IR 05000409/2008001: Difference between revisions

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| issue date = 09/12/2008
| issue date = 09/12/2008
| title = IR 05000409-08-01; Dairyland Power Cooperative; 08/12-12/2008; (DNMS) - La Crosse Boiling Water Reactor (LACBWR)
| title = IR 05000409-08-01; Dairyland Power Cooperative; 08/12-12/2008; (DNMS) - La Crosse Boiling Water Reactor (LACBWR)
| author name = Lipa C A
| author name = Lipa C
| author affiliation = NRC/RGN-III/DNMS/DB
| author affiliation = NRC/RGN-III/DNMS/DB
| addressee name = Berg W L
| addressee name = Berg W
| addressee affiliation = Dairyland Power Cooperative
| addressee affiliation = Dairyland Power Cooperative
| docket = 05000409
| docket = 05000409
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:ber 12, 2008
[[Issue date::September 12, 2008]]


Mr. W. General Manager Dairyland Power Cooperative 3200 East Avenue South P.O. Box 817 La Crosse, WI 54602-0817
==SUBJECT:==
 
NRC INSPECTION REPORT 050-00409/08-01(DNMS) - LA CROSSE BOILING WATER REACTOR (LACBWR)
SUBJECT: NRC INSPECTION REPORT 050-00409/08-01(DNMS) - LA CROSSE BOILING WATER REACTOR (LACBWR)


==Dear Mr. Berg:==
==Dear Mr. Berg:==
On August 13, 2008, the NRC completed an inspection at the La Crosse Boiling Water Reactor (LACBWR) facility. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements in the areas of facility management and control, decommissioning support, radiological safety, and spent fuel safety. At the conclusion of the inspection on August 13, 2008, the NRC inspectors discussed the results with members of your staff.
On August 13, 2008, the NRC completed an inspection at the La Crosse Boiling Water Reactor (LACBWR) facility. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements in the areas of facility management and control, decommissioning support, radiological safety, and spent fuel safety. At the conclusion of the inspection on August 13, 2008, the NRC inspectors discussed the results with members of your staff.


The inspection consisted of an examination of activities at the facility as they relate to safety and compliance with the Commission's rules and regulations. Specific areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, field observations of activities in progress, and interviews with personnel.
The inspection consisted of an examination of activities at the facility as they relate to safety and compliance with the Commissions rules and regulations. Specific areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, field observations of activities in progress, and interviews with personnel.


Based on the results of this inspection, the NRC did not identify any violations.
Based on the results of this inspection, the NRC did not identify any violations.


In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). The NRC's document system is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. We will gladly discuss any questions you have concerning this inspection.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). The NRCs document system is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. We will gladly discuss any questions you have concerning this inspection.


Sincerely,/RA/
Sincerely,
Christine Lipa, Chief Decommissioning Branch Division of Nuclear Materials Safety Docket No. 050-00409 License No. DPR-45  
/RA/
Christine Lipa, Chief Decommissioning Branch Division of Nuclear Materials Safety Docket No. 050-00409 License No. DPR-45


===Enclosure:===
===Enclosure:===
Inspection Report 050-00409/08-01(DNMS)
Inspection Report 050-00409/08-01(DNMS)
cc w/encl: Roger Christians, Plant Manager B. D. Burks, P.E., Director, Bureau of Field Operations J. Mettner, Chairman, Wisconsin Public Service Commission Spark Burmaster, Coulee Region Energy Coalition State Liaison Officer Chief, Radiation Protection Section WI Department of Health and Social Services, Division of Health DISTRIBUTION w/encl
: Docket File PUBLIC IE-01 RIII PRR K. L. Banovac, FSME A. Persinko, FSME G. W. Purdy, NSIR M. Satorius, RIII S. Reynolds, RIII J Madera, RIII RIII Enf. Coordinator DOCUMENT NAME: G:\SEC\Work in progress\LACBWR 2008 001 DNMS.doc X Publicly Available Non-Publicly Available Sensitive X Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII C RIII C C NAME PJLee:rj WGSnell CALipa DATE 09/11/08 09/11/08 09/12/08 OFFICIAL RECORD COPY
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III


REGION III==
Docket No.: 050-00409 License No.: DPR-45 Report No. : 050-00409/08-01(DNMS)
Docket No.: 050-00409 License No.: DPR-45 Report No. : 050-00409/08-01(DNMS)
Licensee: Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602  
Licensee: Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602 Facility: La Crosse Boiling Water Reactor Location: La Crosse Site Genoa, Wisconsin Dates: August 12 through 13, 2008 Inspectors: Peter J. Lee, Ph.D., CHP, Health Physicist William Snell, Senior Health Physicist Kristina Banovac, Project Manager, FSME Approved by: Christine Lipa, Chief Decommissioning Branch Division of Nuclear Materials Safety Enclosure


Facility: La Crosse Boiling Water Reactor Location: La Crosse Site Genoa, Wisconsin Dates: August 12 through 13, 2008
EXECUTIVE SUMMARY La Crosse Boiling Water Reactor (LACBWR)
 
NRC Inspection Report 050-00409/08-01 (DNMS)
Inspectors: Peter J. Lee, Ph.D., CHP, Health Physicist William Snell, Senior Health Physicist Kristina Banovac, Project Manager, FSME
 
Approved by: Christine Lipa, Chief Decommissioning Branch Division of Nuclear Materials Safety
 
Enclosure 2 EXECUTIVE SUMMARY La Crosse Boiling Water Reactor (LACBWR) NRC Inspection Report 050-00409/08-01 (DNMS)
This routine decommissioning inspection covered aspects of facility management and control, decommissioning support activities, radiological safety, and spent fuel safety.
This routine decommissioning inspection covered aspects of facility management and control, decommissioning support activities, radiological safety, and spent fuel safety.


Facility Management and Control
Facility Management and Control
* The inspectors determined that the licensee staffing was adequate for the decommissioning activities being performed, and that the training requirements of the Decommissioning Plan were being met. (Section 1.1)  
* The inspectors determined that the licensee staffing was adequate for the decommissioning activities being performed, and that the training requirements of the Decommissioning Plan were being met. (Section 1.1)
* The inspectors determined that the licensee's process for evaluating the safety impacts of facility changes and modifications was in compliance with the requirements of 10 CFR 50.59. (Section 1.2)  
* The inspectors determined that the licensees process for evaluating the safety impacts of facility changes and modifications was in compliance with the requirements of 10 CFR 50.59. (Section 1.2)
 
* The inspectors determined that the licensee had enhanced its Quality Assurance program to better address dry cask activities, and were adequately identifying and addressing conditions adverse to quality. The Radiation Safety Committee was meeting and carrying out its responsibilities as required. (Section 1.3)
* The inspectors determined that the licensee had enhanced its Quality Assurance program to better address dry cask activities, and were adequately identifying and addressing conditions adverse to quality. The Radiation Safety Committee was meeting and carrying out its responsibilities as required. (Section 1.3)  
* The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas. (Section 1.4)
* The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas. (Section 1.4)
Decommissioning Support Activities
Decommissioning Support Activities
 
* The licensees maintenance and surveillance activities were conducted in accordance with the maintenance rule, as stated in 10 CFR Part 50.65. (Section 2.1)
* The licensee's maintenance and surveillance activities were conducted in accordance with the maintenance rule, as stated in 10 CFR Part 50.65. (Section 2.1)
Radiological Safety
Radiological Safety
* The inspectors determined that the licensee continued to be effective in controlling radiation worker personal exposure. (Section 3.1)
* The inspectors determined that the licensee adequately implemented its effluent monitoring program. (Section 3.2)
* The inspectors determined that the licensee complied with regulatory requirements for shipping radioactive materials. (Section 3.3)
Spent Fuel Safety
* The inspectors determined that the licensee properly maintained the Spent Fuel Element Storage Well water level, temperature, chemistry, and cleanliness to ensure the safe wet storage of the spent fuel. (Section 4.1)
2  Enclosure


* The inspectors determined that the licensee continued to be effective in controlling radiation worker personal exposure. (Section 3.1)
Report Details1 Summary of Plant Activities The licensees current activities were focused on routine operations regarding the safe storage of spent fuel in the fuel pool and preparations for the dry fuel storage project.
* The inspectors determined that the licensee adequately implemented its effluent monitoring program. (Section 3.2)
* The inspectors determined that the licensee complied with regulatory requirements for shipping radioactive materials. (Section 3.3)
Spent Fuel Safety
* The inspectors determined that the licensee properly maintained the Spent Fuel Element Storage Well water level, temperature, chemistry, and cleanliness to ensure the safe wet storage of the spent fuel. (Section 4.1)
Enclosure 3 Report Details 1 Summary of Plant Activities The licensee's current activities were focused on routine operations regarding the safe storage of spent fuel in the fuel pool and preparations for the dry fuel storage project.


1.0 Facility Management and Control 1.1 Organization, Management and Cost Controls (IP 36801)
1.0 Facility Management and Control 1.1 Organization, Management and Cost Controls (IP 36801)
a. Inspection Scope The inspectors evaluated the licensees decommissioning staffing and reviewed the training program and training records for the current calendar year, including the fuel handler training, radiation protection training, and general employee training. The inspectors also reviewed the training for the contract workers who were granted unescorted access to conduct work in the restricted area.


a. Inspection Scope The inspectors evaluated the licensee's decommissioning staffing and reviewed the training program and training records for the current calendar year, including the fuel handler training, radiation protection training, and general employee training. The inspectors also reviewed the training for the contract workers who were granted unescorted access to conduct work in the restricted area.
b. Observations and Findings The licensees staffing was adequate for the level of work being performed and met requirements of Technical Specifications. A review of the training program and training records identified that the workers had received the required training specified in the Decommissioning Plan.
 
b. Observations and Findings The licensee's staffing was adequate for the level of work being performed and met requirements of Technical Specifications. A review of the training program and training records identified that the workers had received the required training specified in the Decommissioning Plan.


c. Conclusions The inspectors determined that the licensee staffing was adequate for the decommissioning activities being performed, and that the training requirements of the Decommissioning Plan were being met.
c. Conclusions The inspectors determined that the licensee staffing was adequate for the decommissioning activities being performed, and that the training requirements of the Decommissioning Plan were being met.


1.2 Safety Reviews, Design Changes and Modifications (37801)
1.2 Safety Reviews, Design Changes and Modifications (37801)
a. Inspection Scope The inspectors reviewed the licensee's 10 CFR 50.59 safety screening reviews of several facility changes since the last inspection to assess the licensee's conclusions regarding the need for safety evaluations.
a. Inspection Scope The inspectors reviewed the licensees 10 CFR 50.59 safety screening reviews of several facility changes since the last inspection to assess the licensees conclusions regarding the need for safety evaluations.
 
b. Observations and Findings The inspectors verified that the safety review process stated in LACBWR Administrative Control Procedure (ACP)-06.4, 10 CFR 50.59 Reviews, dated April 21, 2003, was consistent with the requirements of 10 CFR 50.59. The licensee conducted safety screening reviews per ACP-06.4. The activities all involved facility changes that did not adversely affect the design functions of the structures, systems, and components (SSCs) as described in the licensees Decommissioning Plan and none of the facility changes required the safety evaluations.


b. Observations and Findings The inspectors verified that the safety review process stated in LACBWR Administrative Control Procedure (ACP)-06.4, "10 CFR 50.59 Reviews," dated April 21, 2003, was consistent with the requirements of 10 CFR 50.59. The licensee conducted safety screening reviews per ACP-06.4. The activities all involved facility changes that did not adversely affect the design functions of the structures, systems, and components (SSCs) as described in the licensee's Decommissioning Plan and none of the facility changes required the safety evaluations.
NOTE: A list of acronyms used in the report is included at the end of the report.


1NOTE: A list of acronyms used in the report is included at the end of the report.
3  Enclosure


Enclosure 4 c. Conclusions The inspector determined that the licensee's process for evaluating the safety impacts of facility changes and modifications was in compliance with the requirements of 10 CFR 50.59.
c. Conclusions The inspector determined that the licensees process for evaluating the safety impacts of facility changes and modifications was in compliance with the requirements of 10 CFR 50.59.


1.3 Self Assessment, Auditing, and Corrective Actions (40801)
1.3 Self Assessment, Auditing, and Corrective Actions (40801)
a. Inspection Scope The inspectors reviewed the licensee's activities associated with quality assurance (QA), identification and tracking of corrective actions, and Safety Review Committee (SRC) commitments. The inspectors reviewed the licensee's Quality Assurance Project Plan (QAPP) for the Dry Cask Storage Project, Revision 1, dated June 2, 2008, ACP- 04.1, "Design and Facility Change Control", Issue 35, ACP-16.0, "Quality Assurance Deficiency Reports and Deposition of Non-Conforming Materials, Parts, and Components", Issue 16, ACP-2.14, "Safety Review Committee (SRC)", Issue 14, and the Final Minutes of the April 29, 2008, LACBWR SRC Meeting. The inspectors met with licensee personnel and reviewed and discussed the QAPP Appendix A Program Implementation Matrix and the identification and disposition of items identified in Corrective Action Requests (CARs).
a. Inspection Scope The inspectors reviewed the licensees activities associated with quality assurance (QA),
identification and tracking of corrective actions, and Safety Review Committee (SRC)
commitments. The inspectors reviewed the licensees Quality Assurance Project Plan (QAPP) for the Dry Cask Storage Project, Revision 1, dated June 2, 2008, ACP- 04.1, Design and Facility Change Control, Issue 35, ACP-16.0, Quality Assurance Deficiency Reports and Deposition of Non-Conforming Materials, Parts, and Components, Issue 16, ACP-2.14, Safety Review Committee (SRC), Issue 14, and the Final Minutes of the April 29, 2008, LACBWR SRC Meeting. The inspectors met with licensee personnel and reviewed and discussed the QAPP Appendix A Program Implementation Matrix and the identification and disposition of items identified in Corrective Action Requests (CARs).


b. Observations and Findings The licensee developed its QAPP for the Dry Cask Storage Project to control work in a project based approach specific to dry cask storage activities. The QAPP incorporates the existing Quality Assurance Program Description (QAPD), site procedures, and corporate procedures, as applicable to the project. The QAPP enhanced the corrective action process specified in the QAPD by including a CAR process to promptly address and track conditions adverse to quality. A review of open CAR items as well as recently closed CAR items indicated issues were being adequately tracked and addressed in a timely manner. A review of the minutes from the most recent SRC Meeting April 29, 2008) indicated that the requirement to meet at least once per year and the quorum requirements were met. The inspectors' review of the SRC Meeting Minutes determined that the SRC was appropriately addressing the type of issues identified in Section 4.7 of ACP-2.14 as pertinent to the SRC, as required.
b. Observations and Findings The licensee developed its QAPP for the Dry Cask Storage Project to control work in a project based approach specific to dry cask storage activities. The QAPP incorporates the existing Quality Assurance Program Description (QAPD), site procedures, and corporate procedures, as applicable to the project. The QAPP enhanced the corrective action process specified in the QAPD by including a CAR process to promptly address and track conditions adverse to quality. A review of open CAR items as well as recently closed CAR items indicated issues were being adequately tracked and addressed in a timely manner. A review of the minutes from the most recent SRC Meeting April 29, 2008) indicated that the requirement to meet at least once per year and the quorum requirements were met. The inspectors review of the SRC Meeting Minutes determined that the SRC was appropriately addressing the type of issues identified in Section 4.7 of ACP-2.14 as pertinent to the SRC, as required.


c. Conclusions The inspectors determined that the licensee had enhanced its Quality Assurance program to better address dry cask activities, and was adequately identifying and addressing conditions adverse to quality. The SRC was meeting and carrying out its responsibilities as required.
c. Conclusions The inspectors determined that the licensee had enhanced its Quality Assurance program to better address dry cask activities, and was adequately identifying and addressing conditions adverse to quality. The SRC was meeting and carrying out its responsibilities as required.


1.4.1 Decommissioning Performance and Status Review at Permanently Shut Down Reactors (71801) a. Inspection Scope
1.4.1 Decommissioning Performance and Status Review at Permanently Shut Down Reactors (71801)
a. Inspection Scope The inspectors conducted plant tours to assess field conditions and decommissioning activities and ensure that radioactively contaminated areas were being controlled.


The inspectors conducted plant tours to assess field conditions and decommissioning activities and ensure that radioactively contaminated areas were being controlled.
4  Enclosure


Enclosure 5 b. Observations and Findings During site tours the inspectors noted that the material condition of facilities and equipment was commensurate with current decommissioning activities. The individuals conducting the tours with the inspectors were cognizant of the work activities in process, the dose levels throughout the facilities, and the locations of contaminated areas. Work areas were observed to be adequately controlled, postings and boundaries were appropriate, and workers were wearing personal protective clothing that was suitable for the work they were performing.
b. Observations and Findings During site tours the inspectors noted that the material condition of facilities and equipment was commensurate with current decommissioning activities. The individuals conducting the tours with the inspectors were cognizant of the work activities in process, the dose levels throughout the facilities, and the locations of contaminated areas. Work areas were observed to be adequately controlled, postings and boundaries were appropriate, and workers were wearing personal protective clothing that was suitable for the work they were performing.


c. Conclusions The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas.
c. Conclusions The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas.


2.0 Decommissioning Support Activities 2.1 Maintenance and Surveillance (62801)
2.0 Decommissioning Support Activities 2.1 Maintenance and Surveillance (62801)
a. Inspection Scope The inspectors reviewed the licensee's maintenance requests and surveillances for 2008, and biannual assessment of maintenance effectiveness of structures, systems, and components (SSCs) during 2006 and 2007, to verify that maintenance and surveillance for SSCs were conducted in a manner that resulted in the safe storage of spent fuel.
a. Inspection Scope The inspectors reviewed the licensees maintenance requests and surveillances for 2008, and biannual assessment of maintenance effectiveness of structures, systems, and components (SSCs) during 2006 and 2007, to verify that maintenance and surveillance for SSCs were conducted in a manner that resulted in the safe storage of spent fuel.


b. Observations and Findings The maintenance and surveillance for SSCs were conducted in accordance with the licensee's program that implemented 10 CFR Part 50.65 " Maintenance Rule" Based on the risk assessment of SSCs, the licensee established 13 functional goals and developed associated monitoring and frequency for each goal. There were four incident reports generated during 2007 and 2008. None of the incidents adversely affected SSC design functions and correction actions had been taken. The licensee's periodic assessments indicated that all functional goals of the SSCs were met.
b. Observations and Findings The maintenance and surveillance for SSCs were conducted in accordance with the licensees program that implemented 10 CFR Part 50.65 Maintenance Rule Based on the risk assessment of SSCs, the licensee established 13 functional goals and developed associated monitoring and frequency for each goal. There were four incident reports generated during 2007 and 2008. None of the incidents adversely affected SSC design functions and correction actions had been taken. The licensees periodic assessments indicated that all functional goals of the SSCs were met.


c. Conclusions The licensee's maintenance and surveillance activities were conducted in accordance with the maintenance rule, as stated in 10 CFR Part 50.65.
c. Conclusions The licensees maintenance and surveillance activities were conducted in accordance with the maintenance rule, as stated in 10 CFR Part 50.65.


3.0 Radiological Safety 3.1 Occupational Radiation Exposure (83750)
3.0 Radiological Safety 3.1 Occupational Radiation Exposure (83750)
a. Inspection Scope The inspectors reviewed the As-Low-As-is-Reasonably-Achievable (ALARA) reviews and radiation work permits for removal of the recirculation piping from the reactor lower cavity during August, 2008. The inspector verified that the licensee had established Enclosure 6procedures, and engineering work controls that were based on sound radiation protection principles in order to achieve occupational exposures that were ALARA.
a. Inspection Scope The inspectors reviewed the As-Low-As-is-Reasonably-Achievable (ALARA) reviews and radiation work permits for removal of the recirculation piping from the reactor lower cavity during August, 2008. The inspector verified that the licensee had established Enclosure
 
procedures, and engineering work controls that were based on sound radiation protection principles in order to achieve occupational exposures that were ALARA.


b. Observations and Findings The licensee provided sufficient shielding of radiation sources in a practical manner.
b. Observations and Findings The licensee provided sufficient shielding of radiation sources in a practical manner.


Also, to reduce potential intakes of radioactive materials, the licensee installed high efficiency particulate air filter-equipped (HEPA) filtration systems in the vicinity of the work areas, and workers also wore half-face mask respirators in the reactor lower cavity area. Based on the review of external exposure records, workers received doses less than the dose limits specified in radiation work permits. The total personnel external exposures were 9602 mrem and the highest dose received by an individual was 1860 mrem. Air sampling data indicated that most of the internal dose was due to americium-241.
Also, to reduce potential intakes of radioactive materials, the licensee installed high efficiency particulate air filter-equipped (HEPA) filtration systems in the vicinity of the work areas, and workers also wore half-face mask respirators in the reactor lower cavity area.


Based on the DAC-hours dose assessments, the total personnel committed effective dose equivalents (CEDE) were 620 mrem and the highest CEDE received by an individual was 182 mrem.
Based on the review of external exposure records, workers received doses less than the dose limits specified in radiation work permits. The total personnel external exposures were 9602 mrem and the highest dose received by an individual was 1860 mrem. Air sampling data indicated that most of the internal dose was due to americium-241. Based on the DAC-hours dose assessments, the total personnel committed effective dose equivalents (CEDE) were 620 mrem and the highest CEDE received by an individual was 182 mrem.


c. Conclusions The inspector determined that the licensee continued to be effective in controlling radiation worker personal exposure.
c. Conclusions The inspector determined that the licensee continued to be effective in controlling radiation worker personal exposure.


3.2 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)
3.2 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)
a. Inspection Scope The inspectors evaluated the licensee's activities to effectively control, monitor, and quantify releases of radioactive materials in liquid, gaseous, and particulate forms to the environment. The inspectors reviewed the licensee's 2007 "Effluent and Environmental Monitoring Reports," and the Offsite Dose Calculation Manual (ODCM).
a. Inspection Scope The inspectors evaluated the licensees activities to effectively control, monitor, and quantify releases of radioactive materials in liquid, gaseous, and particulate forms to the environment. The inspectors reviewed the licensees 2007 Effluent and Environmental Monitoring Reports, and the Offsite Dose Calculation Manual (ODCM).
 
b. Observations and Findings The licensees gaseous effluent monitors and waste water effluent monitor were calibrated and checked for proper operation in accordance with station procedures.


b. Observations and Findings The licensee's gaseous effluent monitors and waste water effluent monitor were calibrated and checked for proper operation in accordance with station procedures. The licensee participates in a cross check program with an off-site laboratory to confirm the quality of its analytical data. Results of a cross check of licensee laboratory results completed in calendar year 2007 indicated agreement in all analytical data.
The licensee participates in a cross check program with an off-site laboratory to confirm the quality of its analytical data. Results of a cross check of licensee laboratory results completed in calendar year 2007 indicated agreement in all analytical data.


The ODCM was comprehensive and contained the requirements listed in the licensee's technical specifications. The effluent monitoring data indicated that release concentrations were consistent with limits specified in 10 CFR Part 20, Appendix B, Table 2, and that doses to the general public were in conformance with Appendix I of 10 CFR Part 50. Further, environmental sampling results indicated only background radiation levels with no distinct contribution from the shutdown reactor.
The ODCM was comprehensive and contained the requirements listed in the licensees technical specifications. The effluent monitoring data indicated that release concentrations were consistent with limits specified in 10 CFR Part 20, Appendix B, Table 2, and that doses to the general public were in conformance with Appendix I of 10 CFR Part 50. Further, environmental sampling results indicated only background radiation levels with no distinct contribution from the shutdown reactor.


c. Conclusions The inspectors determined that the licensee adequately implemented its effluent monitoring program.
c. Conclusions The inspectors determined that the licensee adequately implemented its effluent monitoring program.


Enclosure 73.3 Transportation of Radioactive Materials (86750)
Enclosure
 
3.3 Transportation of Radioactive Materials (86750)
a. Inspection Scope The inspector reviewed the radioactive materials shipping program and applicable shipping documents. The inspector evaluated whether the licensee was in compliance with NRC and Department of Transportation (DOT) shipping requirements.
a. Inspection Scope The inspector reviewed the radioactive materials shipping program and applicable shipping documents. The inspector evaluated whether the licensee was in compliance with NRC and Department of Transportation (DOT) shipping requirements.


b. Observations and Findings The licensee has processed thirteen waste shipments since the last inspection. The waste contained concrete shield blocks, and recirculation piping. The licensee shipped the radiological waste to Energy Solutions sites in Clive, Utah, and Kingston and Oak Ridge, Tennessee. The licensee's shipping manifest showed that personnel packaged, labeled, and marked each shipping container according to the DOT and 10 CFR Part 71 transportation requirements. The licensee verified that the results of radiation and removable contamination levels were within applicable limits. The waste manifest included all required information.
b. Observations and Findings The licensee has processed thirteen waste shipments since the last inspection. The waste contained concrete shield blocks, and recirculation piping. The licensee shipped the radiological waste to Energy Solutions sites in Clive, Utah, and Kingston and Oak Ridge, Tennessee. The licensees shipping manifest showed that personnel packaged, labeled, and marked each shipping container according to the DOT and 10 CFR Part 71 transportation requirements. The licensee verified that the results of radiation and removable contamination levels were within applicable limits. The waste manifest included all required information.


c. Conclusions The inspector determined that the licensee complied with regulatory requirements for shipping radioactive materials.
c. Conclusions The inspector determined that the licensee complied with regulatory requirements for shipping radioactive materials.


4.0 Spent Fuel Safety
4.0 Spent Fuel Safety 4.1 Spent Fuel Pool Safety at Permanently Shutdown Reactors (60801)
a. Inspection Scope The inspectors reviewed the licensees activities to ensure the safe wet storage of spent fuel in the Fuel Element Storage Well (FESW). The review included the verification of water temperature, and water level requirements of Technical Specification (TS) 4.1.2, the surveillance requirements of TS 5.1.2, and the water chemistry and cleanliness control requirements of the licensees Health and Safety Procedure HSP-7.2, for the period of January through July 2008.


4.1 Spent Fuel Pool Safety at Permanently Shutdown Reactors (60801)
b. Observations and Findings All parameters reviewed were consistent with limits specified in HSP-7.2, Sampling of Fuel Element Storage Well. The FESW water level and temperature met the requirements of TS 4.1.2. The FESW water level and temperature had been monitored daily as required by the surveillance requirements of TS 5.1.2.1.


a. Inspection Scope The inspectors reviewed the licensee's activities to ensure the safe wet storage of spent fuel in the Fuel Element Storage Well (FESW). The review included the verification of water temperature, and water level requirements of Technical Specification (TS) 4.1.2, the surveillance requirements of TS 5.1.2, and the water chemistry and cleanliness control requirements of the licensee's Health and Safety Procedure HSP-7.2, for the period of January through July 2008.
c. Conclusions The inspectors determined that the licensee properly maintained the FESW water level, temperature, chemistry, and cleanliness to ensure the safe wet storage of the spent fuel.
 
b. Observations and Findings All parameters reviewed were consistent with limits specified in HSP-7.2, "Sampling of Fuel Element Storage Well." The FESW water level and temperature met the requirements of TS 4.1.2. The FESW water level and temperature had been monitored daily as required by the surveillance requirements of TS 5.1.2.1.


c. Conclusions The inspectors determined that the licensee properly maintained the FESW water level, temperature, chemistry, and cleanliness to ensure the safe wet storage of the spent fuel.
7  Enclosure


Enclosure 85.0 Exit Meeting The inspectors presented the inspection results to members of the licensee's staff at the conclusion of the inspection on August 13, 2008. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietary.
5.0 Exit Meeting The inspectors presented the inspection results to members of the licensees staff at the conclusion of the inspection on August 13, 2008. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietary.


ATTACHMENT: SUPPLEMENTAL INFORMATION  
ATTACHMENT: SUPPLEMENTAL INFORMATION 8  Enclosure


Attachment SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED R. Christians, Plant Manager R. Cota, Training/Security Supervisor J. Henkelman, Quality Assurance Specialist M. Johnsen, Tech Support Engineer * L. Nelson, Health and Safety Supervisor S. Rafferty, Reactor Engineer * D. Tesar, Security Supervisor  
SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED R. Christians, Plant Manager R. Cota, Training/Security Supervisor J. Henkelman, Quality Assurance Specialist M. Johnsen, Tech Support Engineer
* D. Egge, Quality Assurance Supervisor R. Lewton, Electrician & Instrument Technician * J. McRill, Tech Support Engineer * M. Brasel, Project Manager  
* L. Nelson, Health and Safety Supervisor S. Rafferty, Reactor Engineer
* Persons present at the exit meeting.
* D. Tesar, Security Supervisor
* D. Egge, Quality Assurance Supervisor R. Lewton, Electrician & Instrument Technician
* J. McRill, Tech Support Engineer
* M. Brasel, Project Manager
* Persons present at the exit meeting.


INSPECTION PROCEDURES USED IP 36801: Organization, Management and Cost Controls IP 37801: Safety Reviews, Design Changes, and Modifications IP 40801: Self-assessment, Auditing, and Correction Action IP 60801: Spent Fuel Pool Safety IP 62801: Maintenance and Surveillance IP 71801: Decommissioning Performance and Status Review IP 83750: Occupational Radiation Exposure IP 86750: Transportation of Radioactive Materials IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None  
INSPECTION PROCEDURES USED IP 36801: Organization, Management and Cost Controls IP 37801: Safety Reviews, Design Changes, and Modifications IP 40801: Self-assessment, Auditing, and Correction Action IP 60801: Spent Fuel Pool Safety IP 62801: Maintenance and Surveillance IP 71801: Decommissioning Performance and Status Review IP 83750: Occupational Radiation Exposure IP 86750: Transportation of Radioactive Materials IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed  None Discussed None INITIALISMS AND ACRONYMS ACP Administrative Control Procedure ADAMS Agencywide Documents Access and Management System ALARA As Low As is Reasonably Achievable CFR Code of Federal Regulations CAR Corrective Action Request DNMS Division of Nuclear Materials Safety DOT Department of Transportation FESW Fuel Element Storage Well LACBWR La Crosse Boiling Water Reactor NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PARS Publicly Available Records QA Quality Assurance Attachment


Closed None Discussed None INITIALISMS AND ACRONYMS ACP Administrative Control Procedure ADAMS Agencywide Documents Access and Management System ALARA As Low As is Reasonably Achievable CFR Code of Federal Regulations CAR Corrective Action Request DNMS Division of Nuclear Materials Safety DOT Department of Transportation FESW Fuel Element Storage Well LACBWR La Crosse Boiling Water Reactor NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PARS Publicly Available Records QA Quality Assurance Attachment 2 QAPD Quality Assurance Program Description QAPP Quality Assurance Project Plan SSC Structures, Systems, and Components SRC Safety Review Committee
QAPD Quality Assurance Program Description QAPP Quality Assurance Project Plan SSC Structures, Systems, and Components SRC Safety Review Committee 2 Attachment
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Latest revision as of 13:01, 14 November 2019

IR 05000409-08-01; Dairyland Power Cooperative; 08/12-12/2008; (DNMS) - La Crosse Boiling Water Reactor (LACBWR)
ML082560488
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 09/12/2008
From: Christine Lipa
NRC/RGN-III/DNMS/DB
To: Berg W
Dairyland Power Cooperative
References
IR-08-001
Download: ML082560488 (12)


Text

ber 12, 2008

SUBJECT:

NRC INSPECTION REPORT 050-00409/08-01(DNMS) - LA CROSSE BOILING WATER REACTOR (LACBWR)

Dear Mr. Berg:

On August 13, 2008, the NRC completed an inspection at the La Crosse Boiling Water Reactor (LACBWR) facility. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements in the areas of facility management and control, decommissioning support, radiological safety, and spent fuel safety. At the conclusion of the inspection on August 13, 2008, the NRC inspectors discussed the results with members of your staff.

The inspection consisted of an examination of activities at the facility as they relate to safety and compliance with the Commissions rules and regulations. Specific areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, field observations of activities in progress, and interviews with personnel.

Based on the results of this inspection, the NRC did not identify any violations.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). The NRCs document system is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. We will gladly discuss any questions you have concerning this inspection.

Sincerely,

/RA/

Christine Lipa, Chief Decommissioning Branch Division of Nuclear Materials Safety Docket No. 050-00409 License No. DPR-45

Enclosure:

Inspection Report 050-00409/08-01(DNMS)

REGION III==

Docket No.: 050-00409 License No.: DPR-45 Report No. : 050-00409/08-01(DNMS)

Licensee: Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602 Facility: La Crosse Boiling Water Reactor Location: La Crosse Site Genoa, Wisconsin Dates: August 12 through 13, 2008 Inspectors: Peter J. Lee, Ph.D., CHP, Health Physicist William Snell, Senior Health Physicist Kristina Banovac, Project Manager, FSME Approved by: Christine Lipa, Chief Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY La Crosse Boiling Water Reactor (LACBWR)

NRC Inspection Report 050-00409/08-01 (DNMS)

This routine decommissioning inspection covered aspects of facility management and control, decommissioning support activities, radiological safety, and spent fuel safety.

Facility Management and Control

  • The inspectors determined that the licensee staffing was adequate for the decommissioning activities being performed, and that the training requirements of the Decommissioning Plan were being met. (Section 1.1)
  • The inspectors determined that the licensees process for evaluating the safety impacts of facility changes and modifications was in compliance with the requirements of 10 CFR 50.59. (Section 1.2)
  • The inspectors determined that the licensee had enhanced its Quality Assurance program to better address dry cask activities, and were adequately identifying and addressing conditions adverse to quality. The Radiation Safety Committee was meeting and carrying out its responsibilities as required. (Section 1.3)
  • The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas. (Section 1.4)

Decommissioning Support Activities

  • The licensees maintenance and surveillance activities were conducted in accordance with the maintenance rule, as stated in 10 CFR Part 50.65. (Section 2.1)

Radiological Safety

  • The inspectors determined that the licensee continued to be effective in controlling radiation worker personal exposure. (Section 3.1)
  • The inspectors determined that the licensee adequately implemented its effluent monitoring program. (Section 3.2)
  • The inspectors determined that the licensee complied with regulatory requirements for shipping radioactive materials. (Section 3.3)

Spent Fuel Safety

  • The inspectors determined that the licensee properly maintained the Spent Fuel Element Storage Well water level, temperature, chemistry, and cleanliness to ensure the safe wet storage of the spent fuel. (Section 4.1)

2 Enclosure

Report Details1 Summary of Plant Activities The licensees current activities were focused on routine operations regarding the safe storage of spent fuel in the fuel pool and preparations for the dry fuel storage project.

1.0 Facility Management and Control 1.1 Organization, Management and Cost Controls (IP 36801)

a. Inspection Scope The inspectors evaluated the licensees decommissioning staffing and reviewed the training program and training records for the current calendar year, including the fuel handler training, radiation protection training, and general employee training. The inspectors also reviewed the training for the contract workers who were granted unescorted access to conduct work in the restricted area.

b. Observations and Findings The licensees staffing was adequate for the level of work being performed and met requirements of Technical Specifications. A review of the training program and training records identified that the workers had received the required training specified in the Decommissioning Plan.

c. Conclusions The inspectors determined that the licensee staffing was adequate for the decommissioning activities being performed, and that the training requirements of the Decommissioning Plan were being met.

1.2 Safety Reviews, Design Changes and Modifications (37801)

a. Inspection Scope The inspectors reviewed the licensees 10 CFR 50.59 safety screening reviews of several facility changes since the last inspection to assess the licensees conclusions regarding the need for safety evaluations.

b. Observations and Findings The inspectors verified that the safety review process stated in LACBWR Administrative Control Procedure (ACP)-06.4, 10 CFR 50.59 Reviews, dated April 21, 2003, was consistent with the requirements of 10 CFR 50.59. The licensee conducted safety screening reviews per ACP-06.4. The activities all involved facility changes that did not adversely affect the design functions of the structures, systems, and components (SSCs) as described in the licensees Decommissioning Plan and none of the facility changes required the safety evaluations.

NOTE: A list of acronyms used in the report is included at the end of the report.

3 Enclosure

c. Conclusions The inspector determined that the licensees process for evaluating the safety impacts of facility changes and modifications was in compliance with the requirements of 10 CFR 50.59.

1.3 Self Assessment, Auditing, and Corrective Actions (40801)

a. Inspection Scope The inspectors reviewed the licensees activities associated with quality assurance (QA),

identification and tracking of corrective actions, and Safety Review Committee (SRC)

commitments. The inspectors reviewed the licensees Quality Assurance Project Plan (QAPP) for the Dry Cask Storage Project, Revision 1, dated June 2, 2008, ACP- 04.1, Design and Facility Change Control, Issue 35, ACP-16.0, Quality Assurance Deficiency Reports and Deposition of Non-Conforming Materials, Parts, and Components, Issue 16, ACP-2.14, Safety Review Committee (SRC), Issue 14, and the Final Minutes of the April 29, 2008, LACBWR SRC Meeting. The inspectors met with licensee personnel and reviewed and discussed the QAPP Appendix A Program Implementation Matrix and the identification and disposition of items identified in Corrective Action Requests (CARs).

b. Observations and Findings The licensee developed its QAPP for the Dry Cask Storage Project to control work in a project based approach specific to dry cask storage activities. The QAPP incorporates the existing Quality Assurance Program Description (QAPD), site procedures, and corporate procedures, as applicable to the project. The QAPP enhanced the corrective action process specified in the QAPD by including a CAR process to promptly address and track conditions adverse to quality. A review of open CAR items as well as recently closed CAR items indicated issues were being adequately tracked and addressed in a timely manner. A review of the minutes from the most recent SRC Meeting April 29, 2008) indicated that the requirement to meet at least once per year and the quorum requirements were met. The inspectors review of the SRC Meeting Minutes determined that the SRC was appropriately addressing the type of issues identified in Section 4.7 of ACP-2.14 as pertinent to the SRC, as required.

c. Conclusions The inspectors determined that the licensee had enhanced its Quality Assurance program to better address dry cask activities, and was adequately identifying and addressing conditions adverse to quality. The SRC was meeting and carrying out its responsibilities as required.

1.4.1 Decommissioning Performance and Status Review at Permanently Shut Down Reactors (71801)

a. Inspection Scope The inspectors conducted plant tours to assess field conditions and decommissioning activities and ensure that radioactively contaminated areas were being controlled.

4 Enclosure

b. Observations and Findings During site tours the inspectors noted that the material condition of facilities and equipment was commensurate with current decommissioning activities. The individuals conducting the tours with the inspectors were cognizant of the work activities in process, the dose levels throughout the facilities, and the locations of contaminated areas. Work areas were observed to be adequately controlled, postings and boundaries were appropriate, and workers were wearing personal protective clothing that was suitable for the work they were performing.

c. Conclusions The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas.

2.0 Decommissioning Support Activities 2.1 Maintenance and Surveillance (62801)

a. Inspection Scope The inspectors reviewed the licensees maintenance requests and surveillances for 2008, and biannual assessment of maintenance effectiveness of structures, systems, and components (SSCs) during 2006 and 2007, to verify that maintenance and surveillance for SSCs were conducted in a manner that resulted in the safe storage of spent fuel.

b. Observations and Findings The maintenance and surveillance for SSCs were conducted in accordance with the licensees program that implemented 10 CFR Part 50.65 Maintenance Rule Based on the risk assessment of SSCs, the licensee established 13 functional goals and developed associated monitoring and frequency for each goal. There were four incident reports generated during 2007 and 2008. None of the incidents adversely affected SSC design functions and correction actions had been taken. The licensees periodic assessments indicated that all functional goals of the SSCs were met.

c. Conclusions The licensees maintenance and surveillance activities were conducted in accordance with the maintenance rule, as stated in 10 CFR Part 50.65.

3.0 Radiological Safety 3.1 Occupational Radiation Exposure (83750)

a. Inspection Scope The inspectors reviewed the As-Low-As-is-Reasonably-Achievable (ALARA) reviews and radiation work permits for removal of the recirculation piping from the reactor lower cavity during August, 2008. The inspector verified that the licensee had established 5 Enclosure

procedures, and engineering work controls that were based on sound radiation protection principles in order to achieve occupational exposures that were ALARA.

b. Observations and Findings The licensee provided sufficient shielding of radiation sources in a practical manner.

Also, to reduce potential intakes of radioactive materials, the licensee installed high efficiency particulate air filter-equipped (HEPA) filtration systems in the vicinity of the work areas, and workers also wore half-face mask respirators in the reactor lower cavity area.

Based on the review of external exposure records, workers received doses less than the dose limits specified in radiation work permits. The total personnel external exposures were 9602 mrem and the highest dose received by an individual was 1860 mrem. Air sampling data indicated that most of the internal dose was due to americium-241. Based on the DAC-hours dose assessments, the total personnel committed effective dose equivalents (CEDE) were 620 mrem and the highest CEDE received by an individual was 182 mrem.

c. Conclusions The inspector determined that the licensee continued to be effective in controlling radiation worker personal exposure.

3.2 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)

a. Inspection Scope The inspectors evaluated the licensees activities to effectively control, monitor, and quantify releases of radioactive materials in liquid, gaseous, and particulate forms to the environment. The inspectors reviewed the licensees 2007 Effluent and Environmental Monitoring Reports, and the Offsite Dose Calculation Manual (ODCM).

b. Observations and Findings The licensees gaseous effluent monitors and waste water effluent monitor were calibrated and checked for proper operation in accordance with station procedures.

The licensee participates in a cross check program with an off-site laboratory to confirm the quality of its analytical data. Results of a cross check of licensee laboratory results completed in calendar year 2007 indicated agreement in all analytical data.

The ODCM was comprehensive and contained the requirements listed in the licensees technical specifications. The effluent monitoring data indicated that release concentrations were consistent with limits specified in 10 CFR Part 20, Appendix B, Table 2, and that doses to the general public were in conformance with Appendix I of 10 CFR Part 50. Further, environmental sampling results indicated only background radiation levels with no distinct contribution from the shutdown reactor.

c. Conclusions The inspectors determined that the licensee adequately implemented its effluent monitoring program.

6 Enclosure

3.3 Transportation of Radioactive Materials (86750)

a. Inspection Scope The inspector reviewed the radioactive materials shipping program and applicable shipping documents. The inspector evaluated whether the licensee was in compliance with NRC and Department of Transportation (DOT) shipping requirements.

b. Observations and Findings The licensee has processed thirteen waste shipments since the last inspection. The waste contained concrete shield blocks, and recirculation piping. The licensee shipped the radiological waste to Energy Solutions sites in Clive, Utah, and Kingston and Oak Ridge, Tennessee. The licensees shipping manifest showed that personnel packaged, labeled, and marked each shipping container according to the DOT and 10 CFR Part 71 transportation requirements. The licensee verified that the results of radiation and removable contamination levels were within applicable limits. The waste manifest included all required information.

c. Conclusions The inspector determined that the licensee complied with regulatory requirements for shipping radioactive materials.

4.0 Spent Fuel Safety 4.1 Spent Fuel Pool Safety at Permanently Shutdown Reactors (60801)

a. Inspection Scope The inspectors reviewed the licensees activities to ensure the safe wet storage of spent fuel in the Fuel Element Storage Well (FESW). The review included the verification of water temperature, and water level requirements of Technical Specification (TS) 4.1.2, the surveillance requirements of TS 5.1.2, and the water chemistry and cleanliness control requirements of the licensees Health and Safety Procedure HSP-7.2, for the period of January through July 2008.

b. Observations and Findings All parameters reviewed were consistent with limits specified in HSP-7.2, Sampling of Fuel Element Storage Well. The FESW water level and temperature met the requirements of TS 4.1.2. The FESW water level and temperature had been monitored daily as required by the surveillance requirements of TS 5.1.2.1.

c. Conclusions The inspectors determined that the licensee properly maintained the FESW water level, temperature, chemistry, and cleanliness to ensure the safe wet storage of the spent fuel.

7 Enclosure

5.0 Exit Meeting The inspectors presented the inspection results to members of the licensees staff at the conclusion of the inspection on August 13, 2008. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION 8 Enclosure

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED R. Christians, Plant Manager R. Cota, Training/Security Supervisor J. Henkelman, Quality Assurance Specialist M. Johnsen, Tech Support Engineer

  • L. Nelson, Health and Safety Supervisor S. Rafferty, Reactor Engineer
  • D. Tesar, Security Supervisor
  • D. Egge, Quality Assurance Supervisor R. Lewton, Electrician & Instrument Technician
  • J. McRill, Tech Support Engineer
  • M. Brasel, Project Manager
  • Persons present at the exit meeting.

INSPECTION PROCEDURES USED IP 36801: Organization, Management and Cost Controls IP 37801: Safety Reviews, Design Changes, and Modifications IP 40801: Self-assessment, Auditing, and Correction Action IP 60801: Spent Fuel Pool Safety IP 62801: Maintenance and Surveillance IP 71801: Decommissioning Performance and Status Review IP 83750: Occupational Radiation Exposure IP 86750: Transportation of Radioactive Materials IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None INITIALISMS AND ACRONYMS ACP Administrative Control Procedure ADAMS Agencywide Documents Access and Management System ALARA As Low As is Reasonably Achievable CFR Code of Federal Regulations CAR Corrective Action Request DNMS Division of Nuclear Materials Safety DOT Department of Transportation FESW Fuel Element Storage Well LACBWR La Crosse Boiling Water Reactor NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PARS Publicly Available Records QA Quality Assurance Attachment

QAPD Quality Assurance Program Description QAPP Quality Assurance Project Plan SSC Structures, Systems, and Components SRC Safety Review Committee 2 Attachment