LIC-22-0006, Reactor Head Disposition Project Overview

Reactor Head Disposition Project Overview

ML22080A234
Person / Time
Site:	Fort Calhoun
Issue date:	03/17/2022
From:	Allan Barker Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-22-0006
Download: ML22080A234 (45)

Text

LIC-22-0006 March 17, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Fort Calhoun Station (FCS) Reactor Head Disposition Project Overview

References:

1. Letter from NRC (J. Rubenstone) to OPPD (M. Fisher), âFort Calhoun Nuclear Generating Station

â Foreign Obligations Compliance during Decommissioning,â dated August 9, 2018 (ML18201A999).

2. OPPD Letter (T. Burke) to USNRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report," dated December 16, 2019 (LIC-19-0007)

(ML19351E355).

10 CFR 50.82(a)

In a letter dated August 9, 2018 letter (Reference 1), the NRC recommended that OPPD provide a Regulatory Commitment, or some similar method, to ensure the U.S. Government can fulfill its international obligations with the Government of Japan. As a result, in a letter to the NRC on December 16, 2019 (Reference 2), OPPD committed to:

Notify the NRC of the final disposition of the reactor closure vessel head (RCVH) which was obtained from Mitsubishi Heavy Industries in Japan when the RCVH is removed from the FCS site, by transfer to another facility, sold as scrap metal, or any other pathway implemented during the decommissioning process.

It is anticipated that the RCVH will be disposed of as part of the FCS decommissioning process sometime in 2020. The above actions have been entered into the FCS commitment tracking system.

The purpose of this letter is to inform the NRC the final disposition of the OPPD RCVH obtained from Mitsubishi Heavy Industries, in compliance with OPPDâs obligations under the August 9, 2018 letter (reference 1). On November 1, 2021, the RCHV physical decommissioning was commenced and segmented into ten (10) pieces for efficient handling and disposal. The RCHV segments were shipped via railcars on February 2, 2022 from OPPDâs FCS to Energy Solutions Clive Disposal Facility in Clive, Utah. On February 10, 2022 the Clive facility received and accepted the RCVH shipment. The RCVH segments were unloaded and placed in a disposal cell with a Certificate of Disposal documenting the compliant disposal provided to OPPD. The attachments and associated scrap were also included with this disposal. Attachment 1 documents the disposal of the RCVH and contains the Certificate of Disposal.

444 SOUTH 16TH STREET MALL ⢠OMAHA, NE 68102-2247

LIC-22-0006 Page 2

This disposal did not affect the portion of the treaty requiring tracking associated with the nuclear fuel utilized during the operation of this RCVH.

Having complied with the obligations under the August 9, 2018 letter, OPPD deems the issue closed.

If you disagree or should have any questions regarding this report, please contact Andrea K Barker at 531-226-6051. There are no regulatory commitments contained in this letter.

Respectfully,

Andrea K. Barker. CHP. MHP Regulatory Assurance & Emergency Planning Manager AKB/cac

Enclosure:

Attachment 1, Reactor Head Disposition Project Overview c: S. A. Morris, NRC Regional Administrator, Region IV

J. D. Parrott, NRC Senior Project Manager S. Anderson, NRC Health Physicist, Region IV

EnergySolutions, LLC

Reactor Head Disposition Project Overview

OPPD Decommissioning Project

Fort Calhoun Station

Blair, Nebraska

Date IssuedâMarch 8, 2022

Prepared by

James A. Miller

EXECUTIVE

SUMMARY

On November 1, 2021, the Reactor Vessel Head (RVH) disposition process on the Fort Calhoun Decommissioning Project commenced. The RVH disposition process was a multi-phased approach that included the removal of the RVH from the vessel, segmentation of the RVH, surveying and weighing of the RVH, characterization of the RVH, packaging for transport of the RVH, transportation of the RVH to an approved licensed disposal facility, and final and permanent disposal of the RVH.

Upon commencing this project, the RVH was removed from the Reactor Vessel and relocated to the segmentation laydown area within Containment Building. The RVH was segmented into ten pieces with the goal to ensure each piece weighed less than 10,000 lbs. The ten RVH pieces weighed a total 82,719 lbs. The segmentation process utilized a thermal cutting technique (i.e., oxygen-acetylene cutting torches). The segmentation operations, including housekeeping activities, took ten calendar days to complete and was completed on November 11, 2021. The housekeeping activities resulted in collection of cutting slag as a result of the thermal cutting activities. Cutting slag was packaged into two soft-sided sacrificial disposal containers weighing ~7,100 lbs total.

Prior to relocating the RVH pieces and cutting slag containers to the Waste Processing Structure (WPS), each RVH piece was radiologically surveyed and encapsulated with fixative to meet the off-site disposal facility Waste Acceptance Criteria (WAC) for radiological contamination of less than 50,000 dpm/100cm2 (beta-gamma) and 500 dpm/100cm2 (alpha). The radiological survey results and 10 CFR 61 (Part 61) Analysis were used to properly characterize the RVH pieces and cutting slag to demonstrate compliance with the disposal facilityâs (Clive Disposal Facility) WAC and Radioactive Material License and the Department of Transportation regulations. Additionally, this information was utilized to determine waste classification (i.e., Class A).

The RVH pieces and cutting slag containers were relocated from Containment Building to the WPS on January 5th and 6th, 2022, in preparation of packaging into low-sided mill gondola railcars. On January 26th and 27th, 2022, the RVH pieces and cutting slag containers were loaded into three separate railcars commingled with construction debris (i.e., concrete rubble). Two of the three railcars were packaged with three RVH pieces and one cutting slag container while the third railcar was loaded with four RVH pieces. Prior to shipment, all required regulatory paperwork (e.g., Bill of Lading, Manifest, etc) were generated and submitted to the carrier (Union Pacific) and the disposal facility (Clive). The three railcars departed the OPPD site on February 2, 2022.

The railcars traveled seven days from the OPPD site to the Clive Facility located in Clive, Utah, arriving on February 9, 2022. On February 10, 2022, the Clive facility received and accepted the three railcar shipments. On February 11, 2022, the Clive facility unloaded the RVH pieces and cutting slag containers and placed them in the disposal cell for final disposition. The Clive Facility provided Certificates of Disposal (CODs) certifying the waste has been compliantly disposed. The RVH disposition process was conducted over a fourteen-week period.

Attached are pictures, summary reports, and trackers throughout the RVH disposition process.

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Reactor Vessel Head Disposition

Process Summary Reporting

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Reactor Vessel Head disposition routine updates to OPPD January 5th thru February 11th, 2022.

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Reactor Vessel Head Removal

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Reactor Vessel Head relocated from reactor vessel to the segmentation area within the Containment Building on November 1, 2021.

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Reactor Vessel Head Segmentation

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Reactor Vessel Head segmentation activities within the Containment Building, November 1st thru 11th, 2021.

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Reactor Vessel Head Relocate to WPS

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Reactor Vessel Head pieces relocated from Containment Building to WPS, January 5th and 6th, 2022.

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Reactor Vessel Head Cutting Slag Relocate to WPS

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Reactor Vessel Head cutting slag containers relocated from Containment Building to WPS, January 6th, 2022.

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Reactor Vessel Head Pieces and Cutting Slag Containers

Loading into Railcar at WPS

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars, January 26th, 2022.

FURX322300 with pieces 1, 4, 5 and Bag #2

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars, January 26th, 2022.

FURX322355 with pieces 3, 6, 8 and Bag #1

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars, January 27th, 2022.

FURX322336 with pieces 2, 7, 9, 10

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Reactor Vessel Head Pieces and Cutting Slag Containers

Railcars prior to Departing OPPD

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars prior to departing OPPD, February 2nd, 2022.

FURX322300 with pieces 1, 4, 5 and Bag #2

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars prior to departing OPPD, February 2nd, 2022.

FURX322355 with pieces 3, 6, 8 and Bag #1

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars prior to departing OPPD, February 2nd, 2022.

FURX322336 with pieces 2, 7, 9, 10

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Reactor Vessel Head Pieces and Cutting Slag Containers

Reporting to OPPD Summary

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Reactor Vessel Head pieces and cutting slag containers railcar tracking post departing OPPD, February 2nd thru 9th, 2022.

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Reactor Vessel Head Pieces and Cutting Slag Containers

Arrive at Clive

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Reactor Vessel Head pieces and cutting slag containers railcars arrive at Clive, February 9th, 2022.

FURX322300 with pieces 1, 4, 5 and Bag #2

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars prior to departing OPPD, February 2nd, 2022.

FURX322355 with pieces 3, 6, 8 and Bag #1

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Reactor Vessel Head pieces and cutting slag containers loaded in railcars prior to departing OPPD, February 2nd, 2022.

FURX322336 with pieces 2, 7, 9, 10

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0

Reactor Vessel Head Pieces and Cutting Slag Containers

Received and Accepted at Clive

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Reactor Vessel Head pieces and cutting slag containers railcars received and accepted at Clive, February 10th, 2022, signed NRC Form 540.

FURX322300 with pieces 1, 4, 5 and Bag #2

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Reactor Vessel Head pieces and cutting slag containers railcars received and accepted at Clive, February 10th, 2022, signed NRC Form 540.

FURX322355 with pieces 3, 6, 8 and Bag #1

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Reactor Vessel Head pieces and cutting slag containers railcars received and accepted at Clive, February 10th, 2022, signed NRC Form 540.

FURX322336 with pieces 2, 7, 9, 10

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1

Reactor Vessel Head Pieces and Cutting Slag Containers

Processed at Clive

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Reactor Vessel Head pieces and cutting slag containers railcars processed at Clive, February 11th, 2022, unloading of material inside the railcar roll-over facility.

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Reactor Vessel Head pieces and cutting slag containers railcars processed at Clive, February 11th, 2022, material placed in disposal cell.

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2

Reactor Vessel Head Pieces and Cutting Slag Containers

Certificate of Disposal

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Reactor Vessel Head pieces and cutting slag containers Certificate of Disposal, February 11th, 2022, certifying waste has been disposed

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