LIC-24-0015, Response to Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (DQAP) – Clarification of Request for Additional Information Response
| ML24324A349 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun, 07100256  |
| Issue date: | 11/20/2024 |
| 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-24-0015 | |
| Download: ML24324A349 (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 November 20, 2024 LIC-24-0015 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) -
Clarification of Request for Additional Information Response
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. Parrott) 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)
Response to Proposed Revision to the Omaha Public Power District (OPPD)
Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (DQAP) -Request for Additional Information, dated October 7, 2024 (LIC 0012) (ADAMS Accession No ML24281A166)
- 4. E-mail and RAI clarification question on the response to RAI-3 on the NRC review of the DQAP revision - License No. DPR-40, Docket No. 50-285 from NRC (J. Parrott) to OPPD, dated October 24, 2024 (ADAMS Accession No. ML24318C319)
Docusign Envelope ID: D717CC12-4A46-4881-8E95-3B0BF1AB7C70
U. S. Nuclear Regulatory Commission LIC-24-0015 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.
On October 7, 2024, OPPD provided to the NRC a response to the RAIs (reference 3).
On October 24, 2024, the NRC provided OPPD with a clarification question on response to RAI-3 on the NRC review of the DQAP revision (reference 4). Attachment 1 of this letter provides the clarification response to the NRC question.
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.
Sincerely, Scott Focht Vice President, Corporate Strategy and Governance SMF/rjh Attachments: 1. Clarification Response to RAI-3 of the NRCs Review of the FCS DQAP c:
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)
Docusign Envelope ID: D717CC12-4A46-4881-8E95-3B0BF1AB7C70
LIC-24-0015 Attachment 1 Page 1 of 2 ATTACHMENT 1 Clarification Response to RAI-3 of the NRCs Review of the FCS DQAP 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 The NRC RAI clarification for FCS DQAP revision is as follows:
In response to RAI-3, dated October 7, 2024 (ML24281A166) OPPD stated that the removal of the Independent Management Assessment (IMA) and Independent Safety Review (ISR) is a reduction in commitment requested under 10 CFR Part 50.54(a)(4), not under 10 CFR Part 50.54(a)(3)(ii). OPPD used a precedent of Humboldt Bay and stated that the Humboldt Bay ISFSI QAP, Revision 0 was approved without the inclusion of IMA and ISR (in other words, the Humboldt Bay ISFSI QAP was approved never having the IMA and ISR functions). The NRC staff does not believe the comparison between an approved QAP, that never had the IMA and ISR functions, to OPPD removing the IMA and ISR functions from its DQAP to be a valid comparison because the bases from the approved QAP may not be the same as OPPDs requested reduction in commitment. The NRC staff notes that in OPPDs original submittal, dated May 16, 2024 (ML24137A278), the SONGS DQAP was referenced. However, the SONGS DQAP submittal, dated May 1, 2018 (ML18124A055), specifically added the IMA and ISR functions to its DQAP to replace the Nuclear Oversight Board and Onsite Review Committee.
The NRC staff acknowledges that the audit requirements in Paragraph 18.3 of the proposed OPPD DQAP do not change and will provide the necessary audit requirements to satisfy Criterion XVIII of Appendix B to 10 CFR Part 50. However, the purposes and functions of audits are not the same as the purposes and functions of the IMA and ISR. The NRC staff also acknowledges that the IMA and ISR functions will remain in written procedural guidance, as stated in OPPDs RAI response. However, deleting the IMA and ISR functions from the DQAP will prevent the NRC from reviewing these functions in a future revision of the DQAP since it is not the NRCs practice to review implementing procedures in licensing review space.
Therefore, if the licensee intends to remove the IMA and ISR functions from its DQAP, which is a reduction in commitment, OPPD is requested to clarify how the functions and responsibilities of the IMA and ISR can still be achieved and reviewed by the NRC without the IMA and ISR in the DQAP. Also, OPPD is requested to clarify when and under what conditions will the IMA or ISR be used.
OPPD Response:
The IMA and ISR functions remain unchanged with revision 18 to the DQAP. IMA and ISR will remain part of the Stations processes as they are currently embedded in procedural requirements. There is no longer a need to contain these functions within the scope of the DQAP.
In the future, it is envisioned that removing the IMA and ISR requirements from the DQAP provides the OPPD ISFSI Only organization a degree of management freedom to potentially adjust resources to align with the reduced risk associated with the static spent fuel storage condition. In support of this, OPPD knows of no known regulatory requirement for the IMA or Docusign Envelope ID: D717CC12-4A46-4881-8E95-3B0BF1AB7C70
LIC-24-0015 Attachment 1 Page 2 of 2 ISR. The independent external and internal reviews originated in ANSI-N18.7-1972, American National Standard for Administrative Controls for Nuclear Power Plants. This standard is intended for administrative controls for nuclear power plants during operation, therefore it does not have direct applicability to a decommissioning/decommissioned nuclear power plant.
The purpose of the IMA is to evaluate the effectiveness of the FCS QA Program. In an ISFSI only condition, many of the QA program requirements are in a state of dormancy, e.g., QC inspections. These requirements would be reconstituted as needed for any work required on important-to-safety equipment. Therefore, there is very low risk of the QA program having conducted any work, beyond periodic audits, that would solicit an external review to judge program effectiveness. Required periodic audits of the QA program and routine NRC inspections would detect any potential issues. Additionally, the biannual audit of the QA program is conducted per procedure by individuals independent from and having no direct responsibility for the area being audited.
The purpose of the ISR is to perform reviews of proposed changes, tests, and experiments on important-to-safety SSCs, activities, program documents and procedures that are subject to the FCS DQAP requirements. This level of review is infrequent. Documentation that rises to this level, e.g., an engineering change on an important-to-safety SSC, has procedurally driven engineering reviews, peer checks, and approvals built into the process. Additionally, the Certificate of Compliance holder, TN Americas, would prepare and submit to OPPD technical or engineering change documentation that would require OPPD owner review and acceptance.
There are sufficient procedurally driven reviews associated with this process that the ISR review could still be designated for review, but the ISR review may not be needed, or value added. For any regulatory documents or changes that would rise to the ISR level, procedural guidance drives detailed reviews and approvals as well. Additionally, required periodic audits and routine NRC inspections would detect any potential issues. The ISR review could still be designated for review, but the ISR review may not be needed, or value added.
The NRC responsibilities for review of processes associated with the IMA and ISR functions are included in the NRC inspection process for decommissioning power reactors under IMC 2561.
The following NRC inspection procedures would allow and guide the NRC to review IMA and ISR processes as a part of their inspection program:
IP 37801, Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (PSRs)
IP 40801, Problem Identification and Resolution at Permanently Shutdown Reactors IP 71801, Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors Docusign Envelope ID: D717CC12-4A46-4881-8E95-3B0BF1AB7C70