ML110630179

Request for Additional Information, Amendment Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications

ML110630179
Person / Time
Site:	Fort Calhoun
Issue date:	03/07/2011
From:	Lynnea Wilkins Plant Licensing Branch IV
To:	Bannister D Omaha Public Power District
Wilkins, L E, NRR/DORL/LPL4, 415-1377
References
TAC ME4542
Download: ML110630179 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 7, 2011 Mr. David J. Bannister Vice President and CNO Omaha Public Power District Fort Calhoun Station 444 South 16th St. Mall Omaha, NE 68102-2247

SUBJECT:

FORT CALHOUN STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO RELOCATE OPERATING AND SURVEILLANCE REQUIREMENTS FOR THE POWER OPERATED RELIEF VALVE, SAFETY VALVE POSITION, AND TAILPIPE TEMPERATURE INSTRUMENTATION FROM THE TECHNICAL SPECIFICATIONS (TAC NO. ME4542)

Dear Mr. Bannister:

By letter dated August 16, 2010, as supplemented by letter dated September 27,2010, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102290067 and ML102720964, respectively), Omaha Public Power District requested to relocate operating and surveillance requirements for the power-operated relief valve position, safety valve position, and tailpipe temperature instrumentation from the Fort Calhoun Station, Unit 1 (FCS) Technical Specifications to the FCS Updated Safety Analysis Report.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed your submittals and determined that the information specified in the enclosed request for additional information (RAI) is needed for the staff to complete its evaluation. The RAI was discussed with Mr. Hansher and others of your staff on February 24, 2011. Mr. Hansher indicated that the response would be provided within 7 days of receipt of this letter.

If you have any questions, please contact me at 301-415-1377 or via e-mail at Iynnea. wilkins@nrc.gov.

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~;a-~*.* Wilkins, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO RELOCATE OPERATING AND SURVEILLANCE REQUIREMENTS FOR THE POWER-OPERATED RELIEF VALVE, SAFETY VALVE POSITION, AND TAILPIPE TEMPERATURE INSTRUMENTATION FROM THE TECHNICAL SPECIFICATIONS OMAHA PUBLIC POWER DISTRICT, FORT CALHOUN STATION, UNIT NO.1 DOCKET NO. 50-285 By letter dated August 16, 2010, as supplemented by letter dated September 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102290067 and ML102720964, respectively), Omaha Public Power District (OPPD, the licensee) requested changes to the Technical Specifications (TSs) for Fort Calhoun Station, Unit 1 (FCS). The proposed changes would relocate operating and surveillance requirements (SRs) for the power-operated relief valve (PORV) position, safety valve position (PSV), and tail pipe temperature instrumentation from the FCS TSs to the FCS Updated Safety Analysis Report (USAR). Specifically the proposed changes would revise:

• TS Table 2-5, "Instrumentation Operating Requirements for Other Safety Feature Functions"

• TS Table 3-3, "Minimum Frequencies for Checks, Calibrations and Testing of Miscellaneous Instrumentation and Controls" TS Table 2-5, Functions 3,4, and 5, the associated Notes a, b, c, and d, and TS Table 3-3, Functions 23 and 24, would be deleted from the FCS TSs and relocated to the FCS USAR.

TS Table 3-3 Function 21 will be revised to be consistent with NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants," Revision 3.0. Additionally, the TS Table 2-5 associated Note e will be re-Iettered as Note a and TS Table 2-5 footnote ito Note c will be deleted.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed and evaluated the information provided by the licensee and determined that the following information is needed in order to complete its evaluation.

1. By letter dated August 16, 2010, the licensee stated, The loss of the instrumentation has no effect on the probabilistic safety assessment and has not been shown to be significant to health and safety as considered in Criterion 4.

Enclosure

-2 Please provide details on how this statement was concluded. Specifically, please discuss any operating experience involving the failure of this equipment at the plant (or similar experience within the industry) and how this experience is determined to be insignificant. Also, please describe the impact of the failure of this equipment on the base probabilistic risk assessment (PRA) results, including the risk achievement worth and risk reduction worth [or Fussell-Vesely importance] for this equipment (or surrogate PRA component if this equipment is not modeled directly in the PRA), and how these impacts are determined to be insignificant.

2. In the letter dated July 12, 2010 (ADAMS Accession No. ML101930443), OPPD submitted a license amendment request (LAR) to add Note e to TS LCO 2.15, Table 2-5, Item 1. The LAR dated July 12, 2010, is under separate review by the NRC staff. In the letter dated August 16, 2010, OPPD submitted a LAR which requests deletion ofTS 2.15, Table 2-5, Notes a through d. The August 16, 2010, LAR also requests re-Iettering TS 2.15, Table 2-5, Note e to Note a upon subsequent NRC approval of both LARs. Since the re-Iettering of TS 2.15, Table 2-5, Note e to Note a was not reflected on TS 2.15, Table 2-5 in Attachment 1, "Technical Specifications Pages Markup," the NRC staff is concerned that the reference to Note e in TS 2.15, Table 2-5, item 1 will not be re-Iettered when TS 2.15, Table 2-5, Note e is re-Iettered to Note a.

Please provide an integrated TS markup that will show all the changes proposed by the LARs dated July 12 and August 16, 2010, and include the clean TS pages.

3. In the letters dated May 31 and June 1, 2010 {ADAMS Accession Nos.

ML101520198 and ML101530319, respectively}, OPPD requested an emergency amendment to modify TS 2.15, Table 2-5, Note c to allow a one-time extension of the 7-day allowed outage time for the inoperability of Function 4 regarding safety valve acoustic position indication for RC-142 to allow repair prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown).

The onetime extension was applied through footnote i associated with Note c.

This change allowed FCS to continue power operations with inoperable safety valve acoustic position indication on safety valve RC-142. The NRC staff approved the license amendment request on July 12, 2010, in TS Amendment No. 265 (ADAMS Accession No. ML101520296). In the LAR dated August 16, 2010. the licensee proposes to delete footnote i associated with Note c.

However. it is unclear if FCS has used the one-time extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142 and if RC-142 was repaired prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 {Cold Shutdown}.

Please state if. since July 12, 2010, FCS has either used the one-time extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142, or if it was determined that it was no longer needed.

March 7, 2011 Mr. David J. Bannister Vice President and CNO Omaha Public Power District Fort Calhoun Station 444 South 16th St. Mall Omaha, NE 68102-2247

SUBJECT:

FORT CALHOUN STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST TO RELOCATE OPERATING AND SURVEILLANCE REQUIREMENTS FOR THE POWER OPERATED RELIEF VALVE, SAFETY VALVE POSITION, AND TAILPIPE TEMPERATURE INSTRUMENTATION FROM THE TECHNICAL SPECIFICATIONS (TAC NO. ME4542)

Dear Mr. Bannister:

By letter dated August 16, 2010, as supplemented by letter dated September 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102290067 and ML102720964, respectively), Omaha Public Power District requested to relocate operating and surveillance requirements for the power-operated relief valve position, safety valve position, and tailpipe temperature instrumentation from the Fort Calhoun Station, Unit 1 (FCS) Technical Specifications to the FCS Updated Safety Analysis Report.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed your submittals and determined that the information specified in the enclosed request for additional information (RAI) is needed for the staff to complete its evaluation. The RAI was discussed with Mr. Hansher and others of your staff on February 24, 2011. Mr. Hansher indicated that the response would be provided within 7 days of receipt of this letter.

If you have any questions, please contact me at 301-415-1377 or via e-mail at Iynnea.wilkins@nrc.gov.

Sincerely, IRA!

Lynnea E. Wilkins, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

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