LIC-04-0076, License Amendment Request, Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Monitors Using the Consolidated Line Item Improvement Process

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License Amendment Request, Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Monitors Using the Consolidated Line Item Improvement Process
ML042530458
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 09/08/2004
From: Ridenoure R
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-04-0076
Download: ML042530458 (12)
v • d • e


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Omaha Public Power District 444 South 16th Street Mall Omaha NE 68102-2247 September 8,2004 LIC-04-0076 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

Docket No. 50-285

SUBJECT:

Fort Calhoun Station Unit No. 1 License Amendment Request, Application For Technical Specification Improvement to Eliminate Requirements For Hydrogen Monitors Using the Consolidated Line Item Improvement Process Pursuant to 10 CFR 50.90, Omaha Public Power District (OPPD) hereby proposes to make changes to the Fort Calhoun Station (FCS) Technical Specifications (TS).

The proposed amendment will delete the TS requirements related to hydrogen monitors in TS Table 2-10 Item 4 and TS Table 3-3 Item 26. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors, that became effective on September 16,2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors. The availability of this TS improvement was announced in the Federal Register on September 25,2003 as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides revised, clean TS pages. Implementation of TSTF-447 also involves various changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with TS 5.20, Technical Specifications (TS) Bases Control Program.

OPPD requests approval of the proposed amendment by April 15, 2005. OPPD requests 120 days to implement this amendment. The following commitment is made to the NRC in this letter:

OPPD has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at FCS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be maintained as non-safety-related equipment and they shall be included in the Updated Safety Analysis Report (USAR).

This regulatory commitment will be completed by the implementation date.

Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission Page 2 LIC-04-0076 In accordance with 10 CFR 50.91, a copy of this application is being submitted to the designated Nebraska State Official.

I declare under penalty of perjury that the foregoing is true and correct. (Executed on September 8,2004)

If you have any questions or require additional information, please contact Thomas R. Byrne at (402) 533-7368.

Attachments:

1.

Omaha Public Power District Evaluation

2.

Markup of Technical Specification Pages

3.

Proposed Technical Specifications (clean)

C:

Division Administrator - Public Health Assurance, State of Nebraska

LIC-04-0076 Page 1 1.o 2.0 3.0 4.0 5.O 6.0 7.0 8.0 9.0 ATTACHMENT 1 Omaha Public Power District Evaluation for Amendment of Operating License INTRODUCTION DESCRIPTION OF PROPOSED AMENDMENT BACKGROUND REGULATORY REQUIREMENTS & GUIDANCE TECHNICAL ANALYSIS REGULATORY ANALYSIS NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

ENVIRONMENTAL CONSIDERATION PRECEDENCE

10.0 REFERENCES

LIC-04-0076 Page 2 Omaha Public Power District Evaluation For Amendment of Operating License 1.O INTRODUCTION The proposed License amendment deletes Technical Specification (TS) TS Table 2-10, Item 4 and TS Table 3-3, Item 26 related to hydrogen monitors for Fort Calhoun Station Unit No. 1 (FCS). The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-cooled Power Reactors, that became effective on September 16,2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors. The availability of this TS improvement was announced in the Federal Register on September 25,2003 as part of the consolidated line item improvement process (CLIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

0 TS Table 2-10, Item 4 - Deleted TS Table 3-3, Item 26 - Deleted No changes to the FCS TS Bases are required to implement these changes.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25,2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25,2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

LIC-04-0076 Page 3

5.0 TECHNICAL ANALYSIS

The Omaha Public Power District (OPPD) has reviewed the safety evaluation (SE) published on September 25,2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447. OPPD has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to FCS and justify this amendment for the incorporation of the changes to the FCS TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25,2003 (68 FR 5416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25,2003 (68 FR 55416) for this TS improvement, OPPD is making the following verifications and regulatory commitments:

1. OPPD has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at FCS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be maintained as non-safety-related equipment and they shall be included in the Updated Safety Analysis Report (USAR).

This regulatory commitment will be completed by the implementation date.

2. FCS does not have an inerted containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION OPPD has reviewed the proposed no significant hazards consideration determination published on September 25,2003 (68 FR 55416) as part of the CLIIP. OPPD has concluded that the proposed determination presented in the notice is applicable to FCS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

9.0 ENVIRONMENTAL EVALUATION OPPD has reviewed the environmental evaluation included in the model SE published on September 25,2003 (68 FR 55416) as part of the CLIIP. OPPD has concluded that the staffs findings presented in that evaluation are applicable to FCS and the evaluation is hereby incorporated by reference for this application.

LIC-04-0076 Page 4 9.0 PRECEDENT This application is being made in accordance with the CLIIP. OPPD is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staffs model SE published on September 25,2003 (68 FR 55416).

10.0 REFERENCES

10.1 Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25,2003, (68 FR 55416).

LIC-04-0076 Page 1 ATTACHMENT 2 Markup of Technical Specification Pages

TECH N I CAL SPEC I F I CAT I0 N S TABLE 2-10 Instrument Post-Accident Monitoring Instrumentation Operating Limits

1. Containment Wide Range Radiation Monitors (RM-O91A & B)
2. Wide Range Noble Gas Stack Monitor RM-063 (Noble Gas Portion Only)
3. Main Steam Line Radiation Monitor (RM-064)

Minimum 0 pera ble Channels Action

4.

L 3

/h)o

5. Containment Water Level Narrow Range (LT-599 & LT-600)

Wide Range (LT-387 & LT-388)

I 2

6. Containment Wide Range Pressure 2

(b)(c)

7. Reactor Coolant System Subcooled Margin Monitor 2

( N f )

8. Core Exit Thermocouples (i) 2/Core Quadrant (g)(h)
9. Reactor Vessel Level (HJTC) (j) 2 (k)(l)

(a) With the number of OPERABLE channels less than required by the minimum channels operable requirements, initiate the pre-planned alternate method of monitoring the appropriate parameter(s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and

1. either restore the inoperable channel(s) to OPERABLE status within 7 days of the event, or
2. prepare and submit a special report to the Commission pursuant to specification 5.9.3 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedules for restoring the system to OPERABLE status.

(b) With one channel inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

TECHNICAL S PECl Fl CAT1 ONS TABLE 3-3 (Continued)

MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TESTING OF MISCELLANEOUS INSTRUMENTATION AND CONTROLS Channel Description

25.

Containment Purge Isolation Valves (PCV-742A, B, C, & D)

Su rvei I I an ce Function Frequency Surveillance Method

a. Check M
a. Verify valve position using control room indication.
27.

Containment Water Level Narrow Range (LT-599

& LT-600)

Wide Range (LT-387 &

LT-388)

28.

Containment Wide Range Pressure Indication

29.

Toxic Gas Detectors:

YIS-6287A&B (NH3)

a. Check
b. Calibrate
a. Check
b. Calibrate
a. Check
b. Calibrate
a. Check M
a. CHANNEL CHECK R
b. CHANNEL CALIBRATION M
a. CHANNEL CHECK R
b. CHANNEL CALIBRATION M
a. CHANNEL CHECK R
b. CHANNEL CALIBRATION S
a. Comparison of readings from redundant channels.
b. Calibrate Q
b. Gas calibration.

3.1 - Page 19 Amendment No. 54$%,82,87,1 !X,? 82, 183

LIC-04-0076 Page 1 ATTACHMENT 3 Proposed Technical Specification Pages (clean)

TABLE 2-10 Post-Accident Monitorinq Instrumentation Operating Limits Minimum Operable Instrument Channels

1. Containment Wide Range Radiation 2

Monitors (RM-O91A & B)

2. Wide Range Noble Gas Stack Monitor RM-063 (Noble Gas Portion Only)
3. Main Steam Line Radiation Monitor 1

1 (RM-064)

4. Not Used
5. Containment Water Level Narrow Range (LT-599 & LT-600)

Wide Range (LT-387 & LT-388)

6. Containment Wide Range Pressure 1

2 2

2 2/Core Quadrant 2

7. Reactor Coolant System Subcooled Margin Monitor
8. Core Exit Thermocouples (i)
9. Reactor Vessel Level (HJTC) (j)

(a) With the number of OPERABLE channels less than required by the minimum channels operable requirements, initiate the pre-planned alternate method of monitoring the appropriate parameter(s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and

1. either restore the inoperable channel(s) to OPERABLE status within 7 days of the event, or
2. prepare and submit a special report to the Commission pursuant to specification 5.9.3 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedules for restoring the system to OPERABLE status.

(b)

With one channel inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2.21 - Page 3 Amendment No. -W,!!?,W4

TABLE 3-3 (Continued)

25.
26.
27.
28.
29.

Channel Description Containment Purge Isolation Valves (PCV-742Al B, C, & D)

MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TESTING OF MISCELLANEOUS INSTRUMENTATION AND CONTROLS Not Used Containment Water Level Narrow Range (LT-599

& LT-600)

Wide Range (LT-387 &

LT-388)

Containment Wide Range Pressure Indication Toxic Gas Detectors:

YIS-6287A&B (NH3)

Su rvei I lance Function

a. Check
a. Check
b. Calibrate
a. Check
b. Calibrate
a. Check
b. Calibrate
a. Check
b. Calibrate Frequency M

a M

a R

b.

Surveillance Met hod Verify valve position using control room indication.

CHANNEL CHECK CHANNEL CALIBRATION M

a. CHANNEL CHECK R
b. CHANNEL CALIBRATION M
a. CHANNEL CHECK R
b. CHANNEL CALIBRATION S
a. Comparison of readings from redundant channels.

Q

b. Gas calibration.

3.1 - Page 19 Amendment No. 54+8&2,87,3 c17,182, 2 83

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