ML20003H593
| ML20003H593 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/23/1981 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | William Jones OMAHA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20003H594 | List: |
| References | |
| NUDOCS 8105060474 | |
| Download: ML20003H593 (4) | |
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o,j UNITED STATES NUCLEAR REGULATORY COMMISSION
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April 23, 1981 A.
Dockst No. 50-285 W
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Mr. W. C. Jones g
g Division Manager, Production 3
g Operations Omaha Public Power District 1623 Harney Street Omaha, Nebraska 68102
Dear Mr. Jones:
Wa have reviewed your " Application for Amendment of Operating License" dated N3vember 17, 1980, submitted in response to our letter of July 22, 1980.
In this application, you seek to amend Definitions and Sections 2.1.3, 2.20, and 3.2 of the Fort Calhoun Technical Specifications concerning the definition of dose-equivalent I-131, allowable concentrations in the primary and secondary y
coolant, surveillance requirements and other related matters.
i Based on discussions with your staff, you have agreed to a few changes to your application, as submitted, to more closely conform the pending amendment to the request contained in our letter to you of July 22, 1980. Nevertheless, significant differences still remain, and we have concluded that your submittal, even as modified, is not acceptable.
During our review of Omaha Public Power District's application for a power in-crease at the Ft. Calhoun Station, we identified the need for revision of the unit's Technical Specifications on primary coolant activity. Appropriate Tech-nical Specification limits assure the protection of the health and safety of the public in case of accidents involving the release of primary coolant activity (e.g. steam generator tube rupture, LCCA prior to fuel failt"e, steam line failure), as well as limiting occupational exposures and normal operating re-leases.
Our prior generic evaluation of the appropriate coolant activity levels and associated sampling requirements included consideration of the likelihood, mag-nitude, and time-dependent behavior of iodine spikes in the primary coolant resulting from or coinciding with the postulated accidents. This analysis resulted in the specific values of coolant activity in equilibrium and transient conditions, and the sampling frequencies c. ascribed in the Standard Technical Specifications (STS). This analysis, performed for generic application, included the specific plant and site parameters for Ft. Calhoun 1, and, therefore, is applicable to this plant. Our evaluation of the power increase application confirmed that appropriate Technical Specifications were not in place at Ft. Calhoun, and that incorporation of the Standard Technical Specifications 81050604 74
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i Mr. W. C. Jones 2-i would assure appropriate protection of the health and safety of the public.
4 Following approval. of the power increase, you were requested to submit Technical Specification changes confoming to the STS. Your submittal of November 17, 1980 appeared to conform to the STS. We found, however, that key elements of the STS had been changed such that (1) the equilibrium pri-i mary coolant activity limit was essentially removed (i.e., the absence of a limit on the fraction of time that the plant can operate with an iodine
" spike" in effect negated the equilibrium value and substituted the " spike" maximum as the only real limit), (2) the proposed sampling frequencies l
would not assure detection of iodine spikes in the reactor coolant, and (3) the proposed' equilibrium value was twice the STS value. As stated above, i
some of these deficiencies have been cured through discussion with your J
staff. Nevertheless, your proposed Technical Specifications as_ submitted could result in postulated off-site doses substantially in excess of 10 CFR Part 100 guidelines in the event of a steam generator tube rupture under iodine spiking conditions (i.e., with coolant activity up to 60 microcuries/
gram).
The equilibrium value of primary coolant activity is an important ' indicator of the source tem available for iodine spiking. As such, your prvosal to double the STS maximum value could lead to " spiked" coolant activity levels twice the transient limit of 60 microcuries/ gram. A great deal of thought 3
has been devoted to establishing a proper relationship between the equilibrium value and the transient limit. We are enclosing a copy of a paper " Iodine Spiking in BWR and PWR Coolant Systems" to provide you with more information in this area.
We concluded some time ago that the STS equilibrium value is a realistic operating limit, arid that, with reasonably good fuel, this limit will have 4
no impact on plant operation. No operating plant has approached this value.
At the same time, it is our conclusien that the STS requirements on both primary and secondary coolant activity orovide a coherent and rational set of conditions which are necessary for the protection of the public bealth and safety.
We have reviewed our previous analyses, and find no basis for changing our previously reconnen.ied values for coolant activity limits at Ft. Calhoun.
We also note that the STS values have been adopted by the majority of PWR licensees, including those with plants from the same vendor, similar vintage, r
and comparable site characteristics as yours. Our program to implement STS
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values on the remaining PWRs is continuing.
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Mr. W. C. Jones We therefore request that you revise your amendment request to conform to the STS requirements.
If, following.your review of this matter, you still believe that operation above the steady-state limit for up to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> is necessary and justified (versus 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per the STS), we request that you provide justification beyond that offered in your November 17, 1980 submittal.
A response is requested within 60 days of your receipt of this letter.
Please contact us if you have any questions concerning this matter.
Sincerely, Qf W
Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing
Enclosure:
Iodine Spiking paper cc: See next page t
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Omaha Public Power District CC:
Marilyn A. Tebor LeBoeuf, Lamb, Leiby & MacRae -
Director, Criteria and Standards Division 1333 New Hampshire Avenue, N.W.
Office of Radiation Programs (ANR-460 Washington, D. C.
20036 U.S. Environmental Protection Agency )
Washington, D. C.
20460 Mr. Emmett Rogert Chairman, Washington County U.S. Environmental Protection Agency Board of Supervisors Region VII Blair, Nebraska 68023 ATTN: EIS C0ORDINATOR 324 East lith Street Omahc Public Power District Kansas City, Missouri 64106 ATTN:
Mr. Spencer Stevens Plant Manager Fort Calhoun Plant 1623 Harney Street Omaha, Nebraska 68102 Director, Nebraska Departnent of Mr. Frank Gibson Environmental Control W. Dale Clark Library P. O. Box 94877, State House Station 215 South 15th Street Lincoln, Nebraska 68509 Omaha, Nebraska 68102 Alan H. Kirshen, Esq.
Fellman, Ramsey & Kirshen 1166 Woodmen Tower Omaha, Nebraska 68102 Mr. Dennis Kelley U.S.N.R.C. Resident Inspector P. O. Box 68 Fort Calhoun, Nebraska 68023 Mr. Charl Manager es B. Brinkman Washington Nuclear Operations C-E Power Systeam Combustion Engineering, Inc.
4853 Cordell Avenue, Suits A-1 Bethesda, Maryland 20014
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