ML16305A104

Closure of Remaining Confirmatory Action Letter Commitments

ML16305A104
Person / Time
Site:	Fort Calhoun
Issue date:	10/31/2016
From:	Marik S M Omaha Public Power District
To:	Kennedy K M Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
EA-13-243, LIC-16-0066
Download: ML16305A104 (5)

Text

LIC-16-0066 October 31 , 20 16 Mr. K. M. Kennedy Regional Administrator , Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Closure of Remaining Confirmatory Action Letter Commitments

References:

See Page 5

Dear Mr. Kennedy:

EA-13-243 In Reference 1, Omaha Public Power District (OPPD) made post-restart commitments associated with Fort Calhoun Station (FCS) which were confirmed in a NRC Confirmatory Action Letter (CAL) (Reference 2). In early 2016, the NRC completed a Confirmatory Action Letter Follow up Inspection (Reference

3) and closed a number of the CAL commitments.

The Inspection Report also identified eight (8) action items (AI) within the CAL that remained open. OPPD is requesting closure of these remaining commitments based on the OPPD's decision to permanently cease FCS operations.

By letter dated June 24, 2016 (Reference 4), OPPD provided formal notification to the NRC pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1)(i) of OPPD's contingent determination to permanently cease power operations at FCS no later than December 31, 2016. OPPD updated this letter on August 25, 2016 (Reference

5) certifying that it plans to permanently cease power operations at FCS on October 24, 2016. FCS ceased power operations on October 24, 2016. FCS intends to permanently remove all fuel from the reactor vessel in November 2016. The specific bases for closing the remaining eight open CAL action items is provided on the following pages. The eight items are grouped into the three categories as they were listed in NRC Inspection Report (Reference

3) including the reference, AI number and description from Section 5 of the report. 444 South 16th Street Mall Omaha, NE 68102-2247 Mr. K. M. Kennedy LIC-16-0066 Page 2 40A4.1.4:

Design and Licensing Basis (2013-0086)

I AI N b : urn er l o 'f escnp11on 2013-05570-049 1 CAPR-3-Modify the Engineering Support Personnel Training (ESPT) initial and continuing training programs to incorporate CAPR-1 and CAPR-2. Training shall include items 1, 2 and 3 from CAPRs 1 and 2 i to address the identification of design and licensing bases, record types that are included, and the method of retrieval 2013-05570-026 Identify and define the current licensing bases and assure licensing bases documentation remains current, accurate, complete, and retrievable.

1 2013-05570-076 Identify and define the design bases and assure design bases documentation remains current, accurate, complete, and retrievable.

I 2013-05570-092 Complete Phase 3 of the Key Calculation Project. Phase 3 consists of revising any deficient critical calculation or engineering analysis identified from Phase 2, as needed. 2013-05570

-093 Validate the design and licensing basis has been translated into plant operation by verifying that the operation, surveillance, and I maintenance of the safety-related components do not compromise the design and licensing basis. ' i ! ! j These actions were being addressed by the OPPD design and licensing basis project (DLBRP). The DLBRP was suspended indefinitely since the majority of plant systems will no longer be required when FCS is permanently defueled.

When the DLBRP was suspended, the project was approximately fifty percent complete with key systems such as raw water and component cooling water project reviews completed.

Before the DLBRP was suspended, approximately sixty discrepancies were identified and entered i n the station's corrective action program. None of these issues were determined by Shift Management to result in a significant operational concern nor would they significantly impact functions needed to maintain the plant in a permanently defueled status. As part of the decommissioning process, FCS has developed Decommissioning Project Plans (DPP) to address plant systems and equipment that will be necessary to support a permanently defueled status, as well as equipment abandonment and removal. Information from the DLBRP will be utilized dur i ng the implementation of the DPPs including decommissioning updates of the Technical Specifications and Updated Safety Analysis Report (USAR). Some of the key DPPs are listed below: FC-DPP-11 FC-DPP-13 FC-DPP-14

FC-DPP-18 FC-DPP-20 FC-DPP-23

FC-DPP-28 FC-DPP-30 FC-DPP-44 FC-DPP-45 Spent Fuel Pool Configurat i on Plan Decommissioning Support Systems Identification Plan Decommissioning Power Study Plan Decommissioning Accident Analysis Plan Maintenance Rule Program Fire Protection Program Revision Plan PSDAR Preparation Plan USAR Update Plan Personnel Training Plan 50.59 Safety Review Process Mr. K. M. Kennedy L1 C-16-0066 Page 3 FC-DPP-48 FC-DPP-50 FC-DPP-51 FC-DPP-57 FC-DPP-58 Spent Fuel Strategy Procedures Technical Specifications System Abandonment Underground Piping and Tanks 40A4.4: Actions Associated with Containment Internal Structures

{2013-0013)

AI Number Description 1 2012-04392-014 Evaluate the structural design margin for the containment internal 2012-04392-045 structures, and reactor cavity and compartments, and resolve any deficiencies in accordance with its corrective action program {CAP) 2012-04392-048 Regarding Beam 22A and Beam 22B in the containment internal structures resolve any deficiencies in accordance with the CAP. The remaining actions associated with Containment Internal Structures will no longer be relevant when FCS is permanently defueled.

Once the plant is in the defueled condition it is no longer allowed the use the facility for power operation or emplacement of fuel into the reactor vessel as provided in 10 CFR 50.82(a)(2) so the requirements placed on the Containment are no longer applicable.

As a result, OPPD has withdrawn the License Amendment Request (LAR) that was associated with this issue (Reference 6). While not part of the CAL actions, FCS continues to track deficiencies with the auxiliary building structure in CAP (CR 2012-04392-012).

A subsequent LAR (Reference

7) has been submitted to assist in resolving those issues. 40A4.1.8.f:

Piping Code and System Classification and Analysis (2013-0071)

AI Number Description 2012-07724-023 Provide calculations documenting thermal fatigue analysis on the Class I piping systems for primary plant sampling, reactor coolant gas vent, reactor coolant, safety injection, and waste disposal in accordance with USAS B31.7 Draft 1968 The commitment to resolve thermal fatigue on Class I piping systems is not relevant since thermal fatigue conditions will not exist once FCS is permanently defueled.

The scope included in USAS 831.7 Section 700.1 includes; "Piping systems for which rules are specified by this Code are those that are designed to provide a pressure-retaining barrier in a nuclear power plant or to provide for the overall containment of the nuclear plant." The limits on the Class I piping can no longer be exceeded without a pressure source. Also, 10 CFR 50.82, "Termination of license," states that, "upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel. .. , the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel." As such, the requirements of USAS 831.7, no longer apply to the piping systems in such a condition because the reactor coolant, safety injection, and waste disposal pressure boundary will no longer be used as a pressure retaining or fission product barrier when the reactor vessel is permanently defueled.

Mr. K. M. Kennedy L I C-16-0066 Page 4 Based on the above information, OPPD is requesting closure of the eight remaining CAL commitments.

There are no regulatory commitments contained within this letter. If you should have further questions, please contact Mr. Bradley H. Blome , Manager -Site Regulatory Assurance, at 402-533-7270. Respectfully, Shane M. Marik Site Vice President and CNO SMM/cac cc: C. F. Lyon, NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector Mr. K. M. Kennedy LIC-16-0066 Page 5 REFERENCES

1. OPPD Letter (L. P. Cortopassi) to USNRC (M. L. Dapas), "Integrated Report to Support Restart of Fort Calhoun Station and Post-Restart Commitments for Sustained Improvement," dated December 2, 2013 (LIC-13-0164) (ML 13336A785)

2. NRC Letter (M. L. Dapas) to OPPD (L. P. Cortopassi), "Confirmatory Action LetterFort Calhoun Station," dated December 17,2013 (ML 13351A395)

3. NRC Letter (J. Sowa) to OPPD (S. M. Marik), "Fort Calhoun Station-NRC Confirmatory Action Letter Follow up Inspection 05000285/2016007," dated February 11, 2016 (ML 16042A542)

4. OPPD Letter (T. Burke) to US NRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated June 24, 2016 (LIC-16-0043) (ML 16176A213)

5. OPPD Letter (T. Burke) to USNRC (Document Control Desk), "Certification of Permanent Cessation of Power Operations," dated August 25, 2016 (LIC-16-0067) (ML 16242A 127) 6. OPPD Letter (S. M. Marik) to USNRC (Document Control Desk), "Withdrawal of License Amendment Request 03, Revise Current Licensing Basis to Use ACI Ultimate Strength Requirements," dated July 27, 2016 (LIC-16-0051) (ML 16209A126)

7. OPPD Letter (S. M. Marik) to USNRC (Document Control Desk), "License Amendment Request 16-04: Revise Current Licensing Basis to USE ACI Ultimate Strength Requirements," dated October 25, 2016 (LIC-16-0093)