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| | issue date = 10/04/2017 | | | issue date = 10/04/2017 |
| | title = Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664) | | | title = Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664) |
| | author name = Fisher M J | | | author name = Fisher M |
| | author affiliation = Omaha Public Power District | | | author affiliation = Omaha Public Power District |
| | addressee name = | | | addressee name = |
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| =Text= | | =Text= |
| {{#Wiki_filter:L1 C-17 -0068 October 4, 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 | | {{#Wiki_filter:L1 C-17 -0068 October 4, 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 |
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| ==Subject:== | | ==Subject:== |
| Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664) | | Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664) |
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| ==References:== | | ==References:== |
| : 1. Letter from OPPD (M.J. Fisher) to USNRC (Document Control Desk), Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance, dated April 28, 2017 (ML 17118A336) (LIC-17-0038) | | : 1. Letter from OPPD (M.J. Fisher) to USNRC (Document Control Desk), Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance, dated April 28, 2017 (ML17118A336) (LIC-17-0038) |
| : 2. Email from USNRC (J. Kim) to OPPD (E. Matzke), Final RAI for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664), dated August 24,2017 (ML 17236A344) (NRC-17-052) | | : 2. Email from USNRC (J. Kim) to OPPD (E. Matzke), Final RAI for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664), dated August 24,2017 (ML17236A344) (NRC-17-052) |
| On April 28, 2017 Omaha Public Power District (OPPD), requested an exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance. (Reference 1). On August 24, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed changes. Attachment 1 of this letter provides the responses to the RAI. 444 SOUTH 16TH STREET MALL | | On April 28, 2017 Omaha Public Power District (OPPD), requested an exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance. (Reference 1). On August 24, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed changes. Attachment 1 of this letter provides the responses to the RAI. |
| * OMAHA, NE 68102-2247 | | 444 SOUTH 16TH STREET MALL |
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| U.S. Nuclear Regulatory Commission Ll C-17 -0068 Page 2 This letter contains no regulatory commitments. | | U.S. Nuclear Regulatory Commission Ll C-17 -0068 Page 2 This letter contains no regulatory commitments. |
| If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome, Director-Licensing and Regulatory Assurance at (402) 533-7270. | | If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome, Director - Licensing and Regulatory Assurance at (402) 533-7270. |
| Respectfully, Mary J. Fisher Senior Director-Decommissioning Fort Calhoun Station MJF/epm Attachments: | | Respectfully, |
| 1 . Response to Request for Additional Information c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager R. S. Browder, NRC Senior Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska LIC-17-0068 Attachment 1 Page 1 ATTACHMENT 1 Final Request for Additional Information (RAil for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664) FORT CALHOUN STATION, UNIT 1 DOCKET NO.: 50-285 By letter dated April 28, 2017, Omaha Public Power District (OPPD or the licensee), requested an exemption from 10 CFR 140.11(a}(4), which concerns off-site primary and secondary liability insurance. | | ~!Wj Mary J. Fisher Senior Director - Decommissioning Fort Calhoun Station MJF/epm Attachments: 1 . Response to Request for Additional Information c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager R. S. Browder, NRC Senior Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska |
| The regulation requires licensees to have and maintain two levels of financial protection against off-site liability for each nuclear reactor that is licensed to operate, designed for the production of electrical energy, and has a rated capacity of 100,000 kilowatts electric (kWe) or more. The two levels of financial protection are as follows: | | |
| | LIC-17-0068 Page 1 ATTACHMENT 1 Final Request for Additional Information (RAil for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), |
| | Off-site Primary and Secondary Liability Insurance (MF9664) |
| | FORT CALHOUN STATION, UNIT 1 DOCKET NO.: 50-285 By letter dated April 28, 2017, Omaha Public Power District (OPPD or the licensee), |
| | requested an exemption from 10 CFR 140.11(a}(4), which concerns off-site primary and secondary liability insurance. The regulation requires licensees to have and maintain two levels of financial protection against off-site liability for each nuclear reactor that is licensed to operate, designed for the production of electrical energy, and has a rated capacity of 100,000 kilowatts electric (kWe) or more. The two levels of financial protection are as follows: |
| * Primary insurance coverage of $450,000,000 from private sources; and, | | * Primary insurance coverage of $450,000,000 from private sources; and, |
| * Secondary financial protection in the form of private liability insurance available under an industry retrospective rating plan. The licensee requested an exemption from this requirement to reduce the required level of primary off-site liability insurance to $100 million and eliminate the requirement for OPPD to participate in the secondary retrospective rating plan, effective on April 7, 2018. The U.S. Nuclear Regulatory Commission staff has reviewed the licensee's submittal and determined that the following additional information is required in order to complete the review: RAI-SBPB-01: | | * Secondary financial protection in the form of private liability insurance available under an industry retrospective rating plan. |
| In SECY-96-256, "Changes to Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors, 10 CFR 50.54(w)(1) and 10 CFR 140.11," dated December 17, 1996 (ADAMS Accession No. ML 15062A483), the staff recommended changes to the power reactor insurance regulations that would allow licensees to lower offsite primary liability insurance levels to $100 million and withdraw from the secondary retrospective rating plan upon demonstration that the fuel stored in the SFP can be cooled. In its Staff Requirements Memorandum to SECY-96-256, dated January 28, 1997 (ADAMS Accession No. ML 15062A454), the Commission supported the staff's recommendation. | | The licensee requested an exemption from this requirement to reduce the required level of primary off-site liability insurance to $100 million and eliminate the requirement for OPPD to participate in the secondary retrospective rating plan, effective on April 7, 2018. |
| The staff has used this technical criterion of air coolability to grant similar exemptions to other decommissioning reactors (e.g., Kewaunee Power Station (ADAMS Accession No. ML 15026A544), published in the Federal Register on March 24, 2015). The information supporting the requested exemption provided by letter dated April28, 2017, did not specifically address the technical criterion that the spent fuel could be cooled if the spent fuel pool was drained of water. Instead, the discussion addressed the low probability of damage to fuel if the pool were drained of water due to the long time available for actions to provide cooling. Provide an analysis or evaluation that provides reasonable assurance that the fuel could be adequately cooled by air in the event the spent fuel pool were completely drained, either by comparison of input parameters with representative NRC generic analyses or by plant specific analyses. | | The U.S. Nuclear Regulatory Commission staff has reviewed the licensee's submittal and determined that the following additional information is required in order to complete the review: |
| Examples of these approaches for the Kewaunee Power Station are publicly available (ADAMS Accession Nos. ML 14029A064 and ML 14029A067). | | RAI-SBPB-01: |
| LIC-17-0068 Attachment 1 Page 2 OPPD Response OPPD has compiled the requested data comparing the input parameters to the representative NRC generic analyses (NUREG/CR-6451 1997, reference | | In SECY-96-256, "Changes to Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors, 10 CFR 50.54(w)(1) and 10 CFR 140.11," dated December 17, 1996 (ADAMS Accession No. ML15062A483), the staff recommended changes to the power reactor insurance regulations that would allow licensees to lower offsite primary liability insurance levels to $100 million and withdraw from the secondary retrospective rating plan upon demonstration that the fuel stored in the SFP can be air-cooled. In its Staff Requirements Memorandum to SECY-96-256, dated January 28, 1997 (ADAMS Accession No. ML15062A454), the Commission supported the staff's recommendation. The staff has used this technical criterion of air coolability to grant similar exemptions to other decommissioning reactors (e.g., Kewaunee Power Station (ADAMS Accession No. ML15026A544), published in the Federal Register on March 24, 2015). |
| : 2) to the data for the Fort Calhoun Station. Since the Fort Calhoun fuel assemblies have a 20% lower power density and a 10% lower peak burnup combined with low uranium loading there should be a lower heat rate(s) than those cited for NUREG/CR-6451.
| | The information supporting the requested exemption provided by letter dated April28, 2017, did not specifically address the technical criterion that the spent fuel could be air-cooled if the spent fuel pool was drained of water. Instead, the discussion addressed the low probability of damage to fuel if the pool were drained of water due to the long time available for actions to provide cooling. Provide an analysis or evaluation that provides reasonable assurance that the fuel could be adequately cooled by air in the event the spent fuel pool were completely drained, either by comparison of input parameters with representative NRC generic analyses or by plant specific analyses. Examples of these approaches for the Kewaunee Power Station are publicly available (ADAMS Accession Nos. ML14029A064 and ML14029A067). |
| The lower decay heat will be sufficient to offset the reduced cell size of the Region 2 racks compared to the benchmark. | | |
| As a result the FCS spent fuel pool conditions are bounded by the NUREG/CR-6451 benchmark. | | LIC-17-0068 Page 2 OPPD Response OPPD has compiled the requested data comparing the input parameters to the representative NRC generic analyses (NUREG/CR-6451 1997, reference 2) to the data for the Fort Calhoun Station. Since the Fort Calhoun fuel assemblies have a 20% lower power density and a 10% |
| Spent Fuel Zirconium Fire Comparison Parameter i NUREG/CR-4982 1987 N U REG/CR-6451 Fort Calhoun Station (Ref. 1) 1997 (Ref 2) | | lower peak burnup combined with low uranium loading there should be a lower heat rate(s) than those cited for NUREG/CR-6451. The lower decay heat will be sufficient to offset the reduced cell size of the Region 2 racks compared to the benchmark. As a result the FCS spent fuel pool conditions are bounded by the NUREG/CR-6451 benchmark. |
| * Plant Data Power Typical PWR 1130 MWe 500 MWe (3300 MWt) (1500MWt) | | Spent Fuel Zirconium Fire Comparison Parameter i NUREG/CR-4982 1987 N U REG/CR-6451 Fort Calhoun Station (Ref. 1) 1997 (Ref 2) |
| Assemblies Typical PWR 193 133 I MWt/Assembly 17.3 11.3 SFP Rack Design Design High Density High Density High Density Material Stainless Steel Stainless Steel Stainless Steel Pitch N/A 10.4" Region 1: 1 0.4" (N/S) 9.8" (E/W) Region 2: 8. 7" Bottom Orifice 5" diameter 5" diameter 5" diameter (Region 1 &2) Opening per Cell 1 0" diameter Fuel I Design Typical PWR 17x17 14x14 Max Assembly High Burnup 60 GWD/MTU 51.504 GWD/MTU Cycle Burn up last cycle 27 55.231 GWD/MTU Cycle 28 (last cycle) Source Term Decay 700 days (23 months) 17 months 1 7 months 5" diameter 360 days ( 12 months) 1 0" diameter Zirconium Oxidation i Temperature Limit 650 oc I 565 oc I 565 oc LIC-17-0068 Attachment 1 Page 3 ower ensl[y P D "t C ompanson I Parameter NUREG/CR-6451 Fort Calhoun Station 1997 Power Per Assembly 17.3 11.3 (MWt) Fuel Assembly L/W I 8.42 8.03 I (inches) I I Fuel Active Height l 144 129.3 (inches) I Active volume I 10209.1 [0.1673] 8337.4 [0.1366] I (in 3 [m 3]) Power Density 103.4 82.72 (MWt/m 3) Uranium Mass per -0.3893' Assembly (MTU} *For Batch EE1, maximum of C27 and C28 sub-batches | | * Plant Data Power Typical PWR 1130 MWe 500 MWe (3300 MWt) (1500MWt) |
| | Assemblies Typical PWR 193 133 I MWt/Assembly 17.3 11.3 SFP Rack Design Design High Density High Density High Density Material Stainless Steel Stainless Steel Stainless Steel Pitch N/A 10.4" Region 1: 10.4" (N/S) 9.8" (E/W) |
| | Region 2: 8. 7" Bottom Orifice 5" diameter 5" diameter 5" diameter (Region 1&2) |
| | Opening per Cell 10" diameter Fuel Design I Typical PWR 17x17 14x14 Max Assembly High Burnup 60 GWD/MTU 51.504 GWD/MTU Cycle Burn up last cycle 27 55.231 GWD/MTU Cycle 28 (last cycle) |
| | Source Term Decay 700 days (23 months) 17 months 17 months 5" diameter 360 days ( 12 months) 10" diameter Zirconium Oxidation i Temperature Limit 650 oc I 565 oc I 565 oc |
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| | LIC-17-0068 Page 3 Power Densl[y"t Companson I |
| | Parameter NUREG/CR-6451 Fort Calhoun Station 1997 Power Per Assembly 17.3 11.3 (MWt) |
| | Fuel Assembly L/W I 8.42 8.03 I I |
| | (inches) I Fuel Active Height 144 129.3 (inches) l Active volume 10209.1 [0.1673] 8337.4 [0.1366] |
| | I I |
| | I (in 3 [m 3 ]) |
| | Power Density 103.4 82.72 (MWt/m 3 ) |
| | Uranium Mass per - 0.3893' Assembly (MTU} |
| | *For Batch EE1, maximum of C27 and C28 sub-batches |
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| ==Reference:== | | ==Reference:== |
| : 1. NUREG/CR-4982 "Severe Accidents in Spent Fuel Pools in Support of Generic Safety Issue 82", 06/1987 2. NUREG/CR-6451 "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," 04/1997}} | | : 1. NUREG/CR-4982 "Severe Accidents in Spent Fuel Pools in Support of Generic Safety Issue 82", 06/1987 |
| | : 2. NUREG/CR-6451 "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," 04/1997}} |
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Category:Letter type:LIC
MONTHYEARLIC-24-0007, License Amendment Request (LAR) to Revise License Termination Plan (LTP)2024-06-18018 June 2024 License Amendment Request (LAR) to Revise License Termination Plan (LTP) LIC-24-0008, Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (Dqap), Unit No. 1 and ISFSI2024-05-16016 May 2024 Proposed Revision to the Omaha Public Power District (OPPD) Fort Calhoun Station (FCS) Decommissioning Quality Assurance Plan (Dqap), Unit No. 1 and ISFSI LIC-24-0003, Independent Spent Fuel Storage Installation - Radiological Effluent Release Report and Radiological Environmental Operating Report2024-04-25025 April 2024 Independent Spent Fuel Storage Installation - Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-24-0006, (Fcs), Unit 1, Independent Spent Fuel Storage Installation, Phase 1 Final Status Survey Report to Support Approved License Termination Plan2024-04-17017 April 2024 (Fcs), Unit 1, Independent Spent Fuel Storage Installation, Phase 1 Final Status Survey Report to Support Approved License Termination Plan LIC-24-0005, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2024-03-0101 March 2024 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-24-0002, Independent Spent Fuel Storage Installation - Submittal of Annual Radioactive Effluent Release Report2024-02-27027 February 2024 Independent Spent Fuel Storage Installation - Submittal of Annual Radioactive Effluent Release Report LIC-23-0007, Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information2023-12-0606 December 2023 Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information LIC-23-0005, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 20232023-08-24024 August 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 2023 LIC-23-0004, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2023-04-20020 April 2023 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-23-0003, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2023-03-15015 March 2023 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-23-0001, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information2023-02-27027 February 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information LIC-23-0002, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2023-02-20020 February 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information LIC-22-0005, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2022-04-20020 April 2022 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2022-03-30030 March 2022 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-22-0006, Reactor Head Disposition Project Overview2022-03-17017 March 2022 Reactor Head Disposition Project Overview LIC-22-0004, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2022-02-17017 February 2022 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-21-0008, Organizational and Management Change2021-10-28028 October 2021 Organizational and Management Change LIC-21-0007, ISFSI Only Emergency Plan Update2021-09-0808 September 2021 ISFSI Only Emergency Plan Update LIC-21-0004, Radiological Effluent Release Report and Radiological Environmental Operating Report2021-04-29029 April 2021 Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-21-0003, Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report2021-03-30030 March 2021 Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-21-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-22022 February 2021 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0015, Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092)2020-07-29029 July 2020 Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092) LIC-20-0014, Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2020-07-15015 July 2020 Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-20-0012, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2020-05-18018 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool LIC-20-0011, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-05-0707 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0009, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2020-04-30030 April 2020 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-20-0008, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-04-13013 April 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0006, (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E2020-03-26026 March 2020 (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E LIC-20-0004, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-03-10010 March 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2020-02-27027 February 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0002, Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan2020-02-27027 February 2020 Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan LIC-20-0001, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-02-0606 February 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0025, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-12-19019 December 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019 Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-19-0022, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-11-18018 November 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0018, Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2019-11-14014 November 2019 Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-19-0020, Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis2019-10-17017 October 2019 Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis LIC-19-0017, Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 20042019-08-0808 August 2019 Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 An LIC-19-0010, License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associa2019-05-20020 May 2019 License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated LIC-19-0008, Submittal of 2018 Annual Report2019-04-0404 April 2019 Submittal of 2018 Annual Report LIC-19-0004, Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP)2019-03-28028 March 2019 Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP) LIC-19-0005, 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report2019-03-28028 March 2019 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report LIC-19-0001, License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2019-02-28028 February 2019 License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme LIC-19-0003, Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation R2019-02-28028 February 2019 Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation Requ LIC-19-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-01-0303 January 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-18-0031, Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update2018-12-17017 December 2018 Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update LIC-18-0030, Request for Partial Site Release Phase 22018-11-12012 November 2018 Request for Partial Site Release Phase 2 LIC-18-0028, Letter of Intent to Submit Request for Additional Partial Site Release2018-10-18018 October 2018 Letter of Intent to Submit Request for Additional Partial Site Release 2024-06-18
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML23276A0042023-09-28028 September 2023 U.S. EPA Response Letter to NRC Letter on Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites MOU - Fort Calhoun Station, Unit 1 (License No. DPR-40, Docket No. 50-285) LIC-23-0005, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 20232023-08-24024 August 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 2023 LIC-23-0001, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information2023-02-27027 February 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information ML22034A5592022-01-13013 January 2022 Response to 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-OOOO) Ml21350A02 ML20202A6542020-07-16016 July 2020 Response for Fort Calhoun Station Fort Calhoun Station, Unit No. 1, Revised Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-18-0018, Independent Spent Fuel Storage Installation - Emergency Plan Update2018-04-18018 April 2018 Independent Spent Fuel Storage Installation - Emergency Plan Update ML18088B3782018-03-29029 March 2018 Response to Request for Additional Information Regarding Omaha Public Power District'S Decommissioning Funding Plan Update for Fort Calhoun Station Independent Spent Fuel Storage Installation ML17348A6232017-12-14014 December 2017 Response for Fort Calhoun Station Specific Questions and Concerns Regarding Omaha Public Power District'S Post-Shutdown Decommissioning Activities Report (PSDAR) LIC-17-0068, Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)2017-10-0404 October 2017 Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664) LIC-17-0065, Submittal of Response to Request for Additional Information Re Fort Calhoun Request to Revise Their Technical Specifications to Align to Those Requirements for Decommissioning2017-09-26026 September 2017 Submittal of Response to Request for Additional Information Re Fort Calhoun Request to Revise Their Technical Specifications to Align to Those Requirements for Decommissioning ML17268A2212017-09-25025 September 2017 Response to Request for Additional Information (RAI) Regarding License Amendment Request 16-04 Revising Current Licensing Basis to Use Aci Ultimate Strength Requirements ML17264A7502017-09-21021 September 2017 Response to Request for Additional Information (RAI) License Amendment Request Regarding Removal of Dry Cask Loading Limits Fort Calhoun Station, Unit 1 Docket No.: 50-285 (MF9831) LIC-17-0054, Submission of Corrected Pages for Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1 - Request for Additional Information Certified Fuel Handler Training Program2017-06-0606 June 2017 Submission of Corrected Pages for Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1 - Request for Additional Information Certified Fuel Handler Training Program LIC-17-0047, Final Request for Additional Information Concerning License Amendment Request 16-07: Revise the Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2017-05-15015 May 2017 Final Request for Additional Information Concerning License Amendment Request 16-07: Revise the Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme LIC-17-0048, Response to Request for Additional Information Regarding the Fort Calhoun Station Request to Revise Technical Specifications to Align Staffing Requirements for Permanently Defueled Condition2017-04-27027 April 2017 Response to Request for Additional Information Regarding the Fort Calhoun Station Request to Revise Technical Specifications to Align Staffing Requirements for Permanently Defueled Condition LIC-17-0045, Response to Request for Additional Information Defueled Emergency Plan Exemption Request2017-04-20020 April 2017 Response to Request for Additional Information Defueled Emergency Plan Exemption Request LIC-17-0037, Response to Request for Additional Information, Fort Calhoun Station, Unit No.1 - Final Request for Additional Information Concerning Exemption from the Requirements of 10 CFR 50.47 and Appendix E2017-04-14014 April 2017 Response to Request for Additional Information, Fort Calhoun Station, Unit No.1 - Final Request for Additional Information Concerning Exemption from the Requirements of 10 CFR 50.47 and Appendix E LIC-17-0036, Supplemental Response to Request for Additional Information - Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment2017-04-0505 April 2017 Supplemental Response to Request for Additional Information - Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment ML17089A5442017-03-30030 March 2017 Response to Request for Additional Information Certified Fuel Handler Training Program LIC-17-0020, Response to Request for Additional Information, Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment2017-03-0303 March 2017 Response to Request for Additional Information, Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment LIC-17-0024, Supplemental Information Needed for Acceptance of Requested Licensing Action Fort Calhoun Station Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E (CAC No. MF9067). (Non-Proprietary)(Part 4 of 4)2017-02-10010 February 2017 Supplemental Information Needed for Acceptance of Requested Licensing Action Fort Calhoun Station Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E (CAC No. MF9067). (Non-Proprietary)(Part 4 of 4) ML17041A4432017-02-10010 February 2017 Supplemental Information Needed for Acceptance of Requested Licensing Action Fort Calhoun Station Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E (CAC No. MF9067). (Non-Proprietary)(Part 1 of 4) ML17041A4442017-02-10010 February 2017 Supplemental Information Needed for Acceptance of Requested Licensing Action Fort Calhoun Station Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E (CAC No. MF9067). (Non-Proprietary)(Part 2 of 4) LIC-16-0107, Final Response to the Request for Information, Per 10CFR50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident and Corresponding Commitments2016-11-18018 November 2016 Final Response to the Request for Information, Per 10CFR50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident and Corresponding Commitments LIC-16-0090, Response to Request for Additional Information Regarding Certified Fuel Handler Training Program2016-10-0707 October 2016 Response to Request for Additional Information Regarding Certified Fuel Handler Training Program LIC-16-0078, Revision to Response to Request for Information Regarding Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Flood Hazard Reevaluation Report2016-09-14014 September 2016 Revision to Response to Request for Information Regarding Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Flood Hazard Reevaluation Report ML16165A0282016-06-0909 June 2016 Response to NRC Request for Additional Information Revise Current Licensing Basis to Use American Concrete Institute Ultimate Strength Requirements LIC-16-0044, Calculation FC08499 Evaluation of FCS Concrete Compressive Strength Test Data2016-06-0101 June 2016 Calculation FC08499 Evaluation of FCS Concrete Compressive Strength Test Data LIC-16-0025, Ft. Calhoun, Unit 1 - Response to Request for Additional Information Adoption of TSTF-501, Revision 12016-04-0808 April 2016 Ft. Calhoun, Unit 1 - Response to Request for Additional Information Adoption of TSTF-501, Revision 1 LIC-16-0022, Response to NRC Request for Additional Information Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSI/ANS-58.14-20112016-04-0808 April 2016 Response to NRC Request for Additional Information Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSI/ANS-58.14-2011 ML16057A0742016-02-26026 February 2016 Response to Regulatory Information Summary (RIS) 2015-16, Planned Licensing Action Submittals for All Power Reactor Licensees. LIC-16-0001, Response to NRC Request for Additional Information Technical Specification Administrative Changes2016-01-27027 January 2016 Response to NRC Request for Additional Information Technical Specification Administrative Changes LIC-15-0147, Response to NRC Request for Additional Information Fifth Lnservice Testing Interval Relief Requests P-1 and P-22016-01-11011 January 2016 Response to NRC Request for Additional Information Fifth Lnservice Testing Interval Relief Requests P-1 and P-2 LIC-15-0139, ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62015-12-0808 December 2015 ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 ML15350A0192015-11-30030 November 2015 Enclosure 6, Response to Remaining Questions from NRC Request for Additional Information (RAI) Regarding Reactor Vessel Internal Component Aging Management Program. (Non-Proprietary) ML15350A0182015-11-30030 November 2015 Transmittal of Response to Remaining Questions from NRC Request for Additional Information (RAI) Regarding Reactor Vessel Internal Component Aging Management Program LIC-15-0129, Addendum to Response to Request for Information Regarding Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Flood Hazard Reevaluation Report2015-11-0404 November 2015 Addendum to Response to Request for Information Regarding Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Flood Hazard Reevaluation Report LIC-15-0121, ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62015-11-0202 November 2015 ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 LIC-15-0113, Response to Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation2015-09-28028 September 2015 Response to Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation LIC-15-0115, ISFSI - Response to NRC Request for Clean Copy of Emergency Action Level Technical Basis Document2015-09-18018 September 2015 ISFSI - Response to NRC Request for Clean Copy of Emergency Action Level Technical Basis Document LIC-15-0102, Response to NRC Request for Additional Information Re License Amendment Request to Adopt Emergency Action Level Scheme Per NEI 99-01, Rev. 62015-09-11011 September 2015 Response to NRC Request for Additional Information Re License Amendment Request to Adopt Emergency Action Level Scheme Per NEI 99-01, Rev. 6 2023-09-28
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L1 C-17 -0068 October 4, 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285
Subject:
Reply to Final Request for Additional Information (RAI) for Fort Calhoun Exemption from 10 CFR 140.11 (a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)
References:
- 1. Letter from OPPD (M.J. Fisher) to USNRC (Document Control Desk), Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance, dated April 28, 2017 (ML17118A336) (LIC-17-0038)
- 2. Email from USNRC (J. Kim) to OPPD (E. Matzke), Final RAI for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664), dated August 24,2017 (ML17236A344) (NRC-17-052)
On April 28, 2017 Omaha Public Power District (OPPD), requested an exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance. (Reference 1). On August 24, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed changes. Attachment 1 of this letter provides the responses to the RAI.
444 SOUTH 16TH STREET MALL
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U.S. Nuclear Regulatory Commission Ll C-17 -0068 Page 2 This letter contains no regulatory commitments.
If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome, Director - Licensing and Regulatory Assurance at (402) 533-7270.
Respectfully,
~!Wj Mary J. Fisher Senior Director - Decommissioning Fort Calhoun Station MJF/epm Attachments: 1 . Response to Request for Additional Information c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager R. S. Browder, NRC Senior Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska
LIC-17-0068 Page 1 ATTACHMENT 1 Final Request for Additional Information (RAil for Fort Calhoun Exemption from 10 CFR 140.11(a)(4),
Off-site Primary and Secondary Liability Insurance (MF9664)
FORT CALHOUN STATION, UNIT 1 DOCKET NO.: 50-285 By letter dated April 28, 2017, Omaha Public Power District (OPPD or the licensee),
requested an exemption from 10 CFR 140.11(a}(4), which concerns off-site primary and secondary liability insurance. The regulation requires licensees to have and maintain two levels of financial protection against off-site liability for each nuclear reactor that is licensed to operate, designed for the production of electrical energy, and has a rated capacity of 100,000 kilowatts electric (kWe) or more. The two levels of financial protection are as follows:
- Primary insurance coverage of $450,000,000 from private sources; and,
- Secondary financial protection in the form of private liability insurance available under an industry retrospective rating plan.
The licensee requested an exemption from this requirement to reduce the required level of primary off-site liability insurance to $100 million and eliminate the requirement for OPPD to participate in the secondary retrospective rating plan, effective on April 7, 2018.
The U.S. Nuclear Regulatory Commission staff has reviewed the licensee's submittal and determined that the following additional information is required in order to complete the review:
RAI-SBPB-01:
In SECY-96-256, "Changes to Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors, 10 CFR 50.54(w)(1) and 10 CFR 140.11," dated December 17, 1996 (ADAMS Accession No. ML15062A483), the staff recommended changes to the power reactor insurance regulations that would allow licensees to lower offsite primary liability insurance levels to $100 million and withdraw from the secondary retrospective rating plan upon demonstration that the fuel stored in the SFP can be air-cooled. In its Staff Requirements Memorandum to SECY-96-256, dated January 28, 1997 (ADAMS Accession No. ML15062A454), the Commission supported the staff's recommendation. The staff has used this technical criterion of air coolability to grant similar exemptions to other decommissioning reactors (e.g., Kewaunee Power Station (ADAMS Accession No. ML15026A544), published in the Federal Register on March 24, 2015).
The information supporting the requested exemption provided by letter dated April28, 2017, did not specifically address the technical criterion that the spent fuel could be air-cooled if the spent fuel pool was drained of water. Instead, the discussion addressed the low probability of damage to fuel if the pool were drained of water due to the long time available for actions to provide cooling. Provide an analysis or evaluation that provides reasonable assurance that the fuel could be adequately cooled by air in the event the spent fuel pool were completely drained, either by comparison of input parameters with representative NRC generic analyses or by plant specific analyses. Examples of these approaches for the Kewaunee Power Station are publicly available (ADAMS Accession Nos. ML14029A064 and ML14029A067).
LIC-17-0068 Page 2 OPPD Response OPPD has compiled the requested data comparing the input parameters to the representative NRC generic analyses (NUREG/CR-6451 1997, reference 2) to the data for the Fort Calhoun Station. Since the Fort Calhoun fuel assemblies have a 20% lower power density and a 10%
lower peak burnup combined with low uranium loading there should be a lower heat rate(s) than those cited for NUREG/CR-6451. The lower decay heat will be sufficient to offset the reduced cell size of the Region 2 racks compared to the benchmark. As a result the FCS spent fuel pool conditions are bounded by the NUREG/CR-6451 benchmark.
Spent Fuel Zirconium Fire Comparison Parameter i NUREG/CR-4982 1987 N U REG/CR-6451 Fort Calhoun Station (Ref. 1) 1997 (Ref 2)
- Plant Data Power Typical PWR 1130 MWe 500 MWe (3300 MWt) (1500MWt)
Assemblies Typical PWR 193 133 I MWt/Assembly 17.3 11.3 SFP Rack Design Design High Density High Density High Density Material Stainless Steel Stainless Steel Stainless Steel Pitch N/A 10.4" Region 1: 10.4" (N/S) 9.8" (E/W)
Region 2: 8. 7" Bottom Orifice 5" diameter 5" diameter 5" diameter (Region 1&2)
Opening per Cell 10" diameter Fuel Design I Typical PWR 17x17 14x14 Max Assembly High Burnup 60 GWD/MTU 51.504 GWD/MTU Cycle Burn up last cycle 27 55.231 GWD/MTU Cycle 28 (last cycle)
Source Term Decay 700 days (23 months) 17 months 17 months 5" diameter 360 days ( 12 months) 10" diameter Zirconium Oxidation i Temperature Limit 650 oc I 565 oc I 565 oc
LIC-17-0068 Page 3 Power Densl[y"t Companson I
Parameter NUREG/CR-6451 Fort Calhoun Station 1997 Power Per Assembly 17.3 11.3 (MWt)
Fuel Assembly L/W I 8.42 8.03 I I
(inches) I Fuel Active Height 144 129.3 (inches) l Active volume 10209.1 [0.1673] 8337.4 [0.1366]
I I
I (in 3 [m 3 ])
Power Density 103.4 82.72 (MWt/m 3 )
Uranium Mass per - 0.3893' Assembly (MTU}
- For Batch EE1, maximum of C27 and C28 sub-batches
Reference:
- 1. NUREG/CR-4982 "Severe Accidents in Spent Fuel Pools in Support of Generic Safety Issue 82", 06/1987
- 2. NUREG/CR-6451 "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," 04/1997