ML25023A156

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Regulatory Audit Plan Regarding License Amendment to Revise LTP
ML25023A156
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 01/14/2025
From: Randall Fedors, Fuguet N, Jack Parrott, Adam Schwartzman
Reactor Decommissioning Branch, NRC/NMSS/DDUWP/RTAB
To:
Shared Package
ML25023A155 List:
References
EPID L-2024-LLA-0095
Download: ML25023A156 (3)


Text

1 OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS REGULATORY AUDIT PLAN REGARDING THE REQUEST FOR LICENSE AMENDMENT TO APPROVE THE REVISED LICENSE TERMINATION PLAN FOR OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 LICENSE NO. DPR-40 DOCKET NO. 50-285

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Background===

By letter dated June 18, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24177A132), and as supplemented by letter dated October 2, 2024 (ML24276A217). Omaha Public Power District (OPPD or the licensee) requested the U.S.

Nuclear Regulatory Commission (NRC) to approve a request to amend the license for Fort Calhoun Station, Unit No. 1 (FCS). The amendment would approve Revision 2 of the FCS License Termination Plan (LTP) which was originally approved by license amendment dated January 31, 2024 (ML24019A145). The regulatory audit will identify information that will support the basis of the licensing decision and will allow the NRC staff to more efficiently gain insights necessary to complete its review of the LTP Revision amendment request.

Regulatory Bases The proposed OPPD FCS LTP Revision 2 is being reviewed in accordance with the applicable regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, 10 CFR Part 20, Standards for Protection Against Radiation, and applicable guidance provided in NUREG-1757, Vol. 2, Rev.

2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria and NUREG-1575 Multi-Agency Radiation Survey and Site Investigation Manual (ML22194A859 and ML003761445, respectively).

Regulatory Scope The audit will cover the OPPD calculation and use of the revised DCGLs, the physical scope of the areas to be grouted, the radionuclide exposure pathways for the grouted areas, and the radionuclide characterization, survey and dose considerations for the grouted areas. The NRC staff will review basis documents to determine whether the information included in the documents supports the OPPD LTP amendment request and/or is necessary to conduct NRC staff review of the proposed amendment. This audit will provide information necessary to complete the NRC staffs evaluation of the OPPD LTP amendment request. In addition, the regulatory audit may identify additional information that will be required to be docketed to support the basis of the licensing decision and will allow NRC staff to efficiently gain insights on the proposed amendment.

Information Needed OPPD staff should be prepared to provide the NRC staff with the information referenced in the OPPD LTP amendment request.

In addition, the following information needs have been identified below:

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1. FC-24-001, Rev. 0, Use of In-Situ Gamma Spectroscopy for Scan Surveys of Building Surfaces
2. FC-24-002, Rev. 0, Radionuclide Release Through Grouted Trenches
3. FC-24-003, Rev. 1, Ludlum 44-10 Detector Sensitivity for Determining Scan MDCs on Concrete Surfaces
4. FC-24-004, Rev. 1, DCGLs, Remediation Strategy and Survey Methodology for the Auxiliary Building East Trenches
5. Excel Spreadsheet Calculations in Support of FCS LTP Chapter 6, Revision 0
6. A map of the Auxiliary Building grouted areas Additional information needs may arise during the NRC staffs audit.

Audit Team The NRC staff performing this audit will include, but may not be limited to, the following staff:

Audit Team Members Jack Parrott (Audit Leader and Technical Reviewer)

Adam Schwartzman (Technical Reviewer)

Nate Fuguet (Technical Reviewer)

Randy Fedors (Technical Reviewer)

Logistics The virtual audit will begin on January 16, 2025, and continue as necessary. An entrance meeting will commence on January 16, 2025. Additional audit activities, such as a daily status debriefs, will also be planned, as necessary, to support the understanding of information necessary to complete the review of the OPPD LTP amendment request. It is expected that additional interaction may be needed to identify information requests to support the review activities.

The audit will end on February 28, 2025. The audit period may be reduced or extended, dependent on the NRC and OPPD staff progress in addressing audit questions. If new technical items are identified, additional audit sessions may be needed to support the understanding of information necessary to facilitate the continued review of the requested amendment.

The NRC staff will conduct this audit via teleconference and/or video conference with OPPD staff. The NRC staff will use an online reference document portal provided by OPPD staff.

Access to the online portal will be limited to specific NRC staff and the documents in the online portal are read-only (i.e., NRC staff will be prevented from saving, copying, downloading, or printing any documents). The conditions associated with the online reference document portal must be maintained throughout the review. The NRC staff who should be granted access to the portal are those listed in the Audit Team section above.

Deliverables At the completion of the regulatory audit, the NRC staff will conduct an exit briefing and provide a summary of the audit results. The NRC staff plans to prepare a regulatory audit summary that

3 will include the documents reviewed, the audit activities, and any requests for additional information that were discussed or that will be issued based on the audit, as applicable.