LIC-11-0067, Response to Second NRC Request for Additional Information License Amendment Request to Relocate Operating & Surveillance Requirements for Power-Operated Relief Valve, Safety Valve Position, & Tail Pipe Temperature Instrumentation from Te

Response to Second NRC Request for Additional Information License Amendment Request to Relocate Operating & Surveillance Requirements for Power-Operated Relief Valve, Safety Valve Position, & Tail Pipe Temperature Instrumentation from Techn

ML111822610
Person / Time
Site:	Fort Calhoun
Issue date:	06/30/2011
From:	Reinhart J Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-11-0067
Download: ML111822610 (8)

Text

Employment with Equal Opportunity 444 South 16th Street Mall Omaha, NE 68102-2247 June 30, 2011 LIC-11-0067 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

See Page 3

SUBJECT:

Response to Second NRC Request for Additional Information (RAI) Re :

License Amendment Request to Relo cate Operating and Surveillance Requirements for the Po wer-Operated Relief V alve, Safety Valve Position, and Tail Pipe Tem perature Instrumentation from Techni cal Specifications This letter provides the Omaha Public Power Districts (OPPDs) response to the Nuclear Regulatory Commissions (NRCs) second request for additional information (RAI) regarding the lic ense amendment request (LAR) to relocate the operating and surveillance requirements (SRs) for the powe r-operated relief valve (PORV), pressurizer safety valve (PSV) position and tail pipe temperature instrumentation from the Technical Specifications (TS).

In LAR 10-04 (Reference 2), OPPD request ed to relocate the operating and surveillanc e requirements for the PORV a nd PSV a coustic position and tail pipe temperature indication instrumentation from the Fort Calhoun Station (FCS), Unit No. 1, TS to licensee controlled documents.

Based on a conference call held with the NRC staff on September 13, 2010, OPPD supplemented the Reference 2 application to provide additio nal clarifying information regarding the tail pipe temperat ure position indic ation. As requested in Reference 3, OPPD provided drawings (i nterconnection and equipment lists) and photographs of t he control room indic ators for the PORV/PSV acoustic and tail pipe temperature positio n indication instrumentation in Reference 4.

U. S. Nuclear Regulatory Commission LI C-11-0067 Page 2 In Reference 5, the NRC provided three RAI questions related to References 2 and 4.

OPPD's responses to the NRC's RAI questions were provided in Reference 6.

Reference 7 transmitted the NRC's second round of RAI questions pertaining to LAR 10-04. OPPD's responses to the NRC's RAI questions transmitted in Reference 7 are provided in Attachment 1.

There are no regulatory commitments made in this letter.

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 June 30, 2011.

ffrey A. Reinhart Site Vice President JAR/KRW/dll

Attachment:

1. Response to Request for Additional Information c:

E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector

U. S. Nuclear Regulatory Commission LIC-11-0067 Page 3 Reference List

1. Docket No. 50-285

2. Letter from OPPD (J. A. Reinhart) to NRC (Doc ument Control Desk ), License Amendment Request (LAR) 10-04, Proposed Changes to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve and Safety Valve Position and Tail Pipe Temperature Instru mentation, dated August 16, 2010 (LIC 0053) (ML102290067)

3. Letter from NRC (L. Wilkins) to OPPD (D

. J. Bannister), Fort Calho un Station -

Supplemental Information Needed for Acceptance of Requested Licensing Action Re:

Amendment Request (TAC No. ME4542), dated September 17, 2010 (NRC-10-0076)

(ML102580129)

4. Letter from OPPD (J. A. Rein hart) to NRC (Document Control Desk), Supplement to License Amendment Request (LAR) 10-04, Proposed Changes to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve and Safety Valve Position and Tail Pipe Temperature Instrumentation, dated September 27, 2010 (LIC-10-0085) (ML102720964)

5. Letter from NRC (L. E. Wilkins) to OPPD (D. J. Bannister), Fort Calhoun Station, Unit 1 - Request for Additional Information Re : License Amendment Request to Reloc ate Operating and Surveillanc e Requirements fo r the Power Operated Relief Valve, Safety Valve Position, and Tailpipe Temper ature Instrumentation from the Technical Specifications (TAC No. ME4542),

dated March 7, 2011 (NRC-11-0021)

(ML110630179)

6. Letter from OPPD (J. A. Reinhart) to NRC (Document Control Desk), Response to Request for Additional Information (RAI

) Re: Lic ense Amendment Request to Relocate Operating and Surveillanc e Requirements for the Power Operated Relief Valve, Safety Valve Position, and Tail Pipe Temperature Instrumentation from the Technical Specifications, dated April 6, 2011 (LIC-11-0030) (ML110970356)

7. Letter from NRC (L. E. Wilkins) to OPPD (D. J. Bannister), Fort Calhoun Station, Unit 1 - Request for Additional Information Re: License Amendment Request to Reloc ate Operating and Surveillanc e Requirements fo r the Power Operated Relief Valve, Safety Valve Position, and Tailpipe Temper ature Instrumentation from the Technica l Specifications (TAC No. ME4542),

dated May 26, 2011 (NRC-11-0058)

(ML111430724)

LIC-11-0067 Page 1 RESPONSE TO 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 Augu st 16, 2010, as supp lemented by letters dated September 27, 2010, and April 6, 2011 (Agenc ywide Documents Access and Management System (ADAMS)

Accession Nos. ML102290067, ML102720964, an d ML110970356, respectivel y), 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 requireme nts (SRs) for the po wer-operated relief valve (PORV) position, safet y valve position, 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 associat ed Notes a, b, c, and d, and TS Tab le 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 w ill 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 i to Note c will be deleted.

The U.S. Nuclear Regulator y Commission (NRC) staff has r eviewed and evalu ated the information provided b y the licensee and de termined that the follo wing information is needed in order to complete its evaluation.

1.

By letter dated Aug ust 16, 2010, the lic ensee proposed to revise TS Table 3-3 as follows:

Item 21, PORV Operation and Acoustic Position Indication is being revised to delete the words "and Acoustic Position Indication."

Item 21.a, the frequency is being changed from "M to "R" to reflect channel functional testing of PORV operation, which is more aligned with NUREG-1432 surveillance requirements.

LIC-11-0067 Page 2 The licensee also states:

The proposed change also revises SR 3.1, Table 3-3, Item 21 to maintain the existing channel functional test of the PORVs on a refueling frequency, which is aligned with NUREG 1432, Standard Technical Specifications, Combustion Engineering Plants, Revision 3 [STS].

Please provide the exact SR number of the STS to which the licensee is referring.

OPPDs Response to RAI #1:

These statements are in reference to NUREG 1432, Standard Technical Specifications, Combustion Engineering Plants, Revision 3, published June 2004, Surveillanc e

Requirement (SR) 3.4.11.2, which requires that a complete cycle of each PORV is performed every 18 months.

2.

After the deletion of the w ords "and Acoustic Position Indication," TS Table 3-3, Item 21 will read "PORV Operation." However, SR 3.4.12.6, on page 3.4.12-4 of the STS, states: "Perform CHANNEL FUNCT IONAL TEST on each requ ired PORV, excluding actuation" with a FREQUENCY of 31 days.

Please explain the discrepan cy and justify the proposed revision of the requi red SR frequency from "M" to "R."

OPPDs Response to RAI #2:

NUREG 1432, Rev ision 3, (STS), SR 3.4.12.6 refers to the performance of the CHANNEL FUNCTIONAL TEST on each requir ed PORV, excluding actu ation, on a frequency of 31 days. NUREG 1432, SR 3.4.12.6 is in relati on to the low temperature overpressure protection (LTOP) system. T he purpose of this SR, as described in NUREG 1432, Volume 2, Base s pages B 3.4.12-10 and B 3.4.12-11, i s to verify the PORV open setpoints. This SR is fulfilled in the FCS TS by Specification 3.1, Table 3-3, Item 18a (CHANNEL FUNCTIONAL TEST (excluding actuation)). As delineated in th e original license amendment request (Referenc e 2), Enclosure page 7, this FCS T S

surveillance requirement [3.1, Table 3-3, Item 18], remains unchanged by this LAR.

Therefore, as stated in response to RAI #1, OPPDs proposed revision to SR 3.1, Tabl e 3-3, Item 21 to maintain the existing CHAN NEL FUNCTIONAL TEST of the PORVs on a refueling frequency, is align ed with STS SR 3.4.11. 2, which requires th at a complete cycle of each PORV is performed every 18 months.

LIC-11-0067 Page 3

3.

By letter dated Au gust 16, 2010, the licensee proposed to relocate the TS for maintaining and testing the acoustic monitors and the tail pipe temperatures.

Please provide the NRC staff with the proposed wording in the USAR or Technical Requirements Manual that will supplant the revised TS. Also, please describe the plan for identifying what channels will be required, how frequently they are to be tested, and w hat specific functionality is to be demonstrated by the proposed functional tests. In additi on, provide the NRC sta ff with a description of how the proposed functional testing is to be con ducted for each piece of equipment being functionally tested.

OPPDs Response to RAI #3:

The requirements for the test ing of both the PO RV/PSV acoustic monitors and tail pipe temperature instruments will remain the same as they are currently described in the FCS TS. The existing su rveillance tests will b e converted to calibration procedures an d

executed via the Preventive Maintenance Program.

The following is the proposed wording to be included in the FCS Updated Safety Analysis Report (USAR) as part of implementation of the LAR:

4.3.9.4 Power Operated Relief Valves (PORV)

The operability and s urveillance requirements for the PORV ac oustic monitors and tail pipe tem perature instrumentation were relocated from the Tech nical Specifications to the USAR in acco rdance with Technical Specification Amendment No. [XXX]. The requirements listed in Table 4.3-11b and Table 4.3-11c document the minimum requirement s to ensure functional valve position indication is available when required.

In the event the number of channels in Table 4.3-11b falls below the limits given in the colum n entitled "Minimum Functional Channels," the reactor shall be placed in a hot shutdown condition withi n 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If m inimum conditions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from time of discovering loss of functionality, the reactor shall be placed in a cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Table 4.3-11b - PORV Position Indication Functional Limits Instrument Minimum Functional Channels

1. Acoustic Position Indication - Direct 1(a)(c)

2. Tail Pipe Temperature 1(b)(d) a) One channel per valve.

b) One RTD for both PORVs.

c) If item 2 is f unctional, requirements are modified for item 1 to "Restore nonfunctional channels to functional status within 7 days or be in hot shutdown within12 hours."

d) If item 1 is f unctional, requirements are modified for item 2 to "Restore nonfunctional channels to functional status within 7 days or be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

LIC-11-0067 Page 4 Table 4.3-11c - PORV Position Indication Functional Testing Requirements Channel Function Frequency Method Acoustic Position Indication - Direct Test Monthly Channel Functional Test Calibrate Refueling Channel Calibration Tail Pipe Temperature Check Monthly Channel Check Calibrate Refueling Channel Calibration 4.3.10 Pressurizer Safety Valves The operability and s urveillance requirements for the Pressurizer Safety Valves acoustic monitors and tail pipe temperatur e instrumentation were relocated from the Technical Specif ications to the USAR in accordance with Technica l

Specification Amendment No. [XXX]. T he requirements listed in Table 4.3-12a and Table 4.3-12b docum ent the m inimum requirements to ensure functional valve position indication is available when required.

In the event the number of channels in Table 4.3-12a falls below the limits given in the colum n entitled "Minimum Functional Channels," the reactor shall be placed in a hot shutdown condition withi n 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If m inimum conditions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from time of discovering loss of functionality, the reactor shall be placed in a cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Table 4.3-12a - Pressurizer Safety Valve Position Indication Functional Limits Instrument Minimum Functional Channels

1. Acoustic Position Indication 1(a)(c)

2. Tail Pipe Temperature 1(b)(d) a) One channel per valve.

b) Two RTDs, one for each code safety.

c) If item 2 is function al, requirements are modified for item 1 to "Re store nonfunctional channels to functional status within 7 days or be in hot shutdown within12 hours."

d) If item 1 is function al, requirements are modified for item 2 to "Re store nonfunctional channels to functional status within 7 days or be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Table 4.3-12b - Pressurizer Safety Valve Position Indication Functional Testing Requirements Channel Function Frequency Method Acoustic Position Indication Test Monthly Channel Functional Test Calibrate Refueling Channel Calibration Tail Pipe Temperature Check Monthly Channel Check Calibrate Refueling Channel Calibration

LIC-11-0067 Page 5

4.

Please describe how the requirements for establishing limiting conditions for operation as descri bed in paragraph 50.36(c)(2)(ii)(A) of Title 10 of the Code of Federal Regulations (10 CFR) Criterion 1 is still satisfied with respect to the detection of signific ant degradation of the reactor coolan t pressure boundar y associated with pressurizer steam leakag e, after the proposed amen dment goes into effect. In addition, please list the equipment and qualifications (e.g., E Q,

seismic, power supply, etc.) that will fulfill this function.

OPPD Response to RAI #4:

10 CFR 50.36(c)(2)(ii) states, in part, that A technical specif ication limiting condition for operation [LCO] of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(A) Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary The reactor coolant system pressure boundar y leakage limits are addressed in TS LCO 2.1.4. Although the PORV/PSV instruments provide indication of possible RCS leakage, they are not used to implement TS 2.1.4. Additionally, in OPPDs response to RG 1.97, Revision 2 (Reference 6.9 of Reference 2), OPPD committed several instrument loops to fulfill monitoring of the reac tor coolant pressure boundary. Those instruments and their associated qualifications are as follows:

RCS Pressure PT-105/115, Pressurizer RC-4 Wide Range Pressure Transmitter Class 1E Power Supply Seismic 1 EQ Technical Specifications Section 3.1, Table 3-3, Item 16 Containment Pressure PT-783/784, Containment Pressure Wide Range Pressure Transmitter Class 1E Power Supply Seismic 1 EQ Technical Specifications Section 3.1, Table 3-3, Item 28 Containment Sump Water Level LT-387A/B/C/D, Level Transmitter [Containment/Sump Access Level]

LT-388A/B/C/D, Level Transmitter [Containment/Sump Access Level]

Class 1E Power Supply Seismic 1 EQ Technical Specifications Section 3.1, Table 3-3, Item 27