VPN-006-202, Portland General Electric Co., Revision 30 to PGE-8010, Trojan Nuclear Quality Assurance Program
| ML21309A110 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/26/2021 |
| From: | Jenkins B Portland General Electric Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| VPN-006-2021 | |
| Download: ML21309A110 (5) | |
Text
Portland General Electric Company Trojan /SFSI 71760 Columbia River Hwy Rainier, Oregon 97048 ATTN:.Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 October 26, 2021 VPN-006-2021 Trojan ISFSI Docket No.72-017 License No. SNM-2509 Revision 30 to PGE-8010, Trojan Nuclear Quality Assurance Program Pursuant to 10 CFR 72.140(b) and (c) and 10 CFR 71.lOl(b) and (c), this letter submits for Nuclear Regulatory Commission (NRC) approval proposed Revision 30 to PGE-8010, "Portland General Electric (PGE) Nuclear Quality Assurance (QA) Program For Trojan Independent Spent Fuel Storage Installation (10 CFR 72) Operations And Radioactive Material Packaging And Transportation (10 CFR 71) Activities" (Trojan Nuclear QA Program).
In addition, this letter also requests the NRC to issue a revision to PGE QA Program Approval for Radioactive Material Packages No. 0327, Docket No. 71-0327, to reflect NRC approval of the proposed Revision 30 to the Trojan Nuclear QA Program enclosed with this letter. The current PGE QA Program Approval for Radioactive Material Packages No. 0327 is Revision 16, which no longer has an expiration date. As required by 10 CFR 170.31 Section 10.B.2, the $4,300.00 Application Fee, for QA Program Users associated with this 10 CFR 71 QA Program change, accompanies this letter in the form of an "Authorization for Payment By Credit Card" form contained in Enclosure IV.
The primary reason for the changes proposed for Revision 30 to the Trojan Nuclear QA Program is to add flexibility to the upper level of the Trojan organizational structure. Specifically, this revision reflects a new discretionary authority granted to the Corporate Executive Responsible for Trojan to add one or more, permanent or temporary, managers or directors, in the Trojan ISFSI organizational structure between the ISFSI Manager and the Corporate Executive Responsible for Trojan.
These positions are intended to provide additional administrative support to the ISFSI Manager without affecting the overall corporate responsibility for the ISFSI. These positions, if implemented, would not inhibit access and communication between the ISFSI Manager and the ~ oD ~
Corporate Executive Responsible for Trojan.
l--1
VPN-006-2021 October 26, 2021 Page 2 of 2 This revision reflects PG E's desire to allow the Corporate Executive Responsible for Trojan the discretion to apply organizational and administrative flexibility and focus senior management resources to the ISFSI without affecting the day-to-day operational responsibilities of the ISFSI Manager.
This revision also includes minor administrative changes and edits that do not modify or reduce commitments made in this QA Program.
A detailed description of and reason for each change incorporated into proposed Revision 30 of the Trojan Nuclear QA Program is provided as Enclosure I to this letter. Enclosure II to this letter provides a red line version of the proposed Revision 30 to the Trojan Nuclear QA Program, PGE-8010, with strikethroughs, insertions, and sidebars annotated. Enclosure Ill to this letter provides a copy of the entire QA Program containing a clean version of the proposed Revision 30 with sidebars annotated.
These proposed changes to the Trojan Nuclear QA Program will continue to satisfy the requirements of 10 CFR 72 Subpart G and 10 CFR 71 Subpart H for Quality Assurance Programs.
They do not change, modify, nor reduce any commitments in the quality assurance program previously approved by the NRC.
Upon receipt of the NRC approvals requested in this letter, PGE will issue the approved Trojan Nuclear QA Program, Revision 30, concurrently with necessary revisions to Trojan ISFSI procedures.
If there are any questions regarding this letter, please contact Mr. Tom Romay of my staff at (503) 556-7001.
Sincerely,
~~-~
Bradl '
. Jenkins Vice President, Utility Operations Enclosures (4) c:
Director, NRC Region IV, DNMS Todd Cornett, Assistant Director, Energy Siting, ODOE
ENCLOSURE I TO VPN-006-2021 Proposed Revision 30 to PGE-8010 Description of and Reason and Justification for Changes The list below provides the Nuclear Regulatory Commission (NRC) with a description of each change incorporated into proposed Revision 30 to PGE-8010, "Portland General Electric (PGE)
Nuclear Quality Assurance [QA] Program For Trojan Independent Spent Fuel Storage Installation (10 CFR 72) Operations And Radioactive Material Packaging And Transportation {10 CFR 71)
Activities" (Trojan Nuclear QA Program), which is provided as Enclosures II and Ill to PGE Letter No.
VPN-006-2021 concurrently with this Enclosure I. Also included in this list is the reason for each change supporting the conclusion that, following implementation of the change, the Trojan Nuclear QA Program will continue to satisfy the requirements and applicable criteria of 10 CFR 72, Subpart G, and 10 CFR 71, Subpart H.
As mentioned in PGE Letter No. VPN-006-2021 forwarding this enclosure, the primary reason for the changes incorporated into the proposed Revision 30 of the Trojan Nuclear QA Program is to add flexibility to the upper level of the Trojan organizational structure. Specifically, this revision reflects a new discretionary authority granted to the Corporate Executive Responsible for Trojan to add one or more, permanent or temporary, managers or directors, in the Trojan ISFSI organizational structure between the ISFSI Manager and the Corporate Executive Responsible for Trojan. These positions are intended to provide additional administrative support to the ISFSI Manager without affecting the overall corporate responsibility for the ISFSI. These positions, if implemented, would not inhibit access and communication between the ISFSI Manager and the Corporate Executive Responsible for Trojan.
This revision reflects PG E's desire to allow the Corporate Executive Responsible for Trojan the discretion to apply organizational and administrative flexibility and focus senior management resources to the ISFSI without affecting the day-to-day operational responsibilities of the ISFSI Manager.
PGE-8010, PGE Trojan Nuclear QA Program, Revision 30 - Description of Changes:
- Update Cover Page, Table of Contents and List of Effective Pages to Revision 30.
- Update Policy Statement list of personnel responsible for complying with this QA Program by adding "authorized contractors and consultants... "
- Section 1.1: added "and conduct of services" to QA activities that are important to safety.
- Section 1.2.1: added description of allowable additional management position between ISFSI Manager
. and Corp. Executive and emphasized the unchanged responsibilities of the Corp. Executive.
- Multiple deletions of the word "Department" when referring to "QA audits of ISFSI Department activities."
Enclosure I, Page 1 of 3
- Delete all references to "Surveys" as a clarification because PGE Trojan does not perform Commercial Graded Dedications per 10 CFR Part 21. Added "Surveillances" as an additional tool for assessments to be used as deemed necessary by PGE Trojan.
- Section 1.2.2: added to description of ISRC and deleted "department" from "ISFSI department" as there is no ISFSI department. Added "status and" to mirror wording in 10 CFR 72.144{e) and 71.105{d) to say, "status and adequacy." Listed examples of items that should be included in this "status and adequacy" assessment.
- Section 1.2.3: added "PGE employees" to list of personnel that may provide Nuclear Oversight resources.
- Section 1.2.3.1: added to description of ISRC Member Responsible for Managing Nuclear Oversight Resources.
- Section 1.2.3.2: Deleted "department" from "ISFSI department" as there is no ISFSI department. Delete reference to "Surveys" as a clarification because PGE Trojan does not perform Commercial Graded Dedications per 10 CFR Part 21. Added "Surveillances" as an additional tool for assessments to be used as deemed necessary by PGE Trojan. Added "PGE personnel and ISFSI staff" to list of parties authorized to initiate stop work orders as necessary.
- Added amplifying statement regarding role of Nuclear Oversight resources to provide feedback and consultation to Trojan ISFSI staff inquiries regarding implementation of this QA Program in multiple chapters and sections. Sections 1.2, 4.2, 5.2, 6.2, 7.2, 8.2, 10.2, 11.2, 12.2, 13.2, 14.2, 15.2, 16.2, 17.2.
- Section 1.2.3.3: added description of role and responsibility of additional management position in Trojan organization.
- Section 1.2.4: deleted "department" from "ISFSI department" as there is no ISFSI department, changed to "ISFSI Organization."
- Section 1.2.4.1: added to description and responsibilities of the ISFSI Manager. Added description of allowable additional management position between ISFSI Manager and Corp. Executive and emphasized the unchanged responsibilities of the Corp. Executive.
- Section 1.2.4.2: deleted "department" from "ISFSI department" as there is no ISFSI department, clarified composition of Audit team members, deleted "surveys", and added "surveillances."
- Section 1.2.5.1: added "PGE Corporate" to section header. Added responsibilities to role of PGE Corporate Manager of Nuclear Support Organizations.
- Figure 1.0-1: Updated Trojan ISFSI and QA Program Implementation Functional Organization chart, added legend for line designations.
- Section 2.1: added/cited 10 CFR 72.144{e) and 71.105(d) regarding assessment of status and adequacy of Trojan's QA program.
Enclosure I, Page 2 of 3
- Section 2.2.1: Added "ITS 11 acronym, added reference to Trojan's NRC Part 71 program approval 71-0327.
- Section 4.2: clarified title of PGE Corporate purchasing.
- Section 7.2: deleted "appropriate 11 and added "compensatory", deleted "surveys 11
, and added "source surveillance."
- Section 7.2.1: Delete reference to "Surveys" as a clarification because PGE Trojan does not perform Commercial Graded Dedications per 10 CFR Part 21. Added" Source Surveillances" as an additional tool for assessments to be used as deemed necessary by PGE Trojan.
- Section 12.2.1: added "are traceable to the national standards or constants."
- Section 12.2.2: added "out of tolerance" to list of potential as found instrument statuses.
- Section 15.2.3: added detail, "Trojan ISFSI management," who performs reviews and approval of nonconformance reports.
- Section 16.2: Updated to reflect correct terminology used in Trojan's corrective action program; deleted references to "nonconformance reports 11 and replaced with "corrective action reports (CARs)."
- Section 17.2: added clarifying statement "PGE Corporate Manager for record control services is responsible for ensuring that procedures that implement the applicable portions of the Trojan QA Program are established, implemented, and maintained."
- Section 18.2: deleted "department" from "ISFSI department" as there is no ISFSI department, clarified composition of Audit teams.
- Glossary: added definitions for Source Surveillance and Tolerance.
Enclosure I, Page 3 of 3