LIC-14-0135, Supplement to License Amendment Request (LAR) 14-10; One-Time Extension of Technical Specification Surveillance Requirements

Supplement to License Amendment Request (LAR) 14-10; One-Time Extension of Technical Specification Surveillance Requirements

ML14344B017
Person / Time
Site:	Fort Calhoun
Issue date:	12/10/2014
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-14-0135
Download: ML14344B017 (10)

Text

444 South 16th Street Mall Omaha, NE 68102-2247 10 CFR 50.90 LIC-14-0135 December 10, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),

License Amendment Request (LAR) 14-10, One-Time Extension of Technical Specification Surveillance Requirements, dated November 7, 2014 (LIC 0128) (ML1404311A158)

2. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),

Response to NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-10, One-Time Extension of Technical Specification Surveillance Requirements, dated November 21, 2014 (LIC 0131) (ML14303A465)

SUBJECT:

Supplement to License Amendment Request (LAR) 14-10; One-Time Extension of Technical Specification Surveillance Requirements Pursuant to 10 CFR 50.90, the Omaha Public Power District (OPPD) hereby supplements Reference 1 as a result of a phone call with NRR staff on December 4, 2014. During that call, the NRC noted that it is more appropriate to place the footnote extending the surveillance interval to 28 months on Technical Specification (TS) 3.7(1)c rather than on TS 3.7(1)c.ii(2).

This is because both OP-ST-ESF-0002 Diesel Generator No. 1 and No. 2 Auto Operation and OP-ST-ESF-0015 480 Volt Load Shed must be completed to demonstrate satisfactory overall automatic operation of each diesel system.

To support OPPDs request to extend the surveillance test interval to 28 months on TS 3.7(1)c, to this letter addresses three questions from Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle.

Although OPPD is not requesting to go to a 24-month fuel cycle, the evaluation that would support such a request is applicable to this request as well. The GL provides for extending the time limit for completing these surveillances from the existing limit of 22.5 months to a maximum of 30 months. This letter supplements the information provided in References 1 and 2 but does not expand the scope of the LAR nor change OPPDs answers to the three standards set forth in 10 CFR 50.92, Issuance of amendment.

Employment with Equal Opportunity

U.S. Nuclear Regulatory Commission LIC-14-0135 Page2 As a result of the relocation of the footnote, the markup 3.7-Page 2 and the revised 3.7-Page 2 contained in Attachments 1 and 2 of the Enclosure to Reference 1 are being superseded by the change to 3.7 -Page 1 contained in this letter. Attachment 2 contains a markup of the change to 3.7-Page 1 and Attachment 3 contains the clean (i.e., revised) 3.7-Page 1.

OPPD is withdrawing the change to TS 3.6(3)d proposed in Reference 1. A visual examination of the high-efficiency particulate air (HEPA) and charcoal filters in the containment recirculating air cooling and filtering system to ensure that leak paths do not exist was successfully completed on December 6, 2014. The test was due to expire on December 12, 2014.

No regulatory commitments are contained in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska official.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at (402} 533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on

au louis P. Cortopassi Site Vice President and CNO LPC/mle Evaluation of Proposed Change per the Criteria of Generic Letter 91-04 Markup of Technical Specification Page Retyped ("Clean") Technical Specification Page c

M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-14-0135 Page 1 Evaluation of the Proposed Change per the Criteria of Generic Letter 91-04 Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle Generic Letter (GL) 91-04 Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle notes that improved reactor fuels allow licensees to consider an increase in the duration of the fuel cycle for their facilities. GL 91-04 also notes that the staff has reviewed requests for individual plants to modify surveillance intervals to be compatible with a 24-month fuel cycle. Enclosure 1 to GL 91-04 provides generic guidance for preparing such license amendment requests. Enclosure 2 to GL 91-04 describes information required to address the effect that instrument drift caused by an increased calibration interval can have on safety.

1. Licensees should evaluate the effect on safety of an increase in 18-month surveillance intervals to accommodate a 24-month fuel cycle. This evaluation should support a conclusion that the effect on safety is small.

OPPD Response Generic Letter (GL) 91-04 addresses the justification for increased calibration interval using instrument drift that is projected not to exceed the acceptable limits if allowed to accommodate a 24-month fuel cycle. However, Surveillance Test (ST) OP-ST-ESF-0015 480 Volt Load Test does not involve instrument set point or measurement, thus instrument drift is not a factor.

The purpose of OP-ST-ESF-0015 is to verify certain components associated with the 480 volt load shed circuitry properly respond to the initiation of a safety injection actuation signal (SIAS).

Components that are tested in this Surveillance Test (ST) are control relays, specifically General Electric CR120A relays and HFA relays, which change state from normally de-energized to energized and vice versa during the test. Critical subcomponents of these control relays are the relay coils and contacts. Additionally, certain contacts associated with General Electric HEA (lockout) relays are tested in this ST as a means of initiating an SIAS.

The duration of the relays change of state is not measured during the ST because Technical Specifications 3.7(1)c does not require measuring the time required to load shed. The duration in milliseconds of relay actuation is negligible when compared to Diesel Generator (DG) loading measured in seconds. The milliseconds required for the lockout relays and the load shed relays to change state when applied in the root mean squared total time of load shed contributed by the sequencers is negligible. Thus, lockout/load shed relay actuation time has no impact on DG loading/unloading. This ensures that the DGs will not be overloaded when loads are sequenced onto the bus. Thus, the effect on safety is small as testing ensures that a backup, emergency, on-site power source will be available to mitigate a degraded voltage condition during a design basis accident.

Therefore, OP-ST-ESF-0015 can be extended on a one-time basis to 28 months, which will allow it to be performed during the 2015 refueling outage that begins in April 2015.

OP-ST-ESF-0002 Diesel Generator Number 1 and Number 2 Auto Operation does not require an extension as it is within its test interval.

2. Licensees should confirm that historical plant maintenance and surveillance data support this conclusion.

LIC-14-0135 Page 2 OPPD Response A review of past performances of OP-ST-ESF-0015 found that the lockout relays and auxiliary relays tested by OP-ST-ESF-0015 performed as expected and provided immediate load shed. A review of past performances of OP-ST-ESF-0002, determined that the set points of ESF undervoltage relays used for DG automatic start and load shed were found as expected and would have provided immediate DG start upon the loss or degradation of the respective 4160 V buses.

No new calculations were needed to determine the effect of the extended surveillance interval. The current instrument settings and acceptance limits for DG undervoltage relays were reviewed and extrapolated by graphing and determined to be able to support the requested extension period. The allowable values from Technical Specification (TS) 2.14, Table 2-1, Engineered Safety Features System Initiation Instrument Setting Limits, Item 6.a (4.16 KV Emergency Bus Low Voltage) is 2995.2 +104, -20.8 volts. As can be seen from the tables below, the calculated allowable values and as found trip set points are conservative relative to the Technical Specifications.

Note: the relays were replaced with similar relays before Performance 5 due to reaching end of service life. The new relays are the same physically, electrically, and functionally as the old relays and were tested using the same test procedures, test method, set point, and acceptance criteria as the old relays. Therefore, the tables show as left values for Performance 5.

27-1/D1 Undervoltage Relay 1 for Starting Diesel Generator 1 [OP-ST-ESF-0002]

Calculated Performance 1 Performance Performance Performance 4 Performance 5 as Extrapolated value Allowable as found 2 as found 3 as found as found May left March 2013 Value September 2004 May 2006 May 2009 2011 Optimal 112V 113.0V (at bus 110.0V (at bus 110.3V (at 109.0V (at bus 111.9 (at bus 110.75V (at bus (at bus 3920V) 3955.0V) 3850.0V) bus 3860.5V) 3815.0V) 3916.5V) 3876.25V) acceptable.

Instrument Deviation from Deviation Deviation Deviation from Deviation from Extrapolated Uncertainty optimal from optimal from optimal optimal optimal Deviation Minimum 109V +1.0V (at bus -2.0V (at bus -1.7V (at bus -3.0V (at bus -0.1V (at bus -1.25 (at bus (at bus -105V) +35.0V) -70.0V) -59.5V) -105.0V) -3.5V) acceptable -43.75V) acceptable. acceptable. acceptable. acceptable. acceptable.

Maximum 115V Note (1)

(at bus +105V) 27-2/D1 Undervoltage Relay 2 for Starting Diesel Generator 1 [OP-ST-ESF-0002]

Calculated Performance 1 Performance Performance Performance 4 Performance 5 as Extrapolated value Allowable as found 2 as found 3 as found as found left March 2013 Value September 2004 May 2006 May 2009 May 2011 Optimal 112V 112.0V (at bus 112.0V (at bus 111.7V (at bus 109V (at bus 112.3V (at bus 111.4V (at bus (at bus 3920V) 3920.0V) 3920.0V) 3909.5V) 3815.0V) 3930.5V) 3899.0V) acceptable.

Instrument Deviation from Deviation Deviation Deviation from Deviation from Extrapolated Uncertainty optimal from optimal from optimal optimal optimal Deviation Minimum 109V +0V (at bus +0V) 0V (at bus -0.3V (at bus -3.0V (at bus +0.3V (at bus -0.6V (at bus (at bus -105V) acceptable. +0V) -10.5V) -105.0V) +10.5V) -21.0V) acceptable.

acceptable. acceptable. acceptable. acceptable Maximum 115V Note (1)

(at bus +105V)

Note (1): TS 2.14, Table 2-1 Item 6.a requires that the 4.16 KV emergency bus low voltage be at 2995.2 +104, -20.8 V. The relay voltage 109V representing bus voltage 3815.0 V was 715.8 V higher than the TS value with the upper tolerance, thus the safety margin was maintained. The relay was replaced and functionally tested in March 2013 after this performance, thus assuring reliability and repeatability of the relays.

LIC-14-0135 Page 3 27-1/D2 Undervoltage Relay 1 for Starting Diesel Generator 2 [OP-ST-ESF-0002]

Calculated Performance 1 Performance Performance Performance 4 Performance 5 as Extrapolated value Allowable as found 2 as found 3 as found as found left March 2013 Value April 2006 January 2008 September November 2011 2009 Optimal 112V 112.8V (at bus 111.5V (at bus 110.3V (at bus 110.0V (at bus 112.0V (at bus 111.32V (at bus (at bus 3920V) 3948.0V) 3902.5V) 3860.5V) 3850.0V) 3920.0V) 3896.2V) acceptable.

Instrument Deviation from Deviation Deviation Deviation from Deviation from Extrapolated Uncertainty optimal from optimal from optimal optimal optimal Deviation Minimum 109V +0.8V (at bus -0.5V (at bus -1.7V (at bus -2.0V (at bus +0.0V (at bus -0.68V (at bus (at bus -105V) +28.0V) -17.5V) -59.5V) -70.0V) 0.0V) acceptable -23.8V) acceptable.

acceptable. acceptable. acceptable. acceptable.

Maximum 115V (at bus +105V) 27-2/D2 Undervoltage Relay 2 for Starting Diesel Generator 2 [OP-ST-ESF-0002]

Calculated Performance 1 Performance Performance Performance 4 Performance 5 as Extrapolated value Allowable as found April 2 as found 3 as found as found left March 2013 Value 2006 January 2008 September November 2011 2009 Optimal 112V 112.7V (at bus 111.4V (at bus 110.1V (at bus 112.1V (at bus 112.1V (at bus 111.5V (at bus (at bus 3920V) 3944.5V) 3999.0V) 3853.5V) 3923.5V) 3923.5V) 3902.5V) acceptable.

Instrument Deviation from Deviation Deviation Deviation from Deviation from Extrapolated Uncertainty optimal from optimal from optimal optimal optimal Deviation Minimum 109V +0.7V (at bus -0.6V (at bus -1.9V (at bus +0.1V (at bus +0.1V (at bus -0.5V (at bus (at bus -105V) +24.5V) -21.0V) -66.5V) +3.5V) 3.5V) acceptable -17.5V) acceptable.

acceptable. acceptable. acceptable. acceptable.

Maximum 115V (at bus +105V)

Surveillances tests of ESF load shed and Diesel Generator automatic operations were acceptable for the last four (4) operating cycles and four (4) performances of OP-ST-ESF-0002 and OP-ST-ESF-0015 were successfully completed. Extending the interval of testing of these components from 18 months to 28 months on a one-time basis does not adversely affect the safety of the 480 volt load shed circuitry due to the proven reliability of these components and subcomponents (i.e., relays, relay coils, and relay contacts) as a result of years of use at Fort Calhoun Station (FCS) and in the industry and the redundancy of the circuitry.

3. Licensees should confirm that assumptions in the plant licensing basis would not be invalidated on the basis of performing any surveillance at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle. In consideration of these confirmations, licensees need not quantify the effect of the change in surveillance intervals on the availability of individual systems or components.

OPPD Response Updated Safety Analysis Report (USAR) Section 7.3 Engineered Safeguards Controls and Instrumentation describes the plant design basis for the Engineered Safeguards Control System, including the SIAS. The principal operations that occur coincident with a SIAS include containment isolation, automatic start of diesel generators DG-1 and DG-2, and sequential starting of ESF equipment. This includes load shed of the 480 Volt loads tested by OP-ST-ESF-0015.

Since there is no instrument drift consideration for OP-ST-ESF-0015 (it employs lockout relays and auxiliary load shed relays with actuation time not considered in load shed time) and instrument drift consideration for OP-ST-ESF-0002 demonstrate that safety margin is maintained, the successful past performances of OP-ST-ESF-0015 and OP-ST-ESF-0002 provide a high level of confidence that

LIC-14-0135 Page 4 load shed will occur as required to ensure that the DGs are not overloaded when loads are sequenced back onto the bus.

A historical review of General Electric CR120A, HFA, and HEA relays at FCS has determined that these relays have performed reliably over the years, which has been verified via multiple satisfactory performances of OP-ST-ESF-0015 over the past several years. Additionally, relays that have been determined to have reached their end of service life have been replaced so as to ensure their continued reliability. This ensures that a backup, emergency, on-site power source will be available to mitigate a degraded voltage condition during a design basis accident. As a result, the Engineered Safeguards Control System will perform its design basis function and automatically actuate ESF equipment and essential support systems. Thus, the proposed change does not invalidate assumptions or commitments contained in the plant licensing basis.

LIC-14-0135 Page 1 Markup of Technical Specification Page

[Word-processor mark-ups using double underline/strikeout feature for new text/deleted text respectively.]

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.7 Emergency Power System Periodic Tests Applicability Applies to periodic testing and surveillance requirements of the emergency power system.

Objective To verify that the emergency power system will respond promptly and properly when required.

Specifications The following tests and surveillance shall be performed as stated:

(1) Diesel generators:

a. Each diesel engine shall be started at least once per 31 days on a staggered basis.

The engine shall be run with all protective devices operable. The test shall verify that:

i. The diesel starts and accelerates to idle speed. Following a warm-up period as recommended by the manufacturer, the diesel generator will be accelerated to rated speed and voltage.

However, at least once per 184 days in these surveillance tests, the diesel generator shall demonstrate that it can be started and accelerated to rated speed and voltage in less than or equal to 10 seconds without a prior warm-up.

The signal initiated to start the diesel shall be varied from one test to another to verify all manual and auto start circuits.(1) ii. With the diesel running at rated speed and voltage, the generator shall be synchronized with the 4.16 KV bus and the diesel breaker manually closed from the electrical control board. The generator shall then be loaded to at least the continuous(2) KW rating and run for at least 60 minutes before being off-loaded and the diesel breaker tripped.

b. The auto-start initiating circuit for each diesel shall be tested prior to each plant startup if not done during the previous week.

c. Tests shall be conducted during each refueling outage to demonstrate the satisfactory overall automatic operation of each diesel system. This test shall be conducted by:(*)

(*)

During PLANT OPERATING CYCLE 27 only, the maximum allowed surveillance test interval shall not exceed 28 months.

3.7 - Page 1 Amendment No. 41,111,140

LIC-14-0135 Page 1 Retyped (Clean) Technical Specification Page

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.7 Emergency Power System Periodic Tests Applicability Applies to periodic testing and surveillance requirements of the emergency power system.

Objective To verify that the emergency power system will respond promptly and properly when required.

Specifications The following tests and surveillance shall be performed as stated:

(1) Diesel generators:

a. Each diesel engine shall be started at least once per 31 days on a staggered basis.

The engine shall be run with all protective devices operable. The test shall verify that:

i. The diesel starts and accelerates to idle speed. Following a warm-up period as recommended by the manufacturer, the diesel generator will be accelerated to rated speed and voltage.

However, at least once per 184 days in these surveillance tests, the diesel generator shall demonstrate that it can be started and accelerated to rated speed and voltage in less than or equal to 10 seconds without a prior warm-up.

The signal initiated to start the diesel shall be varied from one test to another to verify all manual and auto start circuits.(1) ii. With the diesel running at rated speed and voltage, the generator shall be synchronized with the 4.16 KV bus and the diesel breaker manually closed from the electrical control board. The generator shall then be loaded to at least the continuous(2) KW rating and run for at least 60 minutes before being off-loaded and the diesel breaker tripped.

b. The auto-start initiating circuit for each diesel shall be tested prior to each plant startup if not done during the previous week.

c. Tests shall be conducted during each refueling outage to demonstrate the satisfactory overall automatic operation of each diesel system. This test shall be conducted by:(*)

(*)

During PLANT OPERATING CYCLE 27 only, the maximum allowed surveillance test interval shall not exceed 28 months.

3.7 - Page 1 Amendment No. 41,111,140