conform to the procurement documents.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services 2.2 ANSI N45.2-1 971, Section 8, Control of Purchased Material, Equipment,.

and Services 2.3 Regulatory Guide 1.123/ANSI N45.2.13-76, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants 2.4 10 CFR 71.115, Control of Purchased Material, Equipment, and Services 2.5 10 CFR 72.154, Control of Purchased Material, Equipment, and Services*

3.0 POLICY Measures shall be established to ensure that material, equipment, and services conform to the specified requirements of the related procurement documents.

4.0 GENERAL REQUIREMENTS 4.1 Control of purchased material, equipment, and Services shall include the following, as appropriate:

a. Source evaluation and selection of suppliers.

b. Objective evidence of quality furnished by the supplier.

c. Source inspection, audit, and/or surveillance activities.

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d. Examination of items or services upon delivery or completion.

4.2 Results of source evaluation and selection of suppliers shall be documented and retained on file.

4.3 Procedures for control of materials, equipment, and services shall address the following:

a. Responsibilities of departments performing supplier technical and quality evaluations, and the method of evaluation.

b. Inspection activities that specify the characteristics or processes to be witnessed, inspected or verified; the method of verification and the extent of documentation required; and the organization responsible for implementing the inspection.

c. Auditing to verify conformance and implementation to requirements of this policy. Source inspection and audits may not be necessary when conformance of an item to procurement requirements can be verified by receipt inspection, review of test reports, certified reports or other means specified by Quality Assurance.

d. Receipt inspection of supplier furnished items to ensure: (1) the proper identification of items on the receiving documentation, (2) that the items are inspected and judged acceptable in accordance with predetermined instructions prior to installation or use, (3) that inspection records or certificates of conformance are available at the plant site prior to installation or use of the items, and (4) that items accepted and released are identified as to their inspection status prior to storage or use.

e. Review, acceptance, and maintenance of records to ensure adequacy of documentation that identifies the purchased item, and that specific procurement requirements (e.g., codes, standards, specifications) have been met or satisfied.

f. Review and approval of documentation required to be submitted by the procurement documents (CMTR's, Certificate of Compliance, Procedures, Specifications, etc.).

g. Procurement control of spare or replacement parts for QA Class 1 systems to ensure compliance with requirements that are (1) equivalent to the original requirements or (2) specified by a properly reviewed and approved revision to the original requirements.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-O10 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 41 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Engineering is responsible for:

a. Ensuring quality and qualifications of parts and materials by (1) developing quality specifications and (2) storing parts and materials in accordance with regulatory requirements and in coordination with appropriate nuclear organization groups.

b. Ensuring regulatory compliance of materials and parts by managing procurement documentation and reviewing (and implementing, as appropriate) NRC and related parts/materials bulletins.

c. Examining items or services upon delivery or completion, as deemed necessary to supplement or replace formal inspection activities.

5.2 Quality Assurance is responsible for:

a. Developing and maintaining the ASL.

b. Performing required inspections, evaluations, and audits.

c. The review and concurrence with material management procedures.

d. Auditing the control of purchased material, equipment, and services per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 42 OF 77 VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, &

COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the identification and control of material, parts, and components for the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant tol10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion VIII, Identification and Control of Materials, Parts and Components 2.2 ANSI N45.2-1 971, Section 9, Identification and Control of Materials, Parts, and Components 2.3 10 CFR 71.117, Identification and Control of Materials, Parts, and Components 2.4 10 CFR 72.156, Identification and Control of Materials, Parts, and Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components are properly identified and controlled to preclude the use of incorrect or nonconforming items.

4.0 GENERAL REQUIREMENTS 4.1 Materials, parts, or components, including partially fabricated subassemblies and consumables, shall be identified so they can be related to their applicable drawing, specification, purchase document, and inspection records at any stage from initial receipt through fabrication/construction, installation, repair, modification, or use.

4.2 Identification controls, implementation procedures, and documentation shall be used to ensure that only correct and accepted items are used during all stages of construction, installation, and operation.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 43 OF 77 4.3 Unique identification of items is required, e.g., by part number, serial number, heat number, drawing identification number, or other traceable coding methods.

4.4 Identification is required to be maintained either on the item or on records traceable to the item. Physical identification such as by marking or tagging shall be used to the maximum extent practical.

4.5 When specified by codes, standards, procurement documents, or other requirements, identification is required such that items are traceable to appropriate documentation (e.g., specifications, drawings, purchase orders, manufacturing and inspection documents, nonconformance reports, physical or chemical mill test reports).

4.6 Where identification marking is employed, the marking is required to be clear, unambiguous and indelible, and shall be applied such as not to affect the fit, function, or quality of the item.

4.7 Markings shall be transferred to each part of an item, if subdivided. The markings shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted.

4.8 Procedures are required to provide for the verification and documentation of correct identification of items prior to release for use. Items may be conditionally released under adequate procedural controls.

4.9 Bulk consumables (such as weld rod, chemicals, reagents, gases, resins, lubricating oil and grease, fuel oil, cleaning solvents, etc.) must be identified and controlled in accordance with approved procedures that specify the applicable requirements for identification and use of the consumables.

4.10 In the event the identification or traceability of an item is lost, it shall be handled in accordance with RSQM Section XV.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 General Services is responsible for identification and control of items from procurement through withdrawal from the warehouse.

5.2 Maintenance is responsible for maintaining identification and control of items from withdrawal from the warehouse through installation.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 44 OF 77 5.3 Quality Assurance is responsible for:

a. Review and concurrence of procedures for controlling material, parts, and components from procurement through storage, issuance, and installation.

b. Auditing the process for identification and control of materials, parts, and components in accordance with RSQM Section XVIII.

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RANCHO SECO LICUN;51NU BASIS DOCGUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 45 OF 77 IX. CONTROL OF SPECIAL PROCESSES 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to control special processes used at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes 2.2 ANSI N45.2-1977, Section 10, Control of Special Processes 2.3 ASME Section V and IX 2.4 10 CFR 71.119, Control of Special Processes 2.5 10 CFR 72.158, Control of Special Processes 3.0 POLICY Prior to performing any special processes, procedures shall be established and implemented to ensure that special processes and equipment are controlled and that qualified personnel and procedures accomplish required activities.

4.0 GENERAL REQUIREMENTS 4.1 Prior to performing any special processes, procedures shall be prepared to provide for proper control of special processes, which include welding, heat treating, chemical cleaning, application of protective coatings, and nondestructive examination (NDE).

4.2 Controls shall be established to ensure that only approved materials and equipment are used to perform special processes.

4.3 Personnel who perform special processes shall be qualified in accordance with industry standards.

4.4 Special process requirements shall be prescribed in the controlling specifications, drawings, procurement documents, or procedures.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-0 10 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 46 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section 1, ORGANIZATION.

5.1 Encilneerinci is responsible for:

a. Specifying the special processes on design documents governing maintenance/modification activities.

b. Developing, qualifying, and maintaining special process procedures in accordance with Step 4.1 of this RSQM section.

c. Qualifying personnel or approving contract personnel to perform special processes identified in Step 4.1 of this RSQM section.

d. Performing NDE or approving contract personnel to perform NDE.

5.2 Quality Assurance is responsible for:

a. Review and concurrence of special process procedures.

b. Auditing the special process program in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 47 OF 77 X. INSPECTION 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the inspection of material, parts, and components for the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion X, Inspection 2.2 ANSI N45.2-1971, Section 11, Inspection 2.3 Regulatory Guide 1.58/ANSI N45.2.6-78, Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel with exceptions noted in RSQM Section II.

2.4 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.5 10 CER 71.121, Internal Inspection 2.6 10 CFR 72.160, Licensee Inspection 3.0 POLICY Procedures shall be established and implemented to ensure that inspections are performed to verify compliance with specified requirements at the Rancho Seco nuclear facility.

4.0 GENERAL REQUIREMENTS 4.1 Inspections shall be applied to receiving, maintenance, and modification activities to verify that items and activities conform to specified requirements.

4.2 Inspection planning documents shall be prepared or reviewed by Quality Assurance in accordance with established procedures. Inspection planning documents shall identify the following as applicable:

a. Characteristics and activities to be inspected;

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b. Inspection organization;

c. Accept/reject criteria;

d. Hold points and/or witness points;

e. Inspection Methods;

f. Provisions for recording objective evidence of inspection results; and

g. Measuring and test equipment of the necessary accuracy for performing inspection.

4.3 Process monitoring may be used where direct inspection alone is impractical or inadequate. Both inspection and process monitoring are performed when control is inadequate without both.

4.4 Training and qualification of personnel, who perform inspections including NDE, shall be performed in accordance with approved procedures.

4.5 Hold points are designated as mandatory inspection points when confirmation is needed that the work at the point is acceptable before additional work can proceed. Authorized personnel perform hold point inspections and release work for further processing or use.

4.6 Inspections, including any required hold points, are performed and documented in accordance with written procedures. Inspection results are documented and evaluated by qualified personnel to verify acceptability.

4.7 Quality Assurance personnel perform inspections of receiving, maintenance, and modification activities.

4.8 Inspection records shall contain the following where applicable:

a. Item inspected;

b. The date of the inspection;

c. Inspector or data recorder identification;

d. Identification of M&TE used to perform inspections;

e. Type of observation;

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f. Results or acceptability; and

g. Reference to information on action taken on non-conformances to resolve any discrepancies noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section i, ORGANIZATION.

5.1 Quality Assurance is responsible for:

a. Qualifying Quality Control Inspectors.

b. Preparing or reviewing inspection-planning documents for modification/maintenance activities.

c. Performing inspections per inspection plans.

d. Auditing the inspection program in accordance with RSQM Section XVIII.

5.2 Maintenance is responsible for assuring:

a. Inspections are performed as required by inspection planning.

b. Work does not proceed beyond inspector signoffs for hold points.

5.3 Each organization is responsible for:

a. Supporting inspection activities.

b. Providing prompt corrective action to any deficiencies found during the inspection.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 50 OF 77 Xl. TEST CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for acceptance and surveillance test control at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion Xl, Test Control 2.2 ANSI N45.2-1971, Section 12, Test Control 2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power*

Plants 2.4 10 CFR 71.123, Test Control 2.5 10 CFR 72.162, Test Control 3.0 POLICY Procedures shall be established and implemented to ensure that required testing to demonstrate that structures, systems, and components will perform satisfactorily in service is identified, performed and documented.

4.0 GENERAL REQUIREMENTS 4.1 Tests shall be performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

a. Qualification tests, as applicable, to verify design adequacy.

b. Tests of equipment and components to ensure their proper operation prior to delivery or pre-operational tests;

c. Pre-operational tests to ensure proper and safe operation of systems and equipment prior to startup tests or operations;

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 51 OF 77

d. Startup tests to ensure proper and safe operation of systems and equipment.

e. Surveillance tests to ensure continuing proper and safe operation of systems and equipment.

f. Maintenance tests after preventive or corrective maintenance.

4.2 Test procedures and instructions shall include provisions for the following, as applicable:

a. The requirements and acceptance limits contained in the applicable design and procurement documents;

b. Test prerequisites such as calibrated instrumentation, required test equipment, degree of completeness of the item to be tested, suitable and controlled environmental conditions, and provisions for data collection and storage;

c. Verifying that test prerequisites have been met;

d. Instructions for performing the test;

e. Any inspection points;

f. Acceptance criteria;

g. Documenting or recording test data and results; and

h. Verification of completion.

4.3 Test procedures and instructions shall be reviewed by the applicable organizations for technical content.

4.4 Test results shall be documented and evaluated by responsible authorities to ensure that test requirements have been satisfied.

4.5 Test records shall contain the following information where applicable:

a. Item tested and type of observation;

b. The date and results of the test;

c. Information related to deviations or non-conformances;

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d. Identification of person recording the data;

e. Evidence as to the acceptability of the results; and

f. Action taken to resolve any deviations and non-conformances noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGAN IZATION.

5.1 Quality Assurance is responsible for auditing the test control program per RSQM Section XVIII.

5.2 Engineering is responsible for:

a. Establishing the procedure for acceptance and surveillance testing.

b. Providing personnel to perform the testing and acceptance evaluations.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 53 OF 77 XlI. CONTROL OF MEASURING AND TEST EQUIPMENT 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the control of measuring and test equipment at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment 2.2 ANSI N45.2-1971, Section 13, Control of Measuring and Test Equipment 2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants.

2.4 Regulatory Guide 1.30/ANSI N45.2.4-72, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment with exception noted in Section II of this manual.

2.5 10 CFR 71.125, Control of Measuring and Test Equipment 2.6 10 CFR 72.164, Control of Measuring and Test Equipment 3.0 POLICY Procedures shall be established and implemented to ensure that measuring and testing devices used in final acceptance of activities affecting quality are properly

~controlled, calibrated, and adjusted at specified intervals to maintain the desired accuracy.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for calibration, maintenance, and control of measuring and test equipment utilized in the operation, measurement, inspection, or monitoring of items.

4.2 Measuring and Test Equipment (M&TE) shall be calibrated at specified intervals. These intervals are based on the amount of use, stability,

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RANCHO SECO LIUEINSIN(3 BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 54 OF 77 characteristics and other conditions that could adversely affect the required measurement accuracy. Reference and secondary calibration standards shall be traceable to nationally recognized standards where they exist. Where national standards do not exist, provisions shall be established to document the basis for calibration.

4.3 M&TE used for calibrating plant process instrumentation (PI) shall have calibration ranges, precessions, and accuracy's such that the PI can be calibrated from M&TE with an accuracy ratio of at least two-to-one (M&TE to PI). Calibration accuracy ratios of less than two but equal to or better than one shall be acceptable when equipment to meet specified requirements is not commercially available. The basis of acceptance in these cases shall be documented.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Maintenance is responsible for:

a. Establishing methods for control of measuring and test equipment.

b. Determining the need for calibrated instruments and measuring devices in Rancho Seco nuclear facility activities.

c. Providing administrative procedures that address the requirements for calibration.

d. Control of measurement devices to ensure their use and accuracy.

5.2 Quality Assurance is responsible for auditing the control of measuring and test equipment program per RSQM Section XVIII.

RANCHO SECO LICENSzING~ BASIS DOCGUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 55 OF 77 XIII. HANDLING, STORAGE, AND SHIPPING 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the handling, storage, shipping, cleaning, and preservation of material and equipment at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XIII, Handling, Storage, and Shipping 2.2 ANSI N45.2-1 971, Section 14, Handling, Storage, and Shipping 2.3 Regulatory Guide 1.38/ANSI N45.2.2-1 972, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants with exceptions noted in Section II of this manual.

2.4 10 CFR 71.127, Handling, Storage, and Shipping 2.5 10 CFR 72.166, Handling, Storage, and Shipping 3.0 POLICY Procedures shall be established and implemented to ensure that materials and equipment are properly handled, stored, shipped, cleaned, and preserved to prevent damage or deterioration.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for assuring that proper handling, storage, shipping, and preservation instructions are included in applicable drawings and/or specifications.

4.2 When required for specific items, special protective environments, such as inert gas atmosphere, specific moisture content levels, and temperature levels, shall be specified.

4.3 A shelf life program shall be in effect and monitored to prevent usage after the expiration date without re-certification for extension of shelf life.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 56 OF 77 4.4 Special material handling and preservation instructions shall be developed when required by applicable drawings and/or specifications.

4.5 Materials used for packaging, shipment, and, storage of items that have the potential for causing contamination or radiation exposure require marking and labeling to indicate the need for special radiological controls.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Engineering is responsible for establishing methods and procedures to ensure that applicable drawings and/or specifications include handling, storage, shipping, and preservation requirements.

5.2 Maintenance is responsible for:

a. Establishing methods for special handling, storage, and preservation during maintenance activities.

b. Providing administrative procedures that specify the required controls.

5.3 Quality Assurance is responsible for auditing conformance to the handling, storage, and shipping program per RSQM Section XVIII.

5.4 General Services is responsible for maintaining material and warehousing control of items and equipment that require special handling and storage.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 57 OF 77 XlV. INSPECTION, TEST, AND OPERATING STATUS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a system to identify the inspection, test, and operating status of individual items at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XIV, Inspection, Test and Operating Status 2.2 ANSI N45.2-1 971, Section 15, Inspection, Test, and Operating Status 2.3 10 CFR 71.129, Inspection, Test and Operating Status 2.4 10 CFR 72.168, Inspection, Test and Operating Status 3.0 POLICY Procedures shall be established and implemented to ensure that measures. are provided to indicate the status of inspections, tests, and operations.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall specify the degree of control required for the indication of inspection and test status of items required for modification activities.

4.2 The sequence of inspections, tests, and other operations, and changes thereto, shall be controlled by procedures.

4.3 Procedures shall provide methods for identifying the nonconforming items, inoperable systems and components by tags, markings, labels, etc. to prevent inadvertent use.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 58 OF 77 5.1 Maintenance is responsible for Clearance Program procedures to ensure:

a. Safety of personnel and equipment during maintenance and testing activities.

b. Installation and removal of test and operating status indicators.

5.2 Quality Assurance is responsible for:

a. Identifying the quality status of applicable material, parts, and components.

b. Auditing the inspection, test, and operating status program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 59 OF 77 XV. NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for controlling material, components, parts, or systems that are not in conformance to specified requirements at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCED DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XV, Nonconforming Materials, Parts or Components 2.2 ANSI N45.2-1 971, Section 16, Nonconforming Items 2.3 10 CFR 71.131, Nonconforming Materials, Parts or Components 2.4 10 CFR 72.170, Nonconforming Materials, Parts or Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components that do not conform to specified requirements are controlled to prevent their inadvertent use or installation.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be developed for controlling, documenting, and resolving items, services, or activities identified as nonconforming.

4.2 Marking, tagging, segregating, or other means shall identify nonconforming items.

4.3 Non-conformances shall be documented, processed, controlled and retained to provide records of the actions taken to resolve the nonconforming condition.

RANCHO SECO LICENSING3 BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 60 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Quality Assurance is responsible for:

a. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions. (Refer to RSQM Section XVI regarding corrective action program)

b. Establishing methods for controlling and documenting non-conformances.

c. Ensuring expertise is available to disposition non-conformances.

d. Developing safety analyses that address the nonconforming condition, if required.

a. Auditing the nonconforming materials, parts, or components program per RSQM Section XVIII.

5.2 Rancho Seco management is responsible for:

a. Taking appropriate action to ensure operation of the plant in conformance to license requirements when a nonconformance identifies a condition prohibiting components, structures, or, systems from returning to an acceptable condition.

b. Determining the safety significance of the nonconforming condition on the status of the plant.

c. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions.

d. Ensuring expertise is available to disposition non-conformances.

e. Developing safety analyses that address the nonconforming condition, if required.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 61 OF 77 XVI. CORRECTIVE ACTION 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a corrective action program to ensure that conditions adverse to quality are promptly identified and corrected at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR

50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XVI, Corrective Action 2.2 10 CFR 72, Subpart D, Records, Reports, Inspections, and Enforcement.

2.3 ANSI N45.2-1 971, Section 17, Corrective Action 2.4 10 CFR 71.133, Corrective Action 2.5 10 CFR 72.172, Corrective Action 3.0 POLICY Procedures shall be established and implemented to ensure that significant conditions adverse to quality are identified and that corrective action is taken to preclude repetition.

4.0 GENERAL REQUIREMENTS 4.1 Controls shall ensure conditions adverse to quality such as malfunctions, errors, deficiencies or non-conformances are identified, documented and appropriate corrective action taken. The controls shall ensure that the corrective action is- implemented in a timely manner.

4.2 For significant conditions adverse to quality, corrective action includes determining the cause and extent of the condition, taking corrective action to remedy the condition and taking action to prevent recurrence. These actions shall be reported to management personnel for review and assessment.

5.0 RESPONSIBILITIES

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 62 OF 77 General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Rancho Seco management is responsible for:

a. Formulating appropriate corrective actions.

b. Implementing proposed corrective actions.

c. Ensuring that proposed corrective action is effective.

5.2 Quality Assurance is responsible for:

a. Auditing the Corrective Action Program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 63 OF 77 XVII. QUALITY ASSURANCE RECORDS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the storage and maintenance of Quality Assurance Records that provide the documentary evidence of activities affecting quality performed at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records 2.2 ANSI N45.2-1 971, Section 18, Quality Assurance Records 2.3 Safety Guide 33/ANSI N18.7, Administrative Control for Nuclear Power Plants, paragraph 5.2 2.4 Regulatory Guide 1.28/ANSI/ASME, NQA-1-1 983, Supplement 17S-1, Supplementary Requirements for Quality Assurance Records, with exceptions as noted in RSQM Section II, Attachment 11-3.

2.5 Rancho Seco Quality Manual, Appendix A 2.6 10 CFR 71.135, Quality Assurance Records 2.7 10 CFR 72.174, Quality Assurance Records 3.0 POLICY Procedures shall be established and implemented to ensure storage and maintenance of records that represent evidence of activities described in RSQM Section II, Step 4.4.

4.0 GENERAL REQUIREMENTS 4.1 Quality Assurance records shall be permanently stored in a facility that meets the requirements of Reference 2.4 and 2.5.

4.2 Quality Assurance records shall be protected during interim storage in accordance with Reference 2.4.

RANCHO SECO LICENSINGi BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 64 OF 77 4.3 Documents that furnish evidence of the quality of items and services are generated and controlled in accordance with the procedures that govern those activities. Such documents are considered Quality Assurance Records upon completion. Quality Assurance Records are considered completed when they have been stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated.

4.4 The record system shall provide for identification and retrievability of the records to the extent that information can be obtained in a reasonable amount of time.

4.5 The records program shall address records classification (retention period), storage location and responsibility for retention and retrievability.

4.6 A records retention schedule shall be established which addresses the requirements in References 2.4 and 2.5.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGAN IZATION 5.1 Records Management is responsible for:

a. Establishing methods for control of records.

b. Providing administrative procedures that define the records storage program and provide for ready retrievability.

5.2 Rancho Seco management is responsible for:

a. Transmitting completed records to Records Management.

b. Providing interim storage in accordance with Step 4.2 above and Reference 2.4, prior to transmittal to Records Management.

5.3 Quality Assurance is responsible for auditing the records management system to ensure conformance to specified requirements per RSQM Section XVIII.

RANCHO SLECO LIUNI=N~NL 15A*515 UU)CUMINNI NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 65 OF 77 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 Regulatory Guide 1.144/ANSI N45.2.1 2-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 2.4 Regulatory 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 ensure 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.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 66 OF 77 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 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.

4.6 Process conditions identified as adverse to quality using the Rancho Seco Corrective Action Program.

4.7 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.

4.8 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 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. Training and qualification of audit personnel.

5.2 SMUD management is responsible for:

a. Supporting the audit activities.

1KANI2HO SECGO LIULNI-NU5NL bA*51* VUGUMNI-- NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 67 OF 77

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 Director, Audit Services (AS). 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 Manager 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;

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

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 68 OF 77

k. Process Control Program (PCP) and implementing procedures for processing and packaging of radioactive wastes from liquid systems at least once every two years; I.Performance of activities required by the Quality Assurance Program for Effluent Control and Environmental Monitoring (Regulatory 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 "in" above shall be forwarded to the site Manager, the Director, Power Generation, and the management positions responsible for the areas reviewed. The report should be issued within 30 days after completion.

RANCHO SECO LICENSiIN(G WASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 69 OF 77 Appendix A 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 Manager, but not lower than a direct report to the Site Manager. Such procedures, plans, manuals and programs shall be reviewed periodically in accordance with administrative procedures.

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

b. Proposed changes or modifications to systems or equipment described in the RADSAR 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 Manager or his designee as delineated in writing, but not lower than a direct report to the Site Manager.

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 RADSAR. Such tests or experiments shall be approved by the Site Manager or his designee as delineated in writing, but not lower than a direct report to the Site Manager.

d. Individuals responsible for reviews performed in accordance with Section 1.1 a, 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 Manager 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 event and which provides recommendations to prevent recurrence. The Site Manager shall review these reports.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 70 OF 77 1.2 Audits (See RSQM Section XVIIl)

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 Manager or designee.

1.4 Procedures, Plans, Manuals, and Programs 1.4.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained 1 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. POP implementation.

e. ODCM implementation.

f. REMP MANUAL implementation.

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

RANCHO SECO LICENSING3 BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 71 OF 77 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 Proaram There are no longer any radioactive liquid or gaseous effluents discharged from the site. The Offsite Dose Calculation Manual (ODOM) 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 Radioloqical Environmental Monitoringq Progqram (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.

With the completion of the first phase of decommissioning, the direct radiation pathway is the only pathway still monitored by the REMP.

Accordingly, there is no longer any requirement to participate in an Inter-laboratory Comparison Program (ICP). The vendor supplying the direct radiation monitoring devices must be certified under a National Voluntary Laboratory Accreditation Program (NVLAP). The National Institute of Standards and Technology (NI1ST) administers the NVLAP, which provides third-party accreditation to testing and calibration laboratories.

1.4.4 The changes to the REMP shall be reviewed and approved as set forth in Sections 1.1 and 1.9.

RANCHO SECO LICEN;51NU L3A$IS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 72 OF 77 1.5 Reporting Requirements 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 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 Radioloqical 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.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 73 OF 77 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 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 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 Officel. 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).

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 74 OF 77 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.

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.

RANCHO SECO LICENSING~ BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 75 OF 77

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

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 Plant Review committee (PRC) and Management Safety Review Committee (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 POP:

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.

I b.Shall become effective after approval by the Site Manager.

RANCHO SECU LlICNI-N5N(i IUA*51*5 LVUUMPN I NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 76 OF 77 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 Manager 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:

a. The Licensee, or

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

KANUHU. SI-W LILLNI:NU5N* bA*515 VU()UML-N I NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 77 OF 77 The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample.

Test Freqiuencies 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.

Powering forward. Together.

• SM UD.. ....r i. ..

January 7, 2016 DPG 16-002 U.S. NRC Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Docket 50-312 Rancho Seco Nuclear Generating Station License DPR-54 Docket 72-11 Rancho Seco Independent Spent Fuel Storage Installation License SNM-2510 REPORT OF CHANGES TO THE RANCHO SECO QUALITY ASSURANCE PROGRAM THAT DO NOT REQUIRE PRIOR NRC APPROVAL Attention: Jack Parrott and Chris Allen In accordance with 10 CFR 50.54(a)(3) and 10 CFR 50.4(b)(7), we are required to submit a copy of changes to the Rancho Seco Quality Manual (RSQM) that do not reduce commitments in the quality assurance program previously accepted by the NRC. Changes to the quality program that do not reduce commitments in the program can be made without prior NRC approval.

During calendar year 2015, we revised the RSQM to reflect changes to the corporate organization. Specific portions of the RSQM that were revised include:

1. Quality Assurance Policy

2. RSQM Chapter I "Organization"

3. RSQM Chapter II "Quality Assurance Program"

4. RSQM Chapter XVIII "Audits"

5. Appendix A "10 CFR 50 Administrative Controls" The safety evaluation associated with these changes concluded that these changes ¶ did not reduce any commitments and did not require prior NRC approval. The RSQM continues to implement the requirements of 10 CFR Part 50, Appendix B and 10 CFR Part 72, Subpart G. The individuals and organizations performing quality assurance functions continue to have sufficient authority, organizational freedom, and independence from cost and schedule issues.

/

Rancho Seco Nuclear Generating Station I14440 Twin Cities Road I Herald, GA 95638-9799 I 916.452.3211 Ismud.org *)Ppe'

DPG 16-002 The document is being provided in its entirety because it does not include a List of Effective Pages. However, changes are indicated by "revision bars" in the left margin to aid in review.

If you or members of your staff have any questions requiring additional information or clarification, please contact me at (916) 732-4817.

Sincerely,

.Einar T. Ronningen Manager, Rancho Seco Assets (RJIDTIBG)

Enclosures - (1) Rancho Seco Quality Manual, RSLBD-01O Rev.2 Cc: NRC, Region IV 2

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 1 OF 77 IEFFECTIVE DATE: 04/20/2015 REASON FOR CHANGE:

• Reflect current corporate organization and responsibilities REVISION

SUMMARY

• Revised QA policy Statement to Reflect current corporate organization and responsibilities

• Revised Section 4.0 of the RSQM to reflect new titles within the organization.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 2 OF 77 QUALITY ASSURANCE POLICY The Sacramento Municipal Utility District's (SMUD) policy regarding quality assurance at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72), is as follows:

I. Organizations involved in QA Class 1 activities and the other Program Activity Areas specified in Rancho Seco Quality Manual (RSQM)Section II, Attachment Il-1, shall be structured, managed, and operated to provide compliance with the RSQM. Procedures shall be prepared that implement the activities required to safely operate the Rancho Seco nuclear facility and achieve the following objectives:

a. Comply with government regulations and established SMUD management policies, applying a systematic, disciplined, and uniform approach to quality assurance.

b. Provide facilities designed, modified, constructed, tested and operated in accordance with specified requirements with reasonable assurance that failures or malfunctions will not cause undue risk to public health and safety.

c. Ensure prompt identification and resolution of actual and potential problems in design, procurement, construction, testing, operations, maintenance, and modification of the structures, systems, and components associated with QA Class 1 activities or other applicable Program Activity Areas specified in RSQM Section II, Attachment Il-i.

Ill. The RSQM and implementing procedures constitute the Rancho Seco Quality Assurance Program (QAP). The QAP applies to activities, plans, and programs affecting the operation and the quality of structures, systems, components, and services addressed in the RSQM. The QAP will be implemented by organizations responsible for achieving and verifying quality assurance.

IV. The Chief Generation and Grid Assets Officer has delegated the responsibility and authority for developing the QAP to the Director, Power Generation and executing the QAP to the Director, Audit Services. Any conflicts or questions involving interpretation of the requirements or resulting from the implementation of the QAP must be referred to the Director, Audit Services.

Chris Moffitt Claire Rogers Frankie McDermott Director, Power Generation Director, Audit Services Chief Generation and Grid Assets Officer

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 3 OF 77 Table of Contents I. ORGANIZATION 1.0 PURPOSE ................................................................. 9

2.0 REFERENCES

............................................................ 9 3.0 POLICY .................................................................... 9 4.0 ORGANIZATION AND REQUIREMENTS............................. 10 5.0 RESPONSIBILITIES .................................................... 11 II. QUALITY ASSURANCE PROGRAM 1.0 PURPOSE................................................................ 12

2.0 REFERENCES

........................................................... 12 3.0 POLICY................................................................... 12 4.0 GENERAL REQUIREMENTS........................................... 13 5.0 RESPONSIBILITIES .................................................... 15 6.0 ATTACHMENTS......................................................... 15 I1-1 Application of Rancho Seco Quality Assurance Program Criteria ........ 16 11-2 Regulatory Commitments................................................18 11-3 Exceptions .............................................................. 20 II1. DESIGN CONTROL 1.0 PURPOSE................................................................ 27

2.0 REFERENCES

........................................................... 27 3.0 POLICY................................................................... 27 4.0 GENERAL REQUIREMENTS........................................... 28 5.0 RESPONSIBILITIES .................................................... 30

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 4 OF 77 IV. PROCUREMENT DOCUMENT CONTROL 1.0 PURPOSE................................................................ 31

2.0 REFERENCES

........................................................... 31 3.0 POLICY................................................................... 31 4.0 GENERAL REQUIREMENTS....................................... 31 5.0 RESPONSIBILITIES .................................................... 33 V. INSTRUCTIONS, PROCEDURES. AND DRAWINGS 1.0 PURPOSE................................................................ 35

2.0 REFERENCES

........................................................... 35 3=0 POLICY ................................................................... 35 4.0 GENERAL REQUIREMENTS........................................... 35 5.0 RESPONSIBILITIES .................................................... 36 VI. DOCUMENT CONTROL 1.0 PURPOSE............................................................. 37

2.0 REFERENCES

........................................................... 37 3.0 POLICY................................................................... 37 4.0 GENERAL REQUIREMENTS........................................... 37 5.0 RESPONSIBILITIES .................................................... 38

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 5 OF 77 VII. CONTROL OF PURCHASED MATERIAL. EQUIPMENT. AND SERVICES 1.0 PURPOSE ........................................................... 39

2.0 REFERENCES

........................................................... 39 3.0 POLICY................................................................... 39 4.0 GENERAL REQUIREMENTS ......................................... 39 5.0 RESPONSIBILITIES .................................................... 41 VIII. IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. &

COMPONENTS 1.0 PURPOSE................................................................ 42

2.0 REFERENCES

........................................................... 42 3.0 POLICY................................................................... 42 4.0 GENERAL REQUIREMENTS........................................... 42 5.0 RESPONSIBILITIES .................................................... 43 IX. CONTROL OF SPECIAL PROCESSES 1.0 PURPOSE............................................................... 45

2.0 REFERENCES

........................................................... 45 3.0 POLICY................................................................... 45 4.0 GENERAL REQUIREMENTS........................................... 45 5.0 RESPONSIBILITIES .................................................... 46

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-01O REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 6 OF 77 X. INSPECTION 1.0 PURPOSE................................................................ 47

2.0 REFERENCES

................ ........................................... 47 3.0 PO LIC Y ......................... ...................................... 47 4.0 GENERAL REQUIREMENTS........................................... 47 5.0 RESPONSIBILITIES .................................................... 49 XI. TEST CONTROL 1.0 PURPOSE................................................................ 50

2.0 REFERENCES

........................................................... 50 3.0 POLICY................................................................... 50 4.0 GENERAL REQUIREMENTS........................................... 50 5.0 RESPONSIBILITIES .................................................... 52 XII. CONTROL OF MEASURING AND TEST EQUIPMENT 1.0 PURPOSE................................................................ 53

2.0 REFERENCES

........................................................... 53 3.0 POLICY................................................................... 53 4.0 GENERAL REQUIREMENTS........................................... 53 5.0 RESPONSIBILITIES .................................................... 54

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 7 OF 77 XIII. HANDLING. STORAGE. AND SHIPPING 1.0 PU R PO SE ................... ............................................. 55

2.0 REFERENCES

................ ........................................... 55 3.0 POLICY................................................................... 55 4.0 GENERAL REQUIREMENTS........................................... 55 5.0 RESPONSIBILITIES .................................................... 56 XIV. INSPECTION. TEST. AND OPERATING STATUS .

1.0 PU R PO SE ................... ............................................. 57

2.0 REFERENCES

........................................................... 57 3.0 PO LIC Y ..................... .............................................. 57 4.0 GENERAL REQUIREMENTS........................................... 57 5.0 RESPONSIBILITIES .................................................... 58 XV. NONCONFORMING MATERIALS. PARTS. OR COMPONENTS 1.0 PU RPO SE ................................................................ 59

2.0 REFERENCES

................ ........................................... 59 3.0 POLICY...................,................................................ 59 4.0 GENERAL REQUIREMENTS........................................... 59 5.0 RESPONSIBILITIES .................................................... 60

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 8 OF 77 XVI. CORRECTIVE ACTION 1.0 PU R POSE ................................................................ 61

2.0 REFERENCES

........................................................... 61 3.0 POLICY .............................................................. 61 4.0) GENERAL REQUIREMENTS........................................... 61 5.0 RESPONSIBILITIES ................................................ 62 XVII. QUALITY ASSURANCE RECORDS 1.0 PURPOSE ................................................................ 63

2.0 REFERENCES

........................................................... 63 3.0 PO LIC Y ..................... .............................................. 63 4.0 GENERAL REQUIREMENTS........................................... 63 5.0 RESPONSIBILITIES .................................................. 64 XVIII. AUDITS 1.0 PURPOSE ............................................................ 65

2.0 REFERENCES

........................................................... 65 3.0 PO LIC Y ..................... .............................................. 65 4.0 GENERAL REQUIREMENTS........................................... 65 5.0 RESPONSIBILITIES .................................................... 66 6.0 AUDITS AND AUDIT FREQUENCIES................................. 67 Appendix A 10 CFR 50 ADMINISTRATIVE CONTROLS ....................... 69

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 9 OF 77 I. ORGANIZATION 1.0 PURPOSE This section describes the Sacramento Municipal Utility District (SMUD) organization and personnel responsible for establishing, implementing, and verifying the Quality Assurance Program (QAP) at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS) licensed under 10 CFR Part 50 and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) licensed under 10 CFR Part 72.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion I, Organization 2.2 ANSI N45.2-1 971, Section 3, Organization 2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.4 Rancho Seco Quality Manual, Appendix A 2.5 10 CFR 71.103, Quality Assurance Organization 2.6 10 CFR 72.142, Quality Assurance Organization 3.0 POLICY 3.1 The establishment and implementation of the Rancho Seco QAP, which is comprised of this Rancho Seco Quality Manual (RSQM) and the RSQM implementing procedures, shall be SMUD's responsibility. Some QAP functions may be delegated to other SMUD approved external organizations, but overall responsibility for the QAP remains with SMUD.

3.2 Definitive lines of authority, responsibility, and communication shall be established for those organizations involved in the QAP.

3.3 Quality Assurance personnel assigned to the Rancho Seco nuclear facility have defined responsibilities and organizational freedom to identify problems that affect quality; to initiate, recommend, or provide solutions; and to verify implementation of solutions. They have the authority to initiate action to stop unsatisfactory work pending implementation of necessary corrective action to bring the unsatisfactory conditions into conformance.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 10 OF 77 3.4 The organizational structure and functional responsibility assignments shall be such that attainment of program objectives is accomplished by individuals or groups who inspect, examine, audit or otherwise verify conformance to established requirements, and who are independent of the individuals or groups who performed the original activity.

4.0 ORGANIZATION AND REQUIREMENTS 4.1 The General Manager (GM) through the Chief Generation and Grid Assets Officer shall have corporate responsibility for overall safe operation of the Rancho Seco nuclear facility and shall take any measures needed to ensure acceptable performance of the staff in providing long term monitoring of the remaining radioactive waste.

4.2 The Manager, Rancho Seco Assets reports directly to the Director, Power Generation. The Manager, Rancho Seco Assets ensures that the Rancho Seco nuclear facility is properly staffed and adequately budgeted to ensure,*

staff can safely carry out their responsibilities. The Manager, Rancho Sec0.

Assets also coordinates quality concerns with the Quality Assurance group.

The Manager, Rancho Seco Assets is responsible for the safe and reliable operation of RSNGS, pursuant to 10 CFR Part 50, and the ISFSI, pursuant to 10 CER Part 72. The Manager, Rancho Seco Assets has the responsibility and authority to implement the QAP and ensure optimum quality performance of the Rancho Seco nuclear facility...

The Manager, Rancho Seco Assets is responsible for the administrative  :

actions necessary to ensure that the QAP is implemented by the groups under his direction. To this extent, the Manager, Rancho Seco Assets shall maintain continuing involvement in quality matters and shall assess the scope, status, implementation, and effectiveness of the QAP through the review of Quality Assurance Audits and Surveillances.

4.3 The Director, Audit Services, through the Principal Quality Engineer, is responsible for the Rancho Seco nuclear quality assurance program. The Audit and Quality Services group is independent from operating pressures or other lines of authority, and ensures an active QAP is implemented at the Rancho Seco nuclear facility in accordance with regulatory requirements.

The Audit and Quality Services group has the authority to take any issue concerning the quality of operations at the Rancho Seco nuclear facility to the Director, Power Generation.

4.4 The Audit and Quality Services group shall have sufficient authority and organizational freedom to identify problems that affect quality, recommend

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 11 OF 77 solutions, and verify implementation of solutions, as appropriate.

Commensurate with this responsibility is the authority to initiate action to stop unsatisfactory work pending correction of the unsatisfactory condition.

Corporate and on-site organizational responsibilities are described in greater detail in Rancho Seco Administrative Procedure RSAP- 0101. Specific duties and responsibilities for organizations whose activities affect quality are described in RSQM Sections II through XVIII and Appendix A.

The Manager, Rancho Seco Assets advises the Director, Power Generation on matters related to the safety of operations at the Rancho Seco nuclear facility.

The Manager, Rancho Seco Assets performs safety reviews and provides onsite management oversight of Rancho Seco nuclear facility activities.

The Manager, Rancho Seco Assets is responsible for reviewing all Potential;:

Deviations from Quality (PDQ) to determine if a condition is a Deviation from?:

Quality (DQ) and requires determination of the cause, extent, remedial I corrective actions, and actions to prevent recurrence. The Manager, Rancho Seco Assets reviews and approves DQ dispositions and assigns corrective I actions identified in DQ dispositions. The Manager, Rancho Seco Assets also determines whether a PDQ is potentially reportable pursuant to 10 CFR 21.

5.0 GENERAL RESPONSIBILITIES The nuclear organization is involved in the long term monitoring of the Rancho

• Seco nuclear facility and is responsible for describing and clearly defining the duties and authority of individuals whose work affects quality. RSAP-01 01 defines the Rancho Seco nuclear facility organization and the responsibilities associated with each onsite work group. Each work group has the responsibility to ensure that their procedures implement QAP requirements.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD.-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 12 OF 77 i1. QUALITY ASSURANCE PROGRAM 1.0 PURPOSE The purpose of this section is to describe the Rancho Seco Quality Assurance Program (QAP) implemented at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR

50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCES

2.1 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program 2.2 ANSI N45.2-1971, Section 2, Quality Assurance Program ,

2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.4 10 CFR 71, Subpart H, Quality Assurance Requirements for Packaging and Transportation of Radioactive Material 2.5 10 CFR 72, Subpart G, Quality Assurance Requirements for, the Independent Storage of Spent Nuclear Fuel 2.6 NRC Form 311, Quality Assurance Approval for Radioactive Material Packages, Approval No. 0489 3.0 POLICY The QAP described herein is designed to ensure compliance with the requirements of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" including the requirements of applicable NRC Regulatory Guides and ANSI Standards.

Also, the QAP is designed to fulfill the quality requirements for (1) the use of radioactive material transport packages and (2) the operation of the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) in accordance with 10 CFR 71.101(f) and 10 CFR 72.140(d), respectively.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 13 OF 77 4.0 GENERAL REQUIREMENTS 4.1 This Rancho Seco Quality Manual (RSQM) is organized to present the 18 quality criteria in the order they are addressed in 10 CFR 50, Appendix B. The RSQM states the Rancho Seco policy for each criterion and describes how controls pertinent to each criterion are to be carried out.

4.2 In accordance with 10 CFR 50.54(a), SMUD submits an annual report to the Nuclear Regulatory Commission (NRC) regarding RSQM changes that do not reduce the commitments previously accepted by the NRC. Also, in accordance with 10 CFR 50.54(a), SMUD submits RSQM changes that reduce commitments previously accepted to the NRC for their review and approval prior to implementation.

4.3 The QAP is implemented by organizations responsible for achieving quality and by organizations responsible for verifying quality.

4.4 Engineering identifies the Quality Assurance (QA) classification of structures, systenis, and components (SSCs) commensurate to their importance to safety.

4.5 Quality Assurance classification 1 (QA Class 1) is assigned to SSCs that are considered safety-related in accordance with 10 CFR 50, Appendix B.

4.5.1 The QA Class I assignment includes 10 CFR 72 (ISFSl) and 10 CFR 71 (Transportation Package) SSCs as specified in RSAP-0302.

4.5.2 All 18 elements of the 10 CFR 50, Appendix B quality criteria apply to activities affecting QA Class I SSCs during operation, maintenance, testing, and modifications.

4.6 Some 10 CFR 50, Appendix B quality criteria apply to non-QA Class 1 programs and activities such as radiation protection, emergency preparedness, radioactive waste handling and shipping, fire protection, facility operations, environmental monitoring, security, training, and 10 CFR 71/72 important-to-safety, as indicated in RSQM-Section II, Attachment Il-I.

4.6.1 Engineering identifies thel0 CFR 71 and 10 CFR 72 non-QA Class 1 SSCs that are important-to-safety in accordance with RSAP-0302.

RANCHO SEWO LIUL;NSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 14 OF 77 4.6.2 SMUD activities performed under 10 CFR 71 shall be limited to procurement, maintenance, repair, and use as authorized by the NRC Quality Assurance Program Approval for Radioactive Material Packages (NRC Form 311; Approval Number 0489).

4.7 Attachment Il-I indicates the minimum QAP criteria that must be applied to specific Program Activity Areas.

4.8 Attachments 11-2 and 11-3 tabulate the NRC regulatory guides and ANSI standards, with exceptions and applicable revisions, that SMUD is committed to meeting as part of its QAP.

4.9 Activities associated with the safe operation of the Rancho Seco nuclear facility are accomplished under controlled conditions.

Preparations for such activities include confirmation that prerequisites have been met.

4.11 Development, control, and use of computer programs associated-with the design and safe operation of the Rancho Seco nuclear facility are subject to appropriate controls.

4.12 Training programs shall be established to ensure personnel responsible for performing and verifying activities that affect quality have the required proficiency and qualifications to perform the assigned tasks.

4.13 QAP Policy/Procedures/Instructions:

a. The QAP is documented in written policies, procedures, and .

instructions. The overall policies and general requirements are outlined in the RSQM. Specific details related to implementation of the established QAP policies are contained in Rancho Seco Administrative Procedures (RSAPs). Organizations responsible for performing QAP functions shall prepare additional implementing procedures as necessary. Quality reviews RSAPs to ensure RSQM requirements are accomplished in a controlled manner.

b. Quality is responsible for RSQM preparation, issuance, and control.

The RSQM, including any changes, supplements, or attachments, is issued and maintained as a controlled document.

c. Quality and the Site Manager shall review and approve proposed RSQM changes.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 15 OF 77 4.14 Resolution of Differences:

RSQM requirements take precedence over differing quality requirements specified in other work group procedures until Quality evaluates the issue and determines which requirements must be modified.

Questions or disputes involving RSQM interpretation or implementation must be referred to Quality for resolution.

4.15 Packaging and Transportation of Radioactive Material:

The QAP shall be applied to packaging and transportation of radioactive material as specified in References 2.4 and 2.6.

5.0 RESPONSIBILITIES General organizational responsibilities are described in RSQM Section I, ORGANIZATION 6.0 ATTACHMENTS Il-I, Application of Rancho Seco Quality Assurance Program Criteria 11-2, Regulatory Commitments 11-3, Exceptions

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 16 OF 77 Attachment I1-1 (Page 1 of 2)

APPLICATION OF RANCHO SECO QUALITY ASSURANCE PROGRAM (QAP) CRITERIA (A, B,C)

An 'X' means application of the RSQM requirements associated with the QAP Criteria is required.

(A)

(B) No 'X' means application of the RSQM requirements associated with the QAP Criteria is optional.

(C) RSQM implementing details are provided in the RSAPs and other QAP implementing procedures._______

QAP'CRITERIA

Program Activity Areas_____ __efrn s 4,I I_1 Ill IV V VIl VIIJ VIIIl IX X Xl_ XIIl XIIIl XIV XV XV.I XVII XVIII References Safety Related / 10 CFR 71/72 ISFSI TS 5.4.1k Important-to-Safety, Category A X X X X X X X X X X X X X X X X X X RSQM, APP. A, (QA Class 1) 10 CFR 50, APP. B

____ ____RSAP-0302, Alr. 6 Facility Operations (License ISFSI TS 5.4.1k Condition and Tech. Spec. x x X x X X x X X Xx RSQM Section XVllI Compliance) ___10 CFR 50/72 Licenses ISF5l TS 5.4,1k Radiation Protection X X X(2 ) X X X X X X 10OCFR 20

_______ ___ _____RSQM, APP. A Radioactive Effluent Control ISFS1 TS 5.4.1k Program (RECP) (3) X X X X X X X X X X Reg. Guide 4.15 RSQM, APP. A

______________________ _____10 CFR 50, APP. I Radiological Environmental ISFSI TS 5.4.1k 14 Monitoring Program (REMP) (3) X X X ) X X X X X X X Reg. Guide 4.15

____________________RSQM, APP. A Radwaste Handling and ISF51 TS 5.4.1k Shipping (Including Process X X X X X X X X X X X X X 10 CFR 71 Control Program) ()10 CFR 20.2006(d)

RSAP-0302, ATT. 6

____________________RSQM, APP. A ISFSI TS 5.4.1k & 5.7 Fire Protection (6 X X X X X X X X RSQM, APP. A

__________________________Decommissioning Order ISFSI TS 5.4.1k Security (7) X X X X X X X X 10OCFR 72.44 &186 10 CFR 73 ISFSI TS 5.4.1k Emergency Preparedness X X X X X X X X 10 CFR 50.54(t) 10 CFR 50, APP. E

__________RSOM, APP. A ISFS1 TS 5.4.1k Training X X X X X X X X 10OCFR 72.190

____ RSQM, APP. A 10 CFR 71/72 Important-to- ISFIS TS 5.4.1k Safety, Category B &C 5( X X X X X X X X X X X X X X RSAP-0302,ATT. 6 (QA Class 2) 10 CFR 72.3 & 72.140

__________ ____ ___ _____ ___________10 CFR 71.101 Attachment I1-1 (Page 1 of 2)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 17 OF 77 Footnotes:

(1) 10 CFR 50, Appendix B, Quality Criteria and corresponding RSQM section titles:

I. Organization II. Quality Assurance Criteria III. Design Control IV. Procurement Document Control V. Instruction, Procedures, and Drawings VI. Document Control VII. Control of Purchased Material, Equipment, and Services VIII. Identification and Control of Materials, Parts, and Components IX. Control of Special Processes X. Inspection XI. Test Control XII. Control of Measuring and Test Equipment XIII. Handling, Storage, and Shipping XIV. Inspection, Test, and Operating Status XV. Nonconforming Materials, Parts, or Components XVI. Corrective Action XVII. Quality Assurance Records XVIII. Audits (2) Design Control as applied to permanent protective shielding.

(3) Rancho Seco applies the NRC Regulatory Guide 4.15 QA/QC program to the RECP and REMP. This Regulatory Guide 4.15 program meets the applicable 10 CFR 50, Appendix B QAIQC program requirements.

(4) As applied to environmental monitoring laboratory analysis services.

(5) As applied to 10 CFR 71 activities authorized pursuant to NRC Form 311, "Quality Assurance Approval for Radioactive Material Packages,"

Approval No. 0489. (Refer to RSQM Section II, Steps 4.3.2 and 4.4.2)

(6) No Fire Protection equipment or services falls under the QAP.

ATTACHMENT Il-1 (Page 2 of 2)

REGULATORY COMMITMENTS

.RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 18 OF 77 SMUD commits to the requirements of the regulations and industry standards listed below with any exceptions identified in Attachment 11-3.

Document Revision/Date Title 1 Regulatory Guide 9/75 Personnel Selection and Training 1.8 Per ISFSI Tech. Spec. 5.3 2 Safety Guide 28 6/7/72 Quality Assurance Requirements for ANSI N45.2 1971 Nuclear Power Plants 3 Regulatory Guide 8/85 Supplementary Requirements for Quality 1.28 1983 Assurance Records (See Attachment 11-3, ANSI/ASME NQA- Exception No. 1)

Supplement 17S-1 4 Safety Guide 30 8/11/72 Quality Assurance requirements for the ANSI N45.2.4 1972 installation, Inspection, and Testing of Instrumentation and Electrical Equipment (See Attachment I1-3, Exception No. 2) 5 Safety Guide 33 11/3/72 Administrative Controls for Nuclear Power Plants as Addressed in RSQM Appendix A 6Regulatory Guide 3/16/73 Quality Assurance Requirements for 1.37 1973 Cleaning Fluid Systems and Associated ANSI N45.2.1 Components of Water-Cooled Nuclear Power Plants (See Attachment 11-3, Exception No. 3) 7 Regulatory Guide 3/16/73 Quality Assurance Requirements for 1.38 1972 Packaging, Shipping, Receiving, Storage ANSI N45.2.2 and Handling of Items for Water-Cooled Nuclear Power Plants (See Attachment II-3, Exception No. 8) 8 Regulatory Guide 3/16/73 Housekeeping Requirements for Water-1.39 1973 Cooled Nuclear Power Plants (See ANSI N45.2.3 Attachment 11-3, Exception No. 4)

ATTACHMENT 11-2 (Page 1 of 2)

PANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 19 OF 77 9 Regulatory Guide 6/73 Quality Assurance Requirements for 1.54 1972 Protective Coatings Applied to Nuclear ANSI N101.4 Facilities 10 Regulatory Guide 9/80 Qualification of Nuclear Power Plant 1.58 1978 Inspection, Examination, and Testing ANSI N45.2.6 Personnel (See Attachment 11-3, Exception No. 5) 11 Regulatory Guide 10/73 Quality Assurance Requirements for the 1.64 1974 Design of Nuclear Power Plants (See ANSI N45.2.11 Attachment 11-3, Exception No. 6) 12 Regulatory Guide 2/74 Quality Assurance Terms and Definitions 1.74 1973 (See Attachment 11-3, Exception No. 7)

ANSI N45.2.10 13 Regulatory Guide Rev. 2 Quality Assurance Requirements for 1.94 1978 Installation, Inspection, and Testing of ANSI N45.2.5 Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants 14 Regulatory Guide 6/76 Quality Assurance Requirements for 1.116 1975 Installation, Inspection, and Testing of ANSI N45.2.8 Mechanical Equipment and Systems 15 Regulatory Guide 11/77 Fire Protection Guidelines for Nuclear 1.120 Power Plants 16 Regulatory Guide 7/77 Quality Assurance Requirements for 1.123 Control of Procurement Items and Services 1976 ANSI N45.2.13 for Nuclear Power Plants 17 Regulatory Guide 1/79 Auditing of Quality Assurance Programs 1.144 for Nuclear Power Plants 1977 ANSI N45.2.12 18 Regulatory Guide 8/80 Qualification of Quality Assurance Program 1.146 1978 Audit Personnel for Nuclear Power Plants ANSI N45.2.23 ATTACHMENT 11-2 (Page 2 of 2)

EXCEPTIONS:

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 20 OF 77 EXCEPTION NO. 1: Regulatory Guide 1.28/NQA-1, Supplement 17S-1 SMUD complies with the recommendations of this regulatory guide with the following clarifications:

With regard to Section 2.4 of Supplement 17S-1 titled Index: The phrase "an index" is clarified to mean a collection of documents or indices which, when taken together, supply the information attributed to "an index" in the standard.

The specific location of a record "within a storage area" may not be delineated (e.g., the specific location within a computer record file may not be constant; further, SMUD may utilize a computer assisted random access filing system where such location could not be readily "documented," or would such a location be "relevant.") The storage location will be delineated, but where file locations change with time, the specific location of a record within that file may not always be documented.

With regard to Section 4.3, Supplement 17S-1 titled Safekeepincq: Routine general office and nuclear site security systems and access controls are provided: No special security systems are required to be established for record storage areas.

With regard to Section 4.4, Supplement 17S-1, titled Facility: This Section provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: "Records completed but not yet transferred for permanent storage may be temporarily stored in one-hour fire rated file cabinets. In general, records shall not be maintained in such temporary storage for more than four months after completion without being microfilmed or placed in permanent storage. Open-ended documents revised or updated on a more-or-less continuing basis over an extended period of time (e.g.

personnel qualification and training documents, equipment history cards) which are cumulative in nature (e.g. nonconforming item logs and control room log books) shall become QA records when they are issued as a specific revision (e.g.

the master audit schedule); when they are filled-up or discontinued (e.g. log books or equipment history cards); on a predefined periodic basis when the completed portion of the ongoing document shall be transferred to records control as a "record" (e.g. training and qualification records).

ATTACHMENT 1I-3 ('Pacie 1 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 21 OF 77 EXCEPTION NO. 2: Regulatory Guide 1.30/ANSI N45.2.4-.72 Specific clarifications for ANSI N45.2.4-1 972 are indicated below by section:

Section 1.4 Definitions in this standard that are not included in ANSI N45.2.10 shall be used; all definitions which are included in ANSI N45.2.10 shall be used as clarified in SMUD commitment to Regulatory Guide 1.74.

Section 2.1 Planninqi requirements, as determined by engineering, shall be incorporated into modification procedures.

Section 2.3 Procedures and Instructions shall be implemented as set forth in Sections II, III, V, X and Xl of this program and by compliance with the Rancho Seco Plant Technical Specifications and Regulatory Guide 1.33 (ANSI N18.7).

Section 2.4 Results will be implemented as set forth in Sections X, Xl, and XVII of this program and by compliance with ANSI N18.7 in lieu of the requirements set forth here.

Section 2.5.2 Calibration and Control covers three classes of instrumentation used by SMUD: (1)

M&TE (portable measuring instruments, test equipment, tools, gages, and non-destructive test equipment used in measuring and inspecting safety-related structures, systems, and components); (2) reference standards (primary, secondary, transfer, and working); and (3) permanently installed process instrumentation (PI).

With respect to the first sentence, M&TE and reference standards shall be included in calibration program and shall either be calibrated at prescribed intervals or shall be calibrated prior to use. With respect to the last sentence, personnel shall be trained and procedures shall require that the calibration sticker shall be reviewed to determine calibration status prior to use: This label shall be considered to clearly identify equipment that is out of calibration.

Lack of a sticker shall require record review and affixing a new sticker based on calibration data. M&TE and reference standards shall comply with sentences 2, 3, and 4.

ATTACHMENT II-3 (Paaie 2 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 22 OF 77 With respect to the third sentence, SMUD uniquely identifies each safety-related component of permanently installed process instrumentation. This identification provides traceability to calibration data. These actions are SMUD's alternative to the tagging or labeling of items to indicate the calibration date and the identity of the person who performed the calibration. Permanently installed process instrumentation shall comply with sentences 1, 2, and 5.

Section 3 Pre-construction Verification will be implemented as follows: (1) is required only for modifications, (2) no special checks are required to be made by the person withdrawing a replacement part from the warehouse equivalent controls are ensured by compliance with Regulatory Guide 1.38 (ANSI N45.2.2) as set forth in this table, and, (3) shall be complied with as determined by engineering, by individual technicians as part of the modification process.

Section 5.1 Inspections, including subsections 5.1.1, 5.1.2, and 5.1.3, will be implemented as set forth in Section X of this program. The inspection program will incorporate,= as determined by engineering and Quality those items listed in these subsections.

Section 5.2 Tests, including subsections 5.2.1 through 5.2.3, will be implemented as set forth in Sections IIl and Xl of this program. In some cases Surveillance testing may be used to meet the appropriate requirements of this section.

Section 6 Post Construction Verification is not generally considered applicable at operating facilities because of the scope of the work and the relatively short interval between installation and operation. Where considered necessary by engineering andl Quality, the elements described in this Section will be used in the development and implementation of inspection and testing programs as describe in Sections III, X, and Xl of this program.

Section 7 Data Analysis and Evaluation will be implemented as stated herein after adding the clarifying phrase "Where used" at the beginning of that paragraph.

ATTACHMENT 11-3 (Paae 3 of 7)

.RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 23 OF 77 EXCEPTION NO. 3: Regulatory Guide 1.37/ANSI N45.2.1-73 Specific clarifications for this Regulatory Guide and ANSI N45.2.1-1 973 are indicated below:

With regard to Paragraph C.3 of Regulatory Guide 1.37: The water quality for final flushing of fluid systems and associated components shall be at least equivalent to the quality of the operating system water, except for the oxygen and nitrogen content; but this does not infer that chromate's or other additives, normally in the system water, will be added to the flush water.

With regard to Paragraph 0.4 of Regulatory Guide 1.37: Expendable materials, such as inks and related products; temperature indicating sticks; tapes; gummed labels; wrapping materials (other than polyethylene); water soluble dam materials; lubricants; NDT penetrant materials and couplants, desiccants, which contact stainless steel or nickel alloy surfaces shall not contain lead, zinc, copper, mercury, cadmium and other low melting points metals, their alloys or compounds as basic and essential chemical constituents. No more than 0.1 percent (1,000 ppm) halogens will be allowed where such elements are leachable or where they could be released by breakdown of the compounds under expected environmental conditions.

With regard to Section 5 of ANSI N45.2.1-1 973 titled Installation Cleaning: The recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded, as determined by Engineering or Chemistry.

EXCEPTION NO. 4: Regulatory Guide 1.39/ANSI N45.2.3-73 .

Specific classifications for ANSI N45.2.3-73 are indicated for specific sections below:

Section 1.4 Definitions: Definitions in this standard that are not included in Regulatory Guide 1.74 (ANSI N45.2.10) will be used. All definitions that are included in ANSI N45.2.10 will be used as clarified in SMUD's commitment to Regulatory Guide 1.74.

Section 2.1 ..

Planning: SMUD may choose not to utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with program requirements in the areas of housekeeping, plant and personnel safety, and fire protection.

ATTACHMENT II-3 ('Pane 4 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 24 OF 77 Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented cleanliness inspections that will be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will be established when the reactor system is opened for inspection, maintenance, modification or repair.

Additional housekeeping requirements will be implemented as required for control of radioactive contamination.

Section 2.2 Procedures and Instructions: Appropriate procedures will be written and implemented.

Section 3.2 Control of Facilities: SMUD may choose not to utilize the five-level zone designation system, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with program requirements in the areas of housekeeping, plant and personnel safety, and fire protection.

Cleanliness will be maintained, consistent with the work being performed, 'so as to prevent the entry of foreign material into safety-related systems. This will include, as a minimum, documented cleanliness inspections that will be performed prior to system closure. As necessary, (e.g. the opening is larger than the tools being used) control of personnel, tools, equipment, and supplies will be established when the reactor system is opened for inspection, maintenance, modification or repair.

Additional housekeeping requirements will be implemented as required for control of radioactive contamination.

EXCEPTION NO. 5: Regulatory Guide 1.58/ANSI N45.2.6 SMUD complies with the recommendation of the regulatory guide with the following clarification:

With regard to Paragraph C.5: The Level II1 function of inspection planning, reviewing and concurring with inspection, examination and testing procedures is performed by designated individuals from the Quality & Industrial Safety Department.

ATTFACHMENT II-3 (Paae 5 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 25 OF 77 EXCEPTION NO. 6: Regulatory Guide 1.64/ANSI N45.2.11 SMUD complies with the recommendation of the regulatory guide with the following clarification:

With regard to Paragraph C.2: In exceptional circumstances, the designer's immediate supervisor can perform design verification, provided:

1. The supervisor is the only technically qualified individual available.

2. The need is individually documented and approved in advance by the supervisor's management.

3. QA audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.

EXCEPTION NO. 7: Regulatory Guide 1.74/ANSI N45.2.10-73 SMUD complies with the recommendations of this regulatory guide with the following clarifications:

SMUD reserves the right to define additional words or phrases that are not included in this Standard. Such additional definitions will be documented in appropriate procedures.

In addition to the Standard's definition of "Inspection," SMUD will use the following definition when referring to activities that are NOT performed by QC personnel:

Examining, viewing closely, scrutinizing, looking over or otherwise checking activities.

Personnel performing these functions are not necessarily certified to Regulatory Guide 1.58 (ANSI N45.2.6).

When SMUD intends for Inspection to be performed in accordance with the QA Program by personnel certified as required by that program and for activities defined by "inspection" in ANSI N45.2.10, appropriate references to the plant QC organization or the procedures to be used for performing the activity will be made. If such references are NOT made, inspections are to be considered under the additional definition given above.

"Independent Verification": Verification by an individual other than the person who performed the operation or activity being verified that required actions have been completed. Such verification may not necessarily require confirmation of the action at the physical location if adequate remote indication of completion of action is available. In determining the acceptability of remote verification, the consequences of the action not being 100% completed and the validity of the remote indication for ATTACHMENT 11-3 (Pagje 6 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 26 OF 77 confirming the completion of the desired action will be considered. Examples include, but are not limited to: Verification of a breaker opening by observed remote breaker indication lights; verification of a set point (made with a voltmeter or ammeter for example) by observing the actuation of status or indicating lights at the required panel-meter indicated value; verification that a valve has been positioned by observing the starting or stopping of flow on meter indications or by remote valve positions indicating lights.

"Will": (Not defined in any ANSI Standard) - Means the same as "shall" except when used to denote simple futurity. When used to denote futurity, "will" is normally followed by "be".

EXCEPTION NO. 8: Regulatory Guide 1.38/ANSI N45.2.2 Section 2.7 Classification of Items - SMUD may choose not to utilize the four levels of item' classification, but will address packaging and storage requirements for. items based on the needs of individual items and manufacturers recommendation.

ATTACHMENT 11-3 (Pa~ie 7 of 7)

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 27 OF 77 III. DESIGN CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for control of design activities affecting applicable structures, systems, and components at the Rancho Seco nuclear station, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

In addition, this section defines the requirements for developing and implementing control measures that ensure design functions affecting the performance of operational, construction, and modification activities are carried out in a planned, controlled, and orderly manner and are in compliance with applicable regulatory commitments.

2.0 REFERENCES

2.1 10 CER 50, Appendix B, Criterion Ill, "Design Control" 2.2 10 CFR 50.59, Changes, Tests and Experiments 2.3 Regulatory Guide 1.64/ANSI N45.2.1 1, 1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (with exceptions noted in RSQM Section II) 2.4 ANSI N45.2, Section 4, Design Control 2.5 10 CFR 72.48, Changes, Tests, and Experiments 2.6 10 CFR 71.107, Package Design Control 2.7 10 CFR 72.146, Design Control 3.0 POLICY The requirements specified in this section apply to all organizations performing design functions for modifications, changes, replacement or addition of structures, systems, or components at the Rancho Seco nuclear facility.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 28 OF 77 4.0 GENERAL REQUIREMENTS Procedures shall be established and executed to control design activities.

Procedures covering design control activities shall include the following requirements:

4.1 Applicable design inputs such as design bases, regulatory requirements, codes and standards, methodology, and all assumptions with appropriate justifications are identified, documented, and correctly translated into design output documents such as specifications, drawings, procedures, or instructions.

4.2 Exceptions, waivers to or deviations from engineering requirements are documented and controlled.

4.3 Methods are specified for the selection and classification of suitable materials, parts, equipment, and processes used in meeting applicable requirements for structures, systems, and components.

Materials, parts, components, and equipment that are standard, commercial (off the shelf), or which have been previously approved for other similar applications are reviewed for suitability and appropriately classified.

4.4 Systematic methods are established for communicating and controlling the flow of related design information across the external and internal design interfaces, including any changes to the design information as the work progresses.

4.5 Interfaces between Engineering and other participating design organizations (either internal or external to SMUD) are identified and documented. This identification includes those organizations providing design inputs, design analyses, design specifications, and design verification for operational, construction and modification design activities.

4.6 Participating design organizations establish and describe the controlled methods for preparation, review, approval, release, distribution, and revision of documents (such as design analyses, specifications, drawings, reports) involving design interfaces.

4.7 Design control measures shall provide for verifying or checking the adequacy of design modifications or design changes. Acceptable verification methods include, but are not limited to, design reviews, alternate calculations, or qualification testing. If a test program is used to verify the adequacy of a

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 29 OF 77 design, it must include qualification testing of a prototype unit under the most adverse design conditions.

4.8 Computer program codes used for design calculations are certified for use and their use is specified.

4.9 Design verification is to be performed by competent individuals or groups other than those who performed the original design, but who may be from the same organization. The originator's supervisor may perform this verification provided the supervisor is the only technically qualified individual available and meets the appropriate clarification provisions of Reference 2.4. The results of the design verification efforts must be documented with the identification of the verifier clearly provided.

4.10 Provisions are specified for the control of design analyses such as; reactor physics, stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for in-service inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests.

4.11 Design problems that are identified during field installation or testing activities shall be documented and forwarded to Engineering for evaluation and resolution.

4.12 Design and specification changes, including field changes, receive the same degree of control and approval as the original design unless another qualified, responsible organization is specifically designated.

4.13 Errors and deficiencies in the design process, including computer programs that could adversely affect structures, systems, or components are documented and corrective action is taken to preclude repetition.

4.14 Proposed modifications or design changes which involve an Unreviewed Safety Question or a change to Rancho Seco nuclear facility Licenses or Technical Specifications are handled in accordance with 10 CFR 50.59, 10 CFR 72.48, and 10 CFR 71.107(c), as appropriate.

4.15 Modifications are reviewed by plant personnel for effect on plant operation prior to making the modification operational.

4.16 Design documents are reviewed for accessibility of equipment and components for in-service inspection, tests, maintenance or modifications.

4.17 Design and/or test documentation must be obtained from all suppliers on procurements of ASME code components used for replacement or modification to the Rancho Seco nuclear facility.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 I REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 30 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Engineering is responsible for implementing a design control process per this section and to:

a. Provide and control design change packages.

b. Ensure integrity and regulatory conformance of configuration control.

c. Provide plant configuration control including establishing and maintaining baseline documents.

d. Provide engineering support for facility computers.

e. Perform probabilistic analysis in support of plant design, when necessary.

f. Provide engineering support to the Rancho Seco nuclear organization.

g. Provide and maintain engineering procedures, standards and specifications and drawings.

h. Prepare and maintain the Master Equipment List (MEL) described in RSQM Section I1.

5.2 Quality Assurance is responsible for:

a. Review and concurrence of design control procedures.

b. Monitoring implementation of the design control program.

c. Auditing the design control program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 31 OF 77 IV. PROCUREMENT DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to control procurement documents for material, equipment, and services at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion IV, Procurement Document Control 2.2 ANSI N45.2-1 971, Section 5, Procurement Document Control 2.3 Regulatory Guide 1.123/ANSI N45.2.13-1976, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants 2.4 10 CFR 71.109, Procurement Document Control 2.5 10 CFR 72.148, Procurement Document Control 3.0 POLICY Procurement documents for applicable Rancho Seco nuclear facility materials, equipment, components/spares, or services shall include applicable technical requirements, quality requirements, regulatory requirements, and other provisions necessary to ensure that purchased items and services are adequately described to the supplier.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established and implemented to control the preparation, review, approval and issuance of procurement documents.

4.2 Procurement documents shall include provisions for the following, as applicable:

a. Description of item or service.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 32 OF 77

b. Identification of design specifications and technical requirements by reference to specific drawings, codes, regulations, industry standards, or other documentation, including the applicable revision thereto that describe the items or services to be furnished.

c. Identification of test, inspection, and acceptance requirements, and any special instructions and requirements for activities such as design, fabrication, identification, cleaning, erecting, packaging, handling, shipping, and extended storage.

d. Identification of applicable QAP criteria.

e. Applicability of 10 CFR Part 21.

f. Identification of the documentation, such as drawings, specifications, procedures, fabrication and inspection plans, inspection and test records, personnel and procedure qualifications, and chemical and physical test reports to be prepared and maintained by the supplier or contractor, and the requirement to submit this documentation to SMUD for review and approval.

g. Identification of those records to be retained, controlled, and maintained by the supplier or contractor and those to be delivered to SMUD at the time of shipment of the procured item.

h. SMUD's right of access to the supplier's facilities and records for inspection and audits.

i. Extension of applicable requirements to lower tier subcontractors and suppliers, including SMUD's right of access to facilities and records.

j. Supplier submittal of nonconforming items and SMUD approval for "Accept as is" or "Repair" dispositions of non-conformances.

k. SMUD's right to hold shipment if procurement document requirements, including those for documentation, have not been fulfilled.

4.3 Technical and quality review by qualified personnel and approval by designated individuals shall be performed prior to issuance of the procurement document. The review and approval shall be documented and available for verification.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 33 OF 77 4.4 Review and concurrence by Quality Assurance shall be performed to ensure adequacy of quality requirements and to verify that the requirements are correctly stated, inspectable, and controllable; that there are adequate acceptance and rejection criteria; and that the procurement documents have been prepared, reviewed, and approved in accordance with the requirements of the established procedures.

4.5 Revisions to procurement documents shall receive an equivalent review and approval as the original documents. Exceptions to this include changes in quantity, estimated price, cost codes, taxes, format or editorial changes that do not affect the quality of the item or service.

4.6 Procurement documents for spare or replacement parts for QA Class 1 structures, systems, or components shall specify procurement controls at least equivalent to those required for purchase of the original equipment.

4.7 Methods shall be established to ensure that the items received are traceable to procurement documents.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 General Services is responsible for:

a. Purchase items in conformance with procurement documents.

b. Purchase safety-related (QA Class 1) items from approved suppliers.

c. Arrange for suppliers to be placed on an Approved Suppliers List (ASL). (Refer to RSQM Section VII, step 4.2 regarding ASL)

d. Arrange for source inspection when specified on the procurement documents.

5.2 Engineering is responsible for:

Maintain a staff of qualified engineers who provide technical and quality requirements for purchasing safety-related (QA Class 1) items.

5.3 Quality Assurance is responsible for:

a. Review and concurrence of material management procedures.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010

+I REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 34 OF 77

b. Review and concurrence of procurement documents for safety-related (QA Class 1) items.

c. Auditing the procurement document control program per RSQM Section XVIII.

d. Developing and maintaining the ASL.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 35 OF 77 V. INSTRUCTIONS, PROCEDURES, AND DRAWINGS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that activities affecting the quality or safety of the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72), are described and accomplished in accordance with documented instructions, procedures, drawings, or other documents appropriate to the circumstances.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings 2.2 ANSI N45.2-1 971, Section 6, Instructions, Procedures, and Drawings 2.4 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.4 10 CFR 71.150, Instructions, Procedures, and Drawings 2.5 10 CFR 72.111, Instructions, Procedures, and Drawings 3.0 POLICY Activities affecting quality performance or operational safety at the Rancho Seco nuclear facility shall be described and implemented in accordance with documented instructions, procedures, and drawings.

4.0 GENERAL REQUIREMENTS 4.1 Written instructions, procedures, drawings, or other documents appropriate to the circumstances shall be prepared to provide measures for complying with the provisions of the QAP.

4.2 Instructions, procedures, or drawings shall include applicable quantitative and/or qualitative acceptance criteria for verifying that the activities have been satisfactorily accomplished.

4.3 Procedures shall be established for the review, approval, issuance, change, and use of documents that specify quality requirements such as

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 36 OF 77 instructions, procedures, drawings, and other documents that implement the QAP.

4.4 Activities affecting quality shall be accomplished in accordance with approved instructions, procedures, and drawings.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Rancho Seco management is responsible for ensuring activities that affect quality are described in instructions, procedures, and drawings.

5.2 Quality Assurance is responsible for performing audits to verify that any activities affecting quality are described in instructions, procedures and, drawings. Audits shall be conducted in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 37 OF 77 VI. DOCUMENT CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the issuance and control of documents that control activities affecting quality at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed pursuant to 10 CFR

50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion VI, Document Control 2.2 ANSI N45.2-1 971, Section 7, Document Control 2.3 ANSI N45.2.1 1-1 974, Section 7, Document Control 2.4 10 CFR 71.113, Document Control 2.5 10 CFR 72.152, Document Control 3.0 POLICY Applicable documents, including changes thereto, that prescribe activities affecting the quality operation at the Rancho Seco nuclear facility shall be issued and controlled in a manner that precludes the use of inappropriate or outdated documents.

4.0 GENERAL REQUIREMENTS 4.1 The responsible organization shall establish procedures that define responsibilities and delineate the sequence of actions to be accomplished in preparation, review, approval, and control of instructions, procedures, or drawings, or changes thereto.

4.2 Procedures that establish document control measures shall include:

a. Identification of documents to be controlled;

b. Identification of individuals or organizations responsible for the review, approval, issuance, and revision of documents;

PANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 38 OF 77

c. Criteria to ensure that adequate technical and quality requirements are incorporated prior to implementation;

d. Review of changes to documents by the same organizations that performed the initial review and approval or by the organizations designated in accordance with the applicable procedures.

4.3 Controlled documents, including changes, shall be issued and distributed to organizations noted on distribution lists so that proper and current documents are available as required, and obsolete or superseded documents are identified and not used for prescribed activities.

4.4 Master lists or equivalent means shall be used to identify the current revision of controlled documents and made available at work locations, as appropriate.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Site Document Control (SDC) is responsible for developing and implementing a document control program in accordance with this section.

5.2 Rancho Seco management is responsible for:

a. Complying with document review, approval, and revision authority defined in plant administrative procedures.

b. Ensuring Quality Assurance review of documents with quality assurance related aspects, as appropriate.

5.3 Quality Assurance is responsible for:

a. Reviewing and concurring with document control procedures.

b. Reviewing and concurring with prOcedures, instructions, or documents that implement the QAP to ensure compliance with applicable RSQM provisions.

c. Auditing the document control program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 39 OF 77 VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to ensure that material, equipment, and services purchased for the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72), conform to the procurement documents.

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services 2.2 ANSI N45.2-1 971, Section 8, Control of Purchased Material, Equipment,.

and Services 2.3 Regulatory Guide 1.123/ANSI N45.2.13-76, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants 2.4 10 CFR 71.115, Control of Purchased Material, Equipment, and Services 2.5 10 CFR 72.154, Control of Purchased Material, Equipment, and Services*

3.0 POLICY Measures shall be established to ensure that material, equipment, and services conform to the specified requirements of the related procurement documents.

4.0 GENERAL REQUIREMENTS 4.1 Control of purchased material, equipment, and Services shall include the following, as appropriate:

a. Source evaluation and selection of suppliers.

b. Objective evidence of quality furnished by the supplier.

c. Source inspection, audit, and/or surveillance activities.

....... I* tl I A ................

RANCHO SECO LICGN;51Nr. IBASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 40 OF 77

d. Examination of items or services upon delivery or completion.

4.2 Results of source evaluation and selection of suppliers shall be documented and retained on file.

4.3 Procedures for control of materials, equipment, and services shall address the following:

a. Responsibilities of departments performing supplier technical and quality evaluations, and the method of evaluation.

b. Inspection activities that specify the characteristics or processes to be witnessed, inspected or verified; the method of verification and the extent of documentation required; and the organization responsible for implementing the inspection.

c. Auditing to verify conformance and implementation to requirements of this policy. Source inspection and audits may not be necessary when conformance of an item to procurement requirements can be verified by receipt inspection, review of test reports, certified reports or other means specified by Quality Assurance.

d. Receipt inspection of supplier furnished items to ensure: (1) the proper identification of items on the receiving documentation, (2) that the items are inspected and judged acceptable in accordance with predetermined instructions prior to installation or use, (3) that inspection records or certificates of conformance are available at the plant site prior to installation or use of the items, and (4) that items accepted and released are identified as to their inspection status prior to storage or use.

e. Review, acceptance, and maintenance of records to ensure adequacy of documentation that identifies the purchased item, and that specific procurement requirements (e.g., codes, standards, specifications) have been met or satisfied.

f. Review and approval of documentation required to be submitted by the procurement documents (CMTR's, Certificate of Compliance, Procedures, Specifications, etc.).

g. Procurement control of spare or replacement parts for QA Class 1 systems to ensure compliance with requirements that are (1) equivalent to the original requirements or (2) specified by a properly reviewed and approved revision to the original requirements.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-O10 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 41 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Engineering is responsible for:

a. Ensuring quality and qualifications of parts and materials by (1) developing quality specifications and (2) storing parts and materials in accordance with regulatory requirements and in coordination with appropriate nuclear organization groups.

b. Ensuring regulatory compliance of materials and parts by managing procurement documentation and reviewing (and implementing, as appropriate) NRC and related parts/materials bulletins.

c. Examining items or services upon delivery or completion, as deemed necessary to supplement or replace formal inspection activities.

5.2 Quality Assurance is responsible for:

a. Developing and maintaining the ASL.

b. Performing required inspections, evaluations, and audits.

c. The review and concurrence with material management procedures.

d. Auditing the control of purchased material, equipment, and services per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 42 OF 77 VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, &

COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the identification and control of material, parts, and components for the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant tol10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion VIII, Identification and Control of Materials, Parts and Components 2.2 ANSI N45.2-1 971, Section 9, Identification and Control of Materials, Parts, and Components 2.3 10 CFR 71.117, Identification and Control of Materials, Parts, and Components 2.4 10 CFR 72.156, Identification and Control of Materials, Parts, and Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components are properly identified and controlled to preclude the use of incorrect or nonconforming items.

4.0 GENERAL REQUIREMENTS 4.1 Materials, parts, or components, including partially fabricated subassemblies and consumables, shall be identified so they can be related to their applicable drawing, specification, purchase document, and inspection records at any stage from initial receipt through fabrication/construction, installation, repair, modification, or use.

4.2 Identification controls, implementation procedures, and documentation shall be used to ensure that only correct and accepted items are used during all stages of construction, installation, and operation.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 43 OF 77 4.3 Unique identification of items is required, e.g., by part number, serial number, heat number, drawing identification number, or other traceable coding methods.

4.4 Identification is required to be maintained either on the item or on records traceable to the item. Physical identification such as by marking or tagging shall be used to the maximum extent practical.

4.5 When specified by codes, standards, procurement documents, or other requirements, identification is required such that items are traceable to appropriate documentation (e.g., specifications, drawings, purchase orders, manufacturing and inspection documents, nonconformance reports, physical or chemical mill test reports).

4.6 Where identification marking is employed, the marking is required to be clear, unambiguous and indelible, and shall be applied such as not to affect the fit, function, or quality of the item.

4.7 Markings shall be transferred to each part of an item, if subdivided. The markings shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted.

4.8 Procedures are required to provide for the verification and documentation of correct identification of items prior to release for use. Items may be conditionally released under adequate procedural controls.

4.9 Bulk consumables (such as weld rod, chemicals, reagents, gases, resins, lubricating oil and grease, fuel oil, cleaning solvents, etc.) must be identified and controlled in accordance with approved procedures that specify the applicable requirements for identification and use of the consumables.

4.10 In the event the identification or traceability of an item is lost, it shall be handled in accordance with RSQM Section XV.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 General Services is responsible for identification and control of items from procurement through withdrawal from the warehouse.

5.2 Maintenance is responsible for maintaining identification and control of items from withdrawal from the warehouse through installation.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 44 OF 77 5.3 Quality Assurance is responsible for:

a. Review and concurrence of procedures for controlling material, parts, and components from procurement through storage, issuance, and installation.

b. Auditing the process for identification and control of materials, parts, and components in accordance with RSQM Section XVIII.

........ I A IL I A * ...............

RANCHO SECO LICUN;51NU BASIS DOCGUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 45 OF 77 IX. CONTROL OF SPECIAL PROCESSES 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to control special processes used at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes 2.2 ANSI N45.2-1977, Section 10, Control of Special Processes 2.3 ASME Section V and IX 2.4 10 CFR 71.119, Control of Special Processes 2.5 10 CFR 72.158, Control of Special Processes 3.0 POLICY Prior to performing any special processes, procedures shall be established and implemented to ensure that special processes and equipment are controlled and that qualified personnel and procedures accomplish required activities.

4.0 GENERAL REQUIREMENTS 4.1 Prior to performing any special processes, procedures shall be prepared to provide for proper control of special processes, which include welding, heat treating, chemical cleaning, application of protective coatings, and nondestructive examination (NDE).

4.2 Controls shall be established to ensure that only approved materials and equipment are used to perform special processes.

4.3 Personnel who perform special processes shall be qualified in accordance with industry standards.

4.4 Special process requirements shall be prescribed in the controlling specifications, drawings, procurement documents, or procedures.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-0 10 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 46 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section 1, ORGANIZATION.

5.1 Encilneerinci is responsible for:

a. Specifying the special processes on design documents governing maintenance/modification activities.

b. Developing, qualifying, and maintaining special process procedures in accordance with Step 4.1 of this RSQM section.

c. Qualifying personnel or approving contract personnel to perform special processes identified in Step 4.1 of this RSQM section.

d. Performing NDE or approving contract personnel to perform NDE.

5.2 Quality Assurance is responsible for:

a. Review and concurrence of special process procedures.

b. Auditing the special process program in accordance with RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 47 OF 77 X. INSPECTION 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the inspection of material, parts, and components for the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion X, Inspection 2.2 ANSI N45.2-1971, Section 11, Inspection 2.3 Regulatory Guide 1.58/ANSI N45.2.6-78, Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel with exceptions noted in RSQM Section II.

2.4 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants 2.5 10 CER 71.121, Internal Inspection 2.6 10 CFR 72.160, Licensee Inspection 3.0 POLICY Procedures shall be established and implemented to ensure that inspections are performed to verify compliance with specified requirements at the Rancho Seco nuclear facility.

4.0 GENERAL REQUIREMENTS 4.1 Inspections shall be applied to receiving, maintenance, and modification activities to verify that items and activities conform to specified requirements.

4.2 Inspection planning documents shall be prepared or reviewed by Quality Assurance in accordance with established procedures. Inspection planning documents shall identify the following as applicable:

a. Characteristics and activities to be inspected;

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 48 OF 77

b. Inspection organization;

c. Accept/reject criteria;

d. Hold points and/or witness points;

e. Inspection Methods;

f. Provisions for recording objective evidence of inspection results; and

g. Measuring and test equipment of the necessary accuracy for performing inspection.

4.3 Process monitoring may be used where direct inspection alone is impractical or inadequate. Both inspection and process monitoring are performed when control is inadequate without both.

4.4 Training and qualification of personnel, who perform inspections including NDE, shall be performed in accordance with approved procedures.

4.5 Hold points are designated as mandatory inspection points when confirmation is needed that the work at the point is acceptable before additional work can proceed. Authorized personnel perform hold point inspections and release work for further processing or use.

4.6 Inspections, including any required hold points, are performed and documented in accordance with written procedures. Inspection results are documented and evaluated by qualified personnel to verify acceptability.

4.7 Quality Assurance personnel perform inspections of receiving, maintenance, and modification activities.

4.8 Inspection records shall contain the following where applicable:

a. Item inspected;

b. The date of the inspection;

c. Inspector or data recorder identification;

d. Identification of M&TE used to perform inspections;

e. Type of observation;

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 49 OF 77

f. Results or acceptability; and

g. Reference to information on action taken on non-conformances to resolve any discrepancies noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section i, ORGANIZATION.

5.1 Quality Assurance is responsible for:

a. Qualifying Quality Control Inspectors.

b. Preparing or reviewing inspection-planning documents for modification/maintenance activities.

c. Performing inspections per inspection plans.

d. Auditing the inspection program in accordance with RSQM Section XVIII.

5.2 Maintenance is responsible for assuring:

a. Inspections are performed as required by inspection planning.

b. Work does not proceed beyond inspector signoffs for hold points.

5.3 Each organization is responsible for:

a. Supporting inspection activities.

b. Providing prompt corrective action to any deficiencies found during the inspection.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 50 OF 77 Xl. TEST CONTROL 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for acceptance and surveillance test control at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion Xl, Test Control 2.2 ANSI N45.2-1971, Section 12, Test Control 2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power*

Plants 2.4 10 CFR 71.123, Test Control 2.5 10 CFR 72.162, Test Control 3.0 POLICY Procedures shall be established and implemented to ensure that required testing to demonstrate that structures, systems, and components will perform satisfactorily in service is identified, performed and documented.

4.0 GENERAL REQUIREMENTS 4.1 Tests shall be performed in accordance with procedures and criteria that designate when tests are required and how they are to be performed.

Such testing includes the following:

a. Qualification tests, as applicable, to verify design adequacy.

b. Tests of equipment and components to ensure their proper operation prior to delivery or pre-operational tests;

c. Pre-operational tests to ensure proper and safe operation of systems and equipment prior to startup tests or operations;

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 51 OF 77

d. Startup tests to ensure proper and safe operation of systems and equipment.

e. Surveillance tests to ensure continuing proper and safe operation of systems and equipment.

f. Maintenance tests after preventive or corrective maintenance.

4.2 Test procedures and instructions shall include provisions for the following, as applicable:

a. The requirements and acceptance limits contained in the applicable design and procurement documents;

b. Test prerequisites such as calibrated instrumentation, required test equipment, degree of completeness of the item to be tested, suitable and controlled environmental conditions, and provisions for data collection and storage;

c. Verifying that test prerequisites have been met;

d. Instructions for performing the test;

e. Any inspection points;

f. Acceptance criteria;

g. Documenting or recording test data and results; and

h. Verification of completion.

4.3 Test procedures and instructions shall be reviewed by the applicable organizations for technical content.

4.4 Test results shall be documented and evaluated by responsible authorities to ensure that test requirements have been satisfied.

4.5 Test records shall contain the following information where applicable:

a. Item tested and type of observation;

b. The date and results of the test;

c. Information related to deviations or non-conformances;

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 )

REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 52 OF 77

d. Identification of person recording the data;

e. Evidence as to the acceptability of the results; and

f. Action taken to resolve any deviations and non-conformances noted.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGAN IZATION.

5.1 Quality Assurance is responsible for auditing the test control program per RSQM Section XVIII.

5.2 Engineering is responsible for:

a. Establishing the procedure for acceptance and surveillance testing.

b. Providing personnel to perform the testing and acceptance evaluations.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 53 OF 77 XlI. CONTROL OF MEASURING AND TEST EQUIPMENT 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the control of measuring and test equipment at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment 2.2 ANSI N45.2-1971, Section 13, Control of Measuring and Test Equipment 2.3 Safety Guide 33/ANSI N18.7, Administrative Controls for Nuclear Power Plants.

2.4 Regulatory Guide 1.30/ANSI N45.2.4-72, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment with exception noted in Section II of this manual.

2.5 10 CFR 71.125, Control of Measuring and Test Equipment 2.6 10 CFR 72.164, Control of Measuring and Test Equipment 3.0 POLICY Procedures shall be established and implemented to ensure that measuring and testing devices used in final acceptance of activities affecting quality are properly

~controlled, calibrated, and adjusted at specified intervals to maintain the desired accuracy.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for calibration, maintenance, and control of measuring and test equipment utilized in the operation, measurement, inspection, or monitoring of items.

4.2 Measuring and Test Equipment (M&TE) shall be calibrated at specified intervals. These intervals are based on the amount of use, stability,

................. mA ....................

RANCHO SECO LIUEINSIN(3 BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 54 OF 77 characteristics and other conditions that could adversely affect the required measurement accuracy. Reference and secondary calibration standards shall be traceable to nationally recognized standards where they exist. Where national standards do not exist, provisions shall be established to document the basis for calibration.

4.3 M&TE used for calibrating plant process instrumentation (PI) shall have calibration ranges, precessions, and accuracy's such that the PI can be calibrated from M&TE with an accuracy ratio of at least two-to-one (M&TE to PI). Calibration accuracy ratios of less than two but equal to or better than one shall be acceptable when equipment to meet specified requirements is not commercially available. The basis of acceptance in these cases shall be documented.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Maintenance is responsible for:

a. Establishing methods for control of measuring and test equipment.

b. Determining the need for calibrated instruments and measuring devices in Rancho Seco nuclear facility activities.

c. Providing administrative procedures that address the requirements for calibration.

d. Control of measurement devices to ensure their use and accuracy.

5.2 Quality Assurance is responsible for auditing the control of measuring and test equipment program per RSQM Section XVIII.

RANCHO SECO LICENSzING~ BASIS DOCGUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 55 OF 77 XIII. HANDLING, STORAGE, AND SHIPPING 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for the handling, storage, shipping, cleaning, and preservation of material and equipment at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XIII, Handling, Storage, and Shipping 2.2 ANSI N45.2-1 971, Section 14, Handling, Storage, and Shipping 2.3 Regulatory Guide 1.38/ANSI N45.2.2-1 972, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants with exceptions noted in Section II of this manual.

2.4 10 CFR 71.127, Handling, Storage, and Shipping 2.5 10 CFR 72.166, Handling, Storage, and Shipping 3.0 POLICY Procedures shall be established and implemented to ensure that materials and equipment are properly handled, stored, shipped, cleaned, and preserved to prevent damage or deterioration.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be established for assuring that proper handling, storage, shipping, and preservation instructions are included in applicable drawings and/or specifications.

4.2 When required for specific items, special protective environments, such as inert gas atmosphere, specific moisture content levels, and temperature levels, shall be specified.

4.3 A shelf life program shall be in effect and monitored to prevent usage after the expiration date without re-certification for extension of shelf life.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 56 OF 77 4.4 Special material handling and preservation instructions shall be developed when required by applicable drawings and/or specifications.

4.5 Materials used for packaging, shipment, and, storage of items that have the potential for causing contamination or radiation exposure require marking and labeling to indicate the need for special radiological controls.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Engineering is responsible for establishing methods and procedures to ensure that applicable drawings and/or specifications include handling, storage, shipping, and preservation requirements.

5.2 Maintenance is responsible for:

a. Establishing methods for special handling, storage, and preservation during maintenance activities.

b. Providing administrative procedures that specify the required controls.

5.3 Quality Assurance is responsible for auditing conformance to the handling, storage, and shipping program per RSQM Section XVIII.

5.4 General Services is responsible for maintaining material and warehousing control of items and equipment that require special handling and storage.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 57 OF 77 XlV. INSPECTION, TEST, AND OPERATING STATUS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a system to identify the inspection, test, and operating status of individual items at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XIV, Inspection, Test and Operating Status 2.2 ANSI N45.2-1 971, Section 15, Inspection, Test, and Operating Status 2.3 10 CFR 71.129, Inspection, Test and Operating Status 2.4 10 CFR 72.168, Inspection, Test and Operating Status 3.0 POLICY Procedures shall be established and implemented to ensure that measures. are provided to indicate the status of inspections, tests, and operations.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall specify the degree of control required for the indication of inspection and test status of items required for modification activities.

4.2 The sequence of inspections, tests, and other operations, and changes thereto, shall be controlled by procedures.

4.3 Procedures shall provide methods for identifying the nonconforming items, inoperable systems and components by tags, markings, labels, etc. to prevent inadvertent use.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 58 OF 77 5.1 Maintenance is responsible for Clearance Program procedures to ensure:

a. Safety of personnel and equipment during maintenance and testing activities.

b. Installation and removal of test and operating status indicators.

5.2 Quality Assurance is responsible for:

a. Identifying the quality status of applicable material, parts, and components.

b. Auditing the inspection, test, and operating status program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 59 OF 77 XV. NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for controlling material, components, parts, or systems that are not in conformance to specified requirements at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCED DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XV, Nonconforming Materials, Parts or Components 2.2 ANSI N45.2-1 971, Section 16, Nonconforming Items 2.3 10 CFR 71.131, Nonconforming Materials, Parts or Components 2.4 10 CFR 72.170, Nonconforming Materials, Parts or Components 3.0 POLICY Procedures shall be established and implemented to ensure that materials, parts, or components that do not conform to specified requirements are controlled to prevent their inadvertent use or installation.

4.0 GENERAL REQUIREMENTS 4.1 Procedures shall be developed for controlling, documenting, and resolving items, services, or activities identified as nonconforming.

4.2 Marking, tagging, segregating, or other means shall identify nonconforming items.

4.3 Non-conformances shall be documented, processed, controlled and retained to provide records of the actions taken to resolve the nonconforming condition.

RANCHO SECO LICENSING3 BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 60 OF 77 5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Quality Assurance is responsible for:

a. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions. (Refer to RSQM Section XVI regarding corrective action program)

b. Establishing methods for controlling and documenting non-conformances.

c. Ensuring expertise is available to disposition non-conformances.

d. Developing safety analyses that address the nonconforming condition, if required.

a. Auditing the nonconforming materials, parts, or components program per RSQM Section XVIII.

5.2 Rancho Seco management is responsible for:

a. Taking appropriate action to ensure operation of the plant in conformance to license requirements when a nonconformance identifies a condition prohibiting components, structures, or, systems from returning to an acceptable condition.

b. Determining the safety significance of the nonconforming condition on the status of the plant.

c. Reviewing identified conditions that are adverse to quality and the corrective action associated with those conditions.

d. Ensuring expertise is available to disposition non-conformances.

e. Developing safety analyses that address the nonconforming condition, if required.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 61 OF 77 XVI. CORRECTIVE ACTION 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established to provide for a corrective action program to ensure that conditions adverse to quality are promptly identified and corrected at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR

50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XVI, Corrective Action 2.2 10 CFR 72, Subpart D, Records, Reports, Inspections, and Enforcement.

2.3 ANSI N45.2-1 971, Section 17, Corrective Action 2.4 10 CFR 71.133, Corrective Action 2.5 10 CFR 72.172, Corrective Action 3.0 POLICY Procedures shall be established and implemented to ensure that significant conditions adverse to quality are identified and that corrective action is taken to preclude repetition.

4.0 GENERAL REQUIREMENTS 4.1 Controls shall ensure conditions adverse to quality such as malfunctions, errors, deficiencies or non-conformances are identified, documented and appropriate corrective action taken. The controls shall ensure that the corrective action is- implemented in a timely manner.

4.2 For significant conditions adverse to quality, corrective action includes determining the cause and extent of the condition, taking corrective action to remedy the condition and taking action to prevent recurrence. These actions shall be reported to management personnel for review and assessment.

5.0 RESPONSIBILITIES

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 62 OF 77 General organizational responsibilities are described in Section I, ORGANIZATION.

5.1 Rancho Seco management is responsible for:

a. Formulating appropriate corrective actions.

b. Implementing proposed corrective actions.

c. Ensuring that proposed corrective action is effective.

5.2 Quality Assurance is responsible for:

a. Auditing the Corrective Action Program per RSQM Section XVIII.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 63 OF 77 XVII. QUALITY ASSURANCE RECORDS 1.0 PURPOSE This section describes the Rancho Seco Quality Assurance Program (QAP) measures established for the storage and maintenance of Quality Assurance Records that provide the documentary evidence of activities affecting quality performed at the Rancho Seco nuclear facility, which includes the Rancho Seco Nuclear Generating Station (RSNGS; licensed and undergoing decommissioning pursuant to 10 CFR 50) and the Independent Spent Fuel Storage Installation (ISFSI; licensed and operated pursuant to 10 CFR 72).

2.0 REFERENCE DOCUMENTS 2.1 10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records 2.2 ANSI N45.2-1 971, Section 18, Quality Assurance Records 2.3 Safety Guide 33/ANSI N18.7, Administrative Control for Nuclear Power Plants, paragraph 5.2 2.4 Regulatory Guide 1.28/ANSI/ASME, NQA-1-1 983, Supplement 17S-1, Supplementary Requirements for Quality Assurance Records, with exceptions as noted in RSQM Section II, Attachment 11-3.

2.5 Rancho Seco Quality Manual, Appendix A 2.6 10 CFR 71.135, Quality Assurance Records 2.7 10 CFR 72.174, Quality Assurance Records 3.0 POLICY Procedures shall be established and implemented to ensure storage and maintenance of records that represent evidence of activities described in RSQM Section II, Step 4.4.

4.0 GENERAL REQUIREMENTS 4.1 Quality Assurance records shall be permanently stored in a facility that meets the requirements of Reference 2.4 and 2.5.

4.2 Quality Assurance records shall be protected during interim storage in accordance with Reference 2.4.

RANCHO SECO LICENSINGi BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 64 OF 77 4.3 Documents that furnish evidence of the quality of items and services are generated and controlled in accordance with the procedures that govern those activities. Such documents are considered Quality Assurance Records upon completion. Quality Assurance Records are considered completed when they have been stamped, initialed, or signed and dated by authorized personnel or otherwise authenticated.

4.4 The record system shall provide for identification and retrievability of the records to the extent that information can be obtained in a reasonable amount of time.

4.5 The records program shall address records classification (retention period), storage location and responsibility for retention and retrievability.

4.6 A records retention schedule shall be established which addresses the requirements in References 2.4 and 2.5.

5.0 RESPONSIBILITIES General organizational responsibilities are described in Section I, ORGAN IZATION 5.1 Records Management is responsible for:

a. Establishing methods for control of records.

b. Providing administrative procedures that define the records storage program and provide for ready retrievability.

5.2 Rancho Seco management is responsible for:

a. Transmitting completed records to Records Management.

b. Providing interim storage in accordance with Step 4.2 above and Reference 2.4, prior to transmittal to Records Management.

5.3 Quality Assurance is responsible for auditing the records management system to ensure conformance to specified requirements per RSQM Section XVIII.

RANCHO SLECO LIUNI=N~NL 15A*515 UU)CUMINNI NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 65 OF 77 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 Regulatory Guide 1.144/ANSI N45.2.1 2-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants 2.4 Regulatory 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 ensure 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.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 66 OF 77 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 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.

4.6 Process conditions identified as adverse to quality using the Rancho Seco Corrective Action Program.

4.7 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.

4.8 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 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. Training and qualification of audit personnel.

5.2 SMUD management is responsible for:

a. Supporting the audit activities.

1KANI2HO SECGO LIULNI-NU5NL bA*51* VUGUMNI-- NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 67 OF 77

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 Director, Audit Services (AS). 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 Manager 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;

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

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 68 OF 77

k. Process Control Program (PCP) and implementing procedures for processing and packaging of radioactive wastes from liquid systems at least once every two years; I.Performance of activities required by the Quality Assurance Program for Effluent Control and Environmental Monitoring (Regulatory 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 "in" above shall be forwarded to the site Manager, the Director, Power Generation, and the management positions responsible for the areas reviewed. The report should be issued within 30 days after completion.

RANCHO SECO LICENSiIN(G WASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 69 OF 77 Appendix A 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 Manager, but not lower than a direct report to the Site Manager. Such procedures, plans, manuals and programs shall be reviewed periodically in accordance with administrative procedures.

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

b. Proposed changes or modifications to systems or equipment described in the RADSAR 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 Manager or his designee as delineated in writing, but not lower than a direct report to the Site Manager.

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 RADSAR. Such tests or experiments shall be approved by the Site Manager or his designee as delineated in writing, but not lower than a direct report to the Site Manager.

d. Individuals responsible for reviews performed in accordance with Section 1.1 a, 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 Manager 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 event and which provides recommendations to prevent recurrence. The Site Manager shall review these reports.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 70 OF 77 1.2 Audits (See RSQM Section XVIIl)

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 Manager or designee.

1.4 Procedures, Plans, Manuals, and Programs 1.4.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained 1 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. POP implementation.

e. ODCM implementation.

f. REMP MANUAL implementation.

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

RANCHO SECO LICENSING3 BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 71 OF 77 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 Proaram There are no longer any radioactive liquid or gaseous effluents discharged from the site. The Offsite Dose Calculation Manual (ODOM) 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 Radioloqical Environmental Monitoringq Progqram (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.

With the completion of the first phase of decommissioning, the direct radiation pathway is the only pathway still monitored by the REMP.

Accordingly, there is no longer any requirement to participate in an Inter-laboratory Comparison Program (ICP). The vendor supplying the direct radiation monitoring devices must be certified under a National Voluntary Laboratory Accreditation Program (NVLAP). The National Institute of Standards and Technology (NI1ST) administers the NVLAP, which provides third-party accreditation to testing and calibration laboratories.

1.4.4 The changes to the REMP shall be reviewed and approved as set forth in Sections 1.1 and 1.9.

RANCHO SECO LICEN;51NU L3A$IS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: PANCHO SECO QUALITY MANUAL PAGE 72 OF 77 1.5 Reporting Requirements 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 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 Radioloqical 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.

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 73 OF 77 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 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 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 Officel. 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).

RANCHO SECO LICENSING BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 74 OF 77 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.

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.

RANCHO SECO LICENSING~ BASIS DOCUMENT NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 75 OF 77

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

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 Plant Review committee (PRC) and Management Safety Review Committee (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 POP:

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.

I b.Shall become effective after approval by the Site Manager.

RANCHO SECU LlICNI-N5N(i IUA*51*5 LVUUMPN I NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 76 OF 77 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 Manager 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:

a. The Licensee, or

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

KANUHU. SI-W LILLNI:NU5N* bA*515 VU()UML-N I NUMBER: RSLBD-010 REVISION: 2 TITLE: RANCHO SECO QUALITY MANUAL PAGE 77 OF 77 The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample.

Test Freqiuencies 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.