IR 05000285/2018004

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Omaha Public Power District; Fort Calhoun Station - NRC Inspection Report 05000285/2018-004
ML18319A196
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 11/19/2018
From: Janine Katanic
Division of Nuclear Materials Safety IV
To: Fisher M
Omaha Public Power District
References
IR 2018004
Download: ML18319A196 (12)


Text

ber 19, 2018

SUBJECT:

FORT CALHOUN STATION - NRC INSPECTION REPORT 05000285/2018-004

Dear Ms. Fisher:

This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) inspection conducted on October 22-25, 2018, at the Fort Calhoun Station located near Blair, Nebraska. The NRC inspector discussed the results of this inspection with Mr. Ted Maine and members of your staff during a final exit meeting conducted on October 25, 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 inspector reviewed your planned decommissioning activities to support SAFSTOR and DECON conditions at the facility; controls for spent fuel safety; implementation of your corrective action program; and your preparations for potential adverse weather. 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:

NRC Inspection Report 05000285/2018-004 w/Attachment: Supplemental Information

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 05000285 License No.: DPR-40 Report No.: 05000285/2018-004 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, Nebraska Inspection Dates: October 22-25, 2018 Inspector: Chris D. Steely, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Accompanied By: Troy W. Pruett, Director 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 05000285/2018-004 This U.S. Nuclear Regulatory Commissions (NRCs) inspection was a routine, announced inspection of decommissioning activities being conducted at the Fort Calhoun Station under NRC Inspection Report 05000285/2018-004. 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 with a transition to DECON in accordance with its procedures and the Post-Shutdown Decommissioning Activities Report. The inspector determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. (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 and procedural requirements. The licensee was safely storing the spent fuel assemblies contained in the spent fuel pool. (Section 2.2)

Adverse Weather Protection The licensee had initiated its adverse weather preparations in accordance with regulatory and license requirements. (Section 3.2)

Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors Issues were identified by the licensee at appropriate thresholds and entered into the corrective action program. Issues were screened and prioritized and commensurate with safety significance. Licensee evaluations determined the significance of issues, and included appropriate remedial corrective actions. (Section 4.2)

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 the Fort Calhoun Station (ADAMS Accession ML16176A213). By letter dated November 13, 2016, OPPD notified the NRC that it had permanently ceased power operations at the Fort Calhoun Station on October 24, 2016, and certified pursuant to Title 10 of the Code of Federal Regulations (CFR) 50.82(a)(1)(ii), that as of November 13, 2016, all fuel had been permanently removed from the Fort Calhoun Stations reactor vessel and placed into the spent fuel pool (ADAMS Accession ML16319A254).

On December 28, 2016, the NRC informed the licensee that it was no longer under NRC Inspection Manual Chapters 0305, Operating Reactor Assessment Program; 0608, Performance Indicator Program; and 2515, Light-Water Reactor Inspection Program when conducting oversight activities and assessing site performance (ADAMS Accession ML16363A449). The licensee was informed that the NRCs oversight of licensed activities under decommissioning would be conducted under the provisions in NRC Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program.

The licensee submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) on March 30, 2017 (ADAMS Accession 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 Fort Calhoun Stations PSDAR. The transcript of the public meeting is available in ADAMS under (ADAMS Accession ML17160A394).

The licensee initially 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. On October 11, 2018, however, the OPPD board voted to pivot from SAFSTOR to DECON. DECON will consist of decontamination and deconstruction of the site in a process that will begin much sooner on a date to be determined by OPPD.

On April 12, 2017, Region IV closed the confirmatory action letter regarding the resolution of design issues that had been documented during the NRC Inspection Manual Chapter 0350 operation period, based on the Fort Calhoun Stations 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 (ADAMS Accession ML17102B737). On December 14, 2017 (ADAMS Accession 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 2017-00842. By letter dated July 24, 2018 (ADAMS Accession ML18205A090), the licensee informed the NRC that the commitment actions and the associated condition report 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) (ADAMS Accession 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, (ADAMS Accession ML17276B286). This exemption allows OPPD to discontinue off-site radiological emergency planning activities and reduce the scope of its on-site emergency planning at the Fort Calhoun Station, to be effective no sooner than April 7, 2018. On April 9, 2018, the licensee implemented its NRC approved Permanently Defueled Emergency Plan.

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

1.1 Inspection Scope The inspector reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:

  • Status of ongoing decommissioning activities and planning for future activities;
  • Operability and functionality of systems necessary for safe decommissioning were assessed through plant walkdowns, such as: radioactive effluent monitoring, spent fuel pool level and temperature control, and radiation protection monitors and alarms;
  • Performed plant tours to assess field conditions and decommissioning activities; and
  • Observed and assessed the status of facility housekeeping.

1.2 Observations and Findings The inspector observed the weekly senior leadership team meeting, which focused on the scheduled tasks necessary to eventually begin the DECON process. 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 inspector had discussions with the management team regarding the DECON process. The discussion of decommissioning activities included the radioactive and transportation requirements of shipping large reactor plant components from on-site to the disposal facility and the schedule for moving all fuel from the spent fuel pool (SFP) to the independent spent fuel storage installation. Finally, the licensee acknowledged they understood that the change from SAFSTOR to DECON would require a change to the PSDAR.

During this inspection a tour was conducted of the facility, including the control room, spent fuel pool, and intake structure. The inspector observed the control room logs were maintained electronically and contained pertinent records of the facility operations and status.

The mechanical systems that supported spent fuel pool safety had not undergone any changes since the last inspection. These systems included raw water, which discharges into the Missouri River as the ultimate heat sink; component cooling water; SFP cooling and instrument air and turbine plant cooling water. All major secondary systems had been drained, as well as primary systems not required for SAFSTOR and spent fuel safety. In the areas toured, the licensee had implemented radiation protection controls, including postings and labeling that were in compliance with regulatory and procedure requirements. The inspector also observed the status of boundaries, postings, and labeling to ensure compliance with regulatory and procedural requirements.

Through observations and discussions with staff, the inspector determined that the licensee was appropriately controlling and conducting facility operations in a safe manner. General observations by the inspector 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.

1.3 Conclusion The inspector determined that the licensee and its staff conducted decommissioning activities in accordance with the regulations and license requirements. The plant tour walkdown verified the material condition of structures, systems, and components, and the safe conduct of decommissioning.

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

2.1 Inspection Scope The inspector reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:

  • That design, operational, and administrative measures are in place to prevent a substantial reduction in SFP coolant inventory under normal and accident conditions;
  • Whether the SFP instrumentation, alarms, and leakage detection systems are adequate to assure safe wet storage of spent fuel;
  • That SFP water chemistry and cleanliness control programs maintain water purity standards, limits on radionuclide concentration, and minimum boron concentration in accordance with the technical specification requirements (as applicable);
  • Whether the licensees criticality controls are consistent with the applicable nuclear criticality safety analyses;
  • That licensee procedures, drawings, and PSDAR descriptions and operations regarding the SFP operation and power supplies are adequate; and
  • Determine that the licensee is identifying problems related to SFP activities at an appropriate threshold and entering them into the corrective action program.

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 inspector reviewed the SFP level operational logs and reviewed chemistry data for the period since the last inspection. The inspector 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 2367 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 81°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 Adverse Weather Protection (71111.01)

3.1 Inspection Scope The inspector reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:

  • That weather-related equipment deficiencies identified during the previous year have been corrected prior to the onset of seasonal extremes;
  • Licensee implementation of the seasonal extreme weather preparation procedures and compensatory measures for the seasonal extremes; and
  • Risk significant systems that are required to be protected from the seasonal extreme weather conditions are evaluated.

3.2 Observations and Findings The inspector reviewed several of the licensees procedures including Procedures OI-EW-1, Extreme Weather, Revision 37; OI-EW-2, Cold Weather Operations with Auxiliary Steam Unavailable, Revision 6; SY-FC-101-146, Severe Weather Preparation and Response, Revision 1; and SA-FC-2114, Winter Safety, Revision 3. The inspector discussed the preparations and lessons learned with several licensee staff members regarding the actions taken by the licensee to ensure those systems important to decommissioning safety would not be impaired due to extreme cold weather. Based on the actions taken during the 2017 winter, the licensee did not experience any pipe breaks or impacts to those systems important to decommissioning safety. In preparation for the 2018 winter readiness, the licensee had initiated several work orders to perform the actions necessary for cold weather preparations.

3.3 Conclusions The licensee had initiated its adverse weather preparations in accordance with regulatory and license requirements.

4 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors (40801)

4.1 Inspection Scope The inspector reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:

  • Administrative procedures prescribed actions for the identification, evaluation, and resolution of problems;
  • Licensee procedures prescribed thresholds for the performance of self-assessments, audits, and surveillances;
  • Licensee management reviewed self-assessments, audits, and corrective actions to remain knowledgeable of plant performance;
  • Issues or problems were identified and corrected in accordance with the licensees corrective action program;
  • Quality assurance personnel audited changes in the status of decommissioning and licensee organization; and
  • Licensee management observed maintenance and surveillance activities, operations evolutions, and training.

4.2 Observations and Findings The inspector reviewed the Quality Assurance Topical Report (QATR), Revision 10, Chapter 16, Corrective Action, that described the licensees program to identify and correct conditions adverse to quality and reviewed the licensees Procedure PI-FC-125, Decommissioning Corrective Action Program, Revision 1, which governs the corrective action program.

The inspector observed a Management Review Committee meeting that was typically held weekly. The Management Review Committee had representatives from the different functional areas and a quorum was met, as specified by Procedure PI-FC-125. The inspector observed a good discussion by the Management Review Committee members regarding the appropriate significance level, ownership, and task assignments of the condition reports on the agenda.

The inspector reviewed approximately 30 condition reports, and concluded that the condition reports provided adequate documentation and description of the condition adverse to quality or condition adverse to regulatory compliance as defined by the licensees procedure. In addition, the inspector determined that the significance levels assigned to the respective condition reports were appropriate. The inspector also verified that the corrective actions adequately addressed the deficiencies described in the documentation.

4.3 Conclusions The licensee was adequately implementing its corrective action program in accordance with regulatory requirements and commitments. The licensees audit program was being conducted and maintained in accordance with the appropriate regulatory requirements as prescribed by the QATR, Revision 10.

5 Exit Meeting Summary On October 25, 2018, the NRC inspector presented the final inspection results to Mr. Ted Maine, Plant Manager, 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 inspector.

SUPPLEMENTARY INFORMATION KEY POINTS OF CONTACT Licensee Personnel T. Uehling, Senior Director, Fort Calhoun Station Decommissioning T. Maine, Plant Manager C. Longua, Assistant Plant Manager Operations J. Cate, Manager, Engineering Design and Program J. Shuck, Manager, System Engineering J. McBride, Senior Auditor, NOS B. Blome, Director, License and Regulatory Affairs 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 40801 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors IP 71111.01 Adverse Weather Protection LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed None Discussed None LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations NRC Nuclear Regulatory Commission OPPD Omaha Public Power District PDTS Permanently Defueled Technical Specifications PSDAR Post-Shutdown Decommissioning Activities Report QATR Quality Assurance Topical Report SFP Spent Fuel Pool Attachment

ML18319A196 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: CS Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DNMS/FCDB C:FCDB NAME CSteely JFKatanic SIGNATURE /RA/ /RA/

DATE 11/16/18 11/19/18