ML19354E504

Responds to Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety-Related Equipment. Util Safety Enhancement Program Instituted to Improve Overall Level of Safety at Plant

ML19354E504
Person / Time
Site:	Fort Calhoun
Issue date:	01/26/1990
From:	Morris K OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-13, LIC-90-0050, LIC-90-50, NUDOCS 9001310299
Download: ML19354E504 (5)

Text

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l Omaha Public Power District 1623 Harney Omaha Nebraska 68102 2247 402/536 4000 January 26, 1990 LIC-90 0050 1

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-137 Washington, DC 20555

References:

1. Docket No. 50-285

2. Letter from NRC (J. G. Partlow) dated July 18, 1989 (Generic Letter 89-13)

3. Letter from 0 PPD (W. C. Jones) to NRC (R. D. Martin) dated December 9, 1988 (LIC-88-1094)

4. Letter from NRC (J. L. Milhoan) to OPPD (K. J. Morris) dated September 6, 1989 Gentlemen:

SUBJECT:

Response to Generic Letter 89-13 Enclosed is Omaha Public Power District's (0 PPD) response to the recommendations of Generic Letter 89-13 " Service Water System Problems Affecting Safety-Related Equipment." This response is being submitted under oath in accordance with the reporting requirements of NRC Generic Letter 89-13.

If you should have any questions, please _ contact me.

Sincerely, 4- .SsG K. J. Morris Division Manager Nuclear Operations

-KJM/pjc Attachments c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector 9001310299 900126 PDR P ADOCK 05000285 0h PDC L

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455824 Empioymen n toual opportunity

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  ;

i In the Matter of ) ,

Omaha Public Power District Docket No. 50-285-(Fort Calhoun Station )

Unit No. 1) )

AFFIDAVIT _

W. G. Gates, being duly sworn, hereby' deposes and says that he is the Acting Division Manager - Nuclear Operations _of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the response to NRC Generic Lctter 89-13; that he.is' familiar.with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and-belief.

4V. d. N '

W. G. Gates Acting Division Manager Nuclear Operations STATE OF NEBRASKA)

) ss COUNTY OF DOUGLAS)-

! Subscribed and sworn to before me, a Notary Public in and for~the State of Nebraska on this 14m day of January,1990. 1 i

JJAA-g Notary Public j GENERAL 80TARY4 tate of Nakana J.T. etaAsON l

alt han Es ndy 3133 l

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OPPD Response to NRC GENERIC-LETTER 89-13 APPLICABILITY:

At Fort Calhoun Station (FCF), the " Service Water System" defined in the General-Design Criterion 44 " Cooling Water" of 10 CFR Part 50, Appendix A, is comprised of the Raw Water (RW) System and the Component Cooling Water (CCW)

System. Both of these systems provide for the transfer of heat loads to the plant's ultimate heat sink, the Missouri River.

The CCW System is a closed loop system used to transfer. heat from various components to the RW System which discharges to the Missouri River.

The RW System is a once through cooling water system which removes heat from the CCW system. The RW system is also capable of providing direct cooling water through the CCW piping to selected safety-related components in the event that the CCW system is unavailable.

RESPONSE TO RECOMMENDED ACTIONS: j RECOMMENDED ACTION.I:

For open-cycle service water systems, implement and maintain an ongoing ,

program of surveillance and control techniques to significantly reduce the  !

incidence of flow blockage problems as a result of biofouling, t

OPPD ACTION: I i

The surveillance techniques for a fresh water source without clams [

recommended in Enclosure 1 of Generic Letter 89-13 will be implemented at  ;

FCS: 1.e., the intake structure will be visually inspected for macroscopic i biological fouling organisms on an annual basis and samples of water and substrate will be collected annually-to determine if Asiatic clams have i populated the water source. This surveillance program will be conducted, scheduled and documented under the Preventive Maintenance (PM) program. i FCS does not have and has never had any indication of biofouling in the Circulating Water, Raw Water, CCW, or Water Plant systems. Inspections of the Main Condensers and CCW heat exchangers in the past six to twelve months and other inspections and maintenance activities since plant startup support this position. Therefore, no additional control techniques will be implemented. L This-surveillance program will begin during~the 1990 refueling outage.

RECOMMENDED ACTION II: l Conduct a test program to verify the heat transfer capability of all l safety-related heat exchangers cooled by service water.

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OPPD ACTION:

OPPD will implement a test program for verifying heat transfer capability of individual heat exchangers in the CCW/RW systems.

This program will test the following heat exchangers (Hx): CCW Hx (AC -1A,

-18, -10, -10) quarterly, Letdown Cooling Hx (CH-7) once per year, Shutdown Cooling Hx (AC-4A, -48) once per refueling outage and Spent Fuel Pool Cooling Hx (AC-8) once per year. The test procedures used will provide directions for testing the heat exchangers for performance parameters (i.e., heat transfer rates and cleanliness factors). The testing frequency for these Hx's will be reevaluated based on the trending results of the test data to determine a schedule that ensures a reduction in heat transfer capability can be detected and appropriate remedial actions taken. This program meets the requirements of Enclosure 2 of Generic Letter 89 13.

This test program will begin during the 1990 refueling outage.

RECOMMENDED ACTION III:

Ensure by establishing a routine inspection and maintenance program for open-cycle service water system piping and components that corrosion, erosion, protective coating failure, silting, and bio'ouling cannot degrade the performance of the safety-related systems supplied by service water.

OPPD ACTION:

OPPD will implement an inspection and maintenance program for the major components of the CCW and RW systems that will ensure their reliability to meet their designed safety functions. This program will consist of an initial cleaning and flushing Preventive Maintenance (PM) activity along with an inspection to establish baseline conditions. A cleaning and flushing program will be implemented to provide information for determining the long term PM scheduling interval for each component by the end of the 1991 outage. Implementing this PM program will ensure system reliability and increase system efficiency.

The existing In Service Inspection Program and PM adequately cover maintenance activities on the rest of the components in the CCW and RW systems.

This inspection and maintenance program will begin during the 1990 refueling outage.

RECOMMENDED ACTION IV:

Confirm that the service water system will perform its intended function in accordance with the licensing basis for the plant.

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OPPD ACTION:

OPPD's program to confirm that the Service Water System will perform its intended function will consist of the following actions:  ;

A) Complete the design basis reconstitution for the Raw Water and' Component Cooling Water Systems and evaluate the as-built condition t documented by the system walkdowns.

B) Evaluate the results of the system performance tests to determine that -'

the Raw Water and Component Cooling Water Systems are operating within their respective design bases. 4 C)' Review the Raw Water and Component Cooling Water System to det' ermine

• their. ability to perform required safety functions in the event of-  :

failure of a single active component.  ;

D) Reconcile system walkdowns and design basis open items with the Raw  ;

Water and Component Cooling Water Design Basis Documents to the extent necessary to verify system operability. i This program will be complete prior to leaving Mode 4 upon' completion of the 1991 refueling outage.

RECOMMENDED ACTION V:

Confirm that maintenance practices, operating and emergency procedures, and training that involves the service water system are adequate to ensure that safety-related equipment _ cooled by the' service water system will function as intended and that operators of this equipment will perform effectively.

OPPD ACTION: 1 OPPD's Safety Enhancement Program (SEP) (Reference-3) was instituted _to improve the overall level of safety at FCS. SEP item 41~ upgraded _the FCS Preventive Maintenance Program. SEP item 49 reviewed and revised FCS's emergency operating' procedures. Both these SEP items are complete. SEP '

item 48 is implementing a Procedures Upgrade Project which will, perform a-comprehensive review and upgrade of the FCS operating procedures. The Procedure Upgrade Project is scheduled for completion of safety related procedures in December 1990.

Personnel who perform maintenance on the Raw Water and Component Cooling -

Water systems are trained, qualified and biannually requalified on the  !

tasks necessary to perform this maintenance. Licensed and nonlicensed-operators are trained, qualified and receive annual requalification training on operating and emergency procedures. -The effectiveness of .

licensed opertor performance is evaluated annually as required by 10 CFR

55. System engineers responsible for these systems have received specific training on these systems. When procedures are revised both the FCS' Plant Review Committee and Training evaluate the need for training on these ",

changes.

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