ML18277A308
| ML18277A308 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 11/01/2018 |
| From: | Bruce Watson Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Sauger J Energy Solutions |
| M VAALER NMSS DUWP | |
| References | |
| Download: ML18277A308 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 1, 2018 Mr. John Sauger Executive Vice President Chief Nuclear Officer Reactor D&D EnergySolutions 2701 Deborah Avenue Zion, IL 60099
SUBJECT:
LA CROSSE BOILING WATER REACTOR - APPROVAL OF REVISION 30 TO THE QUALITY ASSURANCE PROGRAM DESCRIPTION
Dear Mr. Sauger:
By letter dated September 4, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18249A247), LaCrosseSolutions, LLC (LS, the licensee), submitted Revision 30 to the Quality Assurance Program Description (QAPD) for the decommissioning La Crosse Boiling Water Reactor (LACBWR) for U.S. Nuclear Regulatory Commission (NRC) review and approval prior to implementation. The proposed LACBWR QAPD provides a consolidated overview of the quality program and controls that govern the operation and maintenance of the LACBWR independent spent fuel storage installation (ISFSI) that will remain at the site once the decommissioning activities at the LACBWR plant are complete.
The proposed changes also reflect the organizational structure that will exist at the facility after approval of a license transfer request (June 27, 2018; ADAMS Accession No. ML18184A444) from LS to the Dairyland Power Cooperative (DPC), which was the original licensee for the LACBWR site. Following approval of the proposed transfer of control of the license, DPC would acquire full ownership of the facility, similar to what existed before the June 1, 2016 (ADAMS Accession No. ML16123A049), license transfer to LS. The proposed QAPD revision would reflect that LSs licensed possession, maintenance, and decommissioning authorities have been transitioned back to DPC upon completion of decommissioning activities at the LACBWR site.
Thereafter, DPC will continue to maintain the onsite ISFSI, and the ultimate disposition of the spent nuclear fuel will be provided for under the terms of DPCs Standard Contract for Disposal of Spent Nuclear Fuel and/or High Level Waste with the U.S. Department of Energy. DPC will also continue to maintain its nuclear decommissioning trust, which is a grantor trust in which funds are segregated from its assets and outside its administrative control. The completion of decommissioning activities at the LACBWR facility, and the transfer of control of the license back to DPC, is currently scheduled to be complete by the end of 2019.
The proposed changes to the LACBWR QAPD, Revision 30, include the following specific changes from the previous Revision 29 of the LACBWR QAPD:
- Elimination of LS from the organizational descriptions in the LACBWR QAPD, and replacement with DPC functional descriptions and organizational structure as appropriate.
J. Sauger
- Changing the position of Quality Assurance Manager to Quality Assurance Representative, with no change to the responsibilities and qualifications for this position. The Quality Assurance Representative is a non-management position; however, the Quality Assurance Representative reports directly to the DPC President and Chief Executive Officer on matters affecting quality.
- Elimination of references to the LACBWR plant and decommissioning efforts since these activities will be complete before implementation of Revision 30 of the LACBWR QAPD.
- Clarification that Section XII, Control of Measuring and Test Equipment [M&TE], of the LACBWR QAPD is applicable only to M&TE used on important to safety components. This change improves consistency with the quality assurance requirements in place at other nuclear facilities where the ISFSI is the only NRC regulated structure left onsite.
Revision 30 of the LACBWR QAPD applies to all activities associated with structures, systems, and components which are important to safety in accordance with Title 10 of the Code of Federal Regulations (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. The LACBWR QAPD also applies to transportation packages licensed by the NRC under 10 CFR Part 71, Packaging and Transportation of Radioactive Material. For other ISFSI activities, the NRC staff has previously confirmed through oversight and inspection activities at the LACBWR ISFSI that administrative programs and procedures ensure compliance with the applicable regulations, and include appropriate controls for activities under the radiological control programs previously contained in the LACBWR Technical Specifications.
The NRCs regulatory requirements related to quality assurance programs are set forth in the applicable portions of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities; Subpart H, Quality Assurance, to 10 CFR Part 71; and Subpart G, Quality Assurance, to 10 CFR Part 72. Although the proposed changes to the LACBWR QAPD were submitted for NRC review and approval in accordance with 10 CFR 50.54(a)(4), the NRC staff does not consider the above changes a reduction in commitment from the quality program controls described in Revision 29 of the LACBWR QAPD, which was approved by the NRC staff on May 31, 2016 (ADAMS Accession No. ML16152A014).
As such, the NRC staff has completed its review of the licensees request and has determined that the quality assurance program, as described in the LACBWR QAPD, Revision 30, continues to meet the criteria of Appendix B to 10 CFR Part 50, and is therefore acceptable without the need for a specific NRC safety evaluation to approve the LACBWR QAPD, Revision 30, prior to implementation. Specifically, the NRC staff has determined that the proposed changes to the LACBWR QAPD are acceptable because they continue to provide an organizational description that includes the organizational structure, functional responsibilities, levels of authority, and interfaces for establishing, executing, and verifying LACBWR quality assurance program implementation as it relates to the LACBWR ISFSI.
In addition, the LACBWR QAPD: (1) establishes independence between the organization performing checking functions related to the quality assurance program and the organization responsible for performing the function; (2) provides for applicable management to be responsible to size the quality assurance organization commensurate with the duties and
J. Sauger responsibilities assigned; and (3) clearly describes and defines responsibility and authority for planning, establishing, and implementing an effective overall quality assurance program.
Accordingly, the NRC staff concludes that the LACBWR quality assurance program complies with the applicable NRC regulations and can be used by DPC for the LACBWR ISFSI.
Should you have any questions regarding this matter, please contact myself or Marlayna Vaaler at (301) 415-3178 or via e-mail at marlayna.vaaler@nrc.gov.
Sincerely,
/RA/
Bruce A. Watson, CHP, Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-409 and 72-046 License No.: DPR-45 cc: La Crosse Boiling Water Reactor Service List
ML18277A308 *via email OFFICE NMSS/DUWP/RDB/PM NMSS/DUWP/LA NRO/DCIP/QVIB/BC NAME MVaaler CHolston KKavanagh*
DATE 10/4/18 10/9/18 10/10/18 OFFICE NMSS/DSFM/IOB/BC NMSS/DUWP/RDB/BC NMSS/DUWPRDB/PM NAME PSilva* BWatson MVaaler DATE 10/24/18 11/1/18 10/11/18 La Crosse Boiling Water Reactor Service List:
Ken Robuck Jeffery Kitsembel President and CEO Division of Energy Regulation EnergySolutions Wisconsin Public Service Commission 299 South Main Street, Suite 1700 P.O. Box 7854 Salt Lake City, UT 84111 Madison, WI 53707-7854 John Sauger Paul Schmidt, Manager Executive VP and Chief Nuclear Officer Radiation Protection Section Reactor D & D Bureau of Environmental and Occupational Health EnergySolutions Division of Public Health 121 W. Trade Street, Suite 2700 Wisconsin Department of Health Services Charlotte, NC 28202 P.O. Box 2659 Madison, WI 53701-2659 Gerard van Noordennen VP Regulatory Affairs Barbara Nick EnergySolutions President and CEO 121 W. Trade Street, Suite 2700 Dairyland Power Cooperative Charlotte, NC 28202 3200 East Avenue South, La Crosse, WI 54602-0817 Joseph Nowak General Manager Cheryl Olson, ISFSI Manager LaCrosseSolutions La Crosse Boiling Water Reactor S4601 State Highway 35 Dairyland Power Cooperative Genoa, WI 54632-8846 S4601 State Highway 35 P.O. Box 817 Russ Workman Genoa, WI 54632-8846 General Counsel EnergySolutions Lane Peters, Site Manager 299 South Main Street, Suite 1700 La Crosse Boiling Water Reactor Salt Lake City, UT 84111 Dairyland Power Cooperative S4601 State Highway 35 Jerome Pedretti, Clerk Genoa, WI 54632-8846 Town of Genoa E860 Mundsack Road Thomas Zaremba Genoa, WI 54632 Wheeler, Van Sickle and Anderson, S.C.
44 East Mifflin Street, Suite 1000 Regional Administrator Madison, WI 53703 U.S. NRC, Region III 2443 Warrenville Road John E. Matthews Lisle, IL 60532-4352 Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004