LIC-24-0012, Independent Spent Fuel Storage Installation - Response to Proposed Revision to Decommissioning Quality Assurance Plan (DQAP) - Request for Additional Information
| ML24281A166 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun, 07100256  |
| Issue date: | 10/07/2024 |
| From: | Focht S Omaha Public Power District |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| LIC-24-0012 | |
| Download: ML24281A166 (1) | |
Text
EMPLOYMENT WITH EQUAL OPPORTUNITY 444 SOUTH 16TH STREET MALL
- OMAHA, NE 68102-2247 10 CFR 50.54(a)(4) 10 CFR 71.106 10 CFR 72.140 October 7, 2024 LIC-24-0012 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054 Omaha Public Power District - Fort Calhoun Quality Assurance Program Approval for Radioactive Material Packages NRC Docket No. 71-0256
Subject:
Response to Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (DQAP) -
Request for Additional Information
References:
- 1. Letter from OPPD (S. Focht) to USNRC (Document Control Desk), Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (DQAP), Unit No. 1 and ISFSI, dated May 16, 2024 (LIC-24-0008) (ADAMS Accession No. ML24137A278)
- 2. Letter from NRC (J. Parrot) to OPPD (S. Focht), Proposed Revision to the Omaha Public Power District Fort Calhoun Station Decommissioning Quality Assurance Plan - Request for Additional Information (EPID# L-2024-LLN-0003), dated September 12, 2024 (ADAMS Accession No. ML24243A104)
- 3. Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, San Onofre Nuclear Generating Station, Units 1, 2 and 3 and the Independent Spent Fuel Storage Installation - Review of Changes to the Decommissioning Quality Assurance Program (CAC 000083; EPIDS L-2018-DP3-0001, L-2018-DP3-0000, L-2018-DP3-0002, and L-2018-DP3-0003),
dated September 24, 2018 (ADAMS Accession No. ML18101A231) 4.
Safety Evaluation Report by the U.S. Nuclear Regulatory Commission, Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0 (CAC No.
001028), dated April 17, 2020 (ADAMS Accession No. ML20092L173)
Your Energy Partner
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Omaha Public Power District
U. S. Nuclear Regulatory Commission LIC-24-0012 Page 2 By letter dated May 16, 2024, Omaha Public Power District (OPPD) submitted to the 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)
(Reference 1) that contains changes that are reductions in commitment in accordance with 10 CFR 50.54(a)(4).
On September 12, 2024, the NRC provided OPPD with a Request for Additional Information (RAI) (Reference 2) regarding the DQAP proposal. Attachment 1 of this letter provides the responses to the RAls.
This letter contains no regulatory commitments.
If you should have any questions regarding this submittal or require additional information, please contact Mr. Randy Hugenroth - Manager, Nuclear Oversight at (531) 226-6032.
- Sin7iy, c:1J-tt+o,_ t~
Scott Focht Vice President, Corporate Strategy and Governance SMF/rjh Attachments: 1. Response to Request for Additional Information
J. Monninger, NRC Regional Administrator, Region IV J. D. Parrott, NRC Senior Project Manager (w/o enclosure)
S. G. Anderson, NRC Senior Health Physicist, Region IV (w/o enclosure)
M. T. Johnson, NRC Senior Health Physicist, Region IV (w/o enclosure)
LIC-24-0012 Attachment 1 Page 1 of 5 ATTACHMENT 1 Response to NRC Request for Additional Information Fort Calhoun Station Revision 18 to the Quality Assurance Topical Report Omaha Public Power District Fort Calhoun Station Unit No. 1 Docket No. 50-285,72-054, 71-025 Fort Calhoun Station (FCS) provides the following responses:
RAI-1
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?
Paragraph 1.2.3 of the proposal states Nuclear Oversight personnel shall have sufficient authority and organizational freedom to identify any quality problems and to verify implementation of corrective actions This language is from the NRC approved San Onofre Nuclear Generating Station (SONGS) QATR revision 9 Safety Evaluation Report which OPPD used for previous revisions of its DQAP. (Reference 3) OPPD agrees this paragraph does not capture all the 10 CFR 50 Appendix B wording. OPPD has modified the proposed revision 18 wording of paragraph 1.2.3 in attachment 2 of this letter to ensure all appendix B wording and intent is included in the DQAP language. The QA Representative will have sufficient authority and organizational freedom to identify quality problems; and initiate, recommend, or provide solutions; and to verify
LIC-24-0012 Attachment 1 Page 2 of 5 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?
The DQAP section 1 Organization states The Vice President, Corporate Strategy and Governance (VP, CS&G) ultimately reports to the OPPD CEO and has the overall responsibility for the establishment and execution of the FCS DQAP. Any responsibility previously assigned to the Manager - Nuclear Oversight will be assigned to the QA Representative who is delegated the responsibility for execution of those duties from the VP, CS&G. The QA Representative reporting structure, independence requirement, and responsibilities are listed in paragraph 1.2.1. These responsibilities assure establishment, control, and verification for 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.
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?
Paragraph 1.2.3 of the proposal currently states Nuclear Oversight personnel shall have sufficient authority and organizational freedom to identify any quality problems and to verify implementation of corrective actions. Additionally, Nuclear Oversight personnel shall have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and nuclear safety considerations. This paragraph, as modified in attachment 2, ensures that any Nuclear Oversight assigned personnel, be it permanent OPPD employee or temporary hired contract employee, 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?
These supplemental Nuclear Oversight personnel in this paragraph would be temporary hired contractors. In the final ISFSI only end state, OPPD envisions utilizing hired
LIC-24-0012 Attachment 1 Page 3 of 5 contractors to fill QA roles similar to the programs utilized by the 3-Yankee Companys decommissioning sites. To ensure these temporary hired contractors are qualified/certified to perform activities that affect quality, OPPD utilizes written procedures. In this case, procedure FCSI-NO-200, Quality Assessments, paragraph 5.24 Qualification / Certification or Re-qualification / Re-certification of Audit Team Leaders with Certifications provided by an outside Organization would guide the VP, CS&G or the designated QA Representative with determination of a temporary hired contractors indoctrination training and certification prior to performing activities that affect quality. This is the process OPPD has in place today and will continue in the future.
Whenever Quality Control Inspection personnel are needed at the ISFSI, procedure FCSI-NO-100, Quality Program Administration, provides the guidance for qualification verification of personnel temporarily hired as contract personnel for the appropriate QC inspection discipline.
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:
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)?
OPPD is requesting NRC approval under 10 CFR Part 50.54(a)(4) and is not utilizing the
LIC-24-0012 Attachment 1 Page 4 of 5 10 CFR Part 50.54(a)(3)(ii) language to request approval of this revision.
In the Safety Evaluation Report issued by the U.S. Nuclear Regulatory Commission, Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0 (CAC No. 001028), dated April 17, 2020 (ADAMS Accession No. ML20092L173) (Reference 4), the NRC approved the Humboldt Bay ISFSI QAP Revision 0 under 10 CFR 72 and 10 CFR 71. Because the ISFSI only end state status at OPPD is very similar to the Humboldt Bay ISFSI only status, OPPD is proposing to remove the IMA and ISR requirements from the DQAP.
Utilization of this Humboldt Bay modification to their DQAP for their 10 CFR part 71 and part 72 condition is an additional modification from the SONGS model OPPD has been using for its DQAP development.
In PG&E Letter HIL-19-001, Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan, Revision 0, dated February 14, 2019 (ADAMS Accession No. ML19045A700), PG&E provides a Compliance Matrix Between 10CFR71/10CFR72 Quality Requirements and the Applicable HB ISFSI QA Plan Sections. This Compliance Matrix does not include any IMA or ISR specific requirements. Their revision 0 was a new document developed when they removed the 10 CFR 50 license from their previous QAP. As such, there is no discussion around removing the IMA and ISR because it was never included in the revision 0 submission which was approved by the NRC (Reference 4).
To specifically answer the above question, the NRC approval of the Humboldt Bay QAP HBI-L6 Revision 0 submittal did not include the IMA or ISR functions that had existed in their QAP prior to their 10 CFR part 50 license termination.
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?
The proposed change removes the IMA and ISR from the License Basis Document DQAP. The IMA and ISR functions will remain in written procedural guidance and can be used by site management to conduct reviews as needed.
The FCS DQAP Paragraph 18.3 Audits requires Scheduling, preparation, personnel selection, performance, reporting, response, follow-up, and records management for audits are performed in accordance with written procedures. Audit scopes and schedules are based upon the status of work progress, important to safety activities being performed, and regulatory requirements. Paragraph 18.4 states in part The frequency of internal audits will be prescribed by the site implementing procedures which govern the conduct of QA audits. Procedure FCSI-NO-200, Quality Assessments, is the written procedure that governs how audits and assessments are scheduled, planned, and conducted at FCS. As part of the 24-month audit cycle, the QA Program is reviewed utilizing a checklist. The checklist includes all 18 criterion of 10 CFR 50 appendix B. The QA Program checklist is completed by an auditor who is not involved in day-to-day QA work at the site. This ensures that QA personnel do not conduct reviews of their own work and ensures that the QA program is still being implemented effectively in accordance with the requirements of Appendix B to 10 CFR Part 50.
Independent Safety Reviewers perform ISRs of proposed changes, tests and
LIC-24-0012 Attachment 1 Page 5 of 5 experiments important to safety SSCs, activities, program documents and procedures that are subject to the FCS DQAP requirements. The ISR function is intended to ensure an adequate review of important to safety activities. Governing procedures ensure this review occurs with or without an ISR involved as appropriate technical reviewers are considered and then assigned for reviews. Written procedures ensure the QA program is 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.
DQAP Paragraph 17.2 states Controls for the administration, identification, receipt, storage, preservation, safekeeping, retrieval, and disposition of records are provided in procedures. OPPD records retention guidance is prescribed in procedure EPND-RM-100, Records Management Program. This procedure describes use of a Standard Record Retention Schedule (SRRS) which is maintained at FCS and other OPPD facilities. Specifically for the FCS ISFSI location, procedure FCSI-AD-SRRS, Standard Retention Schedule, contains the detailed listing of procedural owners, record descriptions, and retention requirements. The deletion of the OPPD DQAP Paragraph C.3.0 is intended to better align the DQAP with the SONGS DQAP model that FCS has been utilizing for its DQAP development.
LIC-24-0012 Attachment 2 Page 1 of 1 ATTACHMENT 2 Response to NRC Request for Additional Information Revised Paragraph 1.2.3 of Proposed Revision 18 of the FCS DQAP Marked up paragraph 1.2.3 Nuclear Oversight personnel shall have sufficient authority and organizational freedom to identify any quality problems; and initiate, recommend, or provide solutions; and to verify implementation of corrective actions solutions. Additionally, Nuclear Oversight personnel shall have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and nuclear safety considerations.
Smooth paragraph 1.2.3 Nuclear Oversight personnel shall have sufficient authority and organizational freedom to identify quality problems; and initiate, recommend, or provide solutions; and to verify implementation of solutions. Additionally, Nuclear Oversight personnel shall have direct access to appropriate levels of management necessary to perform their function and shall be independent from cost and schedule when opposed to quality and nuclear safety considerations.