ML24243A104
| ML24243A104 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun, 07100256  |
| Issue date: | 09/12/2024 |
| From: | Jack Parrott Reactor Decommissioning Branch |
| To: | Focht S Omaha Public Power District |
| References | |
| EPID L-2024-LLN-0003 | |
| Download: ML24243A104 (1) | |
Text
Scott Focht, Vice President Corporate Strategy and Governance Omaha Public Power District 444 South 16th Street Mall Omaha, NE 68102-2247
SUBJECT:
PROPOSED REVISION TO THE OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DECOMMISSIONING QUALITY ASSURANCE PLAN -
REQUEST FOR ADDITIONAL INFORMATION (EPID# L-2024-LLN-0003)
Dear Scott Focht:
By letter dated May 16, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24137A278), Omaha Public Power District (OPPD) submitted a proposed revision to the Fort Calhoun Station, Unit No.1 (FCS) Decommissioning Quality Assurance Plan (DQAP) for review and approval by the U.S. Nuclear Regulatory Commission (NRC). Approval of the change was requested, in accordance with 10 CFR 50.54(a)(4)(iv), because the change involves aspects that are considered a reduction in commitment.
The NRC staff has reviewed OPPDs proposed change to its DQAP and has determined that additional information is required to complete its review. Our request for additional information is enclosed. We request that supplemental information requested in the enclosure to this letter be provided with 30 days from the date of this letter.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of ADAMS.
September 12, 2024
S. Focht 2
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions, please contact me at (301) 415-6634 or via e-mail at Jack.Parrott@nrc.gov.
Sincerely, Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos. 50-285,72-054, and 71-0256 License No. DPR-40
Enclosure:
Request for Additional Information CC:
Distribution via Listserv Scott Focht, OPPD smfocht@oppd.com Randy Hugenroth, OPPD rhugenroth@oppd.com Ben Pearson, OPPD bpearson@oppd.com Andi Barker, OPPD abarker@oppd.com Signed by Parrott, Jack on 09/12/24
S. Focht 3
SUBJECT:
PROPOSED REVISION TO THE OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DECOMMISSIONING QUALITY ASSURANCE PLAN - REQUEST FOR ADDITIONAL INFORMATION (EPID# L-2024-LLN-0003) DATE: September 12, 2024.
DISTRIBUTION:
Public Y. Law, NRR H. Rodriguez, NMSS G. Warnick, RIV ADAMS Accession Number: ML24243A104 OFFICE NMSS/DUWP/RDB NRR/DRO/IQVB NMSS/DUWP/RDB NMSS/DUWP/RDB NAME JParrott KKavanagh NWarnek JParrott DATE 9/10/2024 9/12/2024 9/12/2024 9/12/2024 OFFICIAL RECORD COPY
ENCLOSURE Request for Additional Information Fort Calhoun Unit 1 and Independent Spent Fuel Storage Installation Decommissioning Quality Assurance Plan, Revision 18 (Docket Numbers 50-285,72-054 and 71-0256)
RAI-1
By letter dated May 16, 2024 Agencywide Documents Access and Management System (ADAMS) Accession No. ML24137A278), Omaha Public Power District (OPPD) submitted to the U.S. Nuclear Regulatory Commission (NRC) for review and approval Revision 18 of the Decommissioning Quality Assurance Plan (DQAP) for the Fort Calhoun Station (FCS), Unit 1 and Independent Spent Fuel Storage Installation (ISFSI) that contains changes that are reductions in commitment in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54(a)(4).
The NRC staff has reviewed OPPDs proposed change to its DQAP and has determined that additional information is required to complete its review.
Criterion I, Organization, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, states, in part, that The persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
The persons and organizations performing quality assurance functions shall report to a management level so that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided. of the submittal included a list of changes. For the change in Chapter 1 of the proposed DQAP, the on-site position of Nuclear Oversight Manager is replaced by an off-site position called Quality Assurance (QA) Representative. OPPD states that the change in managerial level from a manager level role to a Quality Assurance Representative level role is considered a reduction in commitment when the Manager is transitioned at the end of the decommissioning project since there is no longer a requirement for a Nuclear Oversight Manager level position permanently stationed at the Fort Calhoun Station, and as such requires NRC approval prior to implementation. This change does not reduce the overall effectiveness of the DQAP. Site Quality Assurance personnel when on site will continue to ultimately report to the Vice President, Corporate Strategy and Governance (VP, CS&G). When designated by the VP, CS&G, the QA Representative will be responsible for the previously assigned Nuclear Oversight Manager duties and will report to the VP, CS&G.
The NRC staff requests OPPD to provide additional information for the following:
a) Who will have sufficient authority and organizational freedom to identify problems, and to initiate, recommend, or provide solutions; and to verify implementation of solutions, for issues related to QA?
b) Who will have the overall responsibilities that the Nuclear Oversight Manager would have, such as establishing, controlling, and verifying the implementation and adequacy of the QA program to ensure that the QA program is still in compliance with the requirements of Appendix B to 10 CFR Part 50?
2 c)
Who will have the required authority and organizational freedom to raise issues related to QA to the appropriate management level when cost and schedule priorities are present that are opposed to safety considerations?
RAI-2
Criterion II Quality Assurance Program, of Appendix B to 10 CFR Part 50 states, in part, that Quality Assurance Program shall provide the indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
In Section 1.2.2 of the proposed DQAP, the Nuclear Oversight personnel is changed to supplemental Nuclear Oversight personnel. The NRC staff requests OPPD to clarify the following:
a) Are these supplemental Nuclear Oversight personnel permanent or temporary hired contractors? If temporary hired contractors, what measures are in place to ensure that they receive the proper indoctrination and training before they perform activities that affect quality?
RAI-3
Criterion II Quality Assurance Program, of Appendix B to 10 CFR Part 50 states, in part, that The applicant shall regularly review the status and adequacy of the quality assurance program.
Management of other organizations participating in the quality assurance program shall regularly review the status and adequacy of that part of the quality assurance program which they are executing.
In Section 1.3.5 of the proposed DQAP, the Independent Safety Review (ISR) is removed. In Appendix D of the proposed DQAP, both the Independent Management Assessment (IMA) and ISR are removed. OPPD states that With the long-term scope of ISFSI focused on security and storage of spent nuclear fuel, there is a reduced need for an IMA and ISR to oversee important-to-safety work. Any reviews needed for design changes or work orders are controlled via written procedures and are sufficiently rigorous to ensure document and work reviews are conducted with the necessary rigor commensurate with the importance and safety significance of the work.
Deletion of the IMA and ISR functions from the DQAP are consistent with the Humboldt Bay ISFSI Only NRC approved QAP. The IMA and ISR functions are still contained in written procedures as an administrative tool but not dictated in the DQAP as a license basis document requirement.
OPPD references an NRC approved SER for Humboldt Bay (ADAMS Accession No. ML20092L173) as past precedent.
OPPD further states that This SER approved their DQAP with the IMA and ISR functions removed. However, since the entering conditions for use of the Humboldt Bay SER are not consistent with the FCS ISFSI Only entering conditions (in this case termination of the Part 50 license), FCS cannot implement this without prior NRC approval.
It is unclear to the NRC staff which section of the reference Humboldt Bay SER removed the IMA and ISR functions for Humboldt Bay. The NRC staff requests OPPD to clarify the following:
3 a) Which section of the Humboldt Bay SER is applicable to the proposed DQAP for FCS regarding the removal of IMA and ISR, in accordance with 10 CFR Part 50.54(a)(3)(ii)?
b) Without the periodic review function of the IMA and ISR, how is the QA program still being implemented effectively in accordance with the requirements of Appendix B to 10 CFR Part 50?
RAI-4
Criterion XVII, Quality Assurance Records, of Appendix B to 10 CFR Part 50 states, in part, that Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. The records shall also include closely-related data such as qualifications of personnel, procedures, and equipment. Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable.
The proposed DQAP deleted Paragraph C.3.0 Records Retention in Appendix D in its entirety.
For those records that furnish evidence of activities affecting quality, such as records and logs of activities related to the safe storage of irradiated fuel, and records/drawing changes reflecting facility design modification made to systems and equipment needed for the safe storage of irradiate fuel, the NRC staff requests OPPD to clarify the retention requirements of these records and how these records will be maintained.