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Advises That 810722 & 820615 Tech Spec Amend Applications,Re Inoperability of Reactor Protection Sys/Esf Actuation Sys channels,unacceptable.Marked-up Tech Specs Indicating Recommended Changes Encl.Response Requested within 30 Days
	ML20027B711
Person / Time
Site:	Fort Calhoun
Issue date:	09/20/1982
From:	Clark R; Office of Nuclear Reactor Regulation
To:	William Jones; OMAHA PUBLIC POWER DISTRICT
References
	NUDOCS 8209290291
	Download: ML20027B711 (9)
	v • d • e

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Docket No. 50-285 i

Mr. W. C. Jones Division Manager, Production Operations Omaha Public Power District 1623 Harney Street i

Omaha, Nebraska 68102 i

Dear Mr. Jones:

SUBJECT:

FORT CALHOUN STATION TECHNICAL SPECIFICATION AMENDMENT APPLICATION REGARDING IN0PERABILITY OF RPS/ESFAS CHANNELS

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The staff has reviewed your application of July 22, 1981, as supplemented by letter of June 15, 1982, on the above subject and concludes that some l

of your pmposed TSs are unacceptable. The District proposes: "if the inoperability is determined as the result of malfunctioning RTDs or nuclear detectors supplying signals to the high power level, thermal margin / low pressurizer pressure, and axial power distribution, these channels may be bypassed for up to 7 days from time of initial loss of operability." The District also proposes: "one channel of the high rate trip-wide range log trip units associated with the startup nuclear detectors may be bypassed for an -unlimited time period." Both of these proposals are unacceptable for the following reasons.

The Commission informed the District by 1ctter dated March 31, 1982 that one of two methods was acceptable to the staff regarding the bypassing and tripping of channels associated with the RPS/ESFAS. One option (Option

1) was to incorporate TSs which would not allow a RPS/ESFAS channel to be bypassed greater than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Another option (0ption 2) was to allow a channel to be bypassed for a lengthy period of time with no degradation to safety if it can be verified that the three protection system channels in two-out-of-three logic are sufficient to satisfy all required protection system criteria. The District advised the Commission by letter dated June 15, 1982 that it did not desire to pursue Option 2.

The District proposed to use the first option (limit bypass to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) with the exception of some I

channels of the RPS which would allow bypass of specific protection channels F

l up to seven days and in the case of another RPS channel, unlimited bypass.

l Based on discussion with the licensee and review of the information supplied, we conclude that the exceptions should not be granted. You have not shown that all required protection system criteria (Option 2) have been met with a channel in bypass. Therefore, it is the staff's position that no protection system channel should be bypassed for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (0ption 1).

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l W. C. Jones The staff has marked up your proposed TSs to delineate a set of TSs which would be acceptable (enclosure 1). We request that the District review the staff's proposal and provide a response within thirty days of your receipt of this letter.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore. OMB Clearance is not required under P.L.96-511.

Please contact us if you have any questions concerning this letter.

Sincerely.

EHpel aleW b).

Robert A. Clark Chief Operating Reactors Branch #3 Division of Licensing

Enclosure:

As stated DISTRIBUTION UDocket Fiie cc w/ enclosure:

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CC:

Marilyn T. Shaw, Esq.

LeBoeuf, Lamb, Leiby & MacRae

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1333,New Hampshire Av'enue, N.W.

Washington, D'. C.

20036 Mr. Jack Jensen Chairman, Washington County Board of Supervisors Blair, Nebraska 68023 U.S. Environmental Protection Agency Region VII ATTN: Regional Radiation Representative 324 East lith Street Kansas City, Missouri 64106

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Mr. Frank dibson W. Dale Clark Library

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215 South 15th Street Omaha, Nebraska 68102 Alan H. Kirshen, Esq.

328 Aquila Court 1615 Howard Street Omaha, Nebraska 68102 Mr. Larry Yandel.1 U.S.N.R.C. Resident Inspector P. O. Box 309 Fort Calhoun, Nebraska 68023 Mr. Charles B. Brinkman Manager - Washington Nuclear Operations C-E Power Systems Combustion Engineering, Inc.

4853 Cordell Avenue, Suite A-1 l

Bethesda, Maryland 20014 Regional Administrator Nuclear Regulatory Commission, Region IV Office of Executive Director for Opbrations 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 l

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1

2.0 LIMITING CONDITIONS FOR OPERATION 2.15 instrumentation and Control Systems Applicability Applies to plant instrumentation systems.

Ob_iective To delineate the conditions of the plant instrumentation and control systems necessary to assure reactor safety.

Specifications The operability of the plant instrument and control systems shall be in accordance with Tables 2-2 through 2-5.

In the event the number of channels of a par,ticular system in service falls one belew the total number of four channels, the inoperabic channel shall be placed in either the. bypassed or tripped condition within one hour if the channel,is equipped with a key operated bypass switch and eight-hours if jumpers or blocks must be installed in the control-circuitry. -For the purpose of testing and maintenance *, the inoperable channel may be bypassed for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months from t1me of initial loss of operability; '-^ ^ "-

40

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epersb4'4 ty i 2:ter-mined cc the recult af malf-une&&ecing "TD: er nuclear-detectors:

supplying rigae'r to th^ high pcuer level, ther.21 : rgin/les pressurizer-pressurc, and axial pcucr distribation, thcam shm.ncis any xn wy7,ccma rm.

,m em 7 a,ye erm- *<-m er 4 4-4,,

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b414 ty.

If the inoperable channel is not restored to operable status after the allowable times for bypass, it shall be placed in the tripped position.

If required for active maintenance or surveillance. testing to establish operability and place a channel back in service, the trip unit may be installed and bypassed af ter the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months cr-7 J j periodys' whichever I cppliccble.

One-ehannel of the high rct t iy.!!c range-leg-+r4p-unite coacciated uith-the : rtup nucles Jct:ter may be hypcceed fer cn-un14mi+ed-t-tae-per-i-od, <vnl w/uZ, An a,<Me gay f 't %. c 4 In the event the number of channels of a particular system in service falls to the limits given in the column entitled " Minimum Operable Channels", one of the inoperable channels must be placed in the tripped position within one hour if the channel is equipped with a bypass switch and within eight hours if jumpers or blocks are required., The second inoperable channel may be bypassed for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

If the channel has not been restored to operable status after 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the _

reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; however, operation can continue without containment isolation signals available if the containment ventilation isolation valves are' closed.

If after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from time of initiating a hot shutdown procedure

'the inoperable channel has not been restored to operable status, the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

I-f---e-s ec o nd-h i gh-r a te-trip-w ide-r a ng e-l og-ch a nne-1-become s -i nope reb 4e3 it rhell be placed ir the tr4pped pccitica wit-hin cac haar.

Amendment No..$, 20, $f, 65, 2-65

h*

1 2.0 LIMITING CONDITIONS FOR OPERATION 2.15 Instrumentation and Control Systems (Continued)

In the event the number of channels ~of a particular system in service falls below the limits given in the columns entit1_ed " Minimum Operable Channels" or " Minimum Degree of Redundancy", except as conditioned by

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the column entitled " Permissible Bypass Conditions", the reactor shall

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be placed in a hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; however, opdra-tion can continue without containment isolation signals available if the ventilation isolation valves are closed.

If minimum conditions are not met within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the minimum number of operable high rate trip-wide range log channels falls below that given in the column entitled " Minimum Operable Channels" in Table 2-2, the reactor shall not be made critical if the plant is attempting a startup or is being operated within the limits prescribed in the column entitled "Permis-sible Bypass Conditions".

If, during power operation, the rod block func, tion of the secondary CEA position indication system and rod block circuit are Inoperable for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the plant computer PDIL alarm, CEA group deviation alar _m and th.e CEA sequencing func, tion are inoperable for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the CEAs shall be withdrawn and maintained at fully withdrawn

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and the control rod drive system mode switch shall be maintained in the off position except when manual motion of CEA Group 4 is requited to control axial power distribution.

Basis During plant operation, the complete instrumentation systems will normally be in service.

Reactor safety is provided by the reactor protection system, which automatically initiates appropriate action to prevent exceeding established limits.

Safety is not compromised, however, by continuing operation with certain instrumentation channels out of service since provisions were made for this in the plant design. This specifica-tion outlines limiting conditions for operation necessary to preserve the effectiveness of the reactor control and protection system when any one or more of the channels are out of service.

All reactor protection and'almost all engineered safety feature channels are supplied with sufficient redundancy to provide the capability for channel test at power, except for backup channels such as derived circuits in engineered safeguards control system.

When one of the four chauncls is taken out of service for maintenance,'

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the protective system logic can be changed to a two-out-of-three coincidence for a reactor trip by bypassing the removed channel. If the_

bypass is not effected, the out-of-service channel (Power Removed)

Amendment No.

2-65a h

TABLE 2 -

Instrument Ooeratine Recuirements for Reactor Protective'Svstem

Test, Minimum Minimum Permissible Maintenance Operable Degree of -

Bypass

& Inoperable No.

Functional Unit Channels Redundancy Condition Bypass

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- 1

!anual (Trip Buttens)

-1 None None N/A.

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2 High Power Level 2(b)(c) 1(c)

Thermal Power Input (e)% ~

Bypassed Below 10-'% of Rated Power (a)(d) 3 Thermal Margin / Low 2(b) 1 Below 10-4% of (e)%

Rated Power (a)(d)

Pressurizer Pressure 4

High Pressurizer 2(b) 1 None (e)

Pressure 5

Low R.C. Flow 2(b) 1 Below 10-'% of (e)

Rated Power (a)(d) 6 Low Steam Generator 2/ Steam 1[ Steam None (e)

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Water Level -

Gin (b)

Gen 7

Low Steam Generator 2/ Steam 1/Steata Below 550 psia (e)

Pressure Gen (b)

Gen (a)(d) 8 Containment High 2(b) 1 During Leak Test (e)

Pressure 9

Axial Power Dis-2(b)(c) g(c)

Below 15% of Rated (e)%

tribution Power 10 High Rate Trip-2 1

Below 10-'% and

% (@)

Wide Range Log Above 15% of

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Rated Power (a)

Channels 11 Loss of Load 2(b) 1 Below 15% of Rated _.(e)..

Power Bypass automatically removed.

a b

One of the inoperable channels must be in the tripped condition within one hour of the time of discovery of loss of operability.

If second channel is inoperable after 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months a unit shutdown must be initiated.

If two channels are inoperable, load shall be reduced to 70% or less of c

rated power.

For low power physics testing this trip may be bypassed up to 10-I% of d

rated power.

Channel may be in bypass for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months from time of discovery of e

loss _of operability.

2-67 Amendment No. (9,

e-TABLE 2-2 *

(Continued) i

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If ino erab e ch 6nel eterm hed to e cau,sfed by 'alfunctionips RTD' or up gd 7 da,ys fro, nuc1 r de ecto the channy may e byp sed fo time scov ry of lo,ss of opdrability.

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Cr/1[per le c/anr,/1 :p'y 'd by a[ed f/r [n un[i[ed tMe p,e d.

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Amendment No.

2-67a

TABLE 2-3 Instrurent Operatine ?ecuirenents for Encineered Safety Features I

Test, Minimum Minhum Permissible Maintenance Operable Degree of 3ypass

& Inoperability No.

Functional Unit Channels Redundancy Conditions Bypass

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~ 1 Safety Iniection A

Manual 1

None None N/A 3

High Contain=ent 2((a)(d)

Pressure A 1

During Leak Test (f) 2 a)(d) 3 C

Pressurizer Low /

Low Pressure A 2(a)(d) 1 Reactor Coolant

-(f) 3 2(a)(d) 1 Pressure Less Than 1700 psia (b) 2 Containment Spray A

Manual

-- 1 None None N/.A 3

'High Containment Pressure A 2(a)(c)(d) 1 During Leak Test (f) 3 2(a)(c)(d) 1 C

Pressurizer Lov/

Lov A 2(a)(c)(d) 1 Reactor Coolant (f) 3 2(a)(c)(d) 1 Pressure Less Dr.an 1700 psia (b) 3 Reeirculation A

Manual 1

None None N/A 2((a)(d)

B SIRW Tank Lov Level A 1

None (f) 2 ")(d) 1 3

L

.Emer ency Off-Site Power Trio A

Manual 1(e)

None None N/A 3

E=ergency Bus Lov Voltage (Each Sus)

- Loss of Voltage 2(d) 1 Reactor Coolant (f)

- Degraded Voltage 2(a)(d) 1 Temperature Less Than 3000F I

Amend:ent No. AI. 65, 2-68

I i.

v TABLE 2-3 (Continued)

Instrument Operating Requirements for Engineered Safety Features

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Test, Minimum Minimum Permissible Maintenance &

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Operable Degree of Bypass Inoperability No.

punctional Unit Channels Redundancy Conditions Bypass 5

Auxiliary Feedwater A

Pbnual 1

None None N/A B

Auto. Initiation A Operatir.g B

Modes 3, 4, and 5

- Steam Generator 3(a){E) 1 f

Low Level

- Steam Generator 3(a)(h) 1 f

Low Pressure,

g) g

- Steam Generator

~3 1

f Differential Pressure a

A and B actuation circuits each have 4 channels.

b Auto removal of bypass above 1700 psia.

Coincident high containment pressure and pressurizer low / low pressure signals c

required for initiation of containment spray, d

One of the inoperable channels must be in the tripped pondition within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of the time of discovery of loss of operability.

If second channel is inoperable after 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months a unit shutdown must be initiated.

e Control switch on incoming breaker.

.2 f

Channel may be bypassed for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months from time of discovery of. loss of operability.

g Two channels are allowed to be inoperable provided that one and only one is l

in the low level actuation permissive condition.

h Three channels required because bypass or failure results in auxiliary l

feedwater actuation block, in the affected channel.

Amendment No. 65, 2-68a r.

_ _____.____________ _ _

ML20027B711

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Dear Mr. Jones:

SUBJECT:

Enclosure:

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ML20027B711

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Dear Mr. Jones:

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Enclosure:

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