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Page 1 of 15 DSAR-Appendix G Responses to 70 Criteria Rev 3 Safety Classification: Usage Level:
Safety Information FCS DESIGN CRITERIA*
In accordance with LIC 16-0074 Fort Calhoun Station (FCS) has been permanently defueled and is no longer in operation. Many of the original 70 draft General Design Criteria (GDC) published for comment in the Federal Register (32 FR 10213) on July 11, 1967 are no longer applicable. The remaining, applicable criteria are contained in Appendix G of the DSAR. Changes to Appendix G of the DSAR must comply with 10 CFR 50.59 and may require NRC approval (i.e., an NRC approved License Amendment).
Appendix G of the DSAR must be revised if NRC approval to supersede or modify the draft GDC and/or method of compliance with the draft GDC is obtained. Procedure NOD-QP-16, Updated Safety Analysis Report, should be consulted prior to revising Appendix G as it contains additional guidance.
Change No.: EC 70007 Reason for Change: Remove waste gas reference Preparer: T. Rice Fort Calhoun Station
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Table of Contents CRITERION 1 - QUALITY STANDARDS ................................................................................ 3 CRITERION 2 - PERFORMANCE STANDARDS .................................................................... 4 CRITERION 3 - FIRE PROTECTION ...................................................................................... 5 CRITERION 5 - RECORDS REQUIREMENT ......................................................................... 6 CRITERION 11 - CONTROL ROOM ....................................................................................... 7 CRITERION 12 - INSTRUMENTATION AND CONTROL SYSTEMS ..................................... 8 CRITERION 17 - MONITORING RADIOACTIVITY RELEASES ............................................. 9 CRITERION 18 - MONITORING FUEL AND WASTE STORAGE......................................... 10 CRITERION 66 - PREVENTION OF FUEL STORAGE CRITICALITY .................................. 11 CRITERION 67 - FUEL AND WASTE STORAGE DECAY HEAT ......................................... 12 CRITERION 68 - FUEL AND WASTE STORAGE RADIATION SHIELDING ........................ 13 CRITERION 69 - PROTECTION AGAINST RADIOACTIVITY RELEASE FROM SPENT FUEL AND WASTE STORAGE............................................................................................. 14 CRITERION 70 - CONTROL OF RELEASE OF RADIOACTIVITY TO THE ENVIRONMENT
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CRITERION 1 - QUALITY STANDARDS Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be identified and then designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed. Where generally recognized codes or standards on design, materials, fabrication, and inspection are used, they shall be identified. Where adherence to such codes or standards does not suffice to assure a quality product in keeping with the safety function, they shall be supplemented or modified as necessary. Quality assurance programs, test procedures, and inspection acceptance levels to be used shall be identified. A showing of sufficiency and applicability of codes, standards, quality assurance programs, test procedures, and inspection acceptance levels used is required.
This criterion is met. Systems are designed and fabricated in accordance with established codes and/or standards as required to assure that their quality is in keeping with the safety function of the component.
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CRITERION 2 - PERFORMANCE STANDARDS Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect public health and safety or to mitigation of their consequences shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice and other local site effects. The design bases so established shall reflect: (a) Appropriate consideration for the most severe of these natural phenomena that have been recorded for the site and the surrounding area and (b) an appropriate margin for withstanding forces greater than those recorded to reflect uncertainties about the historical data and their suitability as a basis for design.
This criterion is met. The systems and components of the Fort Calhoun Station, Unit No. 1 reactor facility that are essential to the prevention or mitigation of accidents that could affect public health and safety are designed, fabricated, and erected to withstand without loss of capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, floods, winds, ice and other local site effects.
Under each of these conditions, stresses in the structural members will not exceed 0.95 yield.
The facility is designed so that the plant can be safely maintained in a safe defueled condition during a tornado. Design considerations associated with tornadoes are further explained in Section 5.11.3 of the DSAR.
Flooding of Fort Calhoun Station, Unit No. 1 is considered highly unlikely. Further information is available in DSAR Section 2.7.1.2.
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CRITERION 3 - FIRE PROTECTION The reactor facility shall be designed (1) to minimize the probability of events such as fires and explosions and (2) to minimize the potential effects of such events to safety.
Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, control room and components of engineered safety features.
This criterion is met (1). The reactor facility is designed to minimize the probability of such events as fires and explosions and to minimize potential effects of such events to safety.
Noncombustible fire resistant materials are used whenever practical throughout the facility.
The facility is provided with a fire protection system which includes detectors, alarms, water supply, fire suppression systems, hose lines and portable extinguishers. Fort Calhoun Station has transitioned into compliance with 10CFR 50.48(f).
For further information the fire protection system is described in DSAR Section 9.11.
1 Amendment No. 290 dated April 17, 2017.
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CRITERION 5 - RECORDS REQUIREMENT Records of the design, fabrication, and construction of essential components of the plant shall be maintained by the reactor operator or under its control throughout the life of the reactor.
This criterion is met. The Omaha Public Power District is the owner and operator of Fort Calhoun Station, Unit No. 1. The Omaha Public Power District will maintain records of the design, fabrication, and construction of essential components of Fort Calhoun Station.
Due to Decommissioning OPPD has sought and received an exemption to records retention as follows:
The Commission hereby grants OPPD's partial exemptions from 10 CFR part 50, appendix B, Criterion XVII; 10 CFR 50.59(d)(3); and 10 CFR 50.71(c) to advance the schedule to remove records associated with SSCs that have been removed from the NRC's licensing basis documents by appropriate change mechanisms.
Records associated with residual radiological activity and with programmatic controls necessary to support decommissioning, such as security and quality assurance, are not affected by the exemption request because they will be retained as decommissioning records until the termination of the FCS license. Also, the licensee did not request an exemption associated with any other record keeping requirements for the storage of spent fuel at its ISFSI under 10 CFR part 50 or the general license requirements of 10 CFR part 72. No exemption was requested from the decommissioning records retention requirements of 10 CFR 50.75, or any other requirements of 10 CFR part 50 applicable to decommissioning and dismantlement.
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CRITERION 11 - CONTROL ROOM
[The facility shall be provided with a control room from which actions to maintain safe operational status of the plant can be controlled. Adequate radiation protection shall be provided to permit access, even under accident conditions, to equipment in the control room or other areas as necessary to shutdown and maintain safe control of the facility without radiation exposures of personnel in excess of 10 CFR 20 limits. It shall be possible to shut the reactor down and maintain it in a safe condition if access to the control room is lost due to fire or other cause.](1)
This criterion is met. Fort Calhoun Station, Unit No.1 is equipped with a control room located in the reactor auxiliary building which is a Class I structure.
The control room is designed to permit the necessary access and occupancy of the control room to allow termination of accidents and resulting consequences.
(1)
Amendment No. 201 implemented on 1/25/2002 allowed the accident source term used in the design basis radiological analyses for control room habitability to be replaced with an alternative source term (AST) pursuant to 10 CFR 50.67, "Accident Source Term".
Holders of operating licenses using an alternative source term under § 50.67, shall meet the requirements of 10 CFR 50, Appendix A, General Design Criteria (GDC) 19, except that with regard to control room access and occupancy, adequate radiation protection shall be provided to ensure that radiation exposures shall not exceed 0.05 Sv (5 Rem) total effective dose equivalent (TEDE) as defined in
§ 50.2 for the duration of the accident.
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CRITERION 12 - INSTRUMENTATION AND CONTROL SYSTEMS Instrumentation and controls shall be provided as required to monitor and maintain variables within prescribed operating ranges.
This criterion is met. Instrumentation is provided for continuous measurement of all significant process variables. Controls are provided for the purpose of maintaining these variables within the limits prescribed for safe operation. The instrumentation conforms to applicable Institute of Electrical and Electronics Engineers (IEEE) standards.
The principal process variables monitored include instrumentation for continuous automatic monitoring of radiation level.
The instrumentation and control systems are described in detail in DSAR Section 7.
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CRITERION 17 - MONITORING RADIOACTIVITY RELEASES Means shall be provided for monitoring the containment atmosphere, the facility effluent discharge paths, and the facility environs for radioactivity that could be released from normal operations, from anticipated transients and from accident conditions.
This criterion is met.
Plant gaseous effluents are vented to the atmosphere through the ventilation discharge duct.
A gas monitor is installed in the duct in order to view the largest available gas volume and thus attain required sensitivity. Particulate monitoring of gaseous effluent is accomplished by 2 fixed filter air samplers located at ground level.
Plant liquid effluents are monitored just downstream of the monitor tanks and upstream of the automatic isolation valve in the auxiliary building to ensure adequate sensitivity.
The above monitors are capable of detecting radioactivity released from normal operations, from anticipated transients and from accident conditions.
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CRITERION 18 - MONITORING FUEL AND WASTE STORAGE Monitoring and alarm instrumentation shall be provided for fuel and waste storage and handling areas for conditions that might contribute to loss of continuity in decay heat removal and to radiation exposures.
This criterion is met. Continuous decay heat removal is assured by monitoring of the water temperature in the spent fuel pool. Any deviation will be alarmed in the control room. Area monitoring of dose rates is supplied in the fuel and waste storage areas. A panel in the control room contains an indicator and alarm for each channel, plus power supplies and a multipoint recorder. Local alarms and indicators are provided at each monitor.
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CRITERION 66 - PREVENTION OF FUEL STORAGE CRITICALITY Criticality in new and spent fuel storage shall be prevented by physical systems or processes.
Such means as geometrically safe configurations shall be emphasized over procedural controls.
This criterion is met. The criteria for the design of the spent fuel storage racks is that the k eff of the fuel array shall remain less than or equal to 0.95 at a 95 percent probability and 95 percent confidence level during normal use and in the event of postulated accidents or mishandling (1), (2), (4)
The safe geometry criteria are established as follows:
a) The receptacles or cavities containing the new or spent fuel assemblies will be arranged vertically in a square lattice. The dimensions of the spent fuel storage rack will be such that the clear space between adjacent receptacles will be sufficient to yield a k eff less than or equal to 0.95 with unborated water (3) b) The insertion of a spent fuel assembly into any part of the water slab between receptacles is prevented by the top frame of the spent fuel rack. The openings in the top frame at each side of a receptacle are not large enough to receive a fuel element.
c) The vertical dimensions of the storage rack will be such that the top of the active fuel portion of the fuel assembly will be a sufficient distance below the top frame to assure that the keff is less than or equal to 0.95 even with a fresh fuel assembly located at the level of the top frame.
d) Distortion of the spent fuel rack structure due to seismic loading shall be prevented by the use of lateral bracing so that there will be no reduction of the water slab between the cavities.
The spent fuel storage racks are further described in DSAR Section 9.5.3.2.
(1)
Amendment No. 236 (2) 63 FR 63130, November 12, 1998 (3)
Amendment No. 240 (4) EA96-01 Rev. 001
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CRITERION 67 - FUEL AND WASTE STORAGE DECAY HEAT Reliable decay heat removal systems shall be designed to prevent damage to the fuel in storage facilities that could result in radioactivity release to plant operating areas or the public environs.
This criterion is met. The fuel pool cooling system removes decay heat from the fuel stored in the spent fuel pool. The system can remove decay heat from a full core discharged from the reactor 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown from a power level of 1500 MWt, while maintaining the pool water temperature below 140°F. The pool has the capability to accommodate 1083 unconsolidated fuel assemblies while the reactor is unloaded.
The cooling system consists of two full capacity pumps, a full capacity heat exchanger, a filter and a demineralizer. The filter and demineralizer maintain the clarity and purity of the water.
Blanked off connections are provided for temporary tie-in to the shutdown cooling system to provide a backup for the fuel pool heat exchanger.
Piping is arranged so that the pool cannot be accidentally drained.
The system will be tested with regard to flow paths, flow capacity, heat transfer capability and mechanical operability prior to initial fuel loading.
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CRITERION 68 - FUEL AND WASTE STORAGE RADIATION SHIELDING Shielding for radiation protection shall be provided in the design of spent fuel and waste storage facilities as required to meet the requirements of 10 CFR 20.
This criterion is met. The fuel storage pool is constructed of reinforced concrete and lined with stainless steel. The fuel storage pool is filled with borated water, which provides a transparent radiation shield and a cooling medium for removal of decay heat.
In the spent pool, a water level is maintained to provide at least 10 feet of water shielding over the top of the fuel. This water will provide sufficient shielding to permit normal occupancy of the area by operating personnel.
The liquid waste disposal containers are built of carbon steel in accordance with ASME Code Section III. The tank lining is hole-free, continuous, and of uniform thickness. The tanks are located in the reactor auxiliary building (a Class I structure) in shielded compartments.
Solid wastes are collected and placed in drums, metal boxes or sea land containers and may be stored in a shielded area if radioactivity levels are high. Spent resins are placed in a shipping container and stored in a shielded area.
The shielding for radiation protection meets the requirements of 10 CFR 20 for all fuel and waste storage areas.
The original steam generator storage facility (OSGSF) meets the radiation protection requirements of 10 CFR 20 for fuel and waste storage areas. See DSAR section 11.2.4.1
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CRITERION 69 - PROTECTION AGAINST RADIOACTIVITY RELEASE FROM SPENT FUEL AND WASTE STORAGE Containment of fuel and waste storage shall be provided if accidents could lead to release of undue amounts of radioactivity to the public environs.
This criterion is met. The spent fuel pool and waste handling facilities are located in the auxiliary building (a Class 1 structure). These areas provide confinement capability in the event of accidental release of radioactive materials and are ventilated with dilution air for discharge to the ventilation discharge duct. The liquid waste hold-up tanks are each located in separate compartments. Each compartment is provided with a floor drain which drains into an auxiliary building sump and is then pumped to the spent regenerant tanks in the auxiliary building.
Other areas where spent fuel and waste are stored include the independent spent fuel storage installation (ISFSI), which is located at the north end of the protected area and the original steam generator storage facility OSGSF) located west of the rail spur near the access road.
In the ISFISI, spent fuel is stored in stainless steel dry shielded canisters (DSCs) placed inside a massive reinforced concrete horizontal storage module (HSM). This design provides a confinement boundary to prevent release of radioactivity to the atmosphere and ensures that doses at the boundary of the owner-controlled area are within the limits established in 10 CFR 72.104 (normal conditions) and 10 CFR 72.106 (accident conditions).
The OSGSF meets the radiation protection requirements of 10 CFR 20 for fuel and waste storage areas. See DSAR Section 11.2.4.1 The Radioactive Waste Processing Building (RWPB) is designed for packaging, solidification and storage of low-level radioactive wastes. See DSAR Section 11.2.4.1
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CRITERION 70 - CONTROL OF RELEASE OF RADIOACTIVITY TO THE ENVIRONMENT The facility design shall include those means necessary to maintain control over the plant radioactive effluents, whether gaseous, liquid, or solid. Appropriate holdup capacity shall be provided for retention of gaseous, liquid, or solid effluents, particularly where unfavorable environmental conditions can be expected to require operational limitations upon the release of radioactive effluents to the environment. In all cases the design for radioactivity control shall be justified (a) on the basis of 10 CFR 20 requirements for normal operations and for any transient situation that might reasonably be anticipated to occur and (b) on the basis of 10 CFR 100(6) dosage level guidelines for potential reactor accidents of exceedingly low probability of occurrence except that reduction of the recommended dosage levels may be required where high population densities or very large cities can be affected by the radioactive effluents.
This criterion is met. The radioactive waste system is designed to limit to acceptable levels the potential release to the environs from radionuclides generated or assembled as a consequence of normal plant operations or emergency conditions, even under unfavorable environmental situations.
The liquid wastes are collected, treated (filtration or demineralization) as appropriate, and analyzed prior to release. A radiation monitor, recorder-controller monitors all liquid discharges from the radioactive waste disposal and control system. An automatic shut-off valve in the discharge line closes if control values are exceeded. The effluent discharge, when diluted, will not exceed requirements of 10 CFR 20.
Space for storage of the solid wastes is provided so that packaging, handling and shipping can be carried out under favorable environmental conditions. All solid waste will be monitored, labeled, packaged and handled according to applicable regulations.
Gaseous wastes are no longer stored. All waste gas collected by the vent header are vented and monitored prior to being released through the Auxiliary Building Stack.
(6)
Amendment No. 201 requires compliance with 10 CFR 50.67 in lieu of 10 CFR 100.