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Category:Letter type:LIC
MONTHYEARLIC-23-0007, Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information2023-12-0606 December 2023 Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information LIC-23-0005, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 20232023-08-24024 August 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 2023 LIC-23-0004, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2023-04-20020 April 2023 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-23-0003, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2023-03-15015 March 2023 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-23-0001, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information2023-02-27027 February 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information LIC-23-0002, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2023-02-20020 February 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information LIC-22-0005, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2022-04-20020 April 2022 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2022-03-30030 March 2022 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-22-0006, Reactor Head Disposition Project Overview2022-03-17017 March 2022 Reactor Head Disposition Project Overview LIC-22-0004, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2022-02-17017 February 2022 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-21-0008, Organizational and Management Change2021-10-28028 October 2021 Organizational and Management Change LIC-21-0007, ISFSI Only Emergency Plan Update2021-09-0808 September 2021 ISFSI Only Emergency Plan Update LIC-21-0004, Radiological Effluent Release Report and Radiological Environmental Operating Report2021-04-29029 April 2021 Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-21-0003, Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report2021-03-30030 March 2021 Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-21-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-22022 February 2021 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0015, Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092)2020-07-29029 July 2020 Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092) LIC-20-0014, Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2020-07-15015 July 2020 Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-20-0012, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2020-05-18018 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool LIC-20-0011, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-05-0707 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0009, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2020-04-30030 April 2020 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-20-0008, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-04-13013 April 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0006, (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E2020-03-26026 March 2020 (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E LIC-20-0004, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-03-10010 March 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2020-02-27027 February 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0002, Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan2020-02-27027 February 2020 Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan LIC-20-0001, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-02-0606 February 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0025, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-12-19019 December 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019 Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-19-0022, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-11-18018 November 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0018, Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2019-11-14014 November 2019 Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-19-0020, Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis2019-10-17017 October 2019 Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis LIC-19-0017, Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 20042019-08-0808 August 2019 Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 An LIC-19-0010, License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associa2019-05-20020 May 2019 License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated LIC-19-0008, Submittal of 2018 Annual Report2019-04-0404 April 2019 Submittal of 2018 Annual Report LIC-19-0004, Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP)2019-03-28028 March 2019 Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP) LIC-19-0005, 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report2019-03-28028 March 2019 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report LIC-19-0001, License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2019-02-28028 February 2019 License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme LIC-19-0003, Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation R2019-02-28028 February 2019 Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation Requ LIC-19-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-01-0303 January 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-18-0031, Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update2018-12-17017 December 2018 Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update LIC-18-0030, Request for Partial Site Release Phase 22018-11-12012 November 2018 Request for Partial Site Release Phase 2 LIC-18-0028, Letter of Intent to Submit Request for Additional Partial Site Release2018-10-18018 October 2018 Letter of Intent to Submit Request for Additional Partial Site Release LIC-18-0027, Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update2018-10-0303 October 2018 Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update LIC-18-0003, License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool2018-09-28028 September 2018 License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool LIC-18-0025, Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 20192018-07-19019 July 2018 Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 2019 LIC-18-0023, Fort Calhoun Station, Unit 1 Request for Partial Site Release2018-06-29029 June 2018 Fort Calhoun Station, Unit 1 Request for Partial Site Release LIC-18-0021, Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan)2018-06-0606 June 2018 Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan) LIC-18-0017, Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy2018-04-26026 April 2018 Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy 2023-08-24
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fjjjjjfj Omaha Public Power District 444 South 1(jh Street Mall Omaha, NE 68102-2247 LlC-14-0049 March 27, 2014 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No.1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285
Subject:
OPPD Response to NRC Request for Additional Information Regarding Seismic Walkdown at Fort Calhoun Station
Reference:
Email from NRC (J. Sebrosky) to OPPD (8. Hansher), "Fort Calhoun Seismic Walkdown Request for Additional Information (MF0126)," dated March 19, 2014 (NRC-14-0023)
This letter is responding to the NRC staff's request for additional information (RAI) regarding the seismic walkdown conducted at Fort Calhoun Station. The Omaha Public Power District's (OPPD) response to the NRC RAI is attached.
This letter contains no new regulatory commitments.
If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Supervisor-Nuclear Licensing, at 402-533-6894.
I declare under penalty of perjury that the foregoing is true and correct. Executed on March 27, 2014.
Respectfully, LoUIs P. CortopaSSi Site Vice President and CNO LPC/JKG/mle
Attachment:
OPPD Response to NRC Request for Additional Information Regarding Seismic Walkdown at Fort Calhoun Station Employment with Equal Opportunity
LI C-14-0049 Attachment Page 1 OPPD Response to NRC Request for Additional Information Regarding Seismic Walkdown at Fort Calhoun Station
LI C-14-0049 Attachment Page 2 By letter dated November 27, 2012, (Agencywide Documents Access and Management System (ADAMS) Accession No ML12340A257) as supplemented by letters dated June 28, 2013, and November 27, 2013 (ADAMS Accession Nos. ML13193A236 and ML13333A674, respectively) Omaha Public Power District, (the licensee) submitted seismic walkdown information in response to the NRC's March 12, 2012, request for information (ADAMS Accession No. ML12053A340). The March 12, 2012, NRC letter requested licensees to conduct seismic hazard walkdowns to verify current plant configuration with the current licensing basis.
Based on a review of your November 27, 2012, June 28, 2013, and November 27, 2013, submittals, the NRC staff has determined that the following additional information (RAI) is required in order to complete its review. The request for additional information was discussed with Mr. Michael Edwards (OPPD Nuclear Licensing Engineer) on March 18, 2013. It was agreed that a response to these RAls would be provided by March 28, 2013.
Should the NRC determine that this RAI is no longer necessary prior to the scheduled date, the request will be withdrawn. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1132 or via e-mail at joseph.sebrosky@nrc.gov. The NRC staff has determined that no security-related or proprietary information is contained herein.
Request for Additional Information
- 1. The staff does not have enough information to verify that there are no items that could lead to rapid drain-down of the Fort Calhoun Station SFP or, if there are drain-down items, that they were sufficiently assessed in accordance with the guidance.
The rapid drain-down discussion does not reach a clear conclusion with respect to equipment that could cause a rapid drain down. In particular, the seismic walkdown report does not include a discussion on the evaluation of penetrations within 10 feet above the top of the fuel assemblies. Also, the report does not include a Rapid Drain-Down list as described in the seismic walkdown guidance (page 8-3). It is unclear whether the SFP items that cause rapid drain-down were included as part of the combined seismic walkdown equipment list (SWEL).
OPPD Response The spent fuel pool (SFP) and SFP cooling system is designed to prevent drainage of the spent fuel pool below the top of stored spent fuel. The top of a fuel assembly in a storage rack is about the same elevation as the bottom of the gate opening which is at elevation 1008' - 6".
There are five possible exit paths from the pool. The cooling water makeup line and the cooling water outlet line (with strainer) are both located at elevation 1034'. The bottom of the fuel transfer gate with the additional plate is at elevation 1009' 8-%". None of these paths is below the top of the spent fuel. The main cooling water supply enters the pool at elevation 1034' and terminates at elevation 1031' - 7". The secondary pool drain line is equipped with a normally locked closed valve (AC-187) at elevation 1011' - 4" to protect the pool from any ruptures of the line downstream of the valve. This line is designed so that a rupture between the valve and the pool wall will not drain the pool below the top of the fuel (Le. , the bottom of the pipe is at elevation 1011' - 0").
LI C-14-0049 Attachment Page 3 Connection Elevation Cooling water makeup 1034' Cooling water outlet 1034' Fuel transfer gate 1009'-8-W' Main cooling water supply 1031' - 7" Secondary pool drain 1011'-4" There are also two temporary 6" SFP cooling lines that are part of a temporary SFP cooling system. The temporary SFP cooling system is only installed if it is necessary to remove the permanent SFP cooling system from service for maintenance. The suction line is less than 7' below the top of the SFP and the return line is less than 7'-6" below the top of the SFP so these lines do not have the potential to be a significant drainage pathway.
The fuel transfer gate and the secondary pool drain are the only two exit paths at elevations less than ten feet above the stored fuel (i.e., below 1018' - 6"). The secondary pool drain line was not considered for inclusion in the SWEL2 list because it is seismically designed and equipped with a normally locked closed isolation valve. Likewise, the fuel transfer gate is seismically designed and is not considered a rapid drain down pathway. Thus, there are no items that could cause the spent fuel pool to drain rapidly (i.e., within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after an earthquake).
As described in Section 6.2 of EA12-021, Revision 1 submitted by OPPD letter, LlC-13-0070 dated June 28, 2013 (Adams Accession No. ML13193A236), components were selected in Base List (BL) 2 that are connected to systems associated with the SFP that could cause loss of SFP inventory. None were identified that could cause the spent fuel pool to drain rapidly.
Components, rather than piping, were selected because EPRI Technical Report 1025286, "Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3," June 2012 does not encompass piping systems and their associated inline valves (Le., manual valves).
These BL-2 items are listed in Attachment 11.1, page 27 of 30 of OPPD letter, LlC-12-0169 dated November 27,2012 (Adams Accession No. ML12340A254). The portions of the spent fuel pool and spent fuel pool cooling system that must be seismically designed are shown below on the system boundary diagram.
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The components of the SFP and SFP cooling system that were included in the SWEL are shown in the following table.
Equipment ID Description Storage Pool Heat Exchanger (HX)
HCV-478 Component Cooling Water (CCW) Outlet Valve AC-SA SFP CirculatinQ pump AC-S8 SFP Circulating pump AC-8 SFPHX AC-7 SFP Demineralizer AC-6 SFP Filter
LI C-14-0049 Attachment Page 5 A SFP inventory in excess of ten feet above the stored fuel assemblies is maintained if any of these components are lost.
- 2. The staff is unable to confirm that the cabinets were opened and inspected. The submittal report, including the seismic walkdown checklists, did not provide any information to confirm that cabinets were opened to view internal lateral anchorages to adjacent cabinets, any internal floor anchorage, and to determine the condition of any internal equipment.
OPPD Response In OPPD letter, L1C-12-0093 dated July 5,2012 (ADAMS Accession No. ML121910223), OPPD confirmed that EPRI Technical Report 1025286 as endorsed by the NRC would be used to conduct the seismic walkdowns and develop the necessary information for Fort Calhoun Station. Section 3 of EPRI Technical Report 1025286 contains the following statement:
The purpose for preparing lists of equipment to be included on the SWEL is to allow those items to be walked down, as described in Section 4: Seismic Walkdowns and Area Walk-8ys. Of course, to be able to perform the Seismic Walkdowns on these items, it is necessary to have access to them and to be able to view their anchorage.
Section 4 of EPRI Technical Report 1025286 contains the following statement:
Guidance for identifying anchorage that could be degraded, non-conforming, or unanalyzed relies on visual inspections of the anchorage and verification of anchorage configuration.
Therefore, in accordance with the EPRI guidance, electrical cabinets on the SWEL were opened and inspected to view internal anchorage as well any other potentially adverse seismic conditions.
- 3. The staff cannot verify that any individual involved in performing a given walkdown activity was not a peer reviewer for that same activity. Table 1, Personnel Functions, of the updated seismic walkdown report lists two individuals to have participated in seismic walkdown and peer review activities (one is the peer review team lead).
Neither the response to the November 1, 2014 RAI-2b, nor the seismic walkdown report address whether these two individuals reviewed their own work or sufficiently explain how this did not contradict the objective of the peer review efforts.
OPPD Response As shown in Table 1 of EA12-021, Revision 1 submitted by OPPD letter, L1C-13-0070, the individuals that performed the seismic walkdowns and who also peer reviewed seismic walkdown checklists (SWC) were Mr. Ashwin Patel and Mr. Jim Carlson. As shown in 1.2 to EA12-021, Revision 1, Mr. Patel prepared SWCs 6,7, and 10 and Mr.
Carlson prepared SWCs 8, 9, 11, 13, 14, and 23. As shown in Section 9.2 of EA 12-021, Revision 1, none of these checklists was selected for a peer review. Therefore, no member of the peer review team reviewed their own seismic walkdown activity, and the objective of the peer review efforts described in EPRI Technical Report 1025286 was maintained.