ML070570160

2/23/07 Ltr to J Connell Maine Yankee - Approval of Quality Assurance Program Changes (TAC No. L24046)

ML070570160
Person / Time
Site:	Maine Yankee
Issue date:	02/23/2007
From:	Hall J NRC/NMSS/SFST/LID/LB
To:	Connell J Maine Yankee Atomic Power Co
Pearson J NMSS/SFPO (301) 415-1985
References
TAC L24046
Download: ML070570160 (6)

Text

February 23, 2007 Mr. James Connell ISFSI Manager Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922

SUBJECT:

MAINE YANKEE - APPROVAL OF QUALITY ASSURANCE PROGRAM CHANGES (TAC NO. L24046)

Dear Mr. Connell:

By letter dated November 29, 2006, Maine Yankee Atomic Power Company (MYAPC) submitted a proposed revision to the quality assurance (QA) program description for Maine Yankee. The revision was submitted as a reduction in commitment under the provisions of 10 CFR 50.54(a)(4).

The proposed revision reflects program simplifications based on the plants decommissioned status. Specifically, all spent fuel has been transferred to the Independent Spent Fuel Storage Installation (ISFSI). Consequently, the primary focus of the quality program requirements for Maine Yankee has shifted to important-to-safety ISFSI structures, systems, components, and associated processes. The Nuclear Regulatory Commission staff (the staff) notes that the quality program also continues to apply to packaging and transportation of radioactive material under 10 CFR Part 71.

The staff reviewed the proposed revision, as documented in the enclosed safety evaluation, and found that the revised program, with the reduction in commitment will continue to satisfy the criteria of 10 CFR Part 50, Appendix B, and 10 CFR 72.140(d). Therefore, the staff finds the proposed changes to the QA program for Maine Yankee acceptable.

Please contact me at (301) 415-1336, or Jim Pearson at (301) 415-1985, for any additional information or clarification you need on this subject.

Sincerely,

/RA/

James R. Hall, Senior Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket Nos: 50-309,72-030 License No.: DPR-36

Enclosure:

Safety Evaluation cc: Maine Yankee distribution list

Mr. James Connell ISFSI Manager Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922

SUBJECT:

MAINE YANKEE - APPROVAL OF QUALITY ASSURANCE PROGRAM CHANGES (TAC NO. L24046)

Dear Mr. Connell:

By letter dated November 29, 2006, Maine Yankee Atomic Power Company (MYAPC) submitted a proposed revision to the quality assurance (QA) program description for Maine Yankee. The revision was submitted as a reduction in commitment under the provisions of 10 CFR 50.54(a)(4).

The proposed revision reflects program simplifications based on the plants decommissioned status. Specifically, all spent fuel has been transferred to the Independent Spent Fuel Storage Installation (ISFSI). Consequently, the primary focus of the quality program requirements for Maine Yankee has shifted to important-to-safety ISFSI structures, systems, components, and associated processes. The Nuclear Regulatory Commission staff (the staff) notes that the quality program also continues to apply to packaging and transportation of radioactive material under 10 CFR Part 71.

The staff reviewed the proposed revision, as documented in the enclosed safety evaluation, and found that the revised program, with the reduction in commitment will continue to satisfy the criteria of 10 CFR Part 50, Appendix B, and 10 CFR 72.140(d). Therefore, the staff finds the proposed changes to the QA program for Maine Yankee acceptable.

Please contact me at (301) 415-1336, or Jim Pearson at (301) 415-1985, for any additional information or clarification you need on this subject.

Sincerely, James R. Hall, Senior Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket Nos: 50-309,72-030 License No.: DPR-36

Enclosure:

Safety Evaluation cc: Maine Yankee distribution list DISTRIBUTION:

SFST r/f NMSS r/f Raymond Lorson. RI WRuland SCrutchfield, OCFO C:\FileNet\ML070570160.wpd OFC: SFST SFST E SFST E SFST NAME: JPearson MDeBose JRHall RLewis DATE: 2/12/07 2/12/07 2/23/07 2/15/07 / / / /

OFFICIAL RECORD COPY

Maine Yankee Service List cc:

Senator Charles Pray Mr. Patrick J. Dostie State Nuclear Safety Advisor State of Maine Nuclear Safety Inspector State Planning Office Department of Health and Human Services State House Station #38 Maine Public Health Augusta, ME 04333 Division of Environmental Health 286 Water St., Key Plaza - 8th Floor First Selectman of Wiscasset State House Station 11 Municipal Building Augusta, ME 04333 U.S. Route 1 Wiscasset, ME 04578 Mr. Mark Roberts U.S. Nuclear Regulatory Commission Friends of the Coast 475 Allendale Road P.O. Box 98 King of Prussia, PA 19406 Edgecomb, ME 04556 David Lewis, Esquire Mr. Jonathan M. Block Shaw Pittman Attorney at Law 2300 North Street, NW P.O. Box 566 Washington, DC 20037 Putney, VT 05346-0566 Mr. James Connell, ISFSI Manager Joseph Fay, Esquire Maine Yankee Atomic Power Company Maine Yankee Atomic Power Company 321 Old Ferry Road 321 Old Ferry Road Wiscasset, ME 04578-4922 Wiscasset, ME 04578-4922 W. Clough Toppan, P.E., Director Mr. Wayne Norton, Vice President Division of Health Engineering and Chief Nuclear Officer Department of Human Services Maine Yankee Atomic Power Company #10 State House Station 321 Old Ferry Road Augusta, ME 04333 Wiscasset, ME 04578-4922

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS PROPOSED REVISION TO THE MAINE YANKEE QUALITY ASSURANCE PROGRAM DOCKET NUMBERS 50-309 AND 72-030

1.0 INTRODUCTION

By letter dated November 29, 2006, Maine Yankee Atomic Power Company (the licensee) submitted a proposed revision (Revision 30) to their Quality Assurance Program Description to be applied at the Maine Yankee Atomic Power Station. This quality assurance (QA) program revision was submitted as a reduction in commitment under the provisions of 10 CFR 50.54(a)(4). The proposed QA program revision reflects changes and program simplification based primarily on having transferred all spent fuel from the spent fuel pool to dry cask storage in the Independent Spent Fuel Storage Installation (ISFSI), and also in consideration of the plants current extensively decommissioned status.

2.0 BACKGROUND

The licensee previously submitted certification of permanent cessation of operations and certification of permanent fuel removal. Subsequently, the licensee has accomplished significant decommissioning of the facility including removal of many major components. All spent fuel has been transferred to the Independent Spent Fuel Storage Installation (ISFSI). As a result of the decommissioning activities, the licensee states that there are no longer any safety-related structures, systems, or components (SSCs) at the facility. The QA program, however, continues to apply to the ISFSI components identified as Important to Safety and to other select areas, such as radiological safety and transportation of radioactive materials.

3.0 EVALUATION 3.1 Basis of Evaluation The existing Maine Yankee QA program (MYQAP) is considered to meet the criteria in Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. Appendix B establishes quality assurance requirements for the design, fabrication, construction, testing, and operation of nuclear power plant safety-related SSCs.

During decommissioning, the regulations require the licensee to maintain a QA program that complies with Appendix B until the Part 50 license is terminated.

An acceptable way of establishing QA program compliance with the requirements of 10 CFR Part 50, Appendix B, quality assurance criteria in support of ISFSI operation and maintenance is by reviewing and evaluating the licensees commitment to the applicable ANSI Standards and corresponding NRC Regulatory Guides. The proposed changes to the MYQAP were qualitatively evaluated and judged based on changes and exceptions to previous commitments to these ANSI standards and associated regulatory guides in the context of the current decommissioning status of the facility.

The changes were also evaluated to ensure continued compliance of the QA program with quality assurance regulations for ISFSIs per 10 CFR 72.140(d). Evaluation of the acceptability

of the QA program changes relative to the ISFSI was performed in accordance with the guidance of NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, which provides a well-defined, uniform basis for evaluating proposed changes to licensee commitments.

Therefore, this evaluation reviews the MYQAP changes for conformance with both 10 CFR Part 50, Appendix B, and 10 CFR Part 72, Subpart G.

3.2 Assessment of QA Program Against 10 CFR Part 72, Subpart G The staff reviewed and evaluated the proposed changes in Revision 30 of the QA program for Maine Yankee, in order to determine whether the MYQAP, as revised, will continue to comply with the requirements of 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, Subpart G, Quality Assurance.

(a) Areas Reviewed:

The complete submittal was reviewed by the staff to confirm that the corresponding guidance for each of the Part 50 and Part 72 quality criteria listed below were acceptably addressed in the revised program:

Quality assurance organization Quality assurance program Design control Procurement document control Instructions, procedures, and drawings Document control Control of purchased material, equipment, and services Identification and control of materials, parts, and components Control of special processes Licensee and certificate holder inspection Test control Control of measuring and test equipment Handling, storage, and shipping control Inspection, test, and operating status Nonconforming materials, parts, or components Corrective action Quality assurance records Audits NUREG-1567 provides specific guidance for evaluating the licensees quality program changes against the above 18 quality criteria in regard to spent fuel dry storage facilities. Based on the staffs review of the MYQAP, the staff has determined that the proposed revision continues to meet the requirements of Subpart G of 10 CFR Part 72. While this evaluation has determined that the MYQAP is acceptable, continued proper implementation of the quality program plan will be assessed during future NRC inspections.

(b) Evaluation Findings 2

The MYQAP describes requirements, procedures, and controls that, when properly implemented, comply with requirements of both 10 CFR Part 50 and 10 CFR Part 72.

The structure of the organization and assignment of responsibility for each activity ensures that designated parties will perform the work to achieve and maintain specified quality requirements.

Conformance to established requirements will be verified by qualified personnel and groups not directly responsible for the activity being performed. These personnel and groups report through a management hierarchy which grants the necessary authority and organizational freedom and provide sufficient independence from economic and scheduling influences.

The quality program plan provides adequate control over activities affecting quality, as well as structures, systems, and components important to safety, consistent with their relative importance to safety.

The Quality Assurance Program for Maine Yankee, Revision 30, is found to meet the requirements of 10 CFR Part 50, Appendix B, and Part 72, Subpart G, based on the review described above.

4.0 CONCLUSION

The proposed changes to the licensees QA program as described above will continue to satisfy the criteria of Appendix B to 10 CFR Part 50, and Subpart G of 10 CFR Part 72.

Principal Contributor: J. Pearson Date: February 23, 2007 3