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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 NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Diesel Fuel Monitoring and Storage Program 12 New fuel additions to the fire protection diesel fuel oil tank will be analyzed for water and sediment, and this water and sediment 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.
Ongoing AR 29458 tasks 01 LRA Section B.2.3 and responses to RAI B.2.3-1 13 The fire protection day tank will be analyzed quarterly for water and sediment and semi-annually for microbiological activity.
Tank analysis -
ongoing AR 29458 task 24.
Response to RAI B.2.3-2
DSAR-15.4 Information Use Page 4 of 9 License Renewal Commitment Listing Rev. 0 ITEM NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Fire Protection Program 14 Additional guidance will be added to the diesel fire pump maintenance procedure to 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 inspect halon system components and fire dampers for corrosion, and mechanical and physical damage.
Specific acceptance criteria will be added to the fire barrier inspection procedures for concrete walls, floors, and ceilings.
Specific guidance will be added to the fire door inspection procedure to inspect for wear and missing parts.
Specific guidance will be developed to replace or inspect in-scope sprinkler heads in accordance with NFPA-25.
Additional guidance will be added to one of the system valve cycling tests to improve system flushing.
Specific guidance will be developed for flow testing the in-scope sprinkler system.
Ongoing AR 29606 tasks 06 and 15 AR 29606 tasks 07, 12, 13, and 16 AR 29606 task 02 AR 29606 tasks 04, 11, and 36 AR 29606 task 08 AR 29606 tasks 14 and 23 AR 29606 task 38 LRA Section B.2.5 15 Enhancements will be made to the Fire Protection Program prior to the period of extended operation to implement the requirements of the interim staff guidance (on wall thinning of piping due to corrosion).
Ongoing AR 29606 task 37 Response to RAI B.2.5-2
DSAR-15.4 Information Use Page 5 of 9 License Renewal Commitment Listing Rev. 0 ITEM NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Deleted Buried Piping and Components Program 19 As identified in the FCS License Renewal Application, the Buried Surfaces External 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 FCS maintenance control procedure to require engineering evaluation of concrete, piping, and piping coatings whenever excavations are performed.
Current routine inspections of diesel fuel oil tanks within the scope of license renewal will be annotated as commitments required to meet license renewal requirements.
A program basis document will be developed which will define the program requirements and compile industry and FCS operating experience related to buried components.
Ongoing AR 29559 task 06 AR 29559 tasks 02, 05, and 07 AR 29559 task 08 Response to RAI B.3.2-1 General Corrosion of External Surfaces Program 20 Procedures will be revised to include acceptance criteria that a visual indication 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.
Ongoing AR 29561 tasks 03, 04, and 08 Response to RAI B.3.3-5
DSAR-15.4 Information Use Page 6 of 9 License Renewal Commitment Listing Rev. 0 ITEM NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Boric Acid Corrosion Prevention Program 21 Specific guidance will be added to the program basis document and applicable procedures to inspect components, structures, and electrical components where boric acid may have leaked.
Add Spent Fuel Pool Cooling and Waste Disposal Systems to the program. Two areas not routinely inspected will be added to inspection scope.
Specific guidance will be implemented for maintenance personnel to report boric acid leakage to the BAC Program Engineer.
Ongoing AR 29657 task 06 AR 29657 tasks 05 and 09 AR 29657 task 08 LRA Section B.2.1 Service Water Reliability Program 22 Inspections to various raw water and cooling water components will be added based on FCS Service Water Reliability Program susceptibility evaluation. These inspection activities will be commensurate with the GALL Program.
Ongoing AR 29443 tasks 01 through 30 LRA Section B.2.2 Overhead Loads and Handling Equipment Program 28 Specific guidance will be added to applicable inspection procedures to inspect 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.
Ongoing AR 30174 task 02 LRA Section B.2.6
DSAR-15.4 Information Use Page 7 of 9 License Renewal Commitment Listing Rev. 0 ITEM NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 30 A periodic task will be initiated as part of the structures monitoring program to take ground water samples on a five year frequency and compare the evaluation results to previous samples.
Ongoing AR 29462 task 11 Response to RAI 3.5.1-8 31 OPPD will inspect the circulating water discharge tunnel every 3rd refueling outage (commitment changed, reference OPPD 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.
Ongoing AR 29462 task 18 Response to POI-3(a) and POI-2.3.3.15-1 32 The following FCS-specific tasks will be added to the SMP:
Performance of periodic sampling and evaluation of ground water.
Guidance to inspect structural components when exposed by excavation.
XI.S5 Specific guidance will be added to inspect masonry walls for cracking and condition of 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 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.
Ongoing AR 29462 task 11 AR 29462 task 13 AR 29462 tasks 01, 02, 03, 04 AR 29462 task 08 LRA Section B.2.10
DSAR-15.4 Information Use Page 8 of 9 License Renewal Commitment Listing Rev. 0 ITEM NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 32 Specific acceptance criteria will be added to the inspection procedures to be commensurate with industry codes, 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.
Ongoing AR 29462 tasks 01, 02, 03, and 04 LRA Section B.2.10 Selective Leaching Program 33 Develop the selective leaching program which reflects the program elements of GALL AMP XI.M33, as clarified in LRA Section B.3.6, and other commitments in response to the NRC staff's review, as documented in the responses to staff RAIs and potential open items (POIs)
Ongoing AR 30149 task 01 LRA Section B.3.6, as reflected in the RAI responses, and POI responses Cables and Connections Program 35 For non-EQ cables and connections within the scope of license renewal and subject to an aging management review:
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).
Ongoing AR 44464 task 01 LRA Section B.3.4 and responses to RAI B.3.4-1
DSAR-15.4 Information Use Page 9 of 9 License Renewal Commitment Listing Rev. 0 ITEM NUMBER COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Periodic Surveillance and Preventative Maintenance Program 36 The aging effects of hardening and loss of strength for elastomers are not included in 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.
Ongoing AR 29894 task 27 Response to RAI 3.3.1-1 38 For commitments listed in the Safety Evaluation Report, OPPD will include this list of commitments in an appropriate subsection of the FCS DSAR Supplement for License Renewal Complete Response to POI-13(j) 41 OPPD will manage the aging of fuse holders in accordance with ISG-5 Ongoing AR 36248 task 01 Response to Open Item 3.6.2.4.5.2-1