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Category:Letter type:LIC
MONTHYEARLIC-23-0007, Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information2023-12-0606 December 2023 Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information LIC-23-0005, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 20232023-08-24024 August 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 2023 LIC-23-0004, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2023-04-20020 April 2023 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-23-0003, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2023-03-15015 March 2023 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-23-0001, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information2023-02-27027 February 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information LIC-23-0002, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2023-02-20020 February 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information LIC-22-0005, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2022-04-20020 April 2022 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2022-03-30030 March 2022 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-22-0006, Reactor Head Disposition Project Overview2022-03-17017 March 2022 Reactor Head Disposition Project Overview LIC-22-0004, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2022-02-17017 February 2022 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-21-0008, Organizational and Management Change2021-10-28028 October 2021 Organizational and Management Change LIC-21-0007, ISFSI Only Emergency Plan Update2021-09-0808 September 2021 ISFSI Only Emergency Plan Update LIC-21-0004, Radiological Effluent Release Report and Radiological Environmental Operating Report2021-04-29029 April 2021 Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-21-0003, Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report2021-03-30030 March 2021 Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-21-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-22022 February 2021 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0015, Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092)2020-07-29029 July 2020 Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092) LIC-20-0014, Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2020-07-15015 July 2020 Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-20-0012, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2020-05-18018 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool LIC-20-0011, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-05-0707 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0009, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2020-04-30030 April 2020 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-20-0008, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-04-13013 April 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0006, (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E2020-03-26026 March 2020 (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E LIC-20-0004, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-03-10010 March 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2020-02-27027 February 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0002, Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan2020-02-27027 February 2020 Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan LIC-20-0001, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-02-0606 February 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0025, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-12-19019 December 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019 Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-19-0022, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-11-18018 November 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0018, Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2019-11-14014 November 2019 Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-19-0020, Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis2019-10-17017 October 2019 Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis LIC-19-0017, Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 20042019-08-0808 August 2019 Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 An LIC-19-0010, License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associa2019-05-20020 May 2019 License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated LIC-19-0008, Submittal of 2018 Annual Report2019-04-0404 April 2019 Submittal of 2018 Annual Report LIC-19-0004, Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP)2019-03-28028 March 2019 Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP) LIC-19-0005, 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report2019-03-28028 March 2019 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report LIC-19-0001, License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2019-02-28028 February 2019 License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme LIC-19-0003, Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation R2019-02-28028 February 2019 Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation Requ LIC-19-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-01-0303 January 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-18-0031, Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update2018-12-17017 December 2018 Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update LIC-18-0030, Request for Partial Site Release Phase 22018-11-12012 November 2018 Request for Partial Site Release Phase 2 LIC-18-0028, Letter of Intent to Submit Request for Additional Partial Site Release2018-10-18018 October 2018 Letter of Intent to Submit Request for Additional Partial Site Release LIC-18-0027, Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update2018-10-0303 October 2018 Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update LIC-18-0003, License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool2018-09-28028 September 2018 License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool LIC-18-0025, Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 20192018-07-19019 July 2018 Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 2019 LIC-18-0023, Fort Calhoun Station, Unit 1 Request for Partial Site Release2018-06-29029 June 2018 Fort Calhoun Station, Unit 1 Request for Partial Site Release LIC-18-0021, Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan)2018-06-0606 June 2018 Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan) LIC-18-0017, Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy2018-04-26026 April 2018 Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy 2023-08-24
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LIC-16-0066 EA-13-243 October 31 , 20 16 Mr. K. M. Kennedy Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285
Subject:
Closure of Remaining Confirmatory Action Letter Commitments
References:
See Page 5
Dear Mr. Kennedy:
In Reference 1, Omaha Public Power District (OPPD) made post-restart commitments associated with Fort Calhoun Station (FCS) which were confirmed in a NRC Confirmatory Action Letter (CAL)
(Reference 2). In early 2016, the NRC completed a Confirmatory Action Letter Follow up Inspection (Reference 3) and closed a number of the CAL commitments. The Inspection Report also identified eight (8) action items (AI) within the CAL that remained open. OPPD is requesting closure of these remaining commitments based on the OPPD's decision to permanently cease FCS operations.
By letter dated June 24, 2016 (Reference 4), OPPD provided formal notification to the NRC pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1)(i) of OPPD's contingent determination to permanently cease power operations at FCS no later than December 31, 2016. OPPD updated this letter on August 25, 2016 (Reference 5) certifying that it plans to permanently cease power operations at FCS on October 24, 2016. FCS ceased power operations on October 24, 2016. FCS intends to permanently remove all fuel from the reactor vessel in November 2016.
The specific bases for closing the remaining eight open CAL action items is provided on the following pages. The eight items are grouped into the three categories as they were listed in NRC Inspection Report (Reference 3) including the reference, AI number and description from Section 5 of the report.
444 South 16th Street Mall Omaha, NE 68102-2247
Mr. K. M. Kennedy LIC-16-0066 Page 2 40A4.1.4: Design and Licensing Basis (2013-0086)
I: AI Nurn b er l o escnp11on
'f 2013-05570-049 1 CAPR Modify the Engineering Support Personnel Training (ESPT) initial and continuing training programs to incorporate CAPR-1 and CAPR-2. Training shall include items 1, 2 and 3 from CAPRs 1 and 2 i to address the identification of design and licensing bases, record types that are included, and the method of retrieval i 2013-05570-026 Identify and define the current licensing bases and assure licensing bases documentation remains current, accurate, complete, and !
retrievable.
12013-05570-076 Identify and define the design bases and assure design bases documentation remains current, accurate, complete, and retrievable.
I 2013-05570-092 Complete Phase 3 of the Key Calculation Project. Phase 3 consists !
j of revising any deficient critical calculation or engineering analysis identified from Phase 2, as needed.
2013-05570-093 Validate the design and licensing basis has been translated into plant operation by verifying that the operation, surveillance, and maintenance of the safety-related components do not compromise I the design and licensing basis.
These actions were being addressed by the OPPD design and licensing basis project (DLBRP).
The DLBRP was suspended indefinitely since the majority of plant systems will no longer be required when FCS is permanently defueled. When the DLBRP was suspended, the project was approximately fifty percent complete with key systems such as raw water and component cooling water project reviews completed. Before the DLBRP was suspended, approximately sixty discrepancies were identified and entered in the station's corrective action program . None of these issues were determined by Shift Management to result in a significant operational concern nor would they significantly impact functions needed to maintain the plant in a permanently defueled status.
As part of the decommissioning process, FCS has developed Decommissioning Project Plans (DPP) to address plant systems and equipment that will be necessary to support a permanently defueled status, as well as equipment abandonment and removal. Information from the DLBRP will be utilized during the implementation of the DPPs including decommissioning updates of the Technical Specifications and Updated Safety Analysis Report (USAR). Some of the key DPPs are listed below:
FC-DPP-11 Spent Fuel Pool Configuration Plan FC-DPP-13 Decommissioning Support Systems Identification Plan FC-DPP-14 Decommissioning Power Study Plan FC-DPP-18 Decommissioning Accident Analysis Plan FC-DPP-20 Maintenance Rule Program FC-DPP-23 Fire Protection Program Revision Plan FC-DPP-28 PSDAR Preparation Plan FC-DPP-30 USAR Update Plan FC-DPP-44 Personnel Training Plan FC-DPP-45 50.59 Safety Review Process
Mr. K. M. Kennedy L1 C-16-0066 Page 3 FC-DPP-48 Spent Fuel Strategy FC-DPP-50 Procedures FC-DPP-51 Technical Specifications FC-DPP-57 System Abandonment FC-DPP-58 Underground Piping and Tanks 40A4.4: Actions Associated with Containment Internal Structures {2013-0013)
AI Number Description 1 2012-04392-014 Evaluate the structural design margin for the containment internal 2012-04392-045 structures, and reactor cavity and compartments, and resolve any deficiencies in accordance with its corrective action program {CAP) 2012-04392-048 Regarding Beam 22A and Beam 22B in the containment internal structures resolve any deficiencies in accordance with the CAP.
The remaining actions associated with Containment Internal Structures will no longer be relevant when FCS is permanently defueled. Once the plant is in the defueled condition it is no longer allowed the use the facility for power operation or emplacement of fuel into the reactor vessel as provided in 10 CFR 50.82(a)(2) so the requirements placed on the Containment are no longer applicable. As a result, OPPD has withdrawn the License Amendment Request (LAR) that was associated with this issue (Reference 6). While not part of the CAL actions, FCS continues to track deficiencies with the auxiliary building structure in CAP (CR 2012-04392-012). A subsequent LAR (Reference 7) has been submitted to assist in resolving those issues.
40A4.1.8.f: Piping Code and System Classification and Analysis (2013-0071)
AI Number Description 2012-07724-023 Provide calculations documenting thermal fatigue analysis on the Class I piping systems for primary plant sampling, reactor coolant gas vent, reactor coolant, safety injection, and waste disposal in accordance with USAS B31.7 Draft 1968 The commitment to resolve thermal fatigue on Class I piping systems is not relevant since thermal fatigue conditions will not exist once FCS is permanently defueled. The scope included in USAS 831.7 Section 700.1 includes; "Piping systems for which rules are specified by this Code are those that are designed to provide a pressure-retaining barrier in a nuclear power plant or to provide for the overall containment of the nuclear plant." The limits on the Class I piping can no longer be exceeded without a pressure source. Also, 10 CFR 50.82, "Termination of license,"
states that, "upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel. .. , the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel."
As such, the requirements of USAS 831.7, no longer apply to the piping systems in such a condition because the reactor coolant, safety injection, and waste disposal pressure boundary will no longer be used as a pressure retaining or fission product barrier when the reactor vessel is permanently defueled.
Mr. K. M. Kennedy L IC-16-0066 Page 4 Based on the above information, OPPD is requesting closure of the eight remaining CAL commitments.
There are no regulatory commitments contained within this letter.
If you should have further questions, please contact Mr. Bradley H. Blome, Manager - Site Regulatory Assurance, at 402-533-7270 .
Respectfully,
~nP~ Fo~
Shane M. Marik Site Vice President and CNO SMM/cac cc: C. F. Lyon, NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector
Mr. K. M. Kennedy LIC-16-0066 Page 5 REFERENCES
- 1. OPPD Letter (L. P. Cortopassi) to USNRC (M. L. Dapas), "Integrated Report to Support Restart of Fort Calhoun Station and Post-Restart Commitments for Sustained Improvement," dated December 2, 2013 (LIC-13-0164) (ML13336A785)
- 2. NRC Letter (M. L. Dapas) to OPPD (L. P. Cortopassi), "Confirmatory Action Letter -
Fort Calhoun Station," dated December 17,2013 (ML13351A395)
- 3. NRC Letter (J. Sowa) to OPPD (S. M. Marik), "Fort Calhoun Station- NRC Confirmatory Action Letter Follow up Inspection 05000285/2016007," dated February 11, 2016 (ML16042A542)
- 4. OPPD Letter (T. Burke) to US NRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated June 24, 2016 (LIC-16-0043)
(ML16176A213)
- 5. OPPD Letter (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067)
(ML16242A127)
- 6. OPPD Letter (S. M. Marik) to USNRC (Document Control Desk), "Withdrawal of License Amendment Request 03, Revise Current Licensing Basis to Use ACI Ultimate Strength Requirements," dated July 27, 2016 (LIC-16-0051) (ML16209A126)
- 7. OPPD Letter (S. M. Marik) to USNRC (Document Control Desk), "License Amendment Request 16-04: Revise Current Licensing Basis to USE ACI Ultimate Strength Requirements," dated October 25, 2016 (LIC-16-0093)