ML17264A750

Response to Request for Additional Information (RAI) License Amendment Request Regarding Removal of Dry Cask Loading Limits Fort Calhoun Station, Unit 1 Docket No.: 50-285 (MF9831)

ML17264A750
Person / Time
Site:	Fort Calhoun, 07201004
Issue date:	09/21/2017
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LlC-17 -0066, MF9831
Download: ML17264A750 (4)

Text

Ll C-17 -0066 September 21, 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 (RAI) License Amendment Request Regarding Removal of Dry Cask Loading Limits Fort Calhoun Station, Unit 1 Docket No.: 50-285 (MF9831)

References:

1. Letter from OPPD (M.J. Fisher) to USNRC (Document Control Desk), License Amendment Request (LAR) 17-03; Removal of Fort Calhoun Station, Unit 1 Dry Cast Loading Limits, dated June 9, 2017 (ML17160A405)(LIC-17-0015)

2. Email from USNRC (J. Kim) to OPPD (E. Matzke), Final RAI for Fort Calhoun LAR Regarding Removal of Dry Cask Loading Limits (MF9831 ), dated August 22, 2017 (ML17234A469) (NRC-17-050)

On June 9, 2017 OPPD submitted LAR 17-03 for removing Dry Cast loading limits from the FCS Technical Specifications (Reference 1). On August 22, 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.

444 SOUTH 16TH STREET MALL

• OMAHA, NE 68102-2247

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U.S. Nuclear Regulatory Commission LIC-17-0066 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,

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~ry J. Fisher Senior Director - Decommissioning Fort Calhoun Station MJF/epm

Attachment:

1. Response to Request for Additional Information 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

L1 C-17-0066 Page 1 ATTACHMENT 1 REQUEST FOR ADDITIONAL INFORMATION (RAI)

LICENSE AMENDMENT REQUEST REGARDING REMOVAL OF DRY CASK LOADING LIMITS FORT CALHOUN STATION, UNIT 1 DOCKET NO.: 50*285 By letter dated June 9, 2017, the Omaha Public Power District (OPPD) (the licensee) submitted a license amendment request (LAR) (Agency Document Access and Management Systems (ADAMS) Accession No. ML17093A309), for Fort Calhoun Station (FCS) Unit 1 to remove the Spent Fuel Cask Loading requirements from its 10CFR50 license. The 2009 revision to 10CFR 50.68 states in paragraph (c) that storage/transportation casks being loaded in the spent fuel pool in accordance with its 10CFR72/1 OCFR71 licensee does not have to also meet the requirements of 10CFR50.68 states in paragraph (b). This change removed the requirement for storage/transportation casks to meet 10CFR50.68 while they are being loaded in 10CFR50 licensee's spent fuel pools.

While the revision to 10CFR50.68 eliminated the requirement for 10CFR50 licensees to have nuclear criticality safety requirements for loading storage/transportation cask in addition to those in the 10CFR72/1 OCFR71 licensees, there have been occasion when the 10CFR72/10CFR71 licensees directly or indirectly took credit for or assumed the presence of some aspect of the 10CFR50 licensee. Therefore the U.S. Nuclear Regulatory Commission staff request the additional information to proceed with its review:

1. Does the OPPD 10CFR71 license directly or indirectly take credit for or assumed the presence of some aspect of the 10CFR50 licensee?

OPPD Response:

OPPD/Fort Calhoun Station does not have a 10CFR71 or a 10CFR72 site specific license. Fort Calhoun Station utilizes a general license as allowed by Subpart K of 10CFR72. Currently Fort Calhoun Station utilizes the NUHOMS 32PT dry fuel storage system in accordance with the Certificate of Compliance (CoC) 1004 through Amendment 9 issued to Transnuclear Inc. as incorporated by the NRC. Yes, some station Part 50 programs (i.e. Radiation Protection, Chemistry, Training, etc.) are credited in the general license as documented and evaluated in the site 72.212 Report.

2. If yes, is any of that overlap affected by the license amendment request in OPPD's June 9, 2017, letter?

OPPD Response:

There is no overlap between the programs indicated in the response to question 1 above and the license amendment request to remove boric acid concentration limits from the 10 CFR 50 licensed technical specifications.

LIC-17-0066 Page 2

3. Remove any aspect of this license amendment request that OPPD's 10CFR71 license directly or indirectly takes credit for or assumes the presence of some aspect of items requested to be removed from OPPD's 10CFR50 licensee?

OPPD Response:

As indicated in the response to items 1 and 2 above, no changes to the license amendment are needed.