ML15266A179
| ML15266A179 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 09/01/2015 |
| From: | Nick B Dairyland Power Cooperative |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LAC-14356 | |
| Download: ML15266A179 (3) | |
Text
LA CROSSE BOILING WATER REACTOR INDEPENDENT SPENT FUEL STORAGE INSTALLATION (LACBWR ISFSI)
DAIRYLAND POWER COOPERATIVE September 1, 2015 In reply, please refer to LAC-14356 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)
Possession-Only License DRP-45 Request for Rescission of NRC Order of September 15, 1994
Reference:
(1) NRC Letter, Erickson to Berg, dated August 7, 1991, Issuing Order to Authorize Decommissioning of LACBWR (2) NRC Letter, Axelson to Berg Dated July 1, 1994, Issuing Notice of Violation and Subject Inspection Report (3) NRC Letter, Knapp to Berg, dated September 15, 1994, Confirmatory Order Modifying NRC Order Authorizing Decommissioning of Facility On August 7, 1991, NRC approved the LACBWR Decommissioning Plan (May 1991) and issued an Order authorizing decommissioning of the LACBWR facility. Section 6.2 of the May 1991 Decommissioning Plan stated the Plant Manager reported directly to the Dairyland Power Cooperative (DPC) Assistant General Manager for Operations. Contrary to that organizational structure, the Plant Manager reported to the Director, South Area Power Production. This was the organization structure described in revision 7 of the Quality Assurance Program Document, submitted to NRC on May 23, 1991.
On July 1, 1994, NRC issued a Severity Level IV Notice of Violation to DPC citing a reduction in the effectiveness of the safety of the facility due to the change in reporting structure for the Plant Manager. A change was made on June 9, 1994 to have the Plant Manager report directly to the Assistant General Manager for Operations. On September 15, 1994, NRC issued a Confirmatory Order Modifying NRC Order Authorizing Decommissioning of Facility. Specifically, the Confirmatory Order modified the Order of August 7, 1991 "to include the following procedure by which the licensee is allowed to: (i) make changes to the facility or procedures as described in the Decommissioning Plan; and (ii) conduct tests or experiments not described in the Decommissioning Plan, without prior NRC approval."
(a)(1) The licensee may (i) make changes in the facility or procedures as described in the Decommissioning Plan and (ii) conduct tests or experiments not described in the Decommissioning Plan, without prior NRC approval, unless the proposed change, test or experiment involves a change in technical specifications (TS) incorporated in the license, an unreviewed safety question, or results in a signi~ficant environmental impact not previously A Touchstone Energy* Cooperative ***
S4601 State Highway 35
- Genoa, WI 54632-8846
- 608-689-4295
- 608-689-4220 fax
- www.dairynet.com
LAC-14xxx Page 2 September 1, 2015 Order or the Final Environmental Statement (FES) related to operation of LACBWR, dated April 21, 1980 (NUREG-O191), Notwithstanding the above, a reduction in site staffing levels below the minimum number for any group or area shown on the organization chart (Fig. 6.1) in the LACBWR Decommissioning Plan, or a change in reporting relationships for the Plant Manager must be submitted to the NRC as specified in 10 CFR 50.4, and receive NRC approval prior to implementation.
(2) A proposed change, test or experiment shall be deemed to involve an unreviewed safety question (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment necessary for SA FSTOR previously evaluated in either the Final Safety Analysis Report (FSAR) or the Decommissioning Plan may be increased, or (ii) f a possibility for an accident or malfunction of a different type than evaluated previously in the FSAR or Decommissioning Plan may be created, or (iii) if the margin of safety as defined in the basis for any TS is reduced.
(b,)('1)The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this procedure, to the extent that these changes constitute changes in the facility or procedures as described in either the FSAR or Decommissioning Plan. The licensee shall also maintain records of tests and experiments performed pursuant to paragraph (a) of this section.
These records must include a written safety evaluation containing the basis for the determination that the changes, tests, or experiments do not involve an unreviewed safety question, or a significant environmental impact not previously evaluated.
(2) The licensee shall annually submit, as specified in 10 CFR 50.4 a report containing a brief description of any changes, tests and experiments, including a summary of the safety evaluation of each.
(3) The licensee shall maintain records of changes in the facility until the date of termination of the license and shall maintain the record of changes in procedures and records of tests and experiments for a period of three years.
(c) If the licensee desires (1) a change in the TS, or (2) to make a ch'ange in the facility or procedures described in the Decommissioning Plan or conduct tests or experiments not described in the Decommissioning Plan, which involve an unreviewed safety question, a change in TS, or a significant environmental impact not previously evaluated, the licensee shall submit an application for amendment of fits license pursuant to 10 CFR 50.90."
Organizational structure is no longer part of the Decommissioning Plan; but is reflected in the QAPD.
Revision 27 of the QAPD was submitted to NRC on August 29, 2014 and was not implemented until NRC approved the QAPD. Current DPC organization outlined in Revision 28 of the QAPD has the Plant Manager reporting to the Site Manager, Genoa. All other elements cited in the Confirmatory Order are captured in the QAPD and supporting documents. Changes to the facility are evaluated using 10 CFR 50.59 or 10 CFR 72.48 processes as required by the QAPD, Section 111, Design Control and Review. A summary report of these activities is included in the biennial update of the Decommissioning Plan.
LAG-i14xxx Page 3 September 1, 2015 All the requirements of the NRC Order are now captured in the QAPD and PSDAR. Changes to these documents are controlled by 10 CFR 50.54(a), 10 CFR 50.059 and 10 CFR 50.82. Therefore, the requirements in the NRC Order are redundant to existing commitments in the QAPD and PSDAR and to regulatory controls for making changes to these documents. DPC requests NRC to rescind the Confrmnatory Order for LACBWR, effective immediately.
If you have any questions concerning this request, please contact Cheryl Olson, LACBWR PlantIISFSI Manager, at (608) 689-4207.
Sincerely, DAIRYLAND POWER COOPERATIVE Barbara Nick President and CEO CLO:tco cc:
Marlayna Vaaler NRC Project Manager