ML24353A090

Safety Evaluation - Fort Calhoun DQAP

ML24353A090
Person / Time
Site:	Fort Calhoun, 07100256
Issue date:	01/13/2025
From:	Yiu Law Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Focht S Omaha Public Power District
References
EPID L-2024-LLN-0003
Download: ML24353A090 (1)

Text

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO REVISE THE DECOMMISSIONING QUALITY ASSURANCE PLAN OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT 1 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. 50-285,72-054 AND 71-0256

1.0 INTRODUCTION

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). The Revision contains changes that reduce commitments in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Part 50.54(a)(4).

As stated in the submittal, the proposed DQAP change transitions the DQAP to the next stage of decommissioning and aligns it with the intended end-state ISFSI-only site. Before this next stage, OPPD moved all spent nuclear fuel and greater than Class C waste to the ISFSI facility for long term storage.

The NRC staff reviewed OPPDs proposed changes to its DQAP and determined that additional information was required to complete its review. By letter dated September 12, 2024, the NRC staff issued a Request for Additional Information (RAI) to OPPD (ADAMS Accession No. ML24243A104). By letter dated October 7, 2024, OPPD submitted its response to the RAI (ADAMS Accession No. ML24281A166). By email dated October 24, 2024 (ADAMS Accession No. ML24318C319), the NRC staff issued a RAI clarification to OPPD. By letter dated November 20, 2024, OPPD submitted its response to the RAI clarification (ADAMS Accession No. ML24324A349).

2.0 REGULATORY BASIS The regulatory requirements for nuclear power plant Quality Assurance (QA) programs are set forth in 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, 10 CFR 50.34(b)(6)(ii), and 10 CFR 50.54(a). In addition, the Commissions regulatory requirements related to QA programs for the packaging and transportation of radioactive material and independent storage of spent nuclear fuel are addressed in 10 CFR Par 71, Subpart H, and 10 CFR Part 72, Subpart G, respectively.

Appendix B to 10 CFR Part 50 establishes the requirements for the design, fabrication, construction, and testing of structures, systems and components (SSCs). The pertinent requirements of Appendix B apply to all activities affecting the safety-related functions of

2 those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying of those SSCs.

10 CFR 50.34(b)(6)(ii) requires the final safety analysis report for a nuclear power plant to include information on the managerial and administrative controls that would ensure safe operation of the facility. The information on the controls shall also include a discussion on how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

10 CFR 50.54(a) requires each nuclear power plant licensee subject to the requirements of Appendix B to implement a QA program. 10 CFR 50.54(a)(4) sets forth the NRCs regulatory requirements regarding changes to a QA program description that are considered reductions in commitment. Changes to a QA program description that reduce the licensees commitments must be submitted to the NRC and receive approval prior to implementation. This includes changes made to the QA program description as presented in the safety analysis report or in a topical report that must be submitted as specified in 10 CFR 50.4.

10 CFR Part 71, Subpart H, establishes the quality assurance requirements applying to the design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair, and modification of components of packaging that are important to safety.

10 CFR Part 72, Subpart G, establishes the quality assurance requirements that apply to design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair, modification of SSCs, and decommissioning that are important to safety.

3.0 TECHNICAL EVALUATION

In reviewing the adequacy of the FCS DQAP, the NRC staff used guidance contained in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, Revision 1, dated August 2015 (ADAMS Accession No. 15037A441), which provides acceptance criteria for QA program descriptions. In addition, the NRC staff used the guidance in NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, dated March 2000 (ADAMS Accession No. ML003686776).

The primary changes proposed in Revision 18 of the FCS DQAP are detailed below:

1) Transition of a permanent position of Manager - Nuclear Oversight to a position of QA Representative that is not stationed permanently on site. The proposed FCS DQAP states that this new position of QA Representative reports to the Vice President - Corporate Strategy and Governance (VP, CS&G), shall not be assigned responsibilities that would prevent the required attention to important to safety matters, and shall have the necessary independence from other line management to

3 ensure effective oversight for all organizations. In addition, the FCS DQAP details the following responsibilities for the QA Representative:

Management of day-to-day oversight of implementation of the DQAP for all important to safety activities.

Authority and obligation to raise any conditions adverse to quality to the Chief Operating Officer and Vice President - Utility Operations (COO) for resolution.

Assuring important to safety activities are performed in accordance with implementing procedures.

Managing the performance of periodic audits, assessment, and inspections to verify important to safety activities have been correctly performed.

Reporting on oversight activities to the VP, CS&G.

Authority to stop work when quality is adversely affected.

From letter dated October 7, 2024 (ADAMS Accession No. ML24281A166), in response to RAI-1, OPPD states that the QA Representative will have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions for issues related to QA. Any responsibility previously assigned to the Manager - Nuclear Oversight will be assigned to the QA Representative. Furthermore, OPPD clarified that any Nuclear Oversight personnel, be it permanent OPPD employee or temporary hired contract employee, will have sufficient authority and organizational freedom to identify any quality problems and to verify implementation of corrective actions; will have direct access to the appropriate levels of management necessary to perform function; and will be independent from cost and schedule when opposed to quality and nuclear safety considerations.

The NRC staff reviewed the proposed change and determined that this change will continue to meet the guidance to establish clear lines of authority and responsibility for activities important to safety to be performed by applicant organizational elements and by contractors, whether onsite or offsite, as stated in Section 12.4.1 of NUREG-1567, and therefore, meets the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G.

2) The utilization of supplemental Nuclear Oversight personnel that are temporary hired contractors. The proposed FCS DQAP states that these supplemental Nuclear Oversight personnel report directly to the QA Representative, implement the relevant provisions of the DQAP utilizing written implementing procedures, and perform independent oversight of line functions and activities. Nuclear Oversight personnel shall not perform oversight activities for which they are directly responsible. Further, they have the responsibility and authority to stop work when quality is adversely affected and immediately raise concerns to the QA Representative.

From letter dated October 7, 2024 (ADAMS Accession No. ML24281A166), in response to RAI-2, OPPD clarifies that these supplemental Nuclear Oversight personnel are temporary hired contractors. To ensure these temporary hired contractors are qualified/certified to perform activities that affect quality, OPPD utilizes written procedures. In addition, wherever Quality Control (QC) Inspection personnel are need at the ISFSI, written procedure provides the guidance for

4 qualification verification of personnel temporarily hired as contract personnel for the appropriate QC inspection discipline.

The NRC staff reviewed the proposed change and determined that this change will continue to meet the guidance to establish clear lines of authority and responsibility for activities important to safety to be performed by applicant organizational elements and by contractors, whether onsite or offsite, as stated in Section 12.4.1 of NUREG-1567, and therefore, meets the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G.

3) The elimination of a separate manager solely responsible for decommissioning oversight. In the proposed FCS DQAP, one manager will now be responsible for decommissioning oversight and ISFSI operations, including ISFSI emergency planning, and will report to the COO. The proposed FCS DQAP further states that the elimination of a separate manager solely responsible for decommissioning oversight is consistent with the long-term ISFSI only condition. In addition, this manager position will be responsible for any decommissioning activities, and specific ISFSI focused responsibilities for spent fuel security and storage.

The NRC staff reviewed the proposed change and determined that this change will continue to meet the guidance to establish clear lines of authority and responsibility for activities important to safety to be performed by applicant organizational elements and by contractors, whether onsite or offsite, as stated in Section 12.4.1 of NUREG-1567, and therefore, meets the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G.

4) Update guidance for electronic storage records. In the proposed FCS DQAP, management of electronic storage of records will utilize the guidance in the following industry standards:

NIRMA TG11-2011, Authentication of Records and Media NIRMA TG15-2011, Management of Electronic Records NIRMA TG16-2011, Software Quality Assurance Documentation and Records NIRMA TG21-2011, Required Records Protection, Disaster Recovery and Business Continuation The NRC staff reviewed the proposed change and determined that this change is consistent with RG 1.28, Quality Assurance Program Criteria (Design and Construction), Revision 6, dated September 2023 (ADAMS Accession No. ML23177A002), and therefore, meets the requirements of Appendix B to 10 CFR Part 50.

5) The elimination of the Independent Management Assessment (IMA) and Independent Safety Review (ISR) in Appendix D of the FCS DQAP. In the proposed FCS DQAP, OPPD states that with the long-term scope of the 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. The IMA and

5 ISR functions are still contained in written procedures as an administrative tool but not dictated in the DQAP as a license basis document requirement.

From letter dated October 7, 2024 (ADAMS Accession No. ML24281A166), in response to RAI-3, OPPD states that the IMA and ISR functions will remain in written procedural guidance and can be used by site management to conduct reviews as needed. In addition, OPPD will conduct periodic audits in accordance with Paragraph 18.3, Audits of the FCS DQAP to ensure that the QA program is still being implemented effectively in accordance with the requirements of Appendix B to 10 CFR Part 50.

From letter dated November 20, 2024 (ADAMS Accession No. ML24324A349), in response to clarification RAI-3, OPPD clarifies that the IMA and ISR functions remain unchanged with Revision 18 of the DQAP. The IMA and ISR will remain part of the Stations processes as they are currently embedded in procedural requirements.

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.

The NRC staff reviewed the proposed change, and due to the reduced scope of important to safety work in the ISFSI only condition, the continuation of routine NRC inspections, and the continuation of OPPD conducting periodic audits, the NRC staff determined that this change will continue to meet the guidance in Section 12, Quality Assurance Evaluation, of NUREG-1567, and therefore, meets the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G.

6) The elimination of the FCS QA File Room (Energy Plaza QA Records Vault), as well as the deletion of Appendix D, Paragraph 3.0, Records Retention regarding record retention requirements in the DQAP. In the proposed FCS DQAP, OPPD states that the ISFSI only condition does not require a dedicated, separate QA vault for records.

These records are and can be maintained electronically and physically at the ISFSI Only Facility (IOF) at FCS. OPPD also states that the deletion of Appendix D, Paragraph 3.0 is acceptable as specific record retention requirements are controlled and maintained per written procedures and processes.

From letter dated October 7, 2024 (ADAMS Accession No. ML24281A166), in response to RAI-4, OPPD states that record retention guidance is prescribed in procedure, which describes the use of a Standard Record Retention Schedule (SRRS) which is maintained at FCS and other OPPD facilities. Specifically for FCS ISFSI location, procedure contains the detailed listing of procedural owners, record descriptions, and retention requirements.

The NRC staff reviewed the proposed change and determined that this change will continue to meet the guidance to generate, supply, or maintain, by or for the applicant, records of the quality of SSCs and activities important to safety, as stated in Section 12.4.17, QA Records, of NUREG-1567, and therefore, meets the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G.

7) The elimination of the Offsite Dose Calculation Manual (ODCM) in Appendix E of the FCS DQAP. In the proposed FCS DQAP, OPPD states that FCS ISFSI written procedures govern specific processes within the ODCM program and how ODCM

6 changes are made. The DQAP still requires an ODCM program in accordance with written procedures, which will govern how changes are made to the ODCM and program specific and detailed requirements.

The NRC staff reviewed the proposed change and determined this change will continue to meet the guidance in Section 11, Radiation Protection Evaluation, of NUREG-1567, and therefore, meets the requirements of 10 CFR Part 71, Subpart H, and 10 CFR Part 72, Subpart G.

4.0 CONCLUSION

The NRC staff used the acceptance criteria of NUREG-1567 and NUREG-0800, Section 17.5, as the basis for evaluating the acceptability of the changes to the FCS DQAP, in conformance with the applicable portions of 10 CFR Part 71, 10 CFR Part 72, and Appendix B to 10 CFR Part

50. The FCS DQAP adequately describes the provisions to meet the QA requirements of 10 CFR Part 71, 10 CFR Part 72, and Appendix B to 10 CFR Part 50 for activities that are important to safety for a facility that has moved all its spent fuel from the spent fuel pools to the ISFSI. Accordingly, the NRC staff concludes that the proposed changes to the FCS DQAP, Revision 18, follow the NRC guidance contained within NUREG-1567 and NUREG-0800, Section 17.5, and comply with the QA requirements contained in 10 CFR Part 71 and 10 CFR Part 72, and are, therefore, acceptable.

5.0 REFERENCES

1.

OPPD letter to the U.S. NRC, 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 (ADAMS Accession No. ML24137A278) 2.

U.S. NRC letter to OPPD, 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.

OPPD letter to the U.S. NRC, Response to Proposed Revision to the Omaha Public Power District (OPPD) For Calhoun Station (FCS) Decommissioning Quality Assurance Plan (DQAP) - Request for Additional Information, dated October 7, 2024 (ADAMS Accession No. ML24281A166) 4.

Email from the U.S. NRC to OPPD, Clarification Question on NRCs Review of the FCS DQAP Revision, dated October 24, 2024 (ADAMS Accession No, ML24318C319) 5.

OPPD letter to the U.S. NRC, 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, dated November 20, 2024 (ADAMS Accession No. ML24324A349) 6.

Safety Evaluation by the U.S. NRC, Haddam Neck Plant, Revision to the Connecticut Yankee Quality Assurance Program (CYQAP), dated December 20, 2005 (ADAMS Accession No. ML053630264)

7 7.

Safety Evaluation by the U.S. NRC, 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, dated September 24, 2018 (ADAMS Accession No. ML18101A231) 8.

Safety Evaluation by the U.S. NRC, Safety Evaluation Report for the Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0, dated April 17, 2020 (ADAMS Accession No. ML20092L173) 9.

Safety Evaluation by the U.S. NRC, Holtec Decommissioning International - Review and Acceptance of the Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program, dated January 12, 2021 (ADAMS Accession No. ML21011A106)

10. NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, dated March 2000 (ADAMS Accession No. ML003686776)

11. NUREG-0800, Standard Review Plan (SRP) 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, Revision 1, dated August 2015 (ADAMS Accession No. ML15037A441)

Principal Contributor: Yiu Law Date: December 6, 2024