LIC-13-0121, Request for Exemption from Requirements of 10 CFR 26.205(d)(7)

Request for Exemption from Requirements of 10 CFR 26.205(d)(7)

ML13231A018
Person / Time
Site:	Fort Calhoun
Issue date:	08/16/2013
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-13-0121
Download: ML13231A018 (15)

Text

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jjjjjj0 Omaha Plll1llt: Pl1lller IJistrid w444 South 16th Street Mall 011Ulha, NE 68102-2247 August 16, 2013 LIC-13-0121 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C. 20555

Reference:

Docket No. 50-285

SUBJECT:

Request for Exemption from Requirements of 10 CFR 26.205(d)(7)

In accordance with the requirements of 10 CFR 26.9, the Omaha Public Power District (OPPD) requests that the Nuclear Regulatory Commission (NRC) approve an exemption for Fort Calhoun Station (FCS), Unit No. 1 from specific requirements of 10 CFR 26.205(d)(7). 10 CFR 26.205(d)(4) and (d)(5) permit the use of less restrictive work hour limitations during the first 60 days of a unit outage, in lieu of the requirements of 10 CFR 26.205(d)(7). The proposed exemption would allow the use of the less restrictive work hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to support activities required for plant startup from the current extended outage, for a period not to exceed 45 days. The proposed exemption would apply to the personnel performing the duties defined in 10 CFR 26.4(a)(1) through (a)(5).

OPPD requests approval of this exemption request within 30 days to support the activities required to complete the current, extended outage.

Details and supporting analysis for the exemption request are provided in Attachment 1. An Environmental Assessment supporting the exemption request is provided in Attachment 2. contains a regulatory commitment that will be applicable during the period of exemption to apply the limitations of 10 CFR 26.205(d)(4) and (d)(5) regarding minimum days off for covered personnel.

If you should have any additional questions or require additional information, please contact Mr. Bill

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Louis P. Cortopassi Site Vice President and CNO Attachments: 1. Request for Exemption from Requirements of 10 CFR 26.205(d)(7)

2. Environmental Assessment

3. Regulatory Commitment List

4. References EmploymentwfthEqua/Opporlunfty

LIC-13-0121 Page 2 Request for Exemption from Requirements of 10 CFR 26.205(d)(7)

Pursuant to 10 CFR 26.9, "Specific exemptions," the Omaha Public Power District (OPPD) hereby requests an exemption from portions of 10 CFR 26.205(d)(7) for Fort Calhoun Station (FCS), Unit No. 1. Currently, 10 CFR 26.205(d)(4) and (d)(5) permit the use of less restrictive work hour limitations during the first 60 days of a unit outage, in lieu of the requirements of 10 CFR 26.205(d)(7). The proposed exemption would allow the use of the less restrictive work hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) for an additional period not to exceed 45 days to support activities required for plant startup from the current extended outage.

The proposed exemption would apply to the personnel performing the duties defined in 10 CFR 26.4(a)(1) through (a)(5).

A. BACKGROUND FCS, Unit No. 1 commenced a refueling outage on April 9, 2011. During the outage, unprecedented flooding in the Missouri River Basin resulted in FCS declaring an Unusual Event (UE) on June 6, 2011, which was exited on August 29, 2011 (Event Notification 46929).

The first 60 days of the outage during which the less restrictive work hour limitations of 10 CFR 26.205(d)(4) and (d)(5) were in effect, ended in June 2011. However, due to the declaration of the flooding emergency, work hour limitations were suspended until the UE was exited on August 29, 2011. Subsequently, the personnel performing the duties defined in 10 CFR 26.4(a)(1) through (a)(5) transitioned to an on-line schedule that complied with 10 CFR 26.205(d)(3). In August 2012, station procedures and processes were revised and an on-line schedule was implemented that complies with 10 CFR 26.205(d)(7) for maximum average work hours.

In October 2012, OPPD submitted a request (Reference 1) for a one-time exemption from requirements of 10 CFR 26.205(d)(7). After several NRC requests for additional information (References 2 and 4) and OPPD responses thereto (References 3 and 5),

on June 11, 2013 the exemption was approved for an additional 60-day period, which expired on August 9, 2013. In obtaining the exemption, OPPD committed (Reference 6) to ensure that no individual covered by 10 CFR 26.4(a)(1) through (a)(5) would work more than 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per week averaged over the two-week period prior to the effective date of the exemption.

During the period of June 11 through August 9, 2013, when the less restrictive work hour limitations of 10 CFR 26.205(d)(4) and (d)(5) were in effect, OPPD completed a significant number of activities required to restart FCS. However, as noted in References 8 and 9, OPPD has revised its current licensing basis for tornadoes and tornado missiles to comply with Regulatory Guide 1.76, Revision 1 and Bechtel Topical Report BC-TOP-9A, Revision 2. This requires the installation of barriers to protect equipment required for safe shutdown from tornado-generated missiles. Within the last

LIC-13-0121 Page 3 several weeks, additional tornado missile vulnerabilities have been identified, and are being aggressively corrected through the modification process.

As a result, additional work remains to restart the plant and protect public health and safety. Due to the number of activities involved and discovery of additional tornado missile vulnerabilities, this work could not be finished in the June 11 to August 9, 2013 window.

B. 10 CFR 26 REQUIREMENTS The 10 CFR 26 requirements involved in the proposed exemption are described below.

10 CFR 26.4(a) defines the categories of individuals that are subject to the work hour controls specified in 10 CFR 26.205. These categories include:

(1) Operating or onsite directing of the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety; (2) Performing health physics or chemistry duties required as a member of the onsite emergency response organization minimum shift complement; (3) Performing the duties of a fire brigade member who is responsible for understanding the effects of fire and fire suppressants on safe shutdown capability; (4) Performing maintenance or onsite directing of the maintenance of SSCs that a risk-informed evaluation process has shown to be significant to public health and safety; and (5) Performing security duties as an armed security force officer, alarm station operator, response team leader, or watchman, hereinafter referred to as security personnel.

10 CFR 26.205(d)(3) provides the following requirements:

Licensees shall either ensure that individuals have, at a minimum, the number of days off specified in this paragraph, or comply with the requirements for maximum average work hours in § 26.205(d)(7). For the purposes of this section, a day off is defined as a calendar day during which an individual does not start a work shift. For the purposes of calculating the average number of days off required in this paragraph, the duration of the shift cycle may not exceed 6 weeks.

(i) Individuals who are working 8-hour shift schedules shall have at least 1 day off per week, averaged over the shift cycle; (ii) Individuals who are working 10-hour shift schedules shall have at least 2 days off per week, averaged over the shift cycle; (iii) Individuals who are working 12-hour shift schedules while performing the duties described in § 26.4(a)(1) through (a)(3) shall have at least 2.5 days off per week, averaged over the shift cycle; (iv) Individuals who are working 12-hour shift schedules while performing the duties described in § 26.4(a)(4) shall have at least 2 days off per week, averaged over the shift cycle; and

LIC-13-0121 Page 4 (v) Individuals who are working 12-hour shift schedules while performing the duties described in § 26.4(a)(5) shall have at least 3 days off per week, averaged over the shift cycle.

10 CFR 26.205(d)(4) provides the following requirements:

During the first 60 days of a unit outage, licensees need not meet the requirements of § 26.205(d)(3) or (d)(7) for individuals specified in § 26.4(a)(1) through (a)(4), while those individuals are working on outage activities. However, the licensee shall ensure that the individuals specified in § 26.4(a)(1) through (a)(3) have at least 3 days off in each successive (i.e., non-rolling) 15-day period and that the individuals specified in § 26.4(a)(4) have at least 1 day off in any 7-day period; 10 CFR 26.205(d)(5) provides the following requirements:

During the first 60 days of a unit outage, security system outage, or increased threat condition, licensees shall control the hours worked by individuals specified in § 26.4(a)(5) as follows:

(i) During the first 60 days of a unit outage or a planned security system outage, licensees need not meet the requirements of § 26.205(d)(3) or (d)(7). However, licensees shall ensure that these individuals have at least 4 days off in each successive (i.e., non-rolling) 15-day period; and (ii) During the first 60 days of an unplanned security system outage or increased threat condition, licensees need not meet the requirements of § 26.205(d)(3), (d)(5)(i), or (d)(7).

10 CFR 26.205(d)(7) provides the following requirements:

Licensees may, as an alternative to complying with the minimum days off requirements in § 26.205(d)(3), comply with the requirements for maximum average work hours in this paragraph.

(i) Individuals may not work more than a weekly average of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />, calculated using an averaging period of up to six (6) weeks, which advances by 7 consecutive calendar days at the finish of every averaging period.

(ii) For purposes of this section, when an individuals work shift starts at the end of a calendar day and concludes during the next calendar day, the licensee shall either consider the hours worked during that entire shift as if they were all worked on the day the shift started, or attribute the hours to the calendar days on which the hours were actually worked.

(iii) Each licensee shall state, in its FFD policy and procedures required by § 26.27 and

§ 26.203(a) and (b), the work hour counting system in § 26.205(d)(7)(ii) the licensee is using.

LIC-13-0121 Page 5 10 CFR 26.9, Specific exemptions, states:

Upon application of any interested person or on its own initiative, the Commission may grant such exemptions from the requirements of the regulations in 10 CFR 26 as it determines are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest.

C. PROPOSED EXEMPTION OPPD requests an exemption from the provisions of 10 CFR 26.205(d)(7) that would allow the application of the less restrictive work hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to be applied to support activities required for plant startup from the current extended outage, in lieu of the work hour limitations described in 10 CFR 26.205(d)(7). The proposed exemption would be applicable for a period not to exceed 45 days to support the activities required for plant startup from the current, extended outage. The proposed exemption would apply to the personnel covered by 10 CFR 26.4(a)(1) through (a)(5). During the period of exemption, OPPD will apply the limitations of 10 CFR 26.205(d)(4) and (d)(5) as applicable to the individuals performing the duties specified in 10 CFR 26.4(a)(1) through (a)(5).

D. BASIS FOR PROPOSED EXEMPTION In accordance with 10 CFR 26.9, "Specific exemptions," the NRC may grant exemptions from the regulations that are determined to be authorized by law, that do not endanger life or property or the common defense and security, and are otherwise in the public interest. This exemption request satisfies these requirements.

The proposed exemption is authorized by law in that no other prohibition of law exists to preclude the activities which would be authorized by the exemption. The provisions of 10 CFR 26.9 allow the NRC to grant exemptions from the requirements of 10 CFR 26.

Therefore, the proposed exemption is authorized by law.

10 CFR 26, Subpart I, as described in the Federal Register Notice (73 FR 16966), is to provide assurance that cumulative fatigue does not compromise the abilities of individuals to safely and competently perform their duties. The maximum average work hour requirements of 10 CFR 26.205(d)(7) address the long-term control of work hours while permitting the occasional use of extended work hours for short duration circumstances such as equipment failure, personnel illness, or attrition. The provisions of 10 CFR 26.205(d)(4) and (d)(5) allow a 60-day period in which the maximum average work hour requirements of 10 CFR 26.205(d)(7) are replaced by less restrictive requirements. The limitations in 10 CFR 26.205(d)(4) and (d)(5) address the control of work hours for unique plant conditions, such as unit outages, which require extended work hours for a more sustained period of time. The less restrictive limitations of 10 CFR 26.205(d)(4) and (d)(5) provide licensees flexibility in scheduling required days off while accommodating the more intensive work schedules that accompany a unit outage.

Limiting the time period in which the less restrictive limitations may be applied provides

LIC-13-0121 Page 6 assurance that cumulative fatigue does not compromise the ability of individuals to safely and competently perform their duties.

The proposed exemption would allow the less restrictive work hour limitations to be applied during a period not to exceed 45 days to support activities required for plant startup from the current extended outage. The exemption will apply to the personnel performing the duties defined in 10 CFR 26.4(a)(1) through (a)(5). After the work hour exemption (Reference 7) expired on August 9, 2013, these personnel began working a normal, on-line schedule in compliance with 10 CFR 26.205(d)(7) for maximum average work hours.

Tables 1 and 2 are derived from the FCS EmpCenter database that is used to monitor covered workers hours and provides a summary of average hours worked obtained from over 3500 data points of weekly hours reported. The tables show the average hours worked for the week and the number of individuals that worked the hours equal to or greater than the average and does not include individuals that reported no work hours for the specified week. This information is provided to indicate that collectively individual workers had periods of reduced hours, even during the period of extended hours. In addition, personnel have transitioned back to normal average work hours and will be following the normal work hour schedule for at least 30 days.

Regulatory Position C.10 from Regulatory Guide 5.73, Fatigue Management For Nuclear Power Plant Personnel, dated February 2009, states:

Licensee employees and contractor/vendor personnel may go from an outage at one site to an outage at another site. When a licensee employee or contractor/vendor performs covered work for a licensee during two or more unit outages or security system outages (or a combination thereof), and the interval(s) between successive outages is less than 9 days, the receiving licensee should determine that the individual has had a 34-hour break period within the 9 days that precede the day on which the individual begins working for the receiving licensee. In addition, when the individual begins work for the receiving licensee, the licensee should ensure that individuals hours worked did not and will not exceed the following limits:

1. 16 work hours in any 24-hour period

2. 26 work hours in any 48-hour period

3. 72 work hours in any 7-day period

LIC-13-0121 Page 7 Table 1 - Average Hours Worked Weeks of June 9 - July 7 Week 6/9/13 6/16/13 6/23/13 6/30/13 7/7/13 Dept.

Dept. Name Average Hours / No. of Workers Met or Exceeded Average Hours per Week No.

315 OPPD Substation & System Prot 40.8 4 of 6 50.8 3 of 7 39.9 5 of 7 26.1 4 of 7 44.2 4 of 7 350 FCS Kiewit Contractors 47 12 of 23 60 12 of 23 57 16 of 27 55.5 15 of 27 58 12 of 26 482 OPPD NE City Maint 39.3 1 of 3 32.5 2 of 3 58.5 2 of 3 58.6 2 of 3 69 1 of 2 485 OPPD Central Maint 28 1 of 1 56.5 1 of 1 55 1 of 1 57.5 1 of 1 54.5 1 of 1 486 OPPD Central Maint - Elec 33.9 3 of 4 47.4 2 of 4 38.6 2 of 4 55.6 2 of 4 49.4 3 of 4 489 OPPD Central Maint - Mech Maint 39.2 4 of 9 55.1 5 of 9 54.2 5 of 9 38 3 of 7 52.9 5 of 9 820 FCS Training 23.3 1 of 2 54.1 1 of 2 54.5 1 of 2 37.7 1 of 2 36.8 1 of 2 830 FCS Security 33.5 70 of 125 45.6 77 of 126 46.5 72 of 128 45 79 of 124 45.5 80 of 120 841 FCS Operations 40.3 34 of 75 54.3 42 of 76 54.6 48 of 78 54.4 53 of 80 50.7 33 of 80 842 FCS Maintenance 47.6 65 of 102 62.4 67 of 102 62.9 68 of 107 59.5 68 of 109 63.7 70 of 108 843 FCS Radiation Protection 34 7 of 10 42 6 of 11 52.8 5 of 12 53.7 6 of 12 54.5 6 of 11 844 FCS Chemistry 33.6 7 of 12 36.3 5 of 11 60.3 9 of 11 59 11 of 12 56.2 9 of 12 845 FCS Work Management 40.2 1 of 3 49.8 1 of 3 42.5 3 of 3 48.3 1 of 2 46.8 1 of 3 850 FCS Misc Contractors 44.6 4 of 9 56.3 3 of 8 54 4 of 7 39.6 3 of 7 39.4 7 of 23 861 FCS Nuclear Projects 54 3 of 3 70 2 of 3 75 1 of 3 70 3 of 3 72 3 of 3

LIC-13-0121 Page 8 Table 2 - Average Hours Worked Weeks of July 14 - August 4 Week 7/14/13 7/21/13 7/28/13 8/4/13 Dept.

Dept. Name Average Hours / No. of Workers Met or Exceeded Average Hours per Week No.

315 OPPD Substation & System Prot 51 4 of 7 45.1 5 of 7 47.4 4 of 7 59.1 5 of 7 350 FCS Kiewit Contractors 58.6 13 of 27 48.5 15 of 26 53.6 14 of 32 52.8 29 of 38 482 OPPD NE City Maint 64 2 of 3 62.5 1 of 3 64.6 2 of 3 48.3 2 of 3 485 OPPD Central Maint 56 1 of 1 54.5 1 of 1 25.5 1 of 1 48 1 of 1 486 OPPD Central Maint - Elec 51.8 2 of 4 61.2 1 of 3 57.2 2 of 3 51.3 2 of 4 489 OPPD Central Maint - Mech Maint 54.2 6 of 9 53.6 6 of 9 53.1 6 of 8 58.5 6 of 8 820 FCS Training 59.5 1 of 2 49.8 1 of 2 59.8 1 of 2 52.8 1 of 2 830 FCS Security 45.3 75 of 122 44.6 58 of 122 46.2 75 of 121 38.8 52 of 122 841 FCS Operations 52.7 38 of 77 52 40 of 80 53.8 42 of 78 47.1 54 of 79 842 FCS Maintenance 62.6 73 of 109 62.5 75 of 106 63.3 66 of 110 60.7 46 of 109 843 FCS Radiation Protection 60 8 of 11 51.8 8 of 12 55.8 9 of 13 48.1 9 of 13 844 FCS Chemistry 59 9 of 12 57.9 10 of 12 51.9 8 of 12 50.6 3 of 12 845 FCS Work Management 50.3 2 of 3 42.3 2 of 3 34.5 2 of 3 41.7 1 of 3 850 FCS Misc Contractors 53.4 3 of 9 44.7 4 of 9 53.8 5 of 9 51.4 5 of 10 861 FCS Nuclear Projects 72 3 of 3 70 3 of 3 72 3 of 3 60 3 of 3

LIC-13-0121 Page 9 Regulatory position C.10 of Regulatory Guide 5.73 allows personnel to work extended hours during successive unit outages provided an adequate interval is provided between the unit outages to address the effects of cumulative fatigue.

Review of the hours worked during the period of the work hour exemption indicate that collectively individuals had periods of reduced hours, and the additional minimum 30 day period of working normal average hours provides assurance that cumulative fatigue will not compromise the ability of these individuals to safely and competently perform their duties. Therefore, the proposed exemption will not endanger life or property or the common defense and security, and is otherwise in the public interest.

Activities Required to Restart the Plant OPPD has undertaken comprehensive and aggressive actions to fully scope and correct the impact of the 2011 flood and recent performance problems at FCS. Systems, structures, and components have been assessed, detailed plans for repair, restoration, and performance improvement have been made, and much work has been accomplished. As noted in Reference 10, Item 2.b, systems that have been shut down for prolonged periods are subject to different environments than those experienced during power operations. As a result, the work load is greater than for a plant that has not been in an extended shutdown.

During the extended shutdown and as a result of being in Inspection Manual Chapter (IMC) 0350, a number of issues were discovered that must be resolved prior to restart.

As reported in Reference 11, it was identified that the high pressure injection pump injection flows to the reactor coolant system are not balanced. This has necessitated physical changes to the plant along with extensive system testing to ensure the system will perform as necessary following a design basis accident. Work also remains to complete modifications installing tornado missile protection.

FCS personnel must complete actions associated with the NRCs restart checklist that is intended to verify that the issues that resulted in the prolonged performance decline at Fort Calhoun Station are resolved prior to restart. Although the workload associated with the restart checklist may involve non-covered workers, there is a substantial amount of work that covered workers must support as well as it involves additional modifications, walk downs, inspections, etc., that are not associated with a normal refueling outage.

In summary, as a result of the extended outage and being in IMC 0350, FCS personnel including workers governed by 10 CFR 26.205 must put in additional hours beyond that required by a normal refueling outage. To accomplish the tasks listed above safely, efficiently, and effectively requires that OPPD be given the flexibility to schedule workers in accordance with 10 CFR 26.205(d)(4) and (d)(5).

LIC-13-0121 Page 10 As described above, this exemption request is consistent with the intent of the fatigue rule. As such, it is within the authority of the NRC to grant this request since changing the timeframe when outage hours can be worked will not endanger life or property or the common defense and security. The added flexibility will provide additional safety margin. There is no negative impact to the public interest as a result of this exemption request while the benefit to the affected employees will result in a positive impact to the public interest.

PRECEDENT On June 24, 2010, the NRC approved an exemption request for the Davis-Besse Nuclear Power Station (DBNPS) Unit 1, which applied the requirements of 10 CFR 26.205(d)(4) and (d)(5) to support the restart from an extended outage. (Agencywide Document Access and Management System (ADAMS) Accession Number ML101730457)

Davis-Besse is cited as precedent because it also sought an exemption because of an extended outage. Following the 60 days allowed by the less restrictive work hour limitations of 10 CFR 26.205(d)(4) and (d)(5), Davis-Besse personnel transitioned to an online schedule that complied with 10 CFR 26.205(d)(3) requirements.

Crystal River Unit 3 (CR-3) also submitted an exemption request (ADAMS Accession Number ML102000019) while in an extended outage preparing for an extended power uprate when delamination was discovered in the reactor-building wall. However, Florida Power Corporation subsequently withdrew the CR-3 exemption request (ADAMS Accession Number ML11103A077).

Fort Calhoun Station Unit 1 previously received an NRC approved exemption as described in Reference 7.

LIC-13-0121 Page 1 Fort Calhoun Station, Unit No. 1 Environmental Assessment The Omaha Public Power District (OPPD) is requesting an exemption from the provisions of 10 CFR 26.205(d)(7) for Fort Calhoun Station (FCS), Unit No. 1. The proposed exemption would allow the application of less restrictive work hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) in lieu of the work hour limitations described in 10 CFR 26.205(d)(7). The proposed exemption is to support the activities required for plant startup from the current, extended outage, for a period not to exceed 45 days. An environmental assessment for the proposed exemption follows.

1. Describe any change to the types, characteristics, or quantities of non-radiological effluents discharged to the environment as a result of the proposed exemption.

OPPD Response:

There are no expected changes in the types, characteristics, or quantities of non-radiological effluents discharged to the environment as a result of the proposed exemption.

The proposed exemption is administrative in nature and is limited to changing the timeframe when less restrictive hours can be worked. This does not result in any changes to the design basis requirements for the structures, systems, and components (SSCs) at FCS that function to limit the release of non-radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of offsite non-radiological effluents will continue to perform their functions, and as a result, there is no significant non-radiological effluent impact. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of non-radiological effluents. In addition, the method of operation of non-radiological waste systems will not be affected by the proposed exemption.

2. Describe any changes to liquid radioactive effluents discharged as a result of the proposed exemption.

OPPD Response:

There are no expected changes to liquid radioactive effluents discharged as a result of the proposed exemption. The proposed exemption is limited to administrative changes regarding the timeframe when less restrictive work hours can be worked and will not result in the production of any different quantity or type of radioactive material in the reactor coolant system. The proposed exemption will not result in changes to the design basis requirements for the SSCs at FCS that function to limit the release of liquid radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of liquid radiological effluents will continue to perform their functions, and as a result, there is no significant liquid radiological effluent impact.

LIC-13-0121 Page 2

3. Describe any changes to gaseous radioactive effluents discharged as a result of the proposed exemption.

OPPD Response:

There are no expected changes to gaseous radioactive effluents discharged as a result of the proposed exemption. The proposed administrative changes to the timeframe when less restrictive work hours can be worked will not result in the production of any different quantity or type of radioactive material in the reactor coolant system. These changes will not result in changes to the design basis requirements for the SSCs at FCS that function to limit the release of gaseous radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of gaseous radiological effluents will continue to perform their functions, and as a result, there is no significant gaseous radiological effluent impact.

4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemption.

OPPD Response:

There are no expected changes to solid radioactive waste generated as a result of the proposed exemption. The proposed administrative changes to the timeframe when less restrictive work hours can be worked will not result in the production of any different quantity or type of radioactive material. These changes will not result in changes to the design basis requirements for the SSCs at FCS that function to limit the release of solid radioactive waste during and following postulated accidents. In addition, radiation surveys will continue to be performed in accordance with plant radiation procedures. The SSCs associated with limiting the release of solid radioactive waste will continue to perform their functions, and as a result, there is no significant solid radioactive waste impact.

5. What is the expected change in occupational dose as a result of the proposed exemption under normal and design basis accident conditions?

OPPD Response:

The proposed exemption will allow less restrictive work hours for a limited period. The exemption will not increase or decrease the amount of work activities that must be completed in preparation of plant startup. As such, no change in occupational dose as a result of the proposed exemption under normal or design basis accident (DBA) conditions is expected.

6. What is the expected change in the public dose as a result of the proposed exemption under normal and design basis accident conditions?

OPPD Response:

Public dose is not changed by the proposed exemption during normal operations or DBA conditions. As noted in items 2, 3 and 4 above, there is no basis to contemplate an increased source of liquid, gaseous, solid radiological effluents, or associated leak rate that could contribute to increased public exposure during normal operations or DBA conditions.

LIC-13-0121 Page 3

7. What is the impact to land disturbance for the proposed exemption?

OPPD Response:

The proposed exemption will allow less restrictive work hours for a limited period. As such, the proposed exemption is administrative in nature and will not result in a land disturbance or affect a historical site.

==

Conclusion:==

There is no significant radiological environmental impact associated with implementing less restrictive work hours for a limited period. The proposed changes will not result in a land disturbance or affect any historical sites nor will they affect non-radiological plant effluents.

LIC-13-0121 Page 1 Regulatory Commitment List This list identifies the action(s) committed to by the Omaha Public Power District (OPPD) in this submittal. Any other actions discussed in this submittal are for informational purposes, or represent intended or planned actions; they are not regulatory commitments.

Regulatory Commitment

1. During the period of exemption, OPPD will apply the limitations of 10 CFR 26.205(d)(4) and (d)(5) as applicable to the individuals performing those duties specified in 10 CFR 26.4(a)(1) through (a)(5) regarding minimum days off for covered personnel.

LIC-13-0121 Page 1 References

1. Letter from Omaha Public Power District (Louis P. Cortopassi) to NRC (Document Control Desk), Request for One-Time Exemption from Requirements of 10 CFR 26.205(d)(7), dated October 10, 2012, (ML12284A344), (LIC-12-0145)

2. Email from NRC (L. E. Wilkins) to OPPD (B. R. Hansher), DRAFT: RAIs Fort Calhoun Work Hour Exemption Request (TAC No. ME9770), dated January 8, 2013

3. Letter from OPPD (M. J. Prospero) to NRC (Document Control Desk), OPPD Response to NRC RAI Regarding Request for Work Hours Exemption, dated March 16, 2013 (ML13101A004) (LIC-13-0007)

4. Email from NRC (L. E. Wilkins) to OPPD (B. R. Hansher), DRAFT: 2nd Round RAIs RE: Fort Calhoun Work Hour Exemption Request, dated April 10, 2013 (ML13100A175)

5. Letter from OPPD (T. W. Simpkin) to NRC (Document Control Desk), OPPD Response to NRC RAI Regarding Request for Work Hours Exemption, dated April 11, 2013 (ML13102A0447) (LIC-13-0046)

6. Letter from OPPD (M. J. Prospero) to NRC (Document Control Desk), OPPD Commitment to NRC Regarding Request for Work Hours Exemption, dated May 24, 2013 (ML13148A057)

(LIC-13-0071)

7. Letter from NRC (L. E. Wilkins) to OPPD (L. P. Cortopassi), Fort Calhoun Station, Unit No.1 Exemption from the Requirements of 10 CFR Part 26, Section 205 (TAC No. ME9770),

dated June 11, 2013 (ML13157A135) (NRC-13-0077)

8. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Exigent License Amendment Request 13-02, Revise Current Licensing Basis to Adopt a Revised Design Basis/Methodology for Addressing Design-Basis Tornado/Tornado Missile Impact, dated July 21, 2013 (ML13203A136) (LIC-13-0061)

9. Letter from NRC (M. T. Markley) to OPPD (L. P. Cortopassi), Fort Calhoun Station, Unit No.1-Issuance Of Exigent Amendment Re: Revise Current Licensing Basis for Addressing Design-Basis Tornado/Tornado Missile Impact (TAC NO. MF2469), dated July 26, 2013 (ML13203A070) (NRC-13-0095)

10. NRC Memorandum (from Tony Vegel to Eric Leeds), Issuance of U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Basis Document, dated November 13, 2012 (NRC-12-0106)

11. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Licensee Event Report 2013-010, Revision 1, for the Fort Calhoun Station, dated July 2, 2013 (LIC 13-0093)