Letter Sequence RAI |
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MONTHYEARLIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019
Post-Shutdown Decommissioning Activities Report
Project stage: Request
ML20100L7232020-03-15015 March 2020
Email: Town of Desoto National Register of Historic Places Eligibility
Project stage: Request
ML20091G5612020-03-30030 March 2020
Annual Decommissioning Funding/Irradiated Fuel Management Status Report
Project stage: Request
ML20111A2162020-05-20020 May 2020
Revised PSDAR Request for Additional Information - RAI
Project stage: RAI
ML20111A2152020-05-20020 May 2020
Letter to Fisher Fort Calhoun Unit 1 Revised PSDAR Request for Additional Information - RAI
Project stage: RAI
ML20202A6542020-07-16016 July 2020
Response for Fort Calhoun Station Fort Calhoun Station, Unit No. 1, Revised Post-Shutdown Decommissioning Activities Report
Project stage: Request
LIC-20-0013, License Amendment Request (LAR) 21-01, Response Re Revised Post-Shutdown Decommissioning Activities Report, Chapter 8 2 Updated Environmental Report, File No. 127690-003 (LIC-20-0013, ML 20202A654)2020-07-16016 July 2020
License Amendment Request (LAR) 21-01, Response Re Revised Post-Shutdown Decommissioning Activities Report, Chapter 8 2 Updated Environmental Report, File No. 127690-003 (LIC-20-0013, ML 20202A654)
Project stage: Request
ML20232D0532020-11-0303 November 2020
Completion of NRC Review of the Fort Calhoun Station Revised Post Shutdown Decommissioning Activities Report (License No. DPR-40, Docket No. 50-285)
Project stage: Approval
2020-03-15
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Category:Request for Additional Information (RAI)
MONTHYEARML23151A0042023-06-0606 June 2023
Second Set RAIs Rev 4
ML22357A0672022-12-30030 December 2022
Enclosure RAI Re Approval of License Termination Plan
ML22119A2472022-05-0303 May 2022
Review of Amendment Request to Add a LC to Include LTP Requirements, RAI for Environmental Review
ML20111A2162020-05-20020 May 2020
Revised PSDAR Request for Additional Information - RAI
ML19241A1812019-08-21021 August 2019
Request for Additional Information on Proposed Changes to the FCS Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-only Status
ML18067A1432018-03-0808 March 2018
Enclosurequest for Additional Information (Letter to M. J. Fisher Request for Additional Information Regarding Omaha Public Power District'S Decommissioning Funding Plan Update for Fort Calhoun Station ISFSI)
ML17236A3442017-08-24024 August 2017
NRR E-mail Capture - Final RAI for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)
ML17236A3462017-08-24024 August 2017
NRR E-mail Capture - Final RAI for Fort Calhoun LAR Regarding Permanently Defueled TS (MF9567)
ML17234A4692017-08-22022 August 2017
NRR E-mail Capture - Final RAI for Fort Calhoun LAR Regarding Removal of Dry Cask Loading Limits (MF9831)
ML17194A9732017-07-13013 July 2017
NRR E-mail Capture - Final RAI for Fort Calhoun Ultimate Strength Design for Aux. Bldg LAR (MF8525)
ML17112A0362017-04-20020 April 2017
NRR E-mail Capture - Fort Calhoun Station - Final RAI Regarding Permanently Defueled EP and EAL Scheme Change LAR
ML17090A3942017-03-31031 March 2017
NRR E-mail Capture - Fort Calhoun - Final RAI Regarding Administrative Control TS Change LAR (MF8437)
ML17082A0022017-03-22022 March 2017
NRR E-mail Capture - Fort Calhoun Station - Final Nsir/Dpr RAI Regarding Proposed Emergency Planning Exemption
ML17081A0192017-03-21021 March 2017
NRR E-mail Capture - Fort Calhoun Station - Final RAI Regarding Proposed Emergency Planning Exemption
ML17067A3862017-03-15015 March 2017
Request for Additional Information, Request for Approval of Certified Fuel Handler Training and Retraining Program to Facilitate Activities Associated with Decommissioning and Irradiated Fuel Handling Management
ML17033A9692017-02-0202 February 2017
NRR E-mail Capture - Fort Calhoun Station - Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment
ML16263A0492016-09-20020 September 2016
Request for Additional Information, Request for Approval of Certified Fuel Handler Training and Retraining Program to Facilitate Activities Associated with Decommissioning and Irradiated Fuel Handling Management
ML16174A1502016-06-27027 June 2016
Request for Additional Information, Relief Request, Use of Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1
ML16146A1782016-05-27027 May 2016
Request for Additional Information, Round 2, Request to Revise Current Licensing Basis as Described in the Final Safety Analysis Report to Allow Equipment Classification Methodology from ANSI/ANS-58.14-2011
ML16106A0232016-04-29029 April 2016
Request for Additional Information, Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
ML16104A2872016-04-25025 April 2016
Request for Additional Information, License Amendment Request to Revise Current Licensing Basis to Use American Concrete Institute (Aci) Ultimate Strength Requirements
ML16048A1542016-02-23023 February 2016
Request for Additional Information, License Amendment Request, Revise Current Licensing Basis as Described in the Final Safety Analysis Report to Allow Equipment Classification Methodology from ANSI/ANS-58.14-2011
ML16048A0242016-02-23023 February 2016
Request for Additional Information, License Amendment Request to Adopt Technical Specification Task Force (TSTF)-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control
ML15343A1082015-12-15015 December 2015
Request for Additional Information, License Amendment Request to Make Administrative Changes to the Technical Specifications to Update Titles, Delete Obsolete Actions in Appendix B, and Relocate a Definition
ML15323A0362015-11-24024 November 2015
Request for Additional Information, Relief Requests P-1 - LPSI and CS Pumps and P-2 - Adjusting Hydraulic Parameters Consistent W/Code Case OMN-21, Fifth 10-Year Inservice Testing Interval
ML15194A2722015-07-14014 July 2015
Request for Additional Information, Adopt Emergency Action Level Scheme Pursuant to Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors
ML15057A0152015-03-0303 March 2015
Request for Additional Information, Materials Reliability Program (MRP)-227-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, Implementation Review
ML15043A0612015-02-25025 February 2015
Request for Additional Information, Round 2, License Amendment Request to Revise Updated Safety Analysis Report to Allow Pipe Stress Analysis to Be Performed in Accordance with ASME Code Section III
ML14353A0512014-12-22022 December 2014
Request for Additional Information, Request to Revise Updated Safety Analysis Report, Design and Evaluation of Seismic Class I Structures Using Ascm (Alternate Seismic Criteria and Methodologies) Developed Floor Response Spectra
ML14259A3652014-09-24024 September 2014
Request for Additional Information, License Amendment Request to Revise Updated Safety Analysis Report to Allow Pipe Stress Analysis to Be Performed in Accordance with ASME Code Section III
ML14195A0862014-07-16016 July 2014
Request for Additional Information Associated with Near-Term Task Force Recommendation 2.1, Seismic Hazard and Screening Report
ML13317A5832013-11-25025 November 2013
Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML13304B4182013-11-0101 November 2013
Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns
ML13282A5362013-10-0909 October 2013
Request for Additional Information Email, Round 2, Exemption Request, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage, in Lieu of 10 CFR 26.205(d)(7)
ML13290A0022013-10-0909 October 2013
Request for Additional Information Email, License Amendment Request to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Line Breaks
ML13270A2872013-09-27027 September 2013
Email, Request for Additional Information Round 4 (Apla), Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (2001 Edition)
ML13261A2122013-09-18018 September 2013
Request for Additional Information Email, Exemption Request, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage, in Lieu of 10 CFR 26.205(d)(7)
ML13233A2482013-08-26026 August 2013
Supplemental Information Needed for Acceptance of Requested Licensing Action; Request for Exemption, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage in Lieu of 10 CFR 26.205(d)(7)
ML13235A1682013-08-23023 August 2013
Draft Request for Additional Information Email, Overall Integrated Plan in Response to 3/12/2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)
ML13234A4352013-08-22022 August 2013
Request for Additional Information Email, Round 2, Request to Revise TS 2.0.1, General Requirements, and TS 2.7, Electrical Systems, for Inoperable System, Subsystem. or Component Due to Inoperable Power Source
ML13226A1222013-08-14014 August 2013
Email, Request for Additional Information Round 3 (Apla), Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (2001 Edition)
ML13212A0092013-07-30030 July 2013
Request for Additional Information Email, Request to Revise Technical Specification (TS) 2.0.1, General Requirements, and TS 2.7, Electrical Systems, for Inoperable System, Subsystem, or Component Due to Inoperable Power Source
ML13205A1252013-07-24024 July 2013
Request for Additional Information Email Round 2, Exigent Amendment Request to Revise Current Licensing Basis to Adopt Revised Design Basis/Methodology for Addressing Design-Basis Tornado/Tornado Missile Impact
ML13205A0182013-07-23023 July 2013
Request for Additional Information Email, Exigent License Amendment Request to Revise Current Licensing Basis to Adopt Revised Design Basis/Methodology for Addressing Design-Basis Tornado/Tornado Missile Impact
ML13144A4822013-05-23023 May 2013
Request for Additional Information Email, Decommissioning Funding Status Report
ML13100A1752013-04-10010 April 2013
Request for Additional Information Email, Request for One-Time Exemption from Requirements of 10 CFR 26.205(d)(7) to Allow Less Restrictive Working Hour Limitations to Support Activities for Plant Startup
ML13086A4732013-03-27027 March 2013
Request for Additional Information Email, Request to Revise Technical Specification 2.16, River Level, and Establish EAL Classification Criteria for External Flooding Events Under Radiological Emergency Response Plan
ML13120A0842013-03-22022 March 2013
Request for Additional Information Email Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 20 (TAC No. D91660)
ML13053A2262013-02-22022 February 2013
Email, Second Round Draft Request for Additional Information, Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants.
ML13016A4322013-01-16016 January 2013
E-mail, Request for Additional Information, Round 2, Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (2001 Edition)
2023-06-06
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Text
Fort Calhoun Station, Unit 1 Revised Post-Shutdown Decommissioning Activities Report Review Request for Additional Information
Background
Omaha Public Power District (OPPD) submitted its original Post-Shutdown Decommissioning Activities Report (PSDAR) by letter dated March 30, 2017 (ADAMS Accession No. ML17089A759). NRC staff determined that additional information was needed to complete their review of the original PSDAR and issued a Request for Additional Information (RAI) letter dated October 5, 2017 (ADAMS Accession No. ML17193A263). Specifically, the RAI letter asked for information related to the environmental impact determinations regarding Federally and State-listed Threatened and Endangered Species and Environmental Justice. OPPDs response, dated December 14, 2017 (ADAMS Accession No. ML17348A623), provided adequate response to NRC staff RAIs. By letter dated March 23, 2018 (ADAMS Accession No. ML18011A687), NRC staff determined that OPPD satisfied the requirements of 10 CFR 50.82(a)(4)(i) regarding the environmental impacts associated with site-specific decommissioning activities at Fort Calhoun Station, Unit 1.
The regulation 10 CFR 50.82(a)(7) states, in part, that the licensee shall notify the NRC, in writing and send a copy to the affected State(s), before performing any decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the PSDAR In a letter dated December 16, 2019 (ADAMS Accession No. ML19351E355) OPPD stated that they planned to transition from the SAFSTOR (deferred dismantling) to the DECON (immediate dismantling) method of decommissioning, thus requiring the submittal of a revised PSDAR.
Request for Additional Information The NRC staff has reviewed OPPDs revised PSDAR submittal for transitioning to the DECON method of decommissioning and determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review, requested below:
- 1. Provide a copy of Reference 17 of the revised PSDAR for NRC staff review:
Updated Environmental Report Fort Calhoun Station, File No. 127690-003, dated December 2018.
- 2. Provide a copy of Reference 20 of the revised PSDAR for NRC staff review:
ESI (Environmental Solutions & Innovations, Inc.) - Northern Long-Eared Bat Acoustic and Mist Net Surveys on Fort Calhoun Station in Washington County, Nebraska, dated September 2018.
- 3. In its December 14, 2017, RAI response, OPPD stated that the northern long-eared bat is not present near the site and would, therefore, not be affected by decommissioning.
However, Section 5.1.7, Threatened and Endangered Species, of the revised PSDAR states that federally threatened northern long-eared bats (Myotis septentrionalis) were detected during acoustical and mist net surveys conducted at Fort Calhoun in August 2018.
The revised PSDAR finds that:
[T]he planned decommissioning of FCS will not result in a direct mortality or otherwise jeopardize the local population of any threatened or endangered species.
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Take in any form is strictly prohibited under Section 9 of the Endangered Species Act of 1973, as amended. Take is not limited to direct mortality, but also includes any harassment or harm, among other forms of impacts. Incidental take is take that results from, but is not the purpose of, carrying out an otherwise lawful activity. The revised PSDAR does not fully analyze all forms of take that may occur during decommissioning.
- a. Please more fully explain how decommissioning activities may affect northern long-eared bats in the area by assessing all possible effects and forms of take that may occur during the decommissioning period. For instance, impacts to bats may result from:
- mortality or injury from collisions with plant structures, equipment, or vehicles;
- habitat loss, degradation, disturbance, or fragmentation, and associated effects; and
- behavioral changes resulting from noise, lighting, and other factors associated with decommissioning activities.
The above list is not comprehensive, and other effects may be relevant for the assessment.
- b. If adverse effects or incidental take of northern long-eared bats is possible, please explain how OPPD would obtain the necessary permits under either Endangered Species Act (ESA) Section 7 or ESA Section 10 to exempt such take during the decommissioning period.
- 4. Section 5.1.14 of the revised PSDAR provides an analysis of potential impacts to cultural, historic, and archeological resources. In reviewing this analysis, staff identified two issues of concern related to the protection of historic and cultural resources at FCS that were not identified during the review of the original PSDAR:
- a. OPPDs review of available information identified the presence of remnants from the former town of DeSoto, a historic site potentially eligible for listing in the National Register of Historic Places (NRHP) and located within the lands housing FCS.
However, staff have determined that the DeSoto townsites eligibility as a historic property was characterized inconsistently in the 2003 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437), Supplement 12 Regarding Fort Calhoun Station, and this irregularity was carried forward into the original and revised PSDARs. Specifically, the Nebraska State Historic Preservation Offices records, described in an e-mail dated March 15, 2020 (ADAMS Accession No. ML20100L723), identify that the DeSoto townsite was formally determined eligible for listing on the NRHP in 1989. Accordingly, the revised PSDAR should be revised or supplemented to reflect the townsites correct NRHP eligibility status.
- b. The consideration of nuclear power plants for inclusion in the NRHP or Historic American Engineering Record (HAER) increases as the age of the nuclear power plant approaches or exceeds 50 years of age - one of the criterion for inclusion on the register/record. The decision on whether a nuclear power plant can be considered a historic property and eligible for inclusion is determined by each state historic preservation officer (SHPO). OPPD did not indicate in the revised PSDAR whether they have considered the eligibility of the FCS nuclear facility itself for 2
inclusion on the register or record. There is also no indication that OPPD had contacted the Nebraska SHPO regarding this matter.
Section 4.3.14.2 of NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, (page 4-67) states:
In a few situations, the nuclear facility itself could be potentially eligible for inclusion in the National Register of Historic Places, especially if it is older than 50 years and represents a significant historic or engineering achievement. In this case, appropriate mitigation would be developed in consultation with the SHPO [State Historic Preservation Officer]. Even for buildings that are less than 50 years old, the processes and engineering that were employed may be of interest and may be eligible for the Historic American Engineering Record.
In order to remain in compliance with the National Historic Preservation Act, the NRC is required to take into account the effects of its undertakings on historic properties (see Protection of Historic Properties regulations, 36 CFR 800). Under these regulations, the NRC staffs review of the PSDAR may be considered an undertaking (see 36 CFR 800.16(y)).
According to Protection of Historic Properties regulations in 36 CFR 800.4(a)(2),
Identification of historic properties, in consultation with the SHPO, the NRC is required to Review existing information on historic properties within the area of potential effects, including any data concerning possible historic properties not yet identified. In addition, according to 36 CFR 800.4(a)(3), the NRC must Seek information, as appropriate, from consulting parties, and other individuals and organizations likely to have knowledge of, or concerns with, historic properties in the area, and identify issues relating to the undertaking's potential effects on historic properties.
Regulations in 36 CFR 800.4(c)(1) state:
In consultation with the SHPOthe agency official shall apply the National Register criteria (36 CFR part 63) to properties identified within the area of potential effects that have not been previously evaluated for National Register eligibility.
If requested by the Nebraska SHPO, an eligibility determination for NRHP listing status would need to be conducted by a professional that meets the Secretary of the Interiors standards in 36 CFR 61. A professional, experienced in conducting Historic American Building Surveys, would also be needed to determine the eligibility of listing FCS in the Historic American Engineering Record.
In light of these considerations, does OPPD plan to determine, in consultation with the Nebraska SHPO, the eligibility of the FCS facility itself for inclusion in the National Register of Historic Places or Historic American Engineering Record, and, if required, identify appropriate mitigation measures (e.g., preservation of historic information and data) potentially resulting from this consultation?
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