IR 05000285/2018003

NRC Inspection Report 05000285/2018003

ML18261A034
Person / Time
Site:	Fort Calhoun
Issue date:	09/27/2018
From:	Janine Katanic Division of Nuclear Materials Safety IV
To:	Fisher M Omaha Public Power District
C. Steely
References
IR 2018003
Download: ML18261A034 (15)

Text

ber 27, 2018

SUBJECT:

FORT CALHOUN STATION - NRC INSPECTION REPORT 05000285/2018-003

Dear Ms. Fisher:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted on August 27-30, 2018, at the Fort Calhoun Station located near Blair, Nebraska. The NRC inspectors discussed the results of this inspection with you and other members of your staff, during a final exit meeting conducted on August 30, 2018. The inspection results are documented in the enclosure to this letter.

The NRC inspection examined activities conducted under your license as they relate to public health and safety, common defense and security, and to confirm compliance with the Commissions rules and regulations, and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Specifically, the inspectors reviewed your planned decommissioning activities to support SAFSTOR conditions at the facility; controls for spent fuel safety; implementation of your maintenance program; and your effluent, environmental and monitoring program. No violations within the scope of the inspection were identified and no response to this letter is required.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction. If you have any questions regarding this inspection report, please contact Chris Steely at 817-200-1432, or the undersigned at 817-200-1151.

Sincerely,

/RA/

Janine F. Katanic, PhD, CHP, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Docket No. 50-285 License No. DPR-40 Enclosure:

Inspection Report 05000285/2018-003 w/Attachment: Supplemental Information

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No. 05000285 License No. DPR-40 Report No. 05000285/2018-003 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, Nebraska Inspection Dates: August 27-30, 2018 Inspectors: Rachel S. Browder, CHP, Senior Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Chris D. Steely, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Stephanie G. Anderson, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Approved By: Janine F. Katanic, PhD, CHP, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY Fort Calhoun Station NRC Inspection Report 05000285/2018-003 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the Fort Calhoun Station (FCS)

under Inspection Report 05000285/2018-003. In summary, the licensee was conducting these activities in accordance with site procedures, license requirements, and applicable NRC regulations.

Decommissioning Performance and Status Review at Permanently Shutdown Reactors

• The licensee was using a methodical approach to identify and safely prepare the facilities for SAFSTOR in accordance with its procedures and the Post-Shutdown Decommissioning Activities Report (PSDAR). The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. The licensee was following appropriate NRC guidance for performing site characterization and final status surveys of certain open land areas. (Section 1.2)

Spent Fuel Pool Safety at Permanently Shutdown Reactors

• The licensees spent fuel pool was being maintained in accordance with Permanently Defueled Technical Specifications (PDTS) and procedural requirements. The licensee was safely storing the spent fuel assemblies contained in the spent fuel pool. (Section 2.2)

Maintenance and Surveillance at Permanently Shutdown Reactors

• The licensee implemented its maintenance and surveillance program consistent with procedures and regulatory requirements. The licensee was maintaining plant systems in accordance with the PDTS. The licensee appropriately implemented the maintenance rule to ensure compliance with the requirements of Title 10 Code of Federal Regulations (CFR) 50.65 for structures, systems, and components associated with the storage, control, and maintenance of spent fuel. (Section 3.2)

Organization, Management, and Cost Controls at Permanently Shutdown Reactors

• The licensee maintained an overall organizational structure to support decommissioning activities as required by the PDTS and PSDAR. The licensee was continuing to benchmark activities in preparation of the SAFSTOR strategy with other decommissioned facilities. The licensee was implementing its employee concerns program in which individuals could raise concerns without fear of retaliation. (Section 4.2)

Radioactive Waste Treatment, and Effluent, and Environmental Monitoring

• The licensee implemented and maintained the effluent monitoring and control systems for calendar year 2017 in accordance with the Offsite Dose Calculation Manual (ODCM). The licensees program met the appropriate regulatory requirements set forth in the ODCM for sample collection methodology and locations, quality control and quality assurance of the program, and comparison of data results to pre-operational data results. (Section 5.2)

Report Details Summary of Plant Status On June 24, 2016, Omaha Public Power District (OPPD), the licensee, formally notified the NRC by letter of its intent to permanently cease operations of Fort Calhoun Station (FCS) (ADAMS Accession Number ML16176A213). By letter dated November 13, 2016, OPPD notified the NRC that it had permanently ceased power operations at FCS on October 24, 2016, and certified pursuant to Title 10 Code of Federal Regulations (CFR) 50.82(a)(1)(ii), that as of November 13, 2016, all fuel had been permanently removed from the FCS reactor vessel and placed into the FCS spent fuel pool (ML16319A254). On December 28, 2016, the NRC informed the licensee that it was no longer under NRC Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program, IMC 0608, Performance Indicator Program, and IMC 2515, Light-Water Reactor Inspection Program when conducting oversight activities and assessing site performance (ML16363A449). The licensee was informed that the NRCs oversight of licensed activities under decommissioning would be conducted under the provisions in IMC 2561, Decommissioning Power Reactor Inspection Program.

The licensee submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) on March 30, 2017 (ML17089A759). The PSDAR is not a licensing action and therefore is not approved by the NRC; however, the NRC reviews the report. The licensees PSDAR described the decommissioning activities and schedule to support SAFSTOR strategy for the facility, which is one of the options allowed by the NRC for decommissioning. The NRC subsequently held a public meeting in Omaha, Nebraska on May 31, 2017, to discuss and accept comments regarding the FCS PSDAR. The transcript of the public meeting is available in ADAMS under (ML17160A394).

The licensee selected the SAFSTOR decommissioning option, as described in the PSDAR. The PSDAR described that the licensee plans to continue in SAFSTOR until the spent fuel is transferred to the U.S. Department of Energy in 2058, at which time decommissioning activities will commence. According to the PSDAR, the deferred decontamination and dismantling activities are scheduled to be conducted between 2059 through 2066, to support the termination of the operating license within the required 60-year time period.

On April 12, 2017, Region IV closed the Confirmatory Action Letter regarding the resolution of design issues that had been documented during the Inspection Manual Chapter 0350 operation period, based on FCSs commitment to either: (1) complete the design and licensing basis reconstitution for spent fuel pool/cooling and supporting structures, systems, and components, or (2) submit a license amendment request for an independent spent fuel cooling system (ML17102B737). On December 14, 2017 (ML17348A383), the licensee requested to remove Option 2 above, and committed to complete Option 1 by June 25, 2018. The licensee entered its commitment into the corrective action program as Condition Report (CR) 2017-00842. By letter dated July 24, 2018 (ML18205A090), the licensee informed the NRC that the commitment actions and the associated CR had been closed with documentation supporting the closure of those actions.

On March 6, 2018, the NRC issued License Amendment No. 297 for the Permanently Defueled Technical Specifications (PDTS) (ML18010A087). The license amendment establishes a licensing and safety basis that reflects the permanently shut down and defueled condition of the facility. In general, the amendment eliminated the requirements for operation MODES and MODES where fuel was emplaced in the reactor vessel.

On December 12, 2017, the NRC granted an exemption to OPPD from certain emergency planning requirements in 10 CFR 50.47, Emergency Plans, and Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, (ML17276B286). This exemption allows OPPD to discontinue off-site radiological emergency planning activities and reduce the scope of its on-site emergency planning at FCS, to be effective no sooner than April 7, 2018. On April 9, 2018, the licensee implemented its NRC approved Permanently Defueled Emergency Plan (PDEP).

1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801)

1.1 Inspection Scope The inspectors evaluated the status of the planned decommissioning activities in accordance with the license and regulatory requirements.

1.2 Observations and Findings The inspectors observed the weekly Senior Leadership Team meeting, which focused on the scheduled tasks necessary to place the facility into SAFSTOR condition. The licensees presentations were detailed and management facilitated knowledgeable, wide ranging discussions in order to discern risk, schedule, resources, and how to improve process control and oversight.

The inspectors had discussions with the management team regarding the Dormancy Plan, Revision 0. The Dormancy Plan established key milestones for specific projects that supported the SAFSTOR schedule. The specific projects included dry cask storage, system abandonment, electrical footprint, radioactive waste and transportation, which included the reactor vessel and other large components. At the time of the inspection, the Dormancy Plan contained several decision points, including how to disposition the reactor vessel. Finally, the licensee acknowledged that they understood any change to the decommissioning model that is different from the PSDAR, would necessitate a change to the PSDAR.

During this inspection a tour was conducted of the facility, including the control room.

The inspectors observed the control room logs were maintained electronically and contained pertinent records of the facility operations and status. The inspectors discussed the component FR-758, discharge stack total exhaust flow channel recorder, which was declared non-functional on August 10, 2018. The licensees logs, condition report (CR 2018-00738), and shift managers report provided detailed information. The inspectors verified that the licensee had initiated 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> checks to record the value of the stack exhaust flow to comply with the Offsite Dose Calculation Manual (ODCM). The inspectors observed the immediate indicator for the plant discharge total exhaust flow in the control room, since it was only the recorder that was declared non-functional. In addition, the inspectors observed the alarms on the effluent radiation monitors were consistent with the calculated ODCM values.

Through observations and discussions with staff, the inspectors determined that the licensee was appropriately controlling and conducting facility operations in a safe manner. General observations by the inspectors identified good housekeeping throughout the facility and radiological labels and postings were appropriate for the

areas observed. Discussions with the staff indicated they were knowledgeable of their responsibilities, duties, and of current plant status. Safety was noted to be important to staff as observed by briefings and safety timeouts prior to conducting activities inside the plant.

The licensee had performed a limited site characterization survey, utilizing the services of TSSD Services, Inc., which was documented in a report dated January 2017. The purpose of the limited site characterization survey was to supplement the limited historical site assessment (HSA) that was performed in 2016, in order to address certain gaps in the historical radiological data identified by the HSA. The limited site characterization survey used the services of a contracted laboratory that was certified under a National Environmental Laboratory Accreditation Program (NELAP) and by a quality assurance audit performed under the Nuclear Procurement Issues Corporation (NUPIC) audit process. The conclusions of the characterization survey established that the data quality objectives had been met and that small concentrations of cesium-137, approximately 0.1 picocuries per gram (pCi/g) to 0.4 pCi/g, identified in the environmental areas surveyed were small fractions of the NRC screening level for cesium-137 in soil, which is 11 pCi/g. Other facility related gamma-emitting radionuclides in soil samples from the environmental areas surveyed were below the minimum detectable concentration (MDC)

values. In addition, the licensee concluded that measured concentrations of hard-to-detect beta-emitting radionuclides, such as strontium-90, in soil samples were also below the MDC values.

Since this was a limited site characterization survey, the inspectors agreed with the licensees determination that the collected radiological data was insufficient for use as release basis for the potentially impacted environmental (open land) areas. At the time of the inspection, the licensee was in the process of performing a full, documented final status survey for certain non-impacted open land areas, following its data quality objectives that were established in accordance with NUREG-1757, Volume 1, Revision 2, Consolidated NMSS Decommissioning Guidance and NUREG 1575, Revision 1, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).

1.3 Conclusion The licensee was using a methodical approach to identify and safely prepare the facilities for SAFSTOR in accordance with its procedures and the PSDAR. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. The licensee was following appropriate NRC guidance for performing site characterization and final status surveys of certain open land areas.

2 Spent Fuel Pool Safety at Permanently Shutdown Reactors (60801)

2.1 Inspection Scope The inspectors conducted a review of the spent fuel pool (SFP) operations to ensure the licensee was maintaining the pool in accordance with technical specifications and procedural requirements.

2.2 Observations and Findings The PDTS, Section 2.8.3, requires the SFP water level be maintained greater than or equal to 23 feet over the top of the irradiated fuel assemblies stored in the SFP and the SFP boron concentration to be greater or equal to 500 parts per million (ppm). The NRC inspectors reviewed the SFP level operational logs and reviewed chemistry data for the period since the last inspection. The inspectors concluded that the SFP level remained relatively steady at 41 feet, which is roughly 28 feet above the top of irradiated fuel, for the monitoring periods reviewed. The boron concentration in the SFP was 2313 ppm, which sufficiently met the refueling operational requirements in the PDTS, as stated above.

The SFP temperature was procedurally required to be maintained between 45 and 100 degrees Fahrenheit (°F). The temperature was tracked in the control room, where alarm panel annunciators were set to alert operators if SFP temperatures exceeded 120°F or fell below 50°F. The SFP temperature was approximately 78°F at the time of the inspection.

The licensee was continuing to monitor the leaks from the spent fuel pool to the liner and subsequently to the drain lines. The licensee monitored the leak rate monthly and calculated the approximate leak rate at 1.5 quarts per day (total for both SFP and fuel transfer canal). All leakage was contained and had not impacted the external environment.

2.3 Conclusion The licensees SFP was being maintained in accordance with PDTS and procedural requirements. The licensee was safely storing the spent fuel assemblies contained in the SFP.

3 Maintenance and Surveillance at Permanently Shutdown Reactors (IP 62801)

3.1 Inspection Scope The inspectors reviewed and evaluated the licensees maintenance and surveillance program. In addition, the inspectors verified that the program was being conducted in a manner that resulted in the safe storage of spent fuel and the proper operation of radiation monitoring and effluent control equipment at the facility.

3.2 Observations and Findings The inspectors reviewed the licensees work identification process to determine and evaluate how deficient items were captured and prioritized. The process to capture deficient items was being effectively implemented via required surveillances, normal watch rounds, and daily work requests. The inspectors determined that the prioritization process for work requests was being effectively implemented based on the inspectors review of the work schedule and discussions with the licensee staff and management, who determined the necessary resources and overall effect on plant status.

The inspectors also reviewed surveillance records, system health reports, the maintenance schedule, and items that were currently on the maintenance backlog.

Interviews with maintenance management helped the inspectors determine that the maintenance and surveillance program was being effectively implemented with the appropriate amount of management oversight.

The inspectors evaluated the licensees ability to implement the maintenance rule as required by 10 CFR 50.65. The regulations under 10 CFR 50.65(a)(1) require, in part, that licensees monitor the performance or condition of all structures, systems, and components (SSCs) associated with the storage, control, and maintenance of spent fuel in a safe condition, and in a manner sufficient to provide reasonable assurance that such SSCs were capable of performing their intended functions. The licensee was implementing the maintenance rule under 10 CFR 50.65 as required for decommissioning SSCs and was adequately evaluating the maintenance monitoring during decommissioning.

The licensee had identified those SSCs associated with the storage, control, or maintenance of spent fuel in a safe condition, as well as those SSCs relied upon to remain functional during or following design basis events associated with spent fuel storage, as defined in 10 CFR 50.65. The licensee maintained a maintenance rule functional record for each SSC identified, which specified the acceptable functions of the SSC in order to determine its success during the monitoring period. The inspectors concluded that the licensee had identified the appropriate SSCs under the maintenance rule program and were monitoring them sufficiently.

3.3 Conclusions The licensee implemented its maintenance and surveillance program consistent with procedures and regulatory requirements. The licensee was maintaining plant systems in accordance with the PDTS requirements. The licensee appropriately implemented the maintenance rule to ensure compliance with the requirements of 10 CFR 50.65 for structures, systems, and components associated with the storage, control, and maintenance of spent fuel.

4 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (IP 36801)

4.1 Inspection Scope The inspectors reviewed the licensees management organization to ensure it reflected regulatory requirements and the implementation of PDTS and the PSDAR. In addition, the licensees implementation of the employee concerns program was reviewed.

4.2 Observations and Findings The overall organizational structure at FCS was described in Section 5.2 of the PDTS.

The inspectors verified that the licensee maintained an overall organizational structure to support decommissioning activities and meet the minimum staffing requirements to perform activities specified in PDTS and the PSDAR. The licensee continued to manage and implement several oversight and review committees that established and maintained effective oversight of decommissioning activities. The licensee performed benchmarking with other decommissioning facilities and reviewed and evaluated regulatory information to help inform its decommissioning processes.

The inspectors attended the licensees Senior Leadership Team meeting in which major and significant risk activities were discussed, as well as the status of other activities being conducted at the facility. Based on a review of the tracking tools and the level of management involvement, the inspectors determined that the licensee was planning and sequencing activities in a manner that was reasonably consistent with the PSDAR. The inspectors did not review the cost assessment associated with the activities, because that particular review is performed by NRC Headquarters.

Discussions were held with licensee management on the subject of training and cross-qualification. The licensee informed the inspectors of the importance they were placing on cross-qualification of personnel as staffing was reduced in different areas due to retirements and attrition, in order to safely support dormancy. The inspectors also noted that the licensee was continuing the Systematic Approach to Training as evidenced by inspector reviews of Certified Fuel Handler (CFH) requalification written exams and observations in the plant of CFH job performance measures.

The licensee continued to implement its employee concerns and safety conscious work environment programs, in which workers can feel free to raise concerns to either the licensee or the NRC without fear of retaliation. The inspectors reviewed Licensee Procedure EI-FC-101, Employee Concerns Program, Revision 2, which provided a confidential avenue for individuals to report concerns, within a safety conscious work environment. Based on discussions with the investigator, the inspectors concluded that the investigator was knowledgeable of the types of concerns raised at the facility and was involved in reaching out to individuals from the different line organizations to ensure concerns were addressed. The inspectors observed that posters regarding the employee concerns program were prominently displayed across the site.

4.3 Conclusions The licensee maintained an overall organizational structure to support decommissioning activities as required by the PDTS and PSDAR. The licensee was continuing to benchmark activities in preparation of the SAFSTOR strategy with other decommissioned facilities.

The licensee was implementing its employee concerns program in which individuals could raise concerns without fear of retaliation.

5 Radioactive Waste Treatment, and Effluent, and Environmental Monitoring (IP 84750)

5.1 Inspection Scope The inspectors reviewed the licensees 2017 Annual Radioactive Effluent Release Report and the Annual Radiological Environmental Operating Report to verify that the program was implemented consistent with the licensees PDTS and ODCM requirements.

5.2 Observations and Findings The PDTS, Section 5.16, requires, in part, that the licensee establish, implement, and maintain a radiological effluents and environmental monitoring program as specified in the ODCM. The ODCM provided the methodology and parameters for monitoring, sampling, performing analyses, and reporting of radiation and radionuclides in the

environment. In addition PDTS, Sections 5.9.4.a and 5.9.4.b, requires the licensee to submit the Radiological Effluent Release Report and Radiological Environmental Operating Report to the NRC before May 1 of each year. The 2017 Annual Radiological Effluent Release Report and Radiological Environmental Operating Report were submitted on April 11, 2018 (ML18106A037). The Annual Radiological Effluent Release Report also included a copy of the ODCM, as required by the PDTS, Section 5.17.d.

The annual radioactive effluent release report documented the gaseous and liquid effluents for 2017. The inspectors reviewed the annual report and compared the data and information provided against the requirements in the ODCM. The licensee monitored releases of fission and activation products, tritium, dissolved and entrained gases, and gross alpha radioactivity in the liquid effluents. The licensee calculated the quarterly doses at the site boundary in accordance with the ODCM and the results were less than one millirem (mrem) based on the liquid and gaseous effluent releases.

The inspectors conducted a walk-down with licensee personnel to observe the gaseous and liquid pathways at the facility. The inspectors reviewed the last administrative values for the radwaste liquid effluent and gaseous effluent pathways and determined they were maintained as required by the ODCM. The inspectors also conducted a walk-down with licensee personnel of the groundwater well locations at the site. No new monitoring wells were added to the sampling program in 2017. The groundwater well data was captured in the 2017 Radiological Environmental Operating Report.

The NRC inspectors reviewed the data results collected under the Radiological Environmental Monitoring Program (REMP) and concluded that the licensee had collected the required samples at the specified locations, and performed the analyses in accordance with the ODCM. The licensee monitored airborne, surface water, ground water, milk, vegetation, fish, sediment, food crops, and direct radiation exposure as measured by thermoluminescent dosimeters (TLDs) in order to evaluate the effluent release program at the facility. Based on the air particulate and environmental sample results, there was no accumulation of radioactivity in the environment, as a result of licensed activities.

The licensee performed the biennial environmental land use survey between June 1 and October 1, in accordance with the PDTS, Section 5.16 and ODCM, Section 5.2. The licensee performed the survey in 2016, which was documented in the Annual Radiological Environmental Operating Report. The inspectors confirmed there were no changes in the use of areas at, or beyond the site boundary that would require changes to the REMP.

The licensee made two revisions to its ODCM during the period January 1, 2017, through December 31, 2017, in accordance with Technical Specification 7.17. The revisions incorporated changes to the ODCM, including adding 12 TLD locations. The inspectors determined that the changes were appropriate and did not reduce the effectiveness of the radioactive effluent control program.

Based on the NRCs approved changes to the PDTS on March 7, 2018, which removed a number of plant systems, the licensee subsequently performed 91 changes to its ODCM, Revision 28, in 2018. The PDTS, Section 5.17, allows the licensee to make changes to its ODCM, provided there is sufficient information to support the change together with the appropriate analyses or evaluations to justify the change, and the

levels of radioactive effluent control as required by the NRC regulations are not adversely impacted, and the change has been reviewed by the licensee and found acceptable.

The inspectors reviewed the ODCM, Revision 28 change package, and did not identify any changes that were incorrectly screened or required further evaluation. The inspectors determined that the licensee provided adequate analyses and justifications to support the ODCM change screenings and determinations that were approved by the Plant Manager on November 1, 2017, after the Plant Operations Review Committee approved the package. The licensee implemented the Revision 28, of the ODCM on March 19, 2018, after the PDTS, License Amendment No. 297 had gone into effect.

5.3 Conclusions The licensee implemented and maintained the effluent monitoring and control systems for calendar year 2017 in accordance with the ODCM. The licensees program met the appropriate regulatory requirements set forth in the ODCM for sample collection methodology and locations, quality control and quality assurance of the program, and comparison of data results to pre-operational data results.

6 Exit Meeting Summary On August 30, 2018, the NRC inspectors presented the final inspection results to Ms. Mary J. Fisher, Senior Director FCS Decommissioning, and other members of the licensees staff. No proprietary information was identified with the exception of certain budgeting documents, which were not retained by the inspectors.

SUPPLEMENTARY INFORMATION KEY POINTS OF CONTACT Licensee Personnel T.Maine, Plant Manager C.Longua, Assistant Plant Manager Operations J.Cate, Manager, Engineering Design and Program J.Shuck, Manager, System Engineering S.Arora, Supervisor, Nuclear Engineering J.McBride, Senior Auditor, NOS R.Beck, Supervisor Chemical Operations J.Hoffman, Technical Support Specialist M.Marcellus, Technical Support Specialist C.Cameron, Principal Regulatory Specialist INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 60801 Spent Fuel Pool Safety at Permanently Shutdown Reactors IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors IP 36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors IP 84750 Radioactive Waste Treatment, and Effluent, and Environmental LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed None Discussed None Attachment

LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFH Certified Fuel Handler CFR Code of Federal Regulations CR Condition Report DSAR Defueled Safety Analysis Report FCS Fort Calhoun Station HSA Historical Site Assessment IMC Inspection Manual Chapter MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual NELAP National Environmental Laboratory Accreditation Program NRC Nuclear Regulatory Commission NUPIC Nuclear Procurement Issues Corporation ODCM Offsite Dose Calculation Manual OPPD Omaha Public Power District PDEP Permanently Defueled Emergency Plant PPM Parts Per Million PDTS Permanently Defueled Technical Specifications PSDAR Post-Shutdown Decommissioning Activities Report REMP Radiological Environmental Monitoring Program SFP Spent Fuel Pool SSC Structures, Systems, and Components TLD Thermoluminescent Dosimeter

ML18261A034 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: RSB Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DNMS/FCDB DNMS/FCDB DNMS/FCDB C:FCDB NAME RSBrowder CDSteely SGAnderson JFKatanic SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 9/20/18 9/26/18 9/20/18 9/27/18