ML20170A445

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Independent Spent Fuel Storage Installation Updated Decommissioning Safety Analysis Report, DSAR-15.4, Rev. 0, License Renewal Supplement License Renewal Commitment Listing
ML20170A445
Person / Time
Site: Fort Calhoun, 07100256  Omaha Public Power District icon.png
Issue date: 04/30/2020
From:
Omaha Public Power District
To:
Office of Nuclear Reactor Regulation, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20170A380 List: ... further results
References
LIC-20-0005
Download: ML20170A445 (9)
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Page 1 of 9 DSAR-15.4 License Renewal Supplement License Renewal Commitment Listing Rev 0 Safety Classification: Usage Level:

Safety Information Change No.: EC 69283 Reason for Change: This section is being updated to reflect the permanent cessation of operations of Fort Calhoun Station. The contents of this section have been changed to remove any information which is not applicable during decommissioning.

Preparer: Kristen Jacobsen Fort Calhoun Station

DSAR-15.4 Information Use Page 2 of 9 License Renewal Commitment Listing Rev. 0 Table of Contents 15.4 License Renewal Commitment Listing .................................................................... 3

DSAR-15.4 Information Use Page 3 of 9 License Renewal Commitment Listing Rev. 0 15.4 License Renewal Commitment Listing During the review of the FCS License Renewal Application by the NRC staff, OPPD made commitments to provide aging management programs to manage aging effects of structures and components prior to the period of extended operation, as well as other information. The following table lists these commitments, along with the implementation schedule and the source of the commitment.

ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE Diesel Fuel Monitoring and Storage Program 12 New fuel additions to the fire protection Ongoing AR 29458 LRA Section B.2.3 diesel fuel oil tank will be analyzed for water tasks 01 and responses to and sediment, and this water and sediment RAI B.2.3-1 will be removed, to preclude water contamination, and the tank bottom will be monitored to ensure water or biological activity is not accumulating. UT and/or visual inspections will be performed in the other storage tanks which credit this program for aging management. The low point beyond the main tank is the bottom of the day tank, and a day tank sample will be drawn from the bottom of the tank and analyzed for water and sediment.

13 The fire protection day tank will be analyzed Tank analysis - Response to quarterly for water and sediment and semi- ongoing AR 29458 RAI B.2.3-2 annually for microbiological activity. task 24.

DSAR-15.4 Information Use Page 4 of 9 License Renewal Commitment Listing Rev. 0 ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE Fire Protection Program 14 Additional guidance will be added to the Ongoing AR 29606 LRA Section B.2.5 diesel fire pump maintenance procedure to tasks 06 and 15 inspect the diesel fire pump fuel line and zinc plug for corrosion or mechanical damage.

Specific guidance will be added to the halon and fire damper inspection procedures to AR 29606 tasks 07, inspect halon system components and fire 12, 13, and 16 dampers for corrosion, and mechanical and physical damage.

Specific acceptance criteria will be added to the fire barrier inspection procedures for AR 29606 task 02 concrete walls, floors, and ceilings.

Specific guidance will be added to the fire door inspection procedure to inspect for AR 29606 tasks 04, wear and missing parts. 11, and 36 Specific guidance will be developed to AR 29606 task 08 replace or inspect in-scope sprinkler heads in accordance with NFPA-25.

Additional guidance will be added to one of AR 29606 tasks 14 the system valve cycling tests to improve and 23 system flushing.

Specific guidance will be developed for flow testing the in-scope sprinkler system. AR 29606 task 38 15 Enhancements will be made to the Fire Ongoing AR 29606 Response to Protection Program prior to the period of task 37 RAI B.2.5-2 extended operation to implement the requirements of the interim staff guidance (on wall thinning of piping due to corrosion).

DSAR-15.4 Information Use Page 5 of 9 License Renewal Commitment Listing Rev. 0 ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE Deleted Buried Piping and Components Program 19 As identified in the FCS License Renewal Ongoing Response to Application, the Buried Surfaces External RAI B.3.2-1 Corrosion Program is a new program that will be implemented at FCS prior to the period of extended operation. The new program will include the following items to make it consistent with GALL XI.M34, "Buried Piping and Tanks Inspection" criteria:

  • A revision has been completed to the AR 29559 task 06 FCS maintenance control procedure to require engineering evaluation of concrete, piping, and piping coatings whenever excavations are performed.
  • Current routine inspections of diesel fuel AR 29559 tasks 02, oil tanks within the scope of license 05, and 07 renewal will be annotated as commitments required to meet license renewal requirements.
  • A program basis document will be AR 29559 task 08 developed which will define the program requirements and compile industry and FCS operating experience related to buried components.

General Corrosion of External Surfaces Program 20 Procedures will be revised to include Ongoing AR 29561 Response to acceptance criteria that a visual indication tasks 03, 04, and 08 RAI B.3.3-5 of loss of material or cracking of elastomer ventilation components identified by the accountable Operator or Engineer will not necessarily lead to an unacceptable component.

DSAR-15.4 Information Use Page 6 of 9 License Renewal Commitment Listing Rev. 0 ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE Boric Acid Corrosion Prevention Program 21 Specific guidance will be added to the Ongoing AR 29657 LRA Section B.2.1 program basis document and applicable task 06 procedures to inspect components, structures, and electrical components where boric acid may have leaked.

Add Spent Fuel Pool Cooling and Waste AR 29657 tasks 05 Disposal Systems to the program. Two and 09 areas not routinely inspected will be added to inspection scope.

Specific guidance will be implemented for AR 29657 task 08 maintenance personnel to report boric acid leakage to the BAC Program Engineer.

Service Water Reliability Program 22 Inspections to various raw water and Ongoing AR 29443 LRA Section B.2.2 cooling water components will be added tasks 01 through 30 based on FCS Service Water Reliability Program susceptibility evaluation. These inspection activities will be commensurate with the GALL Program.

Overhead Loads and Handling Equipment Program 28 Specific guidance will be added to Ongoing AR 30174 LRA Section B.2.6 applicable inspection procedures to inspect task 02 for degradation of expansion anchors and surrounding concrete.

Specific guidance will be added to applicable inspection procedures to identify acceptance criteria for general corrosion and degradation of expansion anchors and surrounding concrete.

Specific guidance will be added to applicable inspection procedures to initiate FCS corrective action documentation if excessive general corrosion or cracking of concrete around expansion anchors is identified.

DSAR-15.4 Information Use Page 7 of 9 License Renewal Commitment Listing Rev. 0 ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE 30 A periodic task will be initiated as part of the Ongoing AR 29462 Response to structures monitoring program to take task 11 RAI 3.5.1-8 ground water samples on a five year frequency and compare the evaluation results to previous samples.

31 OPPD will inspect the circulating water Ongoing AR 29462 Response to discharge tunnel every 3rd refueling outage task 18 POI-3(a) and (commitment changed, reference OPPD POI-2.3.3.15-1 letter, LIC-12-0172, dated December 13, 2012) (AR 58218) per the structures monitoring program (B.2.10). The circulating water discharge tunnel will be included within the scope of license renewal as part of the intake structure.

32 The following FCS-specific tasks will be LRA Section added to the SMP: B.2.10 Ongoing AR 29462 Performance of periodic sampling and task 11 evaluation of ground water.

Guidance to inspect structural components AR 29462 task 13 when exposed by excavation.

XI.S5 Specific guidance will be added to inspect AR 29462 tasks 01, masonry walls for cracking and condition of 02, 03, 04 steel bracing.

Specific acceptance criteria will be added to inspection procedures to be commensurate with industry codes, standards, and guidelines.

XI.S6 Specific guidance will be added for AR 29462 task 08 inspection of component supports and the plant-specific components identified in the LRA Section 3 tables. Aging management activities related to these components will be commensurate with industry standards and practices as identified in the NUREG-1801 Structures Monitoring Program criteria.

Additional guidance commensurate with industry codes, standards, and guidelines, will be added to inspection procedures.

DSAR-15.4 Information Use Page 8 of 9 License Renewal Commitment Listing Rev. 0 ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE 32 Specific acceptance criteria will be added to Ongoing AR 29462 LRA the inspection procedures to be tasks 01, 02, 03, and Section B.2.10 commensurate with industry codes, 04 standards, and guidelines.

XI.S7 Additional guidance will be added to the inspection procedure to identify specific parameters to inspect.

Additional guidance will be added to review maintenance activities since last inspection.

Specific acceptance criteria will be added to the inspection procedures to be commensurate with industry codes, standards, and guidelines.

Selective Leaching Program 33 Develop the selective leaching program Ongoing AR 30149 LRA Section B.3.6, which reflects the program elements of task 01 as reflected in the GALL AMP XI.M33, as clarified in LRA RAI responses, Section B.3.6, and other commitments in and POI response to the NRC staff's review, as responses documented in the responses to staff RAIs and potential open items (POIs)

Cables and Connections Program 35 For non-EQ cables and connections within Ongoing AR 44464 LRA Section B.3.4 the scope of license renewal and subject to task 01 and responses to an aging management review: RAI B.3.4-1 OPPD will implement a program and inspection consistent with that described in XI.E1 of the GALL Report (Rev. 0).

OPPD will implement a program and inspection consistent with that described in XI.E2 of the GALL Report (Rev. 0).

OPPD will implement a program and inspection consistent with that described in XI.E3 of the GALL (Rev. 0).

DSAR-15.4 Information Use Page 9 of 9 License Renewal Commitment Listing Rev. 0 ITEM IMPLEMENTATION COMMITMENT SOURCE NUMBER SCHEDULE Periodic Surveillance and Preventative Maintenance Program 36 The aging effects of hardening and loss of Ongoing AR 29894 Response to strength for elastomers are not included in task 27 RAI 3.3.1-1 the general corrosion of external surfaces program (B.3.3). Enhancements will be made to add these AERMs to preventive maintenance tasks under the PS/PMP (B.2.7) to specifically perform hands on type inspections of elastomer expansion joints, seals, and vibration isolators within the scope of license renewal for hardening and loss of strength. Applicable PMs are performed every 18 months.

38 For commitments listed in the Safety Complete Response to Evaluation Report, OPPD will include this POI-13(j) list of commitments in an appropriate subsection of the FCS DSAR Supplement for License Renewal 41 OPPD will manage the aging of fuse Ongoing AR 36248 Response to Open holders in accordance with ISG-5 task 01 Item 3.6.2.4.5.2-1

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