ML14337A089

NRR E-mail Capture - OPPD Response to Technical Specification 3.7(1)c.ii Question

ML14337A089
Person / Time
Site:	Fort Calhoun
Issue date:	12/02/2014
From:	Edwards M Omaha Public Power District
To:	Lyon F Plant Licensing Branch IV
References
MF5143
Download: ML14337A089 (5)

Text

NRR-PMDAPEm Resource From: EDWARDS, MICHAEL L [medwards@oppd.com]

Sent: Tuesday, December 02, 2014 5:02 PM To: Lyon, Fred Cc: SIMPKIN, TERRENCE W; MCMANIS, JOE L; HANSHER, BILL R; ADAMS, JOHN C; PIER, DONALD M; NGUYEN, TRUNG T; WALKER, MEGAN A

Subject:

OPPD Response to Technical Specification 3.7(1)c.ii Question Attachments: Telecon RAI Response Final.docx Hello Fred, Ive attached our response to the NRC question raised during the telecon last week on LAR 14-10, One-Time Extension of Technical Specification Surveillance Requirements.

Please let us know if this will be sufficient or if further discussion is warranted.

Hope you had a nice holiday.

Michael Edwards Nuclear Licensing Engineer Regulatory Assurance Department Omaha Public Power District 9610 Power Lane, Blair NE 68008 402-533-6929 medwards@oppd.com This e-mail contains Omaha Public Power District's confidential and proprietary information and is for use only by the intended recipient. Unless explicitly stated otherwise, this e-mail is not a contract offer, amendment, or acceptance. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

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Hearing Identifier: NRR_PMDA Email Number: 1735 Mail Envelope Properties (D9B37C2F1C3EA14784A17E929D6E4771ACD98202)

Subject:

OPPD Response to Technical Specification 3.7(1)c.ii Question Sent Date: 12/2/2014 5:01:42 PM Received Date: 12/2/2014 5:02:09 PM From: EDWARDS, MICHAEL L Created By: medwards@oppd.com Recipients:

"SIMPKIN, TERRENCE W" <twsimpkin@oppd.com>

Tracking Status: None "MCMANIS, JOE L" <jmcmanis@oppd.com>

Tracking Status: None "HANSHER, BILL R" <bhansher@oppd.com>

Tracking Status: None "ADAMS, JOHN C" <jcadams@oppd.com>

Tracking Status: None "PIER, DONALD M" <dpier@oppd.com>

Tracking Status: None "NGUYEN, TRUNG T" <ttnguyen@oppd.com>

Tracking Status: None "WALKER, MEGAN A" <mawalker@oppd.com>

Tracking Status: None "Lyon, Fred" <Fred.Lyon@nrc.gov>

Tracking Status: None Post Office: SECEX733.oppd.oppd-ds.com Files Size Date & Time MESSAGE 973 12/2/2014 5:02:09 PM Telecon RAI Response Final.docx 24794 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Background:

Technical Specification (TS) 3.7(1)c.ii requires the initiation of a simulated simultaneous loss of 4.16 KV supplies to bus 1A3 and 1A4 and verification of proper operation by the successful completion of (1) bus de-energization, (2) bus load shed, (3) bus re-energization, (4) automatic sequence start of emergency load, and (5) operation of an emergency diesel generator (EDG) for at least 5 minutes while its generator is loaded with the emergency load. Thus, TS 3.7(1)c.ii is an integrated functional test of the engineered safety features (ESF) system with a concurrent loss of offsite power.

License Amendment Request (LAR) 14-10; One-Time Extension of Technical Specification Surveillance Requirements requested an extension for item (2) due to an inability to perform OP-ST-ESF-0015 480 Volt Load Shed with the unit at power. LAR 14-10 noted that OP-ST-ESF-0002 Diesel Generator No. 1 and No. 2 Auto Operation verifies actuation of the same load shed relays as OP-ST-ESF-0015.

NRC Question:

Does OP-ST-ESF-0002 simulate simultaneous loss of 4.16 KV supplies to busses 1A3 and 1A4 and then observe that these 5 things occur as required by TS 3.7(1)c.ii? If that is the case, why is a LAR necessary?

OPPD Response:

OP-ST-ESF-0002 meets the requirements of TS 3.7(1)c.ii by simulating an accident signal (Pressurizer Pressure Low Signal) coincident with loss of offsite power and then verifying that the following occurs:

1. De-energization of bus 1A3 & 1A4

2. Load shedding from bus (both 4.16 KV & 480 V)

3. Energization of bus 1A3 & 1A4

4. Automatic sequence start of emergency load, and

5. Operation of 5 minutes while its generator is loaded with the emergency load.

OP-ST-ESF-0002 verifies that 480 V load shed occurs to the extent that it is necessary to support the operation of the sequencers with emergency loads supplied by offsite power and by the EDGs. 480 V load shed including electrohydraulic (EHC) pumps, hydrogen purge blowers, and waste disposal components are verified by observing that the 480 V load shed relays change state as a result of the simulated accident signal.

4.16 KV load shed is verified by the observation that the EDG output breaker, which is Page 1

interlocked with the 4.16 KV loads, closes. Successful operation of the EDGs during sequencing verifies that load shed is functioning properly.

The wording in TS 3.7(1)c.ii was implemented as part of TS Amendment 111. The application for amendment removed similar EDG surveillance requirements from Table 3-2 to test the diesel start, load shed, synchronizing and loading as part of the SIAS testing to reduce the number of diesel starts consistent with Generic Letter (GL) 84-15 Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability. The application and NRC Safety Evaluation Report state that the circuitry previously tested as part of the SIAS test is redundant to the new TS 3.7(1), and therefore OP-ST-ESF-0015 is designated as fulfilling in part, TS 3.7(1)c.ii.

OP-ST-ESF-0015 fulfills the requirement of TS 3.7(1)c.ii.(2) associated with the Auxiliary Building and the Turbine Building portions of the test (i.e., EHC pumps, hydrogen purge blowers, and waste disposal components). OP-ST-ESF-0015 provides testing to ensure electrical loads, EHC pumps, hydrogen purge blowers, and waste disposal components will respond properly to the initiation of a Safety Injection Actuation Signal (SIAS) by manual tripping of the lock out relays 86B1X/SIAS and 86A1X/SIAS. This allows load shed of the listed loads without having to start the respective EDG and provides redundant testing of the load shed relays.

This method of testing utilizes the requirements of GL 96-01, Testing of Safety Related Logic Circuits, for overlap testing of relays in the ESF system. GL 96-01 requires one level of overlap or separate testing to ensure a circuit malfunction is not masked. OP-ST-ESF-0015 provides overlap for the contacts within the ESF system and is performed during plant shutdowns to avoid plant transients including plant trip and operation inhibit of plant systems. Although OP-ST-ESF-0002 tests all 5 items of TS 3.7(1)c.ii, a LAR is necessary to fulfill the requirement of TS 3.7(1)c.ii.(2) associated with the Auxiliary Building and the Turbine Building portions of the test, which is done by OP-ST-ESF-0015.

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Conclusion:==

As stated above, OP-ST-ESF-0002 meets the requirements of TS 3.7(1)c.ii by simulating an accident signal coincident with loss of offsite power and verifies that 480 V and 4.16 KV load shed occurs to the extent necessary to support the operation of the sequencers with emergency loads supplied by offsite power and by the EDGs.

OP-ST-ESF-0015 fulfills the requirement of TS 3.7(1)c.ii.(2) by ensuring that electrical loads, EHC pumps, hydrogen purge blowers, and waste disposal components respond properly to the initiation of SIAS to allow load shed without having to start the respective EDG. In accordance with GL 96-01, OP-ST-ESF-0015 performs overlap testing of relays in the ESF system to ensure a circuit malfunction is not masked and is performed Page 2

during plant shutdowns to avoid plant transients including plant trip and operation inhibit of plant systems.

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