LIC-17-0068, Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)

Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)

ML17277B665
Person / Time
Site:	Fort Calhoun
Issue date:	10/04/2017
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF9664, LIC-17-0068
Download: ML17277B665 (5)

Text

L1 C-17 -0068 October 4, 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:

Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)

References:

1. Letter from OPPD (M.J. Fisher) to USNRC (Document Control Desk), Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance, dated April 28, 2017 (ML17118A336) (LIC-17-0038)

2. Email from USNRC (J. Kim) to OPPD (E. Matzke), Final RAI for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664), dated August 24,2017 (ML17236A344) (NRC-17-052)

On April 28, 2017 Omaha Public Power District (OPPD), requested an exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance. (Reference 1). On August 24, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed changes. Attachment 1 of this letter provides the responses to the RAI.

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U.S. Nuclear Regulatory Commission Ll C-17 -0068 Page 2 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.

Respectfully,

~!Wj Mary J. Fisher Senior Director - Decommissioning Fort Calhoun Station MJF/epm Attachments: 1 . Response to Request for Additional Information c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. 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-17-0068 Page 1 ATTACHMENT 1 Final Request for Additional Information (RAil for Fort Calhoun Exemption from 10 CFR 140.11(a)(4),

Off-site Primary and Secondary Liability Insurance (MF9664)

FORT CALHOUN STATION, UNIT 1 DOCKET NO.: 50-285 By letter dated April 28, 2017, Omaha Public Power District (OPPD or the licensee),

requested an exemption from 10 CFR 140.11(a}(4), which concerns off-site primary and secondary liability insurance. The regulation requires licensees to have and maintain two levels of financial protection against off-site liability for each nuclear reactor that is licensed to operate, designed for the production of electrical energy, and has a rated capacity of 100,000 kilowatts electric (kWe) or more. The two levels of financial protection are as follows:

• Primary insurance coverage of $450,000,000 from private sources; and,

• Secondary financial protection in the form of private liability insurance available under an industry retrospective rating plan.

The licensee requested an exemption from this requirement to reduce the required level of primary off-site liability insurance to $100 million and eliminate the requirement for OPPD to participate in the secondary retrospective rating plan, effective on April 7, 2018.

The U.S. Nuclear Regulatory Commission staff has reviewed the licensee's submittal and determined that the following additional information is required in order to complete the review:

RAI-SBPB-01:

In SECY-96-256, "Changes to Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors, 10 CFR 50.54(w)(1) and 10 CFR 140.11," dated December 17, 1996 (ADAMS Accession No. ML15062A483), the staff recommended changes to the power reactor insurance regulations that would allow licensees to lower offsite primary liability insurance levels to $100 million and withdraw from the secondary retrospective rating plan upon demonstration that the fuel stored in the SFP can be air-cooled. In its Staff Requirements Memorandum to SECY-96-256, dated January 28, 1997 (ADAMS Accession No. ML15062A454), the Commission supported the staff's recommendation. The staff has used this technical criterion of air coolability to grant similar exemptions to other decommissioning reactors (e.g., Kewaunee Power Station (ADAMS Accession No. ML15026A544), published in the Federal Register on March 24, 2015).

The information supporting the requested exemption provided by letter dated April28, 2017, did not specifically address the technical criterion that the spent fuel could be air-cooled if the spent fuel pool was drained of water. Instead, the discussion addressed the low probability of damage to fuel if the pool were drained of water due to the long time available for actions to provide cooling. Provide an analysis or evaluation that provides reasonable assurance that the fuel could be adequately cooled by air in the event the spent fuel pool were completely drained, either by comparison of input parameters with representative NRC generic analyses or by plant specific analyses. Examples of these approaches for the Kewaunee Power Station are publicly available (ADAMS Accession Nos. ML14029A064 and ML14029A067).

LIC-17-0068 Page 2 OPPD Response OPPD has compiled the requested data comparing the input parameters to the representative NRC generic analyses (NUREG/CR-6451 1997, reference 2) to the data for the Fort Calhoun Station. Since the Fort Calhoun fuel assemblies have a 20% lower power density and a 10%

lower peak burnup combined with low uranium loading there should be a lower heat rate(s) than those cited for NUREG/CR-6451. The lower decay heat will be sufficient to offset the reduced cell size of the Region 2 racks compared to the benchmark. As a result the FCS spent fuel pool conditions are bounded by the NUREG/CR-6451 benchmark.

Spent Fuel Zirconium Fire Comparison Parameter i NUREG/CR-4982 1987 N U REG/CR-6451 Fort Calhoun Station (Ref. 1) 1997 (Ref 2)

• Plant Data Power Typical PWR 1130 MWe 500 MWe (3300 MWt) (1500MWt)

Assemblies Typical PWR 193 133 I MWt/Assembly 17.3 11.3 SFP Rack Design Design High Density High Density High Density Material Stainless Steel Stainless Steel Stainless Steel Pitch N/A 10.4" Region 1: 10.4" (N/S) 9.8" (E/W)

Region 2: 8. 7" Bottom Orifice 5" diameter 5" diameter 5" diameter (Region 1&2)

Opening per Cell 10" diameter Fuel Design I Typical PWR 17x17 14x14 Max Assembly High Burnup 60 GWD/MTU 51.504 GWD/MTU Cycle Burn up last cycle 27 55.231 GWD/MTU Cycle 28 (last cycle)

Source Term Decay 700 days (23 months) 17 months 17 months 5" diameter 360 days ( 12 months) 10" diameter Zirconium Oxidation i Temperature Limit 650 oc I 565 oc I 565 oc

LIC-17-0068 Page 3 Power Densl[y"t Companson I

Parameter NUREG/CR-6451 Fort Calhoun Station 1997 Power Per Assembly 17.3 11.3 (MWt)

Fuel Assembly L/W I 8.42 8.03 I I

(inches) I Fuel Active Height 144 129.3 (inches) l Active volume 10209.1 [0.1673] 8337.4 [0.1366]

I I

I (in 3 [m 3 ])

Power Density 103.4 82.72 (MWt/m 3 )

Uranium Mass per - 0.3893' Assembly (MTU}

• For Batch EE1, maximum of C27 and C28 sub-batches

Reference:

1. NUREG/CR-4982 "Severe Accidents in Spent Fuel Pools in Support of Generic Safety Issue 82", 06/1987

2. NUREG/CR-6451 "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," 04/1997