ML13280A089
| ML13280A089 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/08/2013 |
| From: | Joseph Sebrosky Plant Licensing Branch IV |
| To: | Cortopassi L Omaha Public Power District |
| Sebrosky J | |
| References | |
| TAC MF2869 | |
| Download: ML13280A089 (6) | |
Text
PUBLIC NOTICE NRC STAFF PROPOSES TO AMEND RENEWED FACILITY OPERATING LICENSE AT THE FORT CALHOUN STATION, UNIT 1 The U.S. Nuclear Regulatory Commission (NRC) staff has received an application dated October 6, 2013, from Omaha Public Power District (OPPD, the licensee), for an exigent amendment to the renewed operating license for the Fort Calhoun Station, Unit 1, located in Washington County, Nebraska.
The proposed amendment would revise the Updated Safety Analysis Report (USAR) for pipe break criteria for high energy piping outside of containment. Specifically, the proposed amendment would allow the use of NRC guidance provided in Branch Technical Position Mechanical Engineering Branch 3-1 Revision 2, which allows for the exemption of specific piping sections from postulated failures if certain criteria are met.
In its October 6, 2013, license amendment application, OPPD described how on June 13, 2013, an unevaluated break location in the steam supply to the auxiliary feedwater turbine in Room 19 of the auxiliary building was identified. The next day, OPPD identified a deficiency with verifying that the Electrical Equipment Qualification program met all of the criteria for establishing pipe rupture locations in Room 13 of the auxiliary building. OPPD stated in its October 6, 2013, application that the need to focus resources on making physical improvements to the plant to address the issue while using many of the same resources to research the extent of condition and history of this issue prevented its resolution in a more timely manner. Until recently, OPPD believed that they could replace piping and restart the plant prior to receiving a license amendment under guidance found in NRC Inspection Manual Part 9900: Technical Guidance, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety. OPPD only recently concluded that a license amendment is needed prior to plant restart.
Therefore, OPPD requested that the license amendment request be processed under exigent circumstances in accordance with paragraph 50.91(a)(6) of Title 10 of the Code of Federal Regulations (10 CFR). An exigent amendment reduces the time the public and State have to comment on the associated issue of no significant hazards consideration and allows for notice to be provided through local media (e.g., a newspaper) instead of through the Federal Register. 10 CFR 50.91(a)(6)(i)(B).
The Commission's regulation at 10 CFR 50.91(a)(1) requires that, at the time a licensee requests an amendment, the licensee must provide to the Commission the licensee's analysis about the issue of no significant hazards consideration using the standards in § 50.92, which concern whether the proposed amendment (1) involves a significant increase in the probability or consequences of an accident previously evaluated; or (2) creates the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involves a significant reduction in a margin of safety.
Accordingly, the licensee provided the following information:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change to the current licensing basis (CLB) utilizes NRC guidance (viz., Branch Technical Position (BTP) MEB 3-1, Revision 2, Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment and NRC Generic Letter 87-11 (Relaxation in Arbitrary
Intermediate Pipe Rupture Requirements) regarding the locations where breaks and cracks in high energy piping systems outside containment are to be postulated.
Allowing the use of NRC Generic Letter 87-11 and select sections of BTP MEB 3-1 as the basis for determining postulated break and crack locations does not result in an increase in either the probability of a high energy line break (HELB) outside containment or the consequences of such a break. The proposed change does not involve any physical changes to the affected high energy systems or components. These systems have previously been modified, as appropriate, to lower the stresses in the piping and to improve the ability to inspect the welds, in accordance with the relevant requirements of NRC Generic Letter 87-11 and BTP MEB 3-1.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change to the current licensing basis (CLB) is a methodology change and does not involve any physical changes to the affected high energy systems or components. No new equipment is being installed nor is any installed equipment being operated in a new or different manner. A HELB outside containment in the affected systems is an accident previously evaluated, as discussed in Section 4.0 of Appendix M to the Fort Calhoun Station, Updated Safety Analysis Report (USAR).
No new interactions between systems or components are created. No new failure mechanisms of associated systems will exist.
Therefore, the amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment provides the regulatory basis for changing the CLB to utilize updated NRC guidance regarding the locations where breaks and cracks in high energy piping systems outside containment are to be postulated. As stated in the Background section of BTP MEB 3-1, Rev. 2:
... observation of actual piping failures has indicated that they generally
occur at high stress and fatigue locations, such as at the terminal ends of a piping system at its connection to the nozzles of a component. The rules of this position are intended to utilize the available piping design information by postulating pipe ruptures at locations having relatively higher potential for failure, such that an adequate and practical level of protection may be achieved.
By requiring that the affected piping be maintained within the stress limits and other limits of Generic Letter 87-11 and the identified sections of BTP MEB 3-1, adequate levels of protection will be maintained.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Following the NRC staffs initial review of this license amendment application, the requested amendment has been evaluated against the standards in § 50.92 and the NRC staff has made a proposed (preliminary) determination that the requested amendment involves no significant hazards considerations. The changes do not significantly increase the probability or consequences of any accident previously considered, nor create the possibility of an accident of a different kind, nor significantly decrease any margin of safety.
If the proposed determination that the requested license amendment involves no significant hazards consideration becomes final, the staff will issue the amendment without first offering an opportunity for a public hearing. An opportunity for a hearing will be published in the
Federal Register at a later date and any hearing request will not delay the effective date of the amendment.
If the staff decides in its final determination that the amendment does involve a significant hazards consideration, a notice of opportunity for a prior hearing will be published in the Federal Register and, if a hearing is granted, it will be held before the amendment is issued.
Comments on the proposed determination of no significant hazards consideration may be (1) telephoned to Joseph M. Sebrosky, Senior Project Manager, Plant Licensing Branch IV, by collect call to 301-415-1132, or by facsimile to 301-415-1885, (2) e-mailed to joseph.sebrosky@nrc.gov (3) submitted in writing to the Chief, Rules, Announcements and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. All comments received by close of business on October 15, 2013, from 7:30 a.m. to 4:15 p.m. Federal workdays will be considered in reaching a final determination. A copy of the application dated October 6, 2013, may be examined electronically through the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML13280A297 in the NRC Library at http://www.nrc.gov/reading-rm/adams.html and at the Commission's Public Document Room (PDR), located at One White Flint North, Public File Area O1 F21, 11555 Rockville Pike (first floor), Rockville, Maryland. Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, or 301-415-4737, or by e-mail to pdr.resource@nrc.gov.