ML24079A170

ISFSI, Unit 1 - 10 CFR 50.59 Report, Quality Assurance (QA) Program Changes, Technical Specification Basis Changes, 10 CFR 71.106 Quality Assurance Program Approval, Aging Management Review, Commitment Revisions and Revision of Updated Safe

ML24079A170
Person / Time
Site:	Fort Calhoun, 07100256
Issue date:	03/10/2024
From:	Uehling T Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-24-0004
Download: ML24079A170 (1)

Text

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

,f1"~

10 CFR 50.71(e) 10 CFR 50.4(b)(6) 10 CFR 50.54(a)

Omaha Public Power District 10 CFR 50.59 10 CFR 54.37(b) 10 CFR 71.106 JO CFR.72:48(d)(2)

March 10, 2024 LIC-24-0004

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Omaha Public Power District - Fort Calhoun Quality Assurance Program Approval for Radioactive Material Packages NRC Docket No. 71-0256

Subject:

10 CFR 50.59 Report, Quality Assurance (QA) Program Changes, Technical Specification Basis Changes, 10 CFR 71.106 Quality Assurance Program Approval, Aging Management Review, Commitment Revisions, and Revision of Updated Safety Analysis Report (USAR) to the Decommissioning Safety Analysis Report (DSAR) for Fort Calhoun Station (FCS), Unit No. 1

Reference:

1. Letter from OPPD (T. Via) to NRC (Document.Control Desk), 1 O CFR 50.59 Report, Quality Assurance (QA) Program Changes, Technical Specification Basis Changes, 10 CFR 71.106 Quality Assurance Program Approval, Aging Management Review, Commitment Revisions, and Revision of Updated Safety Analysis Report Revision for Fort Calhoun Station (FCS), Unit No. 1, dated March 10, 2022 (LIC-22-0002). (ML22081A040)

In accordance with 10 CFR 50.59(d)(2), the Omaha Public Power District (OPPD) submits Attachment 1 as the report of changes, tests, and experiments performed pursuant to 10 CFR 50.59 for Fort Calhoun Station (FCS), Unit No. 1. Attachment 2 is provided to describe Quality Assurance (QA) Program changes as required by 10 CFR 50.54(a)(4)(i). Attachment 3 describes changes made to the quality assurance program approval for radioactive material packages. Attachment 4 contains a description of revised regulatory commitments that require Commission notification in accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes." In accordance with FCS Technical Specification Amendment 299, dated December 11, 2019 (ML16275A323), the FCS License no longer contains any Technical Specification (TS) Basis. Since there are no longer any remaining Basis, this amendment also removed the TS Section 5.20 requirement to maintain the program. Attachment 6 provides a brief a:tJ/ 1 1

summary of the Technical Specification Basis Changes (TSBCs) made since the previous.J-submittal (Reference 1) and Attachment 8 provides a list of files on disk (CD/DVD) included in this submittal. /f D 5 3 0, oD4-

444 SOUTH 16TH STREET MALL* OMAHA NE 68102-2247 µJv1~52?

IV1""1 7 5 DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D5586998 u:_. S. Nuclear Regulatory Commission LIC-24-0004 Page2 This information covers the period of March 1, 2022, through February 29, 2024.

In accordance with 1 O CFR 54.37(b), a review of structures, systems; and components (SSCs) newly identified that would have been subject to an aging management review or evaluation of time-limited aging analysis in accordance with 1 O CFR 54.21 was performed with no new SSCs subject to 1 O CFR 54.21 identified.

In accordance with10 CFR 72.48(d)(2) the Omaha Public Power District (OPPD) is submitting the s~mmary report of changes, tests and experiments for the FCS Independent Spent Fuel Storage Installation (ISFSI) subject to evaluation in accordance with 10 CFR 72.48(c)(2). There were no changes, tests, or experiments that required an evaluation to be performed under 10 CFR 72.48.

See Attachment 7. r The DSAR is issued in electronic format. Pursuant to 10 CFR 50. 71 (e) and 10 GFR 50.4(b)(6),

enclosed is one (1) original CD/DVD of the FCS DSAR made since the previous submittal (Reference 1). Attachment 8 contains a list of the files on the CD/DVD.

As required by 10 CFR 50. 71 (e)(2)(i), I certify, through the work performed by qualified personnel,*

that the information in this submittal accurately presents changes made since the previous submittal, necessary to reflect information and analyses submitted to the Commission or prepared pursuant to Commission requirements, and identifies changes made under the provisions of 10 CFR 50.59 but not previously submitted to the Commission.

No commitments to the NRG are made in this letter.

If you should have any questions, please contact Mrs. Andrea K. Barker - Regulatory A~surance and Emergency Planning Manager at (531) 226-6051.

Respectfully, r;:uu~~

L6jll'AqCAB~Jl)!l489...

TIm.::,_ uen11ng Senior Director - Nuclear Decommissioning

TSU/akb

Attachments: 1. Changes, Tests, and Experiments Performed Pursuant to 1 O CFR 50.59.

2. Quality Assurance Program Changes

3. 10 CFR 71.106, Quality Assurance Program Approval for Radioactive Material Package Changes

4. Regulatory Commitments Revised in Accordance with NEI 99-04

5. Information removed from the DSAR

6. Summary of Technical Specification Basis Changes (TSBC)

7. Changes, Tests, and Experiments Performed Pursuant to 10 CFR 72.48

8. List of Files on CD/DVD *

Enclosure:

CD/DVD of DSAR Sections and Figures

c: S. A. Morris, NRG Regional Administrator, Region IV J. D. Parrott, NRG Senior Project Manager (w/o enclosure)

S. G. Anderson, NRG Senior Health Physicist, Region IV (w/o enclosure)

M. T. Johnson, NRG Senior Health Physicist, Region IV (w/o enclosure)

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D5586998

LIC-24-0004 Attachment 1 Page 1

Changes, Tests, and Experiments Performed Pursuant to 10 CFR 50.59 DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

LIC-24-0004 Attachment 1 Page 2

Abbreviations and Acronyms:

CD - Compact Disk USAR - Updated Safety Analysis Report CFR - Code of Federal Reaulations WDS - Waste Disposal System COO - Chief Operations Officer and Vice President - Utility w/o - without Operations OBA - Desian Basis Accident DBT-Design Basis Tornado DOC - Decommissioning Oversite Committee DSAR - Decommissioning Safety Analysis Report EC - Enaineering Change FCS - Fort Calhoun Station, Unit No. 1 FSAR - Final Safety Analysis Report HSM - Horizontal Storage Module IMA-Independent Management Assessment IOEP - ISFSI Only Emeraency Plan IOF - ISFSI Operating Facility IOTS - ISFSI Only Technical Specifications ISFSI - Independent Spent Fuel Storage Installation ITS - important to safety NEI - Nuclear Energy Institute NRC - Nuclear Reaulatorv Commission ODCM - Off-Site Dose Calculation Manual OPPD - Omaha Public Power District PCP - Process Control Proaram PDEP - Permanently Defueled Emergency Plan POTS - Permanently Defueled Technical Specifications PORC - Plant Operations Review Committee QA - Quality Assurance QATR - Quality Assurance Topical Report RW - Radioactive Waste SCR - Safety Review Committee (PORC)

SSC - Structures, Systems and Components TS -Technical Specification TSBC - Technical Specification Basis Chanae UFSAR - ISFSI Updated Final Safety Analysis Report DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D5586998

LIC-24-0004 Attachment 1 Page3

- Changes,Tests, and Experiments Performed Pursuant to-10 CFR 50.59

2022 Evaluations (03/01/2022-12/31/2022)

Note - The 10 CFR 50.59 evaluations summarized below are, for the most part, unedited summaries as approved in the system. As

• a result, the language may be in future tense.

Change Activity

Title:

Nutnbe*r

No 50.59 Evaluations performed in time frame.

2023 Evaluations Note - The 10 CFR 50.59 evaluations summarized below are for the most part, unedited summaries as approved in the system. As a result, the language may be in future tense.

Change *. * *,t(ctivif~( Title ** 50.59 Evaluat~on. Summarx Number:.

No 50.59 Evaluations performed, calendar year.

2024 Evaluations (01/01/2024- 02/29/2024)

Note - The 10 CFR 50.59 evaluations summarized below are for the most part, unedited summaries as approved in the system. As a result, the language may be in future tense.

• Ch,~nge:* *-50.59 Evaluation Summary

\\ ' ",' ", "

Nvmber'

No 50.59 Evaluations in time frame.

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D55B6998

LIC-24-0004 Attachment 2 Page 1

Quality Assurance Program Changes

Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

And

Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054 DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

LIC-24-0004 Attachment 2 Page2

Fort Calhoun Station List of 10 CFR 50.54(a)(3) changes made since.March 1, 2022

QA Progr~m * *The Quality :A~suran*ce Topical Report (QATR). Revision Description

~' ~ ;, ~ -

Change Number" Date of *Chan e

• Revision 17 / Updates the retention requirement for records and logs associated with the irradiated fuel storage from five years to the 01/01/2023 duration of the Facilit O eratin License.

OocuSign Envelope ID: E24BF6ED-5ADA-4368-866A-422BD55B6998

LIC-24-0004 Attachment 3 Page 1.

10 CFR 71.106 Quality Assurance Program Approval for Radioactive Material Package Changes DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

LIC-24-0004 Attachment 3 Page 2

QA Program Revision Description Change Number

[Date of change] ---

N/A No changes have been made to the quality assurance program approval for radioactive material package changes since August 13, 2015, when NRG Form 311, Quality Assurance Program Approval for Radioactive Material Packages was approved (QA Program Approval No. 71-0256, Rev. No. 8).

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422B055B6998

LIC-24-0004 Attachment 4 Page 1

Regulatory Commitments Revised in Accordance with NEI 99-04 DocuSign Envelope ID: E24BF6ED-5ADA-4368-866A-4228D5586998

LIC-24-0004 Attachment 4 Page 2 Regulatory Commitments Revised in Accordance with NEI 99-04

Commitment. Description Number No commitment revisions during this period DocuSign Envelope ID: E248F6ED-5ADA-4368-866A-4228D5586998

LIC-24-0004 Attachment 5 Page 1

Information Removed from the DSAR DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

LIC-24-0004.

Attachment 5 Page2 Information Removed from the DSAR

.. *-: _EC i';lumber, EC 70840 DSAR Sections 1.2, 2.2, 2.11, and DSAR Figure 2.2-4 were revised to address Exclusion Area Boundary wording and to remove the previous Chapter 14 design basis event bounding calculation FC08790, "Atmospheric Dispersion Factors (X/Qs) at the Decommissioning Exclusion Area Boundary (EAB) for Radiological Releases from Fort Calhoun Station." FC08790 was previously used to bound Emergency Plan and Design basis events (previous Chapter 14 events). The above DSAR sections and figures will be revised to reflect previously approved changes which were implemented by EC 70269 and EC 70558 (ECs reflected in previous Biennial Report, LIC-22-0002). FC08790 will remain an Active Calculation for reference purposes. The Exclusion Area term as described in the DSAR was changed to Controlled Area and Site Area Boundary. The boundaries themselves and descriptions of the areas are unchanged.

Editorial Changes:

DSAR Section 1.11: Added formal reference to FC08566 (HIC Drop)

DSAR Section 1.2: Edited to remove unnecessary detail regarding site buildings and equipment that no longer exist in Decommissioning.

DSAR Figure 1.2-1: Revised to reflect the removal of buildings and structures that no longer exist on site.

DSAR Figure 1.2-3 Made historical and removed from DSAR 1.2 figures.*

DSAR Section 2. 7: Edited to remove unnecessary detail regarding the Groundwater Monitoring Program. Reference to the quality documents Where relevant program details can be found was added. 1 DSAR Section 2.8: Updated to reflect most current U.S. Census data (2020) 2.

DSAR Figure 12.1-1: Made historical and removed from the DSAR figures.

The existina Desian & Licensina Basis is unchanged by this EC.

EC 70729 DSAR Section 1.2: Revised to address GTCC Section to incorporate Greater Than Class C Waste (GTCC) storage in the ISFSI.

DSAR Figure 1.2-1: notes an extension to the haul route required for GTCC.

DSAR Appendix G: notes the storage of the GTCC in the ISFSI.

The existing site Design & Licensing Basis is unchanged by the EC

1* 2 During the preparation of this report, it was identified that a changes to Section 2.7 & Section 2.8 from EC 70840 were not incorporated. This was documented in CR 2024-0025. These changes have been incorporated at the time of this report.

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD5586998

LIC-24-0004 Attachment 6 Page 1

Summary of Technical Specification Basis Changes (TSBC)

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D55B6998

- LIC:-24.,Q_004 -

Attachment 6 Page2

- - TS1;3C No. -. Description : ',..

TS Page(s)"

[Date]

With the submission of Amendment 299 (FCS Submission- (ML 16275A323) LIC-18-0003 and NRG issuance NRC-19-026 (ML 19297D677)), dated December 11, 2019, all Technical Specifications Basis and the requirement to maintain them, have been removed.

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D5586998

LIC-24-0004 Attachment 7 Page 1

Changes, Tests, and Experiments Performed Pursuant to 10 CFR 72.48 DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-4228D5586998

LIC-24-0004 Attachment 7 Page 2 Changes, Tests, and Experiments Performed Pursuant to 10 CFR 72.48

2022 Evaluations (03/01/2022 -12/31/2022)

Note - The 10 CFR72.48 evaluations summarized below are for the most part, unedited summaries as approved by process. As a result, the language may be in future tense.

• Change** Activity Title*_. * *... 72.48 EvaJuation Summary Number* **. ;....22-006 GTCC Phase 2 Fort Calhoun Station uses NUHOMS Horizontal Storage cask systems for the storage of spent nuclear fuel and Greater than Class C (GTCC) on the Independent Spent Fuel Storage Installation (ISFSI) pad. This EC incorporates updates to the plant documentation that supports the licensing basis and design basis for the inclusion of GTCC (Greater than Class C) through the utilization of a RWC (Radiological Waste Canister) to be housed within the previously installed HSMs (Horizontal Storage Module) installed per EC 69797.

2023 Evaluations Note - The 10 CFR72.48 evaluations summarized below are for the most part, unedited summaries as approved by process. As a result, the language may be in future tense.

Chang1; ~ctivity Title 72.48 EvaluatiorrSuminary* *...

-Number;

No 72.48 Evaluations performed, calendar year.

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

LIC-24-0004 Attachment 7 Page 3 Changes, Tests, and Experiments Performed Pursuant to 10 CFR 72.48

2024 Evaluations Note - The 10 CFR72.48 evaluations summarized below are for the most part, unedited summaries as approved by process. As a result, the language may be in future tense.

Change Activity Title, 72A8 Evaluation Summary Number

No 72.48 Evaluations performed as of 2-28-2022.

DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422B055B6998

LIC-24-0004 Attachment 8 Page 1

List of Files on Disk DocuSign Envelope ID: E24BF6ED-5ADA-436B-866A-422BD55B6998

LIC-24-0004 Attachment 8 Page2

1. File Name Size Sensitivitv Level Location Folder 001 DSAR ChanQes from Rev 9.odf 66.2 MB Publiclv Available Disk 1-DSAR 002 DSAR Changes from Rev 10.pdf 92.6 MB Publiclv Available Disk 1-DSAR 003 DSAR Rev 10 Clean.odf 358KB Publiclv Available Disk 1-DSAR 004 DSAR Fiqures Section-01.odf 59 KB Publiclv Available Disk 1-DSAR 005 DSAR Figures Section-02.pdf 1.76 MB Publiclv Available Disk 1-DSAR