ML21350A026

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Acceptance Review of License Amend Req. to Add License Condition to Include License Termination Plan Requirements, Req. for Supplemental Info
ML21350A026
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 12/16/2021
From: Jack Parrott
Reactor Decommissioning Branch
To: Via T
Omaha Public Power District
Parrott J
References
EPID L-2021-LIT-0000
Download: ML21350A026 (4)


Text

December 16, 2021 Mr. Troy Via, Chief Operation Officer and Vice President Utility Operations Omaha Public Power District Fort Calhoun Station Mail Stop FC-2-4 9610 Power Lane Blair, NE 68008

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 - ACCEPTANCE REVIEW OF LICENSE AMENDMENT REQUEST TO ADD LICENSE CONDITION TO INCLUDE LICENSE TERMINATION PLAN REQUIREMENTS - REQUEST FOR SUPPLEMENTAL INFORMATION (EPID L-2021-LIT-0000)

Dear Mr. Via:

By letter dated August 3, 2021, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21271A178) Omaha Public Power District submitted a license amendment request for Fort Calhoun Station, Unit No. 1 (FCS). The proposed amendment would add License Condition 3.D to include License Termination Plan (LTP) requirements.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements.

The NRC staff has reviewed your application and concluded that it did not provide technical information in sufficient detail to enable the staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements for the protection of public health and safety and the environment. This informational need was conveyed to your staff during the periodic licensing call on December 9, 2021. In that call, the NRC staff identified that the following information was needed to begin its technical review:

1. Document Request - LTP Chapter 6, Reference 1 Chapter 6, Reference 1 is cited as the source of summary information in the LTP for numerical modeling intended to provide support for concentration results from RESRAD-ONSITE for the Basement Fill Model. However, Reference 1 of Chapter 6 -

Haley & Aldrich, "Hydrogeological Conceptual Site Model, Revision 4, Fort Calhoun Station, Blair, NE," 2021, was not a document included in the LTP submittal. Revision 2 of Reference 1 is specifically listed in the text of early parts of Chapter 6 and was

T. Via 2 included in the LTP submittal. Revision 2 contains a brief description of the conceptual site model along with summaries and data from field tests but does not contain any information on the numerical modeling performed using the interface, Groundwater Vistas, for MODFLOW, MODPATH, and MT3DMS. A more complete description of the numerical modeling than provided in the LTP is needed for NRC staff to better understand the bounds and bases of the RESRAD-ONSITE results for the Basement Fill Model.

2. Document Request - LTP Chapter 6, Reference 6 Multiple similarly titled reports on radionuclides of concern are cited in the LTP, with an explanation provided on pages 6-9. Some of these documents were also cited in Chapters 2 and 5. Chapter 6 Reference 6, Omaha Public Power District, "FC-18-002, Potential Radionuclides of Concern During the Decommissioning of Fort Calhoun Nuclear Station," was not a document provided in the submittal. However, two other, more recent, documents were provided along with the LTP submittal:

Chapter 6, Reference 7: Omaha Public Power District, "FC-20-007, Fort Calhoun Station Potential Radionuclides of Concern.

Chapter 6, Reference 8: Radiation Safety and Control Services, "FC-21-043, Radionuclides of Concern in Support of the Fort Calhoun License Termination Plan," 2021.

Please provide Reference 6 for Chapter 6 or provide an explanation that the information in the latest report contains all the attributed information in the LTP (e.g., details on the suite of radionuclides for the initial sampling for decommissioning in Reference 6 are also included in Reference 8).

3. Clarification on Updated or Revised Documents As noted in the above specific examples, multiple revisions of, or similarly titled, reports are cited in the LTP. Clarification is requested on if there are other revisions or updates of referenced documents that the later revisions or updates contain cumulative information from the earlier reports, or only new information.
4. Data File Request - Subsurface Transport Modeling Please provide the input file sets used in Groundwater Vistas modeling to support results from RESRAD-ONSITE modeling for the Basement Backfill Model.
5. Data Request - Hydrologic Conditions NRC staff requests any historical groundwater level data and river stage measurements from the site that would reflect groundwater elevations near the river. Measurements of groundwater levels from June 2020 are stated in the LTP (pages 6-12) to be reflective of

T. Via 3 historical conditions at the site. The basis is stated to be the steady river stage levels typically between 10 and 15 feet over the past decade based on measurement stations upstream (Decatur) and downstream (Omaha) of the site. The groundwater levels at the site are also stated to be in intimate hydraulic connection with the river (e.g., LTP Section 1.3.6). The hydrologic conditions at the site are used to support the representative and conservative groundwater levels and gradients used in RESRAD-ONSITE model. In addition, hydrologic conditions at the site may impact decommissioning activities (e.g.., excavations, scans, and sampling) thus making the range of conditions expected at the site (e.g., seasonal) a concern given past flooding at the site and concurrent increases in groundwater levels with rising river stages.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

We request that the supplemental information requested above be provided within 30 days from the date of this letter. If you have any questions, please contact me at (301) 415-6634 or jack.parrott@nrc.gov.

Sincerely, Signed by Parrott, Jack on 12/16/21 Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Projects Office of Nuclear Material Safety and Safeguards Docket No. 50-285 cc: Fort Calhoun Listserv Becki Harisis, Manager Office of Radiological Health Nebraska Department of Health & Human Services 301 Centennial Mall South P.O. Box 95026 Lincoln, NE 68509-5026 Becki.Harisis@nebraska.gov

ML21350A026 OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB NAME JParrott JP RFedors RF BWatson BW JParrott JP DATE Dec 16, 2021 Dec 16, 2021 Dec 16, 2021 Dec 16, 2021