LIC-09-0014, Response to NRC Request for Additional Information Concerning License Amendment Clarifying Emergency Diesel Generator Allowed Outage Time

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Response to NRC Request for Additional Information Concerning License Amendment Clarifying Emergency Diesel Generator Allowed Outage Time
ML090690689
Person / Time
Site: Fort Calhoun 
Issue date: 03/06/2009
From: Reinhart J
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-09-0014, TAC MD8569
Download: ML090690689 (6)
v • d • e


Text

Omaha Public Power District 444 South 16th Street Mall Omaha NE 68102-2247 March 6, 2009 LIC-09-0014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285
2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Fort Calhoun Station, Unit No. 1 License Amendment Request (LAR), Clarification of Technical Specification (TS) 2.7(2)j Regarding Emergency Diesel Generators Allowed Outage Time," dated April 22, 2008 (LIC-08-0049)

(ADAMS Accession No. ML081140092)

3. Email from NRC (Lynnea Wilkins) to OPPD (Bill Hansher), "RAI: MD8569 TS 2.7j EDG AOT," dated February 17, 2009 Response to NRC Request for Additional Information Concerning License Amendment Request Clarifying Emergency Diesel Generator Allowed Outage Time (TAC No. MD8569)

SUBJECT:

In Reference 2, the Omaha Public Power District (OPPD) requested a change to Fort Calhoun Station (FCS), Unit No. 1, Renewed Operating License No. DPR-40, to clarify Technical Specification (TS) 2.7(2)j regarding emergency diesel generator (DG) allowed outage time (AOT). The NRC staff reviewed the proposed change and in an email dated February 17, 2009 (Reference 3) transmitted an alternative to the wording proposed by OPPD.

The alternative wording is intended to clearly delineate that the seven consecutive days of DG allowed outage time must not be misconstrued to imply 14 consecutive days in two months (i.e. 7 days at the end of one calendar month followed by 7 days at the beginning of the following month).

OPPD noted in the evaluation accompanying the proposed TS change that operation in such a manner was not consistent with the Reactor Oversight Process, or the Maintenance Rule (10 CFR 50.65(a)(4)), which considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.

Employment with Equal Opportunity 4171

I U. S. Nuclear Regulatory Commission LIC-09-0014 Page 2 OPPD has reviewed and approved the change requested by the NRC and it is incorporated in the attached markup page and clean. page, which supersede the pages provided with Reference 2. As the change is a clarification, the conclusion of the evaluation provided by Reference 2 that the change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), remains valid.

As requested, OPPD will process a TS Basis Change (TSBC) to be implemented with the amendment. The TSBC will further clarify that the seven consecutive days of DG allowed outage time must not be misconstrued to imply 14 consecutive days in two months (i.e. 7 days at the end of one calendar month followed by 7 days at the beginning of the following month).

This is a one-time commitment.

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 March 6, 2009:

Jrey A. Reinhart Vice President JAR/mle Attachments:

1. Technical Specification Page Markup
2. Retyped ("Clean") Technical Specifications c:

E. E: Collins, NRC Regional Administrator, Region IV A. B. Wang, NRC Project Manager J. D. Hanna, NRC Senior Resident Inspector Director, of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-09-0014 Page 1 Technical Specification Page Markup

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.7 Electrical Systems (Continued)

d.

Either one of the 4.16kV engineered safeguards buses, 1A3 or 1A4 may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided the operability of the diesel generator associated with the operable bus is demonstrated immediately and there are no inoperable required engineered safeguards components associated with the operable bus.

e.

One of each group of 4160 V/480 V Transformers (T1 B-3A or 4A), (T1 B-3B or 4B), and (T1 B-3C or 4C) may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided there are no inoperable required engineered safeguards components which are redundant to components on the inoperable transformer.

f.

One of the 480 V distribution buses connected to bus 1A3 or connected to bus 1A4 may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided there are no inoperable required safeguards components which are redundant to components on the inoperable bus.

g..

Either Group of MCC No.'s (3A1, 3B1, 3A2, 3C1, 3C2,) or (4A1, 4A2, 4C1, 4C2) may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided there are no inoperable required safeguards components which are redundant to components on the inoperable MCC. MCC 3C1 may be inoperable in excesswof 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if.

battery chargers No. I and No. 2 are operable.

h.

One of the four 120V a-c instrument buses (A, B, C or D) may be inoperable for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided the reactor protective and engineered safeguards systems instrument channels supplied by the remaining three buses are-all" operable.

i.

Two battery chargers may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided battery charger No. 1 (EE-8C) or No. 2 (EE-8D) is operable.

j.

Either oneof the emergency diesel generators (DG-1 or DG-2) may be inoperable for up to seven consecutive days (t*+*.a*I,,th., d'-a -rg *R ment*., provided there are no inoperable required engineered safeguards components associated with the operable diesel generator. In addition, the cumulative total time of inoperability for both DGs during any calendar month shall not exceed seven days. If one diesel generator is inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (regardless of when the inoperable diesel generator is restored-to operability) EITHER:

(1)

Start the other diesel generator to verify operability, OR (2)

Ensure the absence of common cause for the diesel generator:

inoperability for the other diesel generator.

k.

Not used.

2.7 - Page 3 Amendment No. 60,!47,150, 162,213, 229

LIC-09-0014 Page 1 Retyped Technical Specification Page

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.7 Electrical Systems (Continued)

d.

Either one of the 4.16kV engineered safeguards buses, 1A3 or 1A4 may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided the operability of the diesel generator associated with the operable bus is demonstrated immediately and there are no inoperable required engineered safeguards components associated with the operable bus.

e.

One of each group of 4160 V/480 V Transformers (T1 B-3A or 4A), (T1 B-3B or 4B), and (T1 B-3C or 4C) may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided there are no inoperable required engineered safeguards components which are redundant to components on the inoperable transformer.

f.

One of the 480 V distribution buses connected to bus 1A3 or connected to bus 1A4 may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided there are no inoperable required safeguards components which are redundant to components on the inoperable bus.

g.

Either Group of MCC No.'s (3A1, 3B1, 3A2, 3C1, 3C2,) or (4A1, 4A2, 4C1, 4C2) may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided there are no inoperable required safeguards components which are redundant.to'components on the inoperable MCC. MCC 3C1 may be inoperable in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if battery chargers No. 1 and No. 2 are operable.

h.

One of.the-four 120V a-c instrument buses (A, B, C or D) may be inoperable for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided the reactor protective and engineered safeguards systems instrument channels supplied by-the remaining three busesare all operable.

Two battery chargers may be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided battery charger No. 1 (EE-8C) or No. 2 (EE-8D) is operable.

j.

Either one of the emergency diesel generators (DG-1 or DG-2) may be inoperable for up to seven consecutive days provided there are no' inoperable required engineered safeguards components associated with the operable diesel generator. In addition, the cumulative total time of inoperability for both DGs during any calendar month shall not exceed seven days. If one diesel generator is inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (regardless-of when the inoperable diesel generator is restored to operability) EITHER:

(1)

Start the other diesel generator to verify operability, OR (2)

Ensure the absence of common cause for the diesel generator '

inoperability for the other diesel generator.,

k.

Not used.

2.7 - Page 3

-Amendment No. 69,*1474,10, 162,213,229

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