LIC-05-0075, Response to Request for Additional Information on the License Amendment Request, Revisions of Technical Specifications Table 1-1 and Section 4.0

Response to Request for Additional Information on the License Amendment Request, Revisions of Technical Specifications Table 1-1 and Section 4.0

ML051920034
Person / Time
Site:	Fort Calhoun  (DPR-040)
Issue date:	07/08/2005
From:	Faulhaber H Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-05-0075
Download: ML051920034 (23)

Text

Omaha Public Power Disfrict 444 South 16th Street Mall Omaha NE 68102-2247 July 8,2005 LIC-05-0075 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

References:

1.

Docket No. 50-285

2.

Letter from David J. Bannister (OPPD) to Document Control Desk (NRC) dated November 23, 2004, Fort Calhoun Station Unit No. 1, License Amendment Request, Revisions of Technical Specifications Table 1-1 and Section 4.0 (LIC-04-0117)

SUBJECT:

Fort Calhoun Station Unit No. 1, Response to Request for Additional Information on the License Amendment Request, Revisions of Technical Specifications Table 1-1 and Section 4.0 In Reference 2, the Omaha Public Power District (OPPD) requested amendments to the Fort Calhoun (FCS) Technical Specifications in support of operation of FCS after major components (steam generators, pressurizer, and reactor vessel head) are replaced in 2006. In subsequent conversations with the NRR Project Manager, clarifications to the proposed changes to Technical Specification 4.3.1 were requested and are being provided as attachments to this letter. Specifically, OPPD proposes reworded versions of Technical Specifications 4.3.1.1.e, 4.3.1.1.f, 4.3.1.1.g, 4.3.1.2.b and 4.3.1.2.c to replace the corresponding Technical Specifications proposed in Reference 2. These revised Technical Specifications reflect plant-specific nomenclature for the FCS spent fuel pool (consistent with existing Technical Specification Figure 2-1 0), and licensing basis for the existing new fuel storage racks. These changes therefore supersede the Reference 2 wording that originated in NUREG-1432, Revision 3, Standard Technical Specifications to Combustion Engineering Plants.

These clarifications to Reference 2 are enclosed as Attachments 1 and 2, replacement Markup and Clean Copies, respectively, of the proposed Technical Specifications and Attachment 3, the replacement to Table 2, Administrative Changes to Standard Technical Specifications.

Employment with Equal Opportunity 4171

U. S. Nuclear Regulatory Commission Page 2 LIC-05-0075 I declare under penalty of perjury that the forgoing is true and correct. (Executed on July 8,2005.)

If you have any questions or require additional information, please contact Tom Matthews at (402) 5 3 3 -693 8.

Sincerely, Division Manager Nuclear Engineering H JF/RLJ/rlj Attachments:

1. Replacement Markup of Technical Specification Pages

2. Replacement Clean Copy of Technical Specification Pages

3. Replacement Table 2: Administrative Changes to Standard Technical Specifications

LIC-05-0075 Page 1 Replacement Markup of Technical Specification Pages

TECHNICAL SPECIFICATION TABLE OF CONTENTS (Continued) 2.13 2.14 2.15 2.16 2.17 2.18 2.19 2.20 2.21 2.22 DELETED Engineered Safety Features System Initiation Instrumentation Settings Instrumentation and Control Systems River Level Miscellaneous Radioactive Material Sources DELETED DELETED Steam Generator Coolant Radioactivity Post-Accident Monitoring Instrumentation Toxic Gas Monitors 3.0 SURVEILLANCE REQUIREMENTS 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.1 1 3.12 3.13 3.14 3.15 3.16 3.17 Instrumentation and Control Equipment and Sampling Tests Reactor Coolant System and Other Components Subject to ASME XI Boiler and Pressure Vessel Code Inspection and Testing Surveillance DELETED Containment Test Safety Injection and Containment Cooling Systems Tests Emergency Power System Periodic Tests Main Steam Isolation Valves Auxiliary Feedwater System Reactor Core Parameters DELETED Radioactive Waste Disposal System Radioactive Material Sources Surveillance DELETED DELETED Residual Heat Removal System Integrity Testing Steam Generator Tubes 4.0 DESIGN FEATURES 4.1 Site 4.2 4 2.2 Dr\\-

4.3 TOC - Page 2 Amendment No. 1?

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230

TECH N I CAL SPEC IF I CAT1 0 N TABLE OF CONTENTS (Continued) 5.0 ADMINISTRATIVE CONTROLS 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 5.1 1 5.12 5.13 5.14 5.15 5.16 5.17 5.18 5.19 5.20 5.21 Responsibility Organization Facility Staff Qualifications Training Review and Audit 5.5.1 Plant Review Committee (PRC) 5.5.2 Reportable Event Action Safety Limit Violation Procedures Reporting Requirements 5.9.1 Routine Reports 5.9.2 Reportable Events 5.9.3 Special Reports 5.9.4 Unique Reporting Requirements 5.9.5 Core Operating Limits Report 5.9.6 Record Retention Radiation Protection Program DELETED Secondary Water Chemistry Systems Integrity Post-Accident Radiological Sampling and Monitoring Radiological Effluents and Environmental Monitoring Programs 5.16.1 Radioactive Effluent Controls Program 5.1 6.2 Offsite Dose Calculation Manual (ODCM)

Process Control Program (PCP)

Containment Leakage Rate Testing Program Technical Specification (TS) Bases Control Program Containment Tendon Testing Program Safety Audit and Review Committee (SARC)

RCS Pressure-Temperature Limits Report (PTLR)

Radiological Environmental Monitoring Program 6.0 INTERIM SPECIAL TECHNICAL SPECIFICATIONS 6.1 DELETED 6.2 DELETED 6.3 DELETED 6.4 DELETED TOC - Page 3 Amendment No.

-!,?52,-*

221

TECH N I CAL SPEC I F I CAT1 0 N S 4.0 DESIGN FEATURES 4.1 Site The site for Fort Calhoun Station Unit No. 1 is in Washington County, Nebraska, on the west bank of the Missouri River and approximately nineteen miles north, northwest of the city of Omaha, Nebraska. The exclusion area, as defined in 10 CFR Part 100, Section 100.3(a), consists of appraximately 1242 acres. The exclusion area boundary extent includes approximately 660 acres in Washington County, Nebraska, owned by the Omaha Public Power District (OPPD), and 582 acres in Harrison County, Iowa, on the east bank of the river directly opposite the facility, on which the District retains perpetual easement rights. The minimum exclusion area boundary point is located approximately at the 187.0 degree radial from the outer wall of the containment building and at a distance of 91 0 meters.

TECH N I CAL SPEC I F I CAT1 0 N S 4.0 DESIGN FEATURES (Continued)

TECHNICAL SPECIFICATIONS 4.0 DESIGN FEATURES (Continued)

TECH N I CAL SPEC I F I CAT1 0 NS

TECH N I CAL SPEC1 Fl CAT1 ONS 4.2.3 c c

TECH N I CAL SPEC I F I CAT1 ON S

TECHNICAL SPEC I F I CAT1 ON S

. I.,

A 1 -

I CII-4.4.2 I

TECH N I CAL SPEC I F I CAT I0 N S

TECH N I CAL S PECl F I CAT1 0 N S TABLE 1-1 No.

1 -

2 3

7 8

9 RPS LIMITING SAFETY SYSTEM SETTINGS Reactor Trip Trip Setpoints High Power Level (A) 4-Pump Operation Low Reactor Coolant Flow (B)(F) 4-Pump Operation Low Steam Generator Water Level Low Steam Generator Pressure (C)

High Pressurizer Pressure Thermal Margin/Low Pressure (B)(F)

High Containment Pressure (D)

Axial Power Distribution (E)

Steam Generator Differential Pressure

<109.0% of Rated Power

>95% of 4 Pump Flow 31.2% of Scale F

>500 psia

<2400 psia 1750 psia to 2400 psia (depending on the reactor coolant temperature as shown in the Thermal Margin/Low Pressure 4 Pump Operation Figure provided in the COLR)

<5 psig (as shown in the Axial Power Distribution for 4 Pump Operation Figure provided in the COLR)

< I 35 psid 1.0 - Page 11 Amendment No. &3&47,77,92,!4WXI, 210

LIC-05-0075 Page 1 Replacement Clean Copy of Technical Specification Pages

TECHNICAL SPECIFICATION TABLE OF CONTENTS (Continued) 2.13 2.14 2.15 2.16 2.17 2.18 2.19 2.20 2.21 2.22 DELETED Engineered Safety Features System Initiation Instrumentation Settings Instrumentation and Control Systems River Level Miscellaneous Radioactive Material Sources DELETED DELETED Steam Generator Coolant Radioactivity Post-Accident Monitoring Instrumentation Toxic Gas Monitors 3.0 SURVEILLANCE REQUIREMENTS 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.1 1 3.12 3.13 3.14 3.15 3.16 3.17 Instrumentation and Control Equipment and Sampling Tests Reactor Coolant System and Other Components Subject to ASME XI Boiler and Pressure Vessel Code Inspection and Testing Surveillance DELETED Containment Test Safety Injection and Containment Cooling Systems Tests Emergency Power System Periodic Tests Main Steam Isolation Valves Auxiliary Feedwater System Reactor Core Parameters DELETED Radioactive Waste Disposal System Radioactive Material Sources Surveillance DELETED DELETED Residual Heat Removal System Integrity Testing Steam Generator Tubes 4.0 DESIGN FEATURES 4.1 Site 4.2 Reactor Core 4.3 Fuel Storage TOC - Page 2 Amendment No. ! ! 322,-

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230

TECH N I CAL SPEC I F I CAT I 0 N TABLE OF CONTENTS (Continued) 5.0 ADMINISTRATIVE CONTROLS 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 5.1 1 5.12 5.13 5.14 5.15 5.16 5.17 5.18 5.19 5.20 5.21 Responsibility Organization Facility Staff Qualifications Training Review and Audit 5.5.1 Plant Review Committee (PRC) 5.5.2 Reportable Event Action Safety Limit Violation Procedures Reporting Requirements 5.9.1 Routine Reports 5.9.2 Reportable Events 5.9.3 Special Reports 5.9.4 Unique Reporting Requirements 5.9.5 Core Operating Limits Report 5.9.6 Record Retention Radiation Protection Program DELETED Secondary Water Chemistry Systems integrity Post-Accident Radiological Sampling and Monitoring Radiological Effluents and Environmental Monitoring Programs 5.16.1 Radioactive Effluent Controls Program 5.16.2 Radiological Environmental Monitoring Program Offsite Dose Calculation Manual (ODCM)

Process Control Program (PCP)

Containment Leakage Rate Testing Program Technical Specification (TS) Bases Control Program Containment Tendon Testing Program Safety Audit and Review Committee (SARC)

RCS Pressure-Temperature Limits Report (PTLR) 6.0 INTERIM SPECIAL TECHNICAL SPECIFICATIONS 6.1 DELETED 6.2 DELETED 6.3 DELETED 6.4 DELETED

TECH N I CAL S PECl F I CAT1 ON S 4.0 DESIGN FEATURES 4.1 Site The site for Fort Calhoun Station Unit No. 1 is in Washington County, Nebraska, on the west bank of the Missouri River and approximately nineteen miles north, northwest of the city of Omaha, Nebraska. The exclusion area, as defined in I 0 CFR Part 100, Section 100.3(a), consists of approximately 1242 acres. The exclusion area boundary extent includes approximately 660 acres in Washington County, Nebraska, owned by the Omaha Public Power District (OPPD), and 582 acres in Harrison County, Iowa, on the east bank of the river directly opposite the facility, on which the District retains perpetual easement rights. The minimum exclusion area boundary point is located approximately at the 187.0 degree radial from the outer wall of the containment building and at a distance of 910 meters.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 133 fuel assemblies. Each assembly shall consist of a matrix of Zircalloy or ZIRLO fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UOp) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4.2.2 Control Element Assemblies The reactor core shall contain 49 control element assemblies (CEAs). The control material shall be silver indium cadmium, boron carbide, or hafnium metal as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.I The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent,

b. k,ff I 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.5 of the USAR, 4.0 - Page 1 Amendment No. 36

TECH N I CAL SPEC I F I CAT1 0 NS 4.0 DESIGN FEATURES (Continued)

c. A nominal 8.6 inch center to center distance between fuel assemblies placed in Region 2, the high density fuel storage racks,

d. A nominal 9.8 inches (East-West) by 10.3 inches (North South) center to center distances between fuel assemblies placed in Region 1, the low density fuel storage

racks,

e. New or partially spent fuel assemblies with a discharge burnup in the acceptable domain of Figure 2-1 0 for Region 2 Unrestricted may be allowed unrestricted storage in any of the Region 2 fuel storage racks in compliance with Reference (I),

f. Partially spent fuel assemblies with a discharge burnup between the acceptable domain and Peripheral Cells of Figure 2-1 0 may be allowed unrestricted storage in the peripheral cells of the Region 2 fuel storage racks in compliance with Reference (1 ),

g. New or partially spent fuel assemblies with a discharge burnup in the unacceptable domain of Figure 2-10 will be stored in Region 1 in compliance with Reference (1).

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight

percent,

b. kefi 10.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Reference (2).

c. kefi 20.98 if moderated by aqueous foam, which includes an allowance for uncertainties as described in Reference (2).

d. A nominal 16 inch center to center distance between fuel assemblies placed in the storage racks.

References:

(1)

Letter from R. Wharton (NRC) to T. Patterson (OPPD), Amendment 174 to Facility Operating License No. DPR-40, (TAC NO. M94789) Dated July 30, 1996, NRC-96-0126.

(2)

Ft. Calhoun USAR, Reference 9.5-1 4.0 - Page 2

TECH N I CAL SPEC I F I CAT1 ON S 4.0 DESIGN FEATURES (Continued) 4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 23 ft.

4.3.3 The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1083 fuel assemblies.

4.0 - Page 3

TECHNICAL SPECIFICATIONS TABLE 1-1 RPS LIMITING SAFETY SYSTEM SETTINGS No.

1 2

7 8

9 Reactor Trip High Power Level (A) 4-Pump Operation Low Reactor Coolant Flow (B)(F) 4-Pump Operation Low Steam Generator Water Level Low Steam Generator Pressure (C)

High Pressurizer Pressure Thermal Margin/Low Pressure (B)(F)

High Containment Pressure (D)

Axial Power Distribution (E)

Steam Generator Differential Pressure 1.0 - Page 11 Trip Setpoints

<109.0% of Rated Power

>95% of 4 Pump Flow 31.2% of Scale

>500 psia

~2400 psia 1750 psia to 2400 psia (depending on the reactor coolant temperature as shown in the Thermal Margin/Low Pressure 4 Pump Operation Figure provided in the COLR)

<5 psig (as shown in the Axial Power Distribution for 4 Pump Operation Figure provided in the COLR)

- <I 35 psid Amendment No. -

210

LIC-05-0075 Page 1 Replacement Table 2 Administrative Changes to Standard Technical Specifications

LIC-05-0075 Page 2 Affected FCS Technical Specification 4.3.1.l.c and 4.3.1.1.d 4.3.1.1.e 4.3.1.1.f 4.3.1.1.g 4.3.1.2.b TABLE 2: ADMINISTRATIVE CHANGES TO STANDARD TECHNICAL SPECIFICATIONS Summary of Change FCS Technical Specifications 4.3.1.1.c and 4.3.1.1.d are revised from the STS to include Region 2 and Region l, respectively, to assure consistent nomenclature of the high and low density fuel storage racks to be consistent with the nomenclature presented on existing FCS TS Figure 2-10.

FCS TS 4.3.1.1.e is revised from the 4.3.1.1.e STS wording as follows: 1) acceptable range is changed to acceptable domain, 2) Figure [3.7.18.1] is changed to Figure 2-10 for Region 2 Unrestricted, 3) [either] is replaced with any of the Region 2, and 4) after storage rack(s) add in compliance with Reference (l),, to specify: 1) where the spent fuel falling within this burnup domain will be stored, 2) incorporate the reference prescribing the storage requirement, and 3) be consistent with the terminology of existing TS Figure 2-10.

FCS TS 4.3.1.1.f is added based on revisions to the 4.3.1.1.e STS wording as follows: 1)

Delete New or, 2) begin the specification with Partially, 3) replace the acceptable range with between the acceptable domain and Peripheral Cells, 4) replace Figure [3.7.18-11 with Figure 2-10,,, 5) replace [either] with peripheral cells of Region 2 storage, 6) after storage rack(s) add in compliance with Reference (l), to specify: 1) where the spent fuel falling within this burnup domain will be stored, 2) incorporate the reference prescribing the storage requirement, and 3) be consistent with the terminology of existing TS Figure 2-10.

FCS TS 4.3.1.1.g is revised from the 4.3.1.1.f STS wording as follows: 1) replace unacceptable range with unacceptable domain, 2) replace Figure [3.7.18.1] with Figure 2-1 0, 3) replace compliance with the NRC approved [specific document containing the analytical methods, title, date, or specific configuration or figure] with Region 1 in compliance with Reference (l). to specify: 1) where the spent fuel falling within this burnup domain will be stored, 2) incorporate the reference prescribing the storage requirement, and 3) be consistent with the terminology of existing TS Figure 2-

10.

FCS TS 4.3.1.2.b is revised from the STS wording of keff 10.98 if fully flooded with unborated water, which includes an allowance for uncertainties as described in [Section 9.1 of the FSAR] to keff 50.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Reference (2). because the licensed FCS limit of the new fuel storage racks is 0.95.