LIC-17-0018, Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML17055A756
Person / Time
Site:	Fort Calhoun
Issue date:	02/24/2017
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
EA-12-049, LIC-17-0018
Download: ML17055A756 (6)

Text

10 CFR50.4 10 CFR 50.54 EA-12-049 LIC-17-0018 February 24, 2017 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 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

Omaha Public Power District's Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

References:

See Page 3 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all power reactor licensees and holders of construction permits in active or deferred status. By letter dated August 12, 2016 (Reference 2), the Omaha Public Power District (OPPD) requested relaxation of the Fort Calhoun Station (FCS) implementation date for compliance with Order EA-12-049 to August 31, 2017. The NRC approved the relaxation for Order EA-12-049 for full order implementation at FCS until August 31, 2017 (Reference 3). OPPD submitted a new Overall Integrated Plan (OIP) for Fuel Permanently Removed from the reactor pressure vessel (RPV) to the spent fuel pool (SFP) based on plans to remove all fuel from the RPV to the SFP by December 31, 2016 (Reference 4). OPPD certified all fuel has been permanently removed from the FCS reactor vessel and placed into the FCS spent fuel pool as of November 13, 2016 (Reference 5).

Pursuant to Section IV, Condition C.2 of the Order, licensees are to provide a status report at six-month intervals following submittal of the OIP. In the seventh six-month status report (Reference

6) OPPD stated that because of the permanent cessation of operations and permanent removal of fuel from the reactor vessel the docketed plans to implement the Order and the status provided in the enclosures for previous 6-month updates were no longer valid. The purpose of this letter is to provide the first six-month status report that delineates progress made in implementing the new OIP (Reference 4).

444 South 161h Street Mall Omaha, NE 68102-2247

U. S. Nuclear Regulatory Commission LIC-17-0018 Page 2 There are no other regulatory commitments or changes to regulatory commitments contained in this submittal.

If you should have any questions regarding this submittal, please contact Mr. Bradley H. Blome at (402) 533-7270.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 24, 2017.

,;io/!~

Mary J. Fisher Senior Director Fort Calhoun Station Decommissioning MJF/epm

Enclosure:

Six-Month Status Report for the Implementation of Order EA-12-049 c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Senior Project Manager P. J. Bamford, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector

U.S. Nuclear Regulatory Commission LIC-17-0018 Page 3

References:

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (NRC-12-0020) (ML12054A736)

2. OPPD letter (S. M. Marik) to USNRC (Document Control Desk), Request for Relaxation of March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049 and EA-12-051 ), dated August 12, 2016 (LIC-16-0048) (ML16225A539)

3. NRC Letter (W. Dean) to OPPD (S. Marik), Relaxation of the Schedule Requirements for Order EA-12-049 "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (CAC NO. MF0969),

dated November 21, 2016 (NRC-16-0101) (ML16277A509)

4. OPPD letter (S. Marik) to USNRC (Document Control Desk), Omaha Public Power District's Revised Overall Integrated Plan for Fuel Permanently Removed from the Reactor Vessel to the Spent Fuel Pool in Response to Requirements for Mitigation Strategies for Beyond Design Basis External Events, dated October 31, 2016 (LIC-16-0095) (ML16307A209)

5. OPPD letter (T. Burke) to USNRC (Document Control Desk), Certification of Permanent Removal of Fuel from the Reactor Vessel, dated November 13, 2016 (LIC-16-0074)

(ML16319A254)

6. OPPD letter (S. Marik) to USNRC (Document Control Desk), Omaha Public Power District's Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated August 12, 2016 (LIC-16-0061) (ML16225A541)

LIC-17 -0018 Enclosure Page 1 Fort Calhoun Station, Unit No. 1 Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction OPPD developed an OIP for Fuel Permanently Removed from RPV to SFP (Reference 4) documenting the diverse and flexible strategies (FLEX), in response to Reference 1. This enclosure provides an update of milestone accomplishments since submittal of the OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following have been completed:

• Installation of the Spent Fuel Pool Indication (SPLI)

• Installation of the standpipe between Rooms 81 (Upper Mechanical Penetration Room) and 69 (Auxiliary Building Equipment Room)

• Training and issuance of procedures and guidelines listed below:

SFP Make up Procedures Procedure Number Title AOP-01 Acts of Nature AOP-42 Darkened Plant Recovery AOP-36 Loss of Spent Fuel Pool Cooling EOP/AOP Att. FSG FLEX Support Guidelines Implementation EOP/AOP Att. DGE Diesel Generator ELAP Evaluation FSG-01 Initial Assessment and FLEX Equipment Staging FSG-02 Alternate SFP Makeup and Cooling FSG-03 ELAP Electrical Bus Management FSG-04 Response to Beyond Design Basis Flooding FSG-06 Transition from FLEX Equipment FIG-LTA-01 Water Supply to the FLEX Valve Station from Various Clean Water Sources FIG-LTA-02 Water Supply to the FLEX Valve Station from the Ultimate Heat Sink I (UHS)

FIG-LTA-03 Filling the EFWST from an External Water Source FIG-LTA-04 Filling the SIRWT from the Ultimate Heat Sink (UHS) I FIG-LTA-05 Deployment of External Portable FLEX Pumps FIG-MIS-02 Emergency Portable Equipment Diesel Generator Fuel Sources FIG-MVA-01 Deploy and Operate FLEX DG FIG-MVA-02 Control Room Lighting/HVAC

LIC-17-0018 Enclosure Page 2 Procedure Number Title I FIG-SFP-01 I Fill the Spent Fuel Pool I FIG-SFP-02 Venting the Spent Fuel Pool Area FIG-SFP-03 . Setup and Operation of the BDB Spent Fuel Pool Level Indication System FIG-SFP-04 Water Supply to the FLEX Valve Skid from the Submersible SJRWT Pumps

• Procurement of the diesel fuel oil transfer pumps

• FLEX equipment staged in either the safety-related plant structures or in the FLEX Storage Building.

With the completion of these actions, the mitigation strategies of the OIP can be implemented to cool the fuel in the SFP using water from the ultimate heat sink (Missouri River) for an indefinite period of time.

3 Milestone Schedule Status The Milestone Schedule is attached. The status of each milestone is shown, as are revised completion dates. The sole remaining action is the training and issuance of the following four guidelines.

Procedure Number Title FSG-05 Restoration of Vital Auxiliaries using Offsite Resources FIG-MVA-03 Power 480/4160 VAC Buses With Vendor Supplied Generator FIG-MVA-04 Establish Cooling Water Supply using External Resources FIG-MVA-05 Establish Instrument Air using Vendor Supplied Air Compressor 4 Changes to Compliance Method No changes have been made to the overall compliance method as documented in the Fort Calhoun Station OIP (Reference 4).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter dated August 12, 2016 (Reference 2), the Omaha Public Power District (OPPD) requested relaxation of the implementation date for compliance with Order EA-12-049 to August 31, 2017. The NRC approved the relaxation for Order EA-12-049 for full order implementation at FCS until August 31, 2017 (Reference 3).

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The open item status is provided in Reference 4.

7 Potential Draft Safety Evaluation Impacts A Draft Safety Evaluation for the new OIP has not been issued.

LIC-17-0018 Enclosure Page 3 Fort Calhoun Station EA-12-049 (FLEX) Overall Integrated Implementation Plan for Fuel Permanently Removed from RPV to SFP Milestone Schedule Target Activity Revised Target Milestone Completion I Date Status Completion Date Submit new Overall Integrated Plan Oct. 2016 Complete Submit 6-Month Updates:

Update 1 Feb.2017 Complete FLEX Strategy Evaluation Oct. 2016 Complete Walk-throughs or Demonstrations Dec.2016 Complete Perform Staffing Analysis May. 2016 Complete Modifications:

Modifications Evaluation Oct. 2016 Complete Design Engineering Dec.2016 Complete Implementation Outage Dec 2016 Complete Storage:

Storage Design Engineering Oct. 2015 Complete Storage Implementation Dec.2016 Complete FLEX Equipment:

Procure On-Site Equipment Dec.2016 Complete Develop Strategies with RRC Not utilized Not utilized Install Off-Site Delivery Station (if Not utilized Not utilized Necessary)

Procedures:

PWROG issues NSSS-specific Jun.2014 Complete guidelines Create Site-Specific FSGs Dec.2016 Complete Create Maintenance Procedures Feb.2017 Complete Training:

Develop Training Plan Apr. 2015 Complete Training Complete Dec.2016 Started May 2017 Full Site FLEX Implementation Jun.2017 Started Jun.2017 Submit Completion Report Aug_. 2017 Not Started Aug.2017