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| Therefore, based on the discussions with the NRC, OPPD is extending the commitment to transition to NFPA 805 until the alternative methods are approved by the industry review panel and the impact, if any, can be determined and incorporated into the FCS fire PRA model. OPPD will submit the LAR for transitioning to NFPA 805 no later than 90 days after the industry review panel completes its reviews of the alternative methods. | | Therefore, based on the discussions with the NRC, OPPD is extending the commitment to transition to NFPA 805 until the alternative methods are approved by the industry review panel and the impact, if any, can be determined and incorporated into the FCS fire PRA model. OPPD will submit the LAR for transitioning to NFPA 805 no later than 90 days after the industry review panel completes its reviews of the alternative methods. |
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| U.S. Nuclear Regulatory Commission LI C-11-0054 Page 3 As a result of the extension to the commitment for submitting the LAR for transitioning to NFPA 805 at FCS, it is also necessary to extend the existing enforcement discretion in accordance with the NRC's Enforcement Policy as discussed in Reference | | U.S. Nuclear Regulatory Commission LI C-11-0054 Page 3 As a result of the extension to the commitment for submitting the LAR for transitioning to NFPA 805 at FCS, it is also necessary to extend the existing enforcement discretion in accordance with the NRC's Enforcement Policy as discussed in Reference |
| : 7. As stated in Reference 7, OPPD understands that until such time as the Commission's decision on the revisions to the Enforcement Policy is enshrined in a resultant Staff Requirements Memorandum, the current enforcement discretion should be extended. | | : 7. As stated in Reference 7, OPPD understands that until such time as the Commission's decision on the revisions to the Enforcement Policy is enshrined in a resultant Staff Requirements Memorandum, the current enforcement discretion should be extended. |
| Based on the revised NFPA 805 Transition LAR submittal commitment date, enforcement discretion should be extended accordingly. | | Based on the revised NFPA 805 Transition LAR submittal commitment date, enforcement discretion should be extended accordingly. |
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Category:Letter type:LIC
MONTHYEARLIC-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 LIC-18-0027, Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update2018-10-0303 October 2018 Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update LIC-18-0003, License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool2018-09-28028 September 2018 License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool LIC-18-0025, Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 20192018-07-19019 July 2018 Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 2019 LIC-18-0023, Fort Calhoun Station, Unit 1 Request for Partial Site Release2018-06-29029 June 2018 Fort Calhoun Station, Unit 1 Request for Partial Site Release LIC-18-0021, Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan)2018-06-0606 June 2018 Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan) LIC-18-0017, Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy2018-04-26026 April 2018 Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy 2023-08-24
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Text
Employment with Equal Opportunity
444 South 16 th Street Mall Omaha, NE 68102-2247 LIC-11-0054
June 9, 2011
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk
Washington, D.C. 20555-0001
References:
- 1. Docket No. 50-285 2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Letter of Intent to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," dated June 9, 2008 (LIC-08-0069) (ML081620232) 3. NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Electric Power Research Institute - EPRI 1011989, Final Report, September 2005 4. NUREG/CR-6850, Supplement 1, Fire Probabilistic Risk Assessment Methods Enhancements, Supplement 1 to NUREG/CR-6850 and EPRI 1011989, Electric Power Research Institute - EPRI 1019259, Technical Report, September 2010 5. NRC Memorandum, "Forthcoming Pre-Licensing Teleconference with Omaha Public Power District (TAC No. ME6242)," dated May 16, 2011 (NRC-11-0050) (ML111330643) 6. Teleconference between NRC (L. E. Wilkins, et. al.) and OPPD (B. R.
Hansher, et. al.), NRC Relay of Information to OPPD on NFPA 805 Transition LAR Pre-Submittal Teleconference Presentation Slide 16 , May 27, 2011 7. NRC Staff Requirements Memorandum, SRM-SECY-11-0033, "Proposed NRC Staff Approach to Address Resource Challenges Associated with Review of a Large Number of NFPA 805 License Amendment Requests,"
dated April 20, 2011
SUBJECT:
Notification of Extension of Commitment to Submit License Amendment Request (LAR) to Adopt NFPA 805 and Status Change of Enforcement Discretion at Fort Calhoun Station (FCS), Unit No. 1 The Omaha Public Power District (OPPD) is notifying the Nuclear Regulatory Commission (NRC) of its extension of the June 9, 2011, commitment to submit the license amendment request (LAR) to adopt National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. In Reference 2, OPPD submitted its letter of intent to adopt NFPA 805 at Fort Calhoun Station (FCS), Unit No. 1.
U.S. Nuclear Regulatory Commission LIC-11-0054
Page 2
According to Reference 2, it was expected to take approximately 36 months to develop the NFPA 805 transition LAR; thus, OPPD requested enforcement discretion for 36 months. This enforcement discretion expires on June 9, 2011, and should be extended in accordance with the NRC's Enforcement Policy as discussed in Reference 7.
As requested by the NRC in Reference 5, on May 26, 2011, OPPD participated in a public pre-licensing teleconference with the NRC to discuss the NFPA 805 transition LAR. Subsequent to the pre-licensing teleconference, the NRC requested a follow-up teleconference with OPPD staff in order to relay additional information related to slide 16 of the presentation slides provided during the Reference 5 teleconference. Per discussion with Messrs. Donnie Harrison and Alex Klein during the follow-up teleconference on May 27th (Reference 6), the NRC indicated that it would be a more efficient use of the NRC resources as discussed in Reference 7, if the NRC's review of the LAR submittal did not include review of alternative fire probabilistic risk assessment (PRA) methods.
Prior to LAR submittal, the alternative methods will be reviewed by the Industry New Methods Peer Review Panel to demonstrate thei r acceptability for use in a fire PRA.
OPPD used NUREG/CR-6850 (Reference 3) and NUREG/CR-6850, Supplement 1 (Reference 4), in the development of the fire PRA model and the NFPA 805 transition LAR. Reference 4 states, in part, "Although these FAQs [frequently asked questions] represent interim solutions, it should be noted that not all solutions require longer-term research to develop a lasting and more complete solution. In addition, EPRI 1011989, NUREG/CR-6850 represents one way to develop a fire PRA. Alternative methods may be acceptable provided they can be supported by the state of the art in fi re PRA model development."
OPPD used the draft version of frequently asked question (FAQ) 08-0050, Non-Suppression Probability, which was the version available at the time the fire PRA task was being performed. The current FAQ version, incorporated in NUREG/CR-6850, Supplement 1, was reviewed and it is qualitatively judged that implementation of this version will not impact the conclusions of the LAR. This judgment is primarily based on the low frequency of fire events where the FCS fire PRA credits manual suppression.
In addition to the draft FAQ 08-0050, OPPD used three alternative methods in the development of the FCS fire PRA model for severity factor/non-suppression probability for electrical cabinets; pump fire frequency; and diesel generator severity factor/non-suppression probability.
Therefore, based on the discussions with the NRC, OPPD is extending the commitment to transition to NFPA 805 until the alternative methods are approved by the industry review panel and the impact, if any, can be determined and incorporated into the FCS fire PRA model. OPPD will submit the LAR for transitioning to NFPA 805 no later than 90 days after the industry review panel completes its reviews of the alternative methods.
U.S. Nuclear Regulatory Commission LI C-11-0054 Page 3 As a result of the extension to the commitment for submitting the LAR for transitioning to NFPA 805 at FCS, it is also necessary to extend the existing enforcement discretion in accordance with the NRC's Enforcement Policy as discussed in Reference
- 7. As stated in Reference 7, OPPD understands that until such time as the Commission's decision on the revisions to the Enforcement Policy is enshrined in a resultant Staff Requirements Memorandum, the current enforcement discretion should be extended.
Based on the revised NFPA 805 Transition LAR submittal commitment date, enforcement discretion should be extended accordingly.
Attachment 1 provides the one regulatory commitment being made in this letter. OPPD will submit the license amendment request for transitioning to NFPA 805 no later than 90 days from the industry review panel's completion of its review of the final alternative method proposed in the development of the FCS fire PRA model. If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at 402-533-6894.
Sincerely, er Division Manager -Nuclear Construction and Projects HJF/JLM/dll
Attachment:
- 1. Regulatory Commitment c: E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector LIC-11-0054
Page 1
REGULATORY COMMITMENT
Commitment(s) / Scheduled Completion Date OPPD will submit the license amendment request for transitioning to NFPA 805 no later than 90 days from the industry review panel's completion of its review of the final alternative method proposed in the development of the FCS fire PRA model. [
AR 48249].