ML16069A202
| ML16069A202 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png (DPR-045) |
| Issue date: | 03/17/2016 |
| From: | Vaaler M Reactor Decommissioning Branch |
| To: | Nick B Dairyland Power Cooperative |
| Marlayna Vaaler, 301-415-3178 | |
| References | |
| CAC L53102 | |
| Download: ML16069A202 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 17, 2016 Ms. Barbara A. Nick President and Chief Executive Officer Dairyland Power Cooperative 3200 East Avenue South P.O. Box 817 La Crosse, WI 54602-0817
SUBJECT:
LA CROSSE BOILING WATER REACTOR - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REQUEST FOR REVIEW AND APPROVAL OF REVISION 29 TO THE QUALITY ASSURANCE PROGRAM DESCRIPTION (CAC NO. L53102)
Dear Ms. Nick:
By letter dated October 29, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16020A004), as supplemented by letter dated November 17, 2015 (ADAMS Accession No. ML16015A018), Dairyland Power Cooperative (Dairyland) submitted an application seeking the NRC review and approval of Revision 29 of the Quality Assurance Program Description (QAPD) for the decommissioning of La Crosse Boiling Water Reactor (LACBWR) prior to implementation of the revised QAPD.
These changes to the QAPD support a license transfer application submitted by Dairyland on October 8, 2015 (ADAMS Accession No. ML15307A309), as well as the impending submittal of the LACBWR License Termination Plan, and will not be implemented until these documents are also approved by the NRC.
In order to complete its review, the NRC staff requests additional information as specified in the Enclosure. The requested information was discussed in part with your staff during a conference call with NRC staff on December 15, 2015. Additional administrative documents were submitted to the NRC as a result of the conference call in support of the on-going review; however, the staff has determined that additional information is needed to support completion of the QAPD review. In order to continue an expedited review of the subject request, please respond to this request for additional information by April 22, 2016.
If you have any questions, please contact me at (301) 415-3178 or via e-mail at Marlayna.Vaaler@nrc.gov.
Sincerely,
/RA/
Marlayna Vaaler, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-409 and 72-046 License No.: DPR-45
Enclosure:
Request for Additional Information cc w/ enclosure:
La Crosse Boiling Water Reactor Service List
- by memo OFFICE NMSS/RDB/PM NMSS/DUWP/LA NRO/DCIP/QVIB NMSS/RDB/BC NAME M. Vaaler C. Holston K. Kavanagh*
B. Watson DATE 3/8/2016 3/10/2016 2/26/2016 3/17/2016
La Crosse Boiling Water Reactor Service List Mr. Thomas Zaremba Wheeler, Van Sickle and Anderson, S.C.
44 East Mifflin Street, Suite 1000 Madison, WI 53703-3398 Mr. George Kruck Chairman, Town of Genoa S5277 Mound Ridge Road Genoa, WI 54632 Mr. Jeffery Kitsembel Electric Division Wisconsin Public Service Commission P.O. Box 7854 Madison, WI 53707-7854 Mr. Paul Schmidt, Manager Radiation Protection Section Bureau of Environmental and Occupational Health Division of Public Health Wisconsin Department of Health Services P.O. Box 2659 Madison, WI 53701-2659 Ms. Cheryl Olson, ISFSI Supervisor La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 Genoa, WI 54632-8846 Mr. Lane Peters La Crosse Boiling Water Reactor Dairyland Power Cooperative S4601 State Highway 35 Genoa, WI 54632-8846 Regional Administrator Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352
Enclosure REQUEST FOR ADDITIONAL INFORMATION PROPOSED REVISION TO QUALITY ASSURANCE PROGRAM DESCRIPTION LA CROSSE BOILING WATER REACTOR DAIRYLAND POWER COOPERATIVE DOCKET NOS. 50-409 AND 72-046 By letter dated October 29, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16020A004), as supplemented by letter dated November 17, 2015 (ADAMS Accession No. ML16015A018), Dairyland Power Cooperative (Dairyland) submitted an application seeking the NRC review and approval of Revision 29 of the Quality Assurance Program Description (QAPD) for the decommissioning of La Crosse Boiling Water Reactor (LACBWR) prior to implementation of the revised QAPD. These changes to the QAPD support a license transfer application submitted by Dairyland on October 8, 2015 (ADAMS Accession No. ML15307A309), as well as the impending submittal of the LACBWR License Termination Plan.
The staff has completed its review of Revision 29 of the QAPD, as well as administrative documents Administrative Control Procedure (ACP) 20-2.02, QA Program - Qualified Technical Review (TR) Process, Issue 0, dated January 12, 2016, and ACP-20-02.04, Independent Management Assessment, Issue 0 (undated), provided by Dairyland following a clarification teleconference held on December 15, 2015.
The following additional information is necessary to complete the staffs review:
RAI-LACBWR-01: Qualification Requirements for Qualified Technical Reviewers As a part of the review of Revision 29 to the LACBWR QAPD, the NRC staff examined the regulations that relate to implementation of a quality assurance program at both power reactors and Independent Spent Fuel Storage Installations (ISFSIs). These regulations are summarized below:
The requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54 (a)(1) specify, in part, that each nuclear power plant or fuel reprocessing plant licensee subject to the quality assurance criteria in appendix B of this part shall implement the quality assurance program described or referenced in the Safety Analysis Report, including changes to that report.
The requirements of 10 CFR 50.54 (a)(3) specify, in part, that each licensee described in paragraph (a)(1) of this section may make a change to a previously accepted quality assurance program description included or referenced in the Safety Analysis Report without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC.
The requirements of 10 CFR 71.101 (b) specify, in part, that each licensee, certificate holder, and applicant for a [Certificate of Compliance] (CoC) shall establish, maintain, and execute a quality assurance program satisfying each of the applicable criteria of §§ 71.101 through 71.137 and satisfying any specific provisions that are applicable to the licensee's activities including procurement of packaging.
The requirements of 10 CFR 71.101 (f) specify, in part, that a Commission-approved quality assurance program that satisfies the applicable criteria of subpart H of this part, appendix B of part 50 of this chapter, or subpart G of part 72 of this chapter, and that is established, maintained, and executed regarding transport packages, will be accepted as satisfying the requirements of paragraph (b) of this section.
Finally, the requirements of 10 CFR 71.106(a) specify, in part, that each quality assurance program approval holder shall submit, in accordance with § 71.1(a), a description of a proposed change to its NRC-approved quality assurance program that will reduce commitments in the program description as approved by the NRC. The quality assurance program approval holder shall not implement the change before receiving NRC approval.
Following its review of Revision 29 to the LACBWR QAPD against the above requirements, the staff has concluded that the proposed revision contains a reduction in commitments in the licensees quality assurance program. Revision 28 of the QAPD,Section II, Quality Assurance Program, Subsection F, Personnel Training and Qualification, specified minimum qualification requirements for an Operations Review Committee member, including a stipulation that equivalent qualifications shall be in accordance with American National Standards Institute (ANSI) standard 18.1-1971, Selection and Training of Nuclear Power Plant Personnel. The proposed revision to the LACBWR QAPD includes minimum qualification requirements for the position of Qualified Technical Reviewer, which will functionally replace the Operations Review Committee. The proposed minimum qualification allows for equivalent qualifications to be evaluated on a case by case basis.
Subsequent to the December 15, 2015, teleconference, the staff noted that the qualification requirements previously detailed in Revision 28 of the LACBWR QAPD were shifted to Administrative Control Procedure 20-2.02, QA Program - Qualified Technical Review (TR)
Process; however, this document is not considered part of a Commission-approved quality assurance program. Therefore, Dairylands proposed change to the qualification requirements specified for a Qualified Technical Reviewer represents a reduction in commitment in the licensees quality assurance program.
Accordingly, please either restore the minimum qualification requirements applicable to a Qualified Technical Reviewer to Revision 29 of the LACBWR QAPD, or provide a justification for how these requirements will continue to be met in Dairyland administrative procedures whose future revisions are not subject to NRC review and approval.