ML16291A019

OPPD Pre-Submittal Meeting Regarding Fort Calhoun Station Decommissioning October 18, 2016

ML16291A019
Person / Time
Site:	Fort Calhoun
Issue date:	10/17/2016
From:	Omaha Public Power District
To:	Lyon C Plant Licensing Branch IV
Lyon C, NRR-DORL 415-2296
References
TAC MF8114
Download: ML16291A019 (14)

Text

Omaha Public Power District (OPPD)

Fort Calhoun Station (FCS) Decommissioning October 18, 2016

FCS Decommissioning Team 2

Mary Fisher - Sr. Dir. FCS Decommissioning Brad Blome - Mgr. Site Regulatory Assurance Herb Childs - Mgr. Site Security Ted Maine - Mgr. Radiation Protection Tim Uehling - Mgr. Site Training Also present: David Daigle - ENERCON, Emergency Preparedness Specialist

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Background===

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• OPPD is a publicly-owned electric utility and is a political subdivision of the state of Nebraska

• Governed by a publicly elected Board of Directors

• On 5/12/16, OPPD management recommended ceasing FCS operations to the Board of Directors

• On 6/16/16, OPPD Board of Directors voted and approved ceasing FCS operations and going to SAFSTOR

Initial NRC Submittals 4

• Initial certification to Permanently Cease Operations by 12/31/16 submitted on 6/24/16

• Updated certification submitted on 8/25/16, FCS will Permanently Cease Operations on 10/24/16

• Certification of Permanent Removal of Fuel from the Reactor Vessel will be submitted in November 2016

Decommissioning Approach 5

Multidisciplinary teams supplemented with several vendors with decommissioning experience Benchmarking Trips to Crystal River, Vermont Yankee, Zion, Kewaunee; future trips planned Industry decommissioning groups

Nuclear Energy Institute (NEI) Decommissioning Transition Team

Industry Regulatory Assurance (RA) Decommissioning Users Group

Emergency Planning Decommissioning Users Group Decommissioning Oversight Committee

Key SAFSTOR Decision Points 6

Decommissioning Funds Possible Decommissioning Services Agreement fourth quarter 2016 Independent Spent Fuel Storage Installation (ISFSI) timeline and vendor selection for additional casks second quarter 2017 Evaluate SAFSTOR/DECON timelines

All Spent Fuel On ISFSI Rev 1 10/13/16 SHUTDOWN Oct 24, 2016 Fort Calhoun SAFSTOR Timeline Decom cost Update to NRC ONLINE 3Q16 1Q17 2Q17 3Q17 4Q17 3Q19 4Q19 2Q21 3Q21 4Q16 1Q18 3Q18 4Q18 1Q19 2Q19 1Q21 1Q20 2Q20 3Q20 4Q20 2Q18 Plant in SAFSTOR YEAR 2016 2017 2018 2019 2020 2021 2022 4Q21 2Q22 3Q22 1Q22 Submit Letter(s)

- Cease Operations

- Permanent Defueled PSDAR/DCE Submittal

~03/31/17 PDTS Issued 4Q22 1Q23 ISFSI Campaign ISFSI Only Tech Specs Issued Decom cost Update to NRC Decom cost Update to NRC Decom cost Update to NRC Decom cost Update to NRC 2023 3Q16 1Q17 2Q17 3Q17 4Q17 3Q19 4Q19 2Q21 3Q21 4Q16 1Q18 3Q18 4Q18 1Q19 2Q19 2Q18 1Q21 1Q20 2Q20 3Q20 4Q20 4Q21 2Q22 3Q22 1Q22 4Q22 1Q23 End Zirc Fire Period 17 months Evaluate SFP Cooling MOD MODIFICATIONS ENG/PROGRAMS SECURITY PLAN ORGANIZATION CHANGES USAR and Accident Analysis Tech Specs ODCM Revise Security Plan (Defueled)

Chapter 14 USAR update Remaining USAR Update Pri Sys Abandonment Developed by DECOM Team Note: This Color Graphic is a communication tool only. It is not a controlled document or schedule and subject to change.

Prepare/

Submit PDTS Determine Engineering Programs required/not required Prepare/issue ODCM Revise ERO Plan (PSEP/PDEP)

Change MGMT Plans-Implement FHA Analysis System Reclassification NRC Review PDTS System Eval/Recategorize System Isolation/draining and abandonment EMERGENCY PLANNING Trans to SAFSTOR (1)

Transition to SAFSTOR (2)

Prepare/submit ISFSI Only Tech Specs NRC review ISFSI Only Tech Specs Systems Drain/

Energy Removal (Avail/Abandon)

Systems Drain/

Energy Removal (Avail/Abandon)

(No Spent Fuel in Pool)

Sec Sys Abandonment SFP Sys Abandon PDEP/no offsite staff or facilities ERO Plan (ISFSI ONLY)

Prepare/issue ODCM Revise Security Plan (ISFSI ONLY)

NRC Review of Security Plan Exemption request NRC Review of Security Plan Exemption request NRC Approval of PDEP and exemption Request SFP Indication MOD Electrical footprint reduction Heating/cooling footprint reduction USAR Update USAR Update Change MGMT Plans-develop System Reclassification Post MODs Engineering Develop ECs for MODs Staffing Adjustments HE-2 Aux Bldg Crane MOD Maintain Cybersecurity Plan Decision Milestone SAFSTOR/DECON Legend:

DCE - Decommissioning Cost Estimate ERO - Emergency Response Organization FHA - Fuel Handling Analysis ISFSI - Independent Spent Fuel Storage Installation ODCM - Offsite Dose Calculation Manual PDEP - Permanently Defueled E-Plan PSDAR - Post Shutdown Decommissioning Activities Report PSEP - Post Shutdown E-Plan PDTS - Permanently Defueled Tech Specs SFP - Spent Fuel Pool USAR - Updated Safety Analysis Report Milestone Review SAFSTOR/DECON NRC Approval of PSEP Revise Fire Hazard Analysis Review Fire Brigade Staffing Adjustments Safstor Decon Safstor Decon Developed by Transition Team Note: Represents our best knowledge as of this revision. This plan will be updated as new information dictates.

Station procedure reviews/revisions/deletions Install SFP Cooling MOD

Emergency Plan Changes 8

Post Shutdown EPlan Submitted 9/2/16 Revised on-shift and Emergency Response Organization (ERO) staffing based on analysis of required post-shutdown ERO positions but does not change any Emergency Action Level (EALs)

Meeting with all supporting offsite agencies held on 9/8/16; additional meetings are scheduled Verification drills including offsite agencies scheduled for first quarter 2017

Emergency Plan Changes 9

Supporting submittals

• Certified Fuel Handler (CFH) Training Program submitted on 7/7/16

• One Request for Additional Information (RAI) received; response provided 10/7/16

• Technical Specifications (TS), Section 5, Administrative Controls, License Amendment Request (LAR) submitted 9/28/16

• Severe Weather Security Plan Exemption Request (10CFR73.55) submitted 10/7/16

Emergency Plan Changes 10 Permanently Defueled EPlan Revises EALs, removes all offsite ERO functions and significantly reduces ERO staffing Initial draft prepared and undergoing cross-disciplinary team & offsite agency reviews Supporting vendor analyses: Zirconium Fire, Shine, Radiation Monitor Set Points and updated Fuel Handling Accident Boundary Dose Permanently Defueled EPlan and associated Exemption Requests (10CFR50.47 & App E) will be submitted December 2016

Other Submittal Plans

• NRC fee reclassification in November 2016

• Exemption for Maintenance of Records in December 2016

• SAFSTOR Security submittal in December 2016

• Post Shutdown Decommissioning Activities Report (PSDAR), Decommissioning Cost Estimate (DCE),

Spent Fuel Management plan and Limited Site Characterization in first quarter 2017

• Permanently Defueled TS LAR in first quarter 2017

• Insurance Exemption requests in first quarter 2017

• Quality Assurance Topical Report update in first quarter 2017 11

Other Submittal Plans Fukushima

• Letter submitted to NRC on 8/12/16 for relaxation of implementation date for compliance with Order EA-12-049 (Mitigation Strategies for Beyond Design Basis External Events) to 8/31/17

• Request to rescind Order EA-12-051 (Reliable Spent Fuel Pool Instruments) submitted 9/9/16

• Updated Overall Integrated Plan (OIP) for EA12049 by 10/31/16

• Certify compliance with EA-12-049 by 8/31/17 12

Other Submittal Plans Confirmatory Action Letter (CAL) items

• Submit LAR for Class 1 Structures (Auxiliary Building) needed to support decommissioning in October 2016

• Submit letter to request closure of NRC CAL items in October 2016 National Fire Protection Association (NFPA) 805

• LAR to delete Fire Protection License Condition and utilize NFPA 805 Decommissioning Fire Program in December 2016 CyberSecurity

• Applicable CyberSecurity submittals based on proposed NRC guidance planned in first quarter 2017 13

FCS Decommissioning Closing Comments/Questions 14