LIC-17-0065, Submittal of Response to Request for Additional Information Re Fort Calhoun Request to Revise Their Technical Specifications to Align to Those Requirements for Decommissioning

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Submittal of Response to Request for Additional Information Re Fort Calhoun Request to Revise Their Technical Specifications to Align to Those Requirements for Decommissioning
ML17269A343
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 09/26/2017
From: Fisher M
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF9567, LIC-17-0065
Download: ML17269A343 (26)
v • d • e


Text

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Omaha Public Power District LIC-17-0065 September 26, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Response to Request for Additional Information Regarding the Fort Calhoun Station Request to Revised Fort Calhoun Station Technical Specifications to align to those requirements for decommissioning (CAC No. MF9567)

References:

1. Letter from OPPD (M. Fisher) to USNRC (Document Control Desk), "License Amendment Request (LAR) 17-01: "Revised Fort Calhoun Station Technical Specifications to align to those requirements for decommissioning," dated March 31,2017 (LIC-17-0001) (ML17093A309)
2. Email from NRC (J. Kim) to OPPD (E. Matzke), "Request for Additional Information Regarding the Fort Calhoun Station Request to Revised Fort Calhoun Station Technical Specifications to align to those requirements for decommissioning (CAC NO. MF9567)",

dated August 24, 2017 (ML17236A346)

By letter dated March 31, 2017 (Reference 1, LAR 17-01 ), the Omaha Public Power District (OPPD) proposed an amendment to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station (FCS). The proposed amendment would revise the 10 CFR Part 50 License and associated Technical Specifications (TS) to Permanently Defueled Technical Specifications (POTS) consistent with the permanent cessation of reactor operations. In general, the changes proposed the elimination of those TS applicable in operating modes or modes where fuel is placed in the reactor vessel. Changes to other TS limiting conditions for operation, definitions, surveillance requirements, administrative controls, as well as several license conditions were also proposed.

On August 24, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed technical administrative changes. Attachment 1 of this letter provides the responses to this RAI. Attachment 2 of this letter provides the revised markup sections to the LAR. Attachment 3 of this letter provides an updated "red line" markup of the proposed changes to TS from Reference 1. Attachment 4 of this letter provides the "clean" markup of the proposed changes. This proposed change has been reviewed and approved the station's plant operations review committee (PORC).

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U.S. Nuclear Regulatory Commission Ll C-17 -0065 Page2 This letter contains no regulatory commitments.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome- Director Licensing and Regulatory Assurance at (402) 533-7270.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 26, 2017.

~;

Mary J. Fisher Senior Director - Decommissioning Fort Calhoun Station MJF/dmp Attachments: 1. Response to Request for Additional Information

2. Revision of License Amendment Request 17-01
3. Revised "Redline" Affected section of Permanently Defueled Technical Specifications
4. "Clean" Markup of Affected Sections of Permanently Defueled Technical Specifications c: K. M. Kennedy, NRC Regional Administrator, Region IV J. Kim, NRC Project Manager R.S. Browder, NRC Senior Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-17-0065 Page 1 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE FORT CALHOUN STATION REQUEST TO REVISED FORT CALHOUN STATION TECHNICAL SPECIFICATIONS TO ALIGN TO THOSE REQUIREMENTS FOR DECOMMISSIONING (CAC No. MF9567)

1. With the removal of TS 2.8.1(1) and TS 2.8.3(3) there will no longer be any requirement, either directly or indirectly, for FCS Unit 1 to maintain any soluble boron in its SFP. With respect to SFP soluble boron provide the following information:
a. How much soluble boron is necessary to maintain SFP keff less than or equal to 0.95 for accidents other than the misloading/misplacement of unirradiated fuel; i.e.,

the misloadinglmisplacement of partially spent fuel assemblies?

b. What obligates FCS Unit 1 to maintain this amount of soluble boron in its SFP?

RAI-1 OPPD responses:

Section 2.8.1 response:

Fort Calhoun Station (FCS) Technical Specifications (TS) Section 2.8.1 (1) is no longer required. Since the FCS license no longer authorizes use of the facility for power operation or emplacement or retention of fuel into the reactor vessel as provided in 10 CFR Part 50.82(a)(2), this section is no longer applicable and its proposed deletion is acceptable.

Section 2.8.3 response:

Section 2.8.3(3) utilizes the term "unirradiated" fuel assemblies in context to the minimum requirements for unrestricted storage in all regions of the spent fuel pool (SFP) racks. The section provides limitations for the misleading of an unirradiated fuel assembly which was obviated by the permanent shutdown of the station. In such, no new unirradiated fuel will be loaded into the SFP. This rationale does not account for assemblies located in the SFP that have been irradiated but do not meet the free storage requirements associated with adequate burn up. This issue has been entered into the site's corrective action program.

A correction is being made to this section to identify the appropriate wording which will ensure reactivity requirements associated with the SFP are maintained at all time in the event of a misloaded fuel assembly within any region of the pool. The FCS analysis of record, EA96-001, Ft Calhoun Spent Fuel Rack Criticality Evaluation, Revision 1 (Reference 1), shows that a soluble boron concentration of 425 ppm, rounded to 500 ppm for conservatism and to allow for uncertainty in measurement, is required to protect against the most severe credible accident (misleading of a 5% enriched assembly when using the checkerboard option). It does not specifically evaluate partially depleted fuel when associated with misleading. However, all partially depleted fuel assembly reactivity requirements are bounded by the unirradiated fuel requirement. The correction to this section will revise the wording to ensure reactivity requirements are maintained at all times in the event of a misloaded fuel assembly within any region of the SFP. Therefore, the minimum boron concentration analyzed for a misplaced unirradiated fuel assembly will be maintained in this section's requirements, but will be revised to be associated with all fuel assemblies regardless of remaining enrichment. To clarify the present condition associated with the station's decommissioning status, the use of "unirradiated" will be removed from the section.

LIC-17-0065 Page 2 Section 2.8.3(3) discusses the requirements for fuel movement during all operating modes and its correlation toTS 2.0.1. This section is being revised to remove the sentence references toTS 2.0.1.

Since the FCS license no longer authorizes use of the facility for power operation or emplacement or retention of fuel into the reactor vessel as provided in 10 CFR Part 50.82(a)(2), the statement this section has no correlation to the requirement of TS 2.0.1 is no longer required. It also includes a proposed change of the section title and defined term from "refueling" to "fuel handling".

Section 3.2 response:

Restoration of the surveillance requirement associated with the SFP boron concentration will also be completed to ensure monitoring of the POTS limits is maintained. Section 3.2, Table 3-4 item 5, footnote, will be revised to include periodic sampling requirements and removes the correlation to unirradiated fuel. The periodic verification of boron in the pool ensures that there is adequate boric acid within the SFP to maintain fuel reactivity well below the minimum requirements. The SFP period of sampling, every 7 days, provides adequate administrative control to ensure no unintentional dilution has occurred and is consistent with the requirements of NUREG-1432, Standard Technical Specifications (STS), Section 3.7.17.1 (Reference 2) and benchmarked plants Crystal River (Reference 3), SONGS (Reference 4), and Kewanee (Reference 5).

LIC-17-0065 Page 3

2. The Applicability of TS 2.8.3(1) states, "Applies to storage of spent fuel assemblies whenever any irradiated fuel assembly is stored in Region 2 (including peripheral cells) of the spent fuel pool." Unless all fuel stored in the FCS Unit 1 SFP satisfies the requirements for storage in PERPIPHERAL CELLS per TS Figure 2-10 the potential for a misloading/misplacement of fuel exists whether fuel is stored in Region 2, Region 1, or both. Therefore the NRC staff requests OPPD make the Applicability of TS 2.8.3(1) applicable any time fuel is stored in the FCS Unit 1 TS.

RAI-2 OPPD response:

The proposed revision, which changes the title of this section and removes the discussion of its correlation to Section 2.01, was administrative in nature. The applicability of storage of spent fuel within Region 2 (including periphery cells) of the SFP was not part of the proposed change. In such, no change to this attribute in this section is being requested by FCS.

In response to the concern associated with the misleading or misplacing a fuel assembly into the periphery cells of Region 2. Section 2.8.3(3) provides the requirements to prevent exceeding any SFP reactivity limits associated with a misloaded fuel assembly as revised in RAI-1 and is included in this response. Even if an assembly is purposefully placed into this area, with or without an assembly previously located in this region, Section 2.8.3(1) would be applicable and would apply the fuel movement requirements prior to the planned move. The Limiting Conditions for Operation (LCO) actions associated with the loading of the fuel assembly would also be applicable. There would be no occasion in which a fuel assembly would be placed into Region 2 of the SFP that would prevent use of this section and, if required, the associated LCO.

Although, FCS is not a standard technical specification plant. A comparison of FCS and NUREG-1432, STS (Reference 2) was performed and showed a consistent application of this specification:

3. 7. 18 Spent Fuel Pool Storage LCO 3.7.18 The combination of initial enrichment and burnup of each fuel assembly stored in [Region 2] shall be within the acceptable [burnup domain] of Figure 3. 7. 18-1 [or in accordance with Specification 4.3.1.1].

APPLICABILITY: Whenever any fuel assembly is stored in [Region 2] of the fuel storage pool.

There would be no occasion in which a fuel assembly would be placed into Region 2 of the SFP that would prevent use of this section and, if required, the associated LCO. No change is being proposed associated with this specific issue.

LIC-17-0065 Page4

3. The modification to TS 4.3.1.1(b), 4.3.1.3(b), and 4.3.1.3(c) change the requirement from

" ... allowance for uncertainties as described in Section 9.5 of the USAR." to " ... allowance for uncertainties." However, no justification is provided for deleting this information from the TS. Therefore the NRC staff requests the following:

OPPD provide the justification for removing this information from the TS, or revise the request to include the new location this information in TS 4.3.1.1(b), 4.3.1.3(b), and 4.3.1.3(c).

RAI-3 OPPO response:

The previous proposed removal of the specific reference included in these sections was considered administrative.

A review of benchmark plants for a comparison of FCS section 4.3.1.1 was performed including Crystal River (Reference 3), SONGS (Reference 4 ), and Kewanee (Reference 5). This review provided examples of the use of this type of reference within the actual specification. With this precedent, the use of references within these sections will be restored. A revision is being proposed to these sections to keep them consistent with the remaining sections in the POTS. In such, the sections will be revised to remove the term "USAR" and replace it with "FSAR as updated". A comparison of the bench marked plants and STS was also performed for section 4.3.1.3 and no examples of use of this section could be found. For consistency, this section will also be restored and revised to be consistent with section 4.3.1.1. The change to the verbiage is consistent with the benchmark plants and other sections of the POTS.

LIC-17-0065 Page 5 REFERENCES

1. EA96-001, Ft Calhoun Spent Fuel Rack Criticality Evaluation, Revision 1
2. NUREG 1432, Standard Technical Specifications Combustion Engineering Plants, Revision 4
3. Crystal River Unit 3 Nuclear Generating Plant- Issuance of Amendment for Permanently Shutdown and Defueled Operating License and Technical Specifications (TAC No. MF3089)

(ML15224A286)

4. San Onofre Nuclear Generating Station, Units 2 and 3-lssuance of Amendment for Permanently Shutdown and Defueled Operating License and Technical Specifications (TAC Nos. MF3774 and MF3775)," dated July 17, 2015 (ML15139A390)
5. Kewaunee Power Station - Issuance of Amendment for Permanently Shutdown and Defueled Technical Specifications and Certain License Conditions (TAC No. MF1952)," dated February 13, 2015 (ML14237A045)

Ll C-1 7-0065 Page 1 ATTACHMENT 2 REVISION OF LICENSE AMENDMENT REQUEST 17-01 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO.1 DOCKET NO. 50-285

Ll C-17 -0065 Page 2 Revision to LAR 17-01 :

The previous submitted changes associated with the Fort Calhoun Station (FCS) licensed amendment request (LAR) are highlighted in "grey" to provide an aid in review of the new!y proposed changes. The insertion of the revised sections will require Permanently Defueled Technical Specifications (POTS) pages to be renumbered accordingly.

Section 2.8.3:

FCS proposes the following changes to the proposed revision to TS sections to clarify applicability and ensure compliance with the station's criticality analysis:

2.8 Refueling Fuel Handling 2.8.3 Refueling Fuel Handling Operations- Spent Fuel Pool (continued) 2.8.3(3) .Q.Et-+Q Spent Fuel Pool Boron Concentration Applicability Applies to the boron concentration of the spent fuel pool when unirradiated fuel assemblies are stored in the spent fuel pool. The provisions of Specification 2.0.1 for Limiting Conditions for Operations are not applicable.

Objective To minimize the possibility of an accident that could affect public health and safety from occurring when unirradiated fuel assemblies are stored in the spent fuel pool.

Specification The spent fuel pool boron concentration shall be ~ 500 ppm.

Required Actions (1) With the spent fuel pool boron concentration < 500 ppm, suspend FUEL HANDLING REFUELING OPERATIONS in the spent fuel pool immediately, and (2) Restore spent fuel pool boron concentration to ~ 500 ppm immediately.

Technical Specifications Basis change for section 2.8.3(3) is consistent with the revised section.

Section 2.8.3(3) change basis revision for LAR 17-01:

The following replaces LAR basis content for this section in its entirety; Spent Fuel Pool Boron Concentration, establishes the minimum boron concentration requirement with Boral poisoned storage racks to maintain the ketr below 0.95 in the event a misloaded unirradiated fuel assembly is located next to a spent fuel assembly. A misloaded fuel assembly at maximum enrichment condition, in the absence of soluble poison, may result in exceeding the allowable design effective multiplication factor. A change to this section is proposed to ensure SFP boron concentration requirement is adequate to maintain the ketr below 0.95 in the event a misloaded irradiated fuel assembly is located next to another irradiated fuel assembly in any SFP region. Soluble boron in the SFP water, for which credit is permitted under these conditions, would assure that the effective multiplication factor is

LIC-17-0065 Page 3 maintained substantially less than the design condition. No unirradiated fuel assemblies are currently stored in the SFP. Since the FCS license no longer authorizes use of the facility for power operation or emplacement or retention of fuel into the reactor vessel as provided in 10 CFR Part 50.82(a)(2), and the limitations provided by the proposed revised License Condition 2.8.(2) provides no unirradiated fuel assemblies will be received. Based on the above, the proposed revision to this section is acceptable.

This section is being revised to remove the statement that it is not correlated toTS 2.0.1. Since the FCS license no longer authorizes use of the facility for power operation or emplacement or retention of fuel into the reactor vessel as provided in 10 CFR Part 50.82(a)(2), it will no longer be possible to enter any of the listed operating modes and the statement this section has no correlation to the requirement of TS 2.0.1 is no longer required. Based on the above, the proposed change to this section is acceptable. It also includes a proposed change of the title and defined term from "refueling" to "fuel handling." This is an administrative change and does not affect the technical content or requirements of the TS section.

Based on the above, the proposed change to this section is acceptable.

With the TS section being deleted in its entirety, the applicable basis and surveillance sections will also be removed.

Section 3.2:

TABlE 3 4 (Continued)

MINIMUM FREQUENCIES FOR SAMPliNG TESTS Type of Measurement Sample and Analysis and Analysis Frequency

1. Reactor Coolant

,(Continued)

(c) Cold Shutdown (1) Chloride 1 per 3 days (Operating Mode 4)

(d) Refueling Shutdown (1) Chloride 1 per 3 days~

(Operating Mode 5) (2) Boron Concentration 1 per 3 days~

(e) Refueling Operation (1) Chloride 1 per 3 days~

(2) Boron Concentration 1 per 3 days~

2. SIR\IIJ Tank Boron Concentration M Boron Concentration \I\ I
3. Concentrated Boric **

Acid Tanks

4. Sl Tanks Boron Concentration M

&.--Spent Fuel Pool Boron Concentration >. See Footnote 1-4 below

6. Steam Generator Blowdown Isotopic Analysis for Dose .,

\1\l{a}

(Operating Modes 1 and 2) Equi'lalent I 131

Ll C-17 -0065 Page4 (1) Until the radioactivity of the reactor coolant is restored to #1 <PCi/gm DOSE EQUIVALENT I 131.

(2) Sample to be taken after a minimum of 2 EFPD and 20 days of power operation have elapsed since reactor 'IKlS subcritical for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer.

(3) Boron and chloride sampling/analyses are not required when the core has been off loaded.

Reinitiate boron and chloride sampling/analyses prior to reloading fuel into the cavity to assure adequate shutdovm margin and allowable chloride levels are met.

(41---Prior to placing unirradiated fuel assemblies in the spent fuel pool or placing fuel assemblies in a spent fuel cask in the spent fuel pool, and weekly when unirradiated fuel assemblies are stored in the spent fuel pool, or every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when fuel assemblies are in a spent fuel storage cask in the spent fuel pool.

Section 3.2 change basis revision for LAR 17-01:

Replaces LIC-17 -0001 Enclosure page 38 associated with Section 3.2 Table 3-4 Item 5, Note 4;

< ... > "Also, table 3-4 item 5, note 4 is modified to remove discussions regarding the storage or placement of unirradiated fuel assemblies in the pool , and adds a restriction to periodically sample the spent fuel pool as long as there is fuel stored in the SFP.

Since the FCS license no longer authorizes use of the facility for power operation or emplacement or retention of fuel into the reactor vessel as provided in 10 CFR Part 50.82(a)(2), and the limitations provided by the proposed License Condition 2.8.(2) provides no unirradiated fuel assemblies will be received. The above proposed revision to License Condition 2.8 (2) removes the ability to receive or use special nuclear fuel as reactor fuel. In such, no unirradiated fuel will be placed in the SFP The periodic verification of boron in the pool ensures that there is adequate boric acid within the SFP to maintain fuel reactivity well below the minimum requirements. The period of sampling, every 7 days, provides adequate administrative control to ensure no unintentional dilution has occurred and is consistent with the requirements of Standard Technical Specifications, Section 3. 7.17 .1 (Reference 6.7). Therefore, the modification of this note is acceptable. The basis section will also be revised to reflect this proposed change." < >

LIC-17-0065 Page 5 Section 4.3 revision:

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,
b. kett s 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the FSAR as updated YSAR, < ... >

4.3.1.3 The spent fuel casks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,
b. kett < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the-FSAR as updated YSAR,
c. kett s 0.95 if fully flooded with borated water ~ 800 ppm, which includes an allowance for uncertainties as described in Section 9.5 of the-FSAR as updated USAR, < ... >

Section 4.3 change basis revision for LAR 17-01:

The following replaces LAR basis content for these sections in its entirety; Section 4.3.1.1 (b), Criticality, establishes requirements regarding the design, use, and maintenance of spent fuel storage racks. The acronym "USAR" is being replaced by an equivalent description" FSAR as updated" to more accurately describe the plant basis requirements and to allow for future decommissioning This change is administrative and does not change the technical content or requirements of the TS. Therefore, the proposed change to this section is acceptable.

Section 4.3.1.3(b) and (c), Criticality, establishes requirements regarding the design, use, and maintenance of spent fuel casks. The acronym "USAR" is being replaced by an equivalent description" FSAR as updated" to more accurately describe the plant basis requirements and to allow for future decommissioning. This change is administrative and does not change the technical content or requirements of the TS. Therefore, the proposed change to this section is acceptable.

Added to

REFERENCES:

6.7 NUREG 1432, Standard Technical Specifications Combustion Engineering Plants, Revision 4

LIC-17 -0065 Page 1 ATTACHMENT 3 REVISED "REDLINE" AFFECTED SECTION OF PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS Revision 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO.1 DOCKET NO. 50-285 DPR-40

LIC-17 -0065 Page 2 2.0 LIMITING CONDITIONS FOR OPERATION 2.8 Refueling Fuel Handling 2.8.3 Refueling Fuel Handling Operations- Spent Fuel Pool (continued) 2.8.3(3) Spent Fuel Pool Boron Concentration Applicability Applies to the boron concentration of the spent fuel pool when unirradiated fuel assemblies are stored in the spent fuel pool. The provisions of Speoifioation 2.0.1 for Limiting Conditions for Operations are not applioable.

Objective To minimize the possibility of an accident that could affect public health and safety from occurring when unirradiated fuel assemblies are stored in the spent fuel pool.

Specification The spent fuel pool boron concentration shall be~ 500 ppm.

Required Actions (1) With the spent fuel pool boron concentration < 500 ppm, suspend FUEL HANDLING REFUELING OPERATIONS in the spent fuel pool immediately, and (2) Restore spent fuel pool boron concentration to ~ 500 ppm immediately.

2.8 - Page 44 4 Amendment No.4-88, ###

DPR-40

LIC-17 -0065 Page 3 2.0 liMITING CONDITIONS FOR OPERATION 2.8 Refueling Bases (continued) 2.8.3(1) Spent Fuel Assembly Storage (Continued)

The provisions of Specification 2.0.1 for Limiting Conditions for Operations are not applicable. If moving fuel assemblies while in MODES 4 or 5, LCO 2.0.1 would not speeify any actions. If moving fuel assemblies in MODES 1, 2, or 3, the fuel movement is independent of reactor operation. Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdovm. When "immediately" is used as a completion time, the required action should be pursued without delay and in a controlled manner.

2.8.3(2) Spent Fuel Pool Water Level The minimum water level in the spent fuel pool meets the assumption of iodine decontamination factors following a fuel handling accident. When the water level is lower than the required level, the movement of irradiated fuel assemblies in the spent fuel pool is immediately suspended. This effectively precludes a fuel handling accident from occurring in the spent fuel pool. Suspension of REFUELING FUEL HANDLING OPERATIONS shall not preclude completion of movement of a component to a safe, conservative position. The provisions of Specification 2.0.1 for Limiting Conditions for Operations are not applicable. If moving fuel assemblies while in MODES 4 or 5, LCO 2.0.1 'Nould not specify any actions. If moving fuel assemblies in MODES 1, 2, or 3, the fuel movement is independent of reactor operation. Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

When "immediately" is used as a completion time, the required action should be pursued without delay and in a controlled manner.

2.8.3(3) Spent Fuel Pool Boron Concentration The basis for the 500 ppm boron concentration requirement with Boral poisoned storage racks is to maintain the keff below 0.95 in the event a misloaded unirradiated fuel assembly is located next to a spent fuel assembly. A misloaded unirradiated fuel assembly at maximum enrichment condition, in the absence of soluble poison, may result in exceeding the design effective multiplication factor. A misloaded irradiated fuel assembly is bounded by this requirement. Soluble boron in the spent fuel pool water, for which credit is permitted under these conditions, would assure that the effective multiplication factor is maintained substantially less than the design condition.

This LCO applies whenever unirradiated fuel assemblies are stored in the spent fuel pool.

The boron concentration is periodically sampled in accordance with Specification 3.2.

Sampling is performed prior to movement of unirradiated fuel to the spent fuel pool and periodically when unirradiated fuel is stored in the spent fuel pool.

2.8- Page 28 Amendment No. 188,201,204, 239, 257 DPR-40

UC-17-0065 Page4 2.0 LIMITING CONDITIONS FOR OPERATION 2.8 Rerueling Bases (sontinued) 2.8.3(3) Spent Fuel Pool Boron Consentration (Continued)

The provisions of Spesifisation 2.0.1 for Limiting Conditions for Operations are not applisable. If moving ruel assemblies 'A'hile in MODES 4 or 5, LCO 2.0.1 would not spesify any astions. If moving fuel assemblies in MODES 1, 2, or 3, the fuel movement is independent of reastor operation. Therefore, inability to suspend movement of fuel assemblies is not suffisient reason to require a reastor shutdovm.

When "immediately" is used as a completion time, the required action should be pursued without delay and in a controlled manner. Suspension of refueling operations shall not preclude completion of movement of a component to a safe, conservative position.

2.8.3(4) Spent Fuel Pool Area Ventilation The spent fuel pool area ventilation system sontains a sharsoal filter to prevent release of signifisant radionuslides to the outside atmosphere. The system does not automatisally realign and therefore must be IN OPERATION prior to REFUELING OPERATIONS in the spent fuel pool. vVhen the spent fuel pool area ventilation system is not IN OPERATION, the movement of irradiated fuel assemblies in the spent fuel pool is immediately suspended. This effestively presludes a fuel handling assident from ossurring in the spent fuel pool. VVhen "immediately" is used as a sompletion time, the required astian should be pursued without delay and in a sontrolled manner.

Suspension of REFUELING OPERATIONS shall not preslude sompletion of movement of a somponent to a safe, sonservative position.

The provisions of Spesifisation 2.0.1 for Limiting Conditions for Operations are not applisable. If moving fuel assemblies while in MODES 4 or 5, LCO 2.0.1 would not spesify any astions. If moving fuel assemblies in MODES 1, 2, or 3, the fuel movement is independent of reastor operation. Therefore, inability to suspend movement of fuel assemblies is not suffisient reason to require a reastor shutdown.

2.8.3(5) Control Room Ventilation System (CRVS)

Operating the CRVS in the Filtered Air mode and requiring a radiation monitor to be IN OPERATION are conservative measures to reduse sontrol room operator exposure.

This allows the radiologisal sonsequenses analysis for a ruel handling assident to sredit the Filtered Air mode at the time of the assident.

Radiation monitoring will assure operators are alerted if a radiologisal insident oscurs.

This spesifisation san be satisfied by using a permanent spent fuel pool area radiation monitor or a portable area radiation monitor.

2.8 Page 26 Amendment No. 239, 257 DPR-40

LIC-17-0065 Page 5 TABlE 3 4 (Continued)

MINIMUM FREQUENCIES FOR SAMPliNG TESTS Type of Measurement Sample and Analysis and Analysis Frequency

1. Reactor Coolant (Continued)

(s) Cold Shutdown (1) Chloride 1 per a days (Operating Mode 4)

(d) Refueling Shutdown (1) Chloride 1 per a days~

(Operating Mode 5) (2) Boron Concentration 1 per a days~

(e) Refueling Operation (1) Chloride 1 per a days~

(2) Boron Concentration 1 per a days~

2. SIRVV Tank Boron Concentration M
a. Concentrated Boris Boron Concentration \Ill Asid Tanks
4. Sl Tanks Boron Concentration M

&.-----Spent Fuel Pool Boron Concentration See Footnote 1-4 below

6. Steam Generator Blo'Ndown Isotopic Analysis for Dose ..

\Ill~

(Operating Modes 1 and 2) Equivalent I 131 (1) Until the radioactivity of the reactor coolant is restored to #1 ct>Citgm DOSE EQUIVALENT I 131.

(2) Sample to be taken after a minimum of 2 EFPD and 29 days of power operation have elapsed sinse reactor 'Nas subsritisal for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer.

(3) Boron and chloride samplingtanalyses are not required when the sore has been off loaded. Reinitiate boron and chloride sampling/analyses prior to reloading fuel into the savity to assure adequate shutdown margin and allowable chloride levels are met.

f4+-Prior to placing unirradiated fuel assemblies in the spent fuel pool or placing fuel assemblies in a spent fuel cask in the spent fuel pool, and weekly when unirradiateEI fuel assemblies are stored in the spent fuel pool, or every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when fuel assemblies are in a spent fuel storage cask in the spent fuel pool.

(5) When Steam Generator Dose Equivalent I 131 exseeEls 59 percent of the limits in Specification 2.29, the sampling and analysis frequency shall be increased to a minimum of 5 times per 'Neek. VIJhen Steam Generator Dose Equivalent I 131 exceeds 75 percent of this limit, the sampling and analysis frequency shall be insreaseEI to a minimum of onse per Elay.

3.2 - Page 72 Amendment No. 28,67,86,124,133,152 172,188,239, 257, ###

DPR-40

LIC-17-0065 Page 6 4.0 DESIGN FEATURES 4.1 Site The site for Fort Calhoun Station Unit No. 1 is in Washington County, Nebraska, on the west bank of the Missouri River and approximately nineteen miles north, northwest of the city of Omaha, Nebraska. The exclusion area description, as defined in 10 CFR Part 100, Section 100.3(a), is located in the Final Safety Analysis Report, as updated consists of approximately 1242 acres. The exclusion area boundary extent includes approximately 660 acres in VVashington County, Nebraska, O'Nned by the Omaha Public Power District (OPPD), and 582 acres in Harrison County, Iowa, on the east bank of the river directly opposite the facility, on '.vhich the District retains perpetual easement rights. The minimum exclusion area boundary point is located approximately at the 187.0 degree radial from the outer wall of the containment building and at a distance of 910 meters.

4.2 DELETED Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 133 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLQ, or M5 clad fuel rods Vlith an initial composition of natural or slightly enriched uranium dioxide (U02) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply 'Nith all fuel safety design bases. /\ limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4 .2.2 Control Element Assemblies The reactor core shall contain 49 control element assemblies (CE/\s). The control material shall be silver indium cadmium, boron carbide, or hafnium metal as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,
b. keff ~ 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the FSAR as updated US/\R, 4.0 - Page 1 Amendment No. 36,236, 241 , ###

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Ll C-17 -0065 Page 7 4.0 DESIGN FEATURES (Continued)

c. A nominal 8.6 inch center to center distance between fuel assemblies placed in Region 2, the high density fuel storage racks,
d. A nominal 9.8 inches (East-West) by 10.3 inches (North South) center to center distances between fuel assemblies placed in Region 1, the low density fuel storage racks,
e. New or 13Partially spent fuel assemblies with a discharge burnup in the "acceptable domain" of Figure 2-10 for "Region 2 Unrestricted" may be allowed unrestricted storage in any of the Region 2 fuel storage racks in compliance with Reference (1 ).
f. Partially spent fuel assemblies with a discharge burnup between the "acceptable domain" and "Peripheral Cells" of Figure 2-10 may be allowed unrestricted storage in the peripheral cells of the Region 2 fuel storage racks in compliance with Reference (1 ).
g. Nev.' or 13Partially spent fuel assemblies with a discharge burnup in the "unacceptable domain" of Figure 2-10 will be stored in Region 1 in compliance with Reference (1 ).

4.3.1.2 DELETED The nevt' fuel storage rack is designed and shall be maintained witJcl;.

a. F"uel assemblies having a maximum U 235 enrichment of 5.0 weight percent,
b. A nominal 16 inch center to center distance beh\*een fuel assemblies placed in the storage rack.

4.3.1.3 The spent fuel casks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,
b. ketr < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the FSAR as updated USAR,
c. ketr:::; 0.95 if fully flooded with borated water :2: 800 ppm, which includes an allowance for uncertainties as described in Section 9.5 of the-FSAR as updated USAR,
d. A nominal 9.075-inch center-to-center distance between fuel assemblies placed in the spent fuel cask,
e. Spent fuel assemblies with a combination of discharge burnup and initial average assembly enrichment in the "acceptable" range of Figure 2-11.

- - - - - - - - - - - - - - - - - - ' 1 - . 0 - Page 2 Amendment No. 236,239, 240, ###

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LIC-17-0065 Page 1 ATTACHMENT 4 "CLEAN" MARKUP OF AFFECTED SECTIONS OF PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO.1 DOCKET NO. 50-285

2.0 LIMITING CONDITIONS FOR OPERATION 2.8 Fuel Handling 2.8.3 Fuel Handling Operations- Spent Fuel Pool (continued) 2.8.3(3) Spent Fuel Pool Boron Concentration Applicability Applies to the boron concentration of the spent fuel pool when fuel assemblies are stored in the spent fuel pool.

Objective To minimize the possibility of an accident that could affect public health and safety from occurring when fuel assemblies are stored in the spent fuel pool.

Specification The spent fuel pool boron concentration shall be :2: 500 ppm.

Required Actions (1) With the spent fuel pool boron concentration< 500 ppm, suspend FUEL HANDLING OPERATIONS in the spent fuel pool immediately, and (2) Restore spent fuel pool boron concentration to :2: 500 ppm immediately.

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2.0 LIMITING CONDITIONS FOR OPERATION 2.8 Fuel Handling 2.8.3(1) Spent Fuel Assembly Storage The spent fuel pool is designed for noncriticality by use of neutron absorbing material.

The restrictions on the placement of fuel assemblies within the spent fuel pool, according to Figure 2-10, and the accompanying LCO, ensures that the kett of the spent fuel pool always remains < 0.95 assuming the pool to be flooded with unborated water.

A spent fuel assembly may be transferred to the spent fuel pool Region 2 provided an independent verification of assembly burnups has been completed and the assembly burnup meets the acceptance criteria identified in Figure 2-10. When the configuration of fuel assemblies stored in Region 2 (including the peripheral cells) is not in accordance with Figure 2-10, immediate action must be taken to make the necessary fuel assembly movement(s) to bring the configuration into compliance with Figure 2-10. Acceptable fuel assembly burnup is not a prerequisite for Region 1 storage because Region 1 will maintain any type of fuel assembly that the plant is licensed for in a safe, coolable, subcritical geometry.

2.8.3(2) Spent Fuel Pool Water Level The minimum water level in the spent fuel pool meets the assumption of iodine decontamination factors following a fuel handling accident. When the water level is lower than the required level, the movement of irradiated fuel assemblies in the spent fuel pool is immediately suspended. This effectively precludes a fuel handling accident from occurring in the spent fuel pool. Suspension of FUEL HANDLING OPERATIONS shall not preclude completion of movement of a component to a safe, conservative position. When "immediately" is used as a completion time, the required action should be pursued without delay and in a controlled manner.

2.8.3(3) Spent Fuel Pool Boron Concentration The basis for the 500 ppm boron concentration requirement with Boral poisoned storage racks is to maintain the kett below 0.95 in the event a misloaded unirradiated fuel assembly is located next to a spent fuel assembly. A misloaded unirradiated fuel assembly at maximum enrichment condition, in the absence of soluble poison, may result in exceeding the design effective multiplication factor. A misloaded irradiated fuel I assembly is bounded by this requirement. Soluble boron in the spent fuel pool water, for which credit is permitted under these conditions, would assure that the effective multiplication factor is maintained substantially less than the design condition.

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2.0 LIMITING CONDITIONS FOR OPERATION 2.8 Fuel Handling Basis (continued) 2.8.3(3) Spent Fuel Pool Boron Concentration (Continued)

This LCO applies whenever fuel assemblies are stored in the spent fuel pool. The boron concentration is periodically sampled in accordance with Specification 3.2.

Sampling is performed periodically when fuel is stored in the spent fuel pool.

When "immediately" is used as a completion time, the required action should be pursued without delay and in a controlled manner. Suspension of refueling operations shall not preclude completion of movement of a component to a safe, conservative position.

2.8.3(6) Spent Fuel Cask Loading (1) Soluble Boron The basis for the 800 ppm minimum boron concentration requirement during spent fuel cask loading operations is to maintain the keff in the cask system less than or equal to 0.95 in the event a mis-loaded unirradiated fuel assembly is located anywhere in the cask with up to 31 other fuel assemblies meeting the burnup and enrichment requirements of LCO 2.8.3(6)(2). This boron concentration also ensures the keff in the cask system will be less than or equal to 0.95 if an unirradiated fuel assembly is dropped in the space between the spent fuel racks and the cask loading area during cask loading operations next to a spent fuel assembly. A mis-loaded or dropped unirradiated fuel assembly at maximum enrichment condition, in the absence of soluble poison, may result in exceeding the design effective multiplication factor. Soluble boron in the spent fuel pool water, for which credit is permitted during spent fuel cask loading operations, assures that the effective multiplication factor is maintained substantially less than the design basis limit.

This LCO applies whenever a fuel assembly is located in a spent fuel cask submerged in the spent fuel pool. The boron concentration is periodically sampled in accordance with Specification 3.2. Sampling is performed prior to movement of fuel into the spent fuel cask and periodically thereafter during cask loading operations, until the cask is removed from the spent fuel pool.

When "immediately" is used as a completion time, the required action should be pursued without delay and in a controlled manner. Suspension of FUEL HANDLING OPERATIONS shall not preclude completion of movement of a component to a safe, conservative position.

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TABLE 3-4 MINIMUM FREQUENCIES FOR SAMPLING TESTS Type of Measurement Sample and Analysis and Analysis Frequency

1. Spent Fuel Pool Boron Concentration See Footnote (1) below (1) Prior to placing fuel assemblies in a spent fuel cask in the spent fuel pool, and weekly when fuel assemblies are stored in the spent fuel pool, or every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when fuei assemblies are in a spent fuel storage cask in the spent fuel pool.

3.2 - Page 2 Amendment No. ###

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4.0 DESIGN FEATURES 4.1 Site The site for Fort Calhoun Station Unit No. 1 is in Washington County, Nebraska, on the west bank of the Missouri River and approximately nineteen miles north, northwest of the city of Omaha, Nebraska. The exclusion area description, as defined in 10 CFR Part 100, Section 100.3(a), is located in the Final Safety Analysis Report, as updated.

4.2 DELETED 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,
b. kett s 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the FSAR as updated,
d. A nominal 9.8 inches (East-West) by 10.3 inches (North South) center to center distances between fuel assemblies placed in Region 1, the low density fuel storage racks,
e. Partially spent fuel assemblies with a discharge burnup in the "acceptable domain" of Figure 2-10 for "Region 2 Unrestricted" may be allowed unrestricted storage in any of the Region 2 fuel storage racks in _compliance with Reference (1 ).
f. Partially spent fuel assemblies with a discharge burnup between the "acceptable domain" and "Peripheral Cells" of Figure 2-10 may be allowed unrestricted storage in the peripheral cells of the Region 2 fuel storage racks in compliance with Reference (1 ).
g. Partially spent fuel assemblies with a discharge burnup in the "unacceptable domain" of Figure 2-10 will be stored in Region 1 in compliance with Reference (1 ).

4.3.1.2 DELETED 4.0- Page 1 Amendment No. ###

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4.0 DESIGN FEATURES (Continued) 4.3.1.3 The spent fuel casks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,
b. kett < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the FSAR as updated,
c. kett s 0.95 if fully flooded with borated water;;:: 800 ppm, which includes an allowance for uncertainties as described in Section 9.5 of the FSAR as. updated,
d. A nominal 9.075-inch center-to-center distance between fuel assemblies placed in the spent fuel cask,
e. Spent fuel assemblies with a combination of discharge burnup and initial average assembly enrichment in the "acceptable" range of Figure 2-11 .

4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below 23 ft. above the top of irradiated fuel assemblies seated in the storage racks.

4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1083 fuel assemblies.

References:

(1) Letter from R. Wharton (NRC) toT. Patterson (OPPD), Amendment 174 to Facility Operating License No. DPR-40, (TAC NO. M94789) Dated July 30, 1996, NRC-96-0126.

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