ML20035C834
| ML20035C834 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 04/06/1993 |
| From: | Steven Bloom Office of Nuclear Reactor Regulation |
| To: | Tira Patterson OMAHA PUBLIC POWER DISTRICT |
| References | |
| TAC-M79675, NUDOCS 9304090130 | |
| Download: ML20035C834 (5) | |
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UNITED STATES hytd
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%g April 6, 1993 Docket No. 50-285 1
Mr. Terry 1.. Patterson i
Division Manager - Nuclear Operations Omaha Public Power District 444 South 16th Street Mall Mail Stop BE/ EPA Omaha, Nebraska 68102-2247 j
Dear Mr. Patterson:
SUBJECT:
EXEMPTION FOR PENETRATION M-3 FROM 10 CFR PART 50, APPENDIX J REQUIREMENTS (TAC NO. M79675)
By letter dated January 26, 1983, of Fort Calhoun Station, Unit No. 1, requested an exemption from thethe lice requirements of Appendix J for Type C leakage tests on the containment isolation valve (check valve CH-198) associated with the charging pump discharge header (penetration M-3.
the licensee pr)oposed technical specification changes t Subsequently, by letter dated November 27, 1985, reflect the requested exemption.
Based on supporting documentation from the November 27, 1985, letter, the staff in a safety evaluation (SE) dated January 10, 1986, concluded that the i
containment isolation valve CH-198 met all requirements provided in Section III.C.2.(b) of 10 CFR Part 50 Appendix J for valves pressurized with fluid from a water seal system. Accordingly, the staff concluded that the proposed technical specification was acceptable and no exemption was needed.
By letter dated February 14, 1991, the licensee notified the staff of a revised containment pressure analysis indicating that for certain accident scenarios the post-LOCA containment pressure would remain above 6 psig for the initial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and would remain above the water head existing in the charging pump system for the duration of the accident.
Therefore, penetration M-3 would be a potential leakage path. Consequently, the above exclusion of penetration M-3 from the Appendix J Type C test requirements was invalidated.
By letter dated May 1,1992, the licensee stated that the final corrective actions, which will require operator actions and associated procedures to isolate this potential containment leakage path, had been implemented.
We have reviewed the licensee's corrective actions and prepared the enclosed SE.
Based on our review, we find that the basis for the exclusion of the ERC Fi!E CEgygg enm.
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Mr. Terry L. Patterson ;
containment isolation valves associated with ' penetration M-3.is acceptable.
l Therefore, we consider. the issue of Type C testing requirements for~ the above cited containment isolation valve resolved.
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Sincerely, i..
ORIGINAL SIGNED BY:
j Steven Bloom, Project Manager.
l Project Directorate IV-1 Division of Reactor Projects - III/IV/V-Office of Nuclear Reactor. Regulation
Enclosure:
Exemption cc w/ enclosure:
j See next page DISTRIBUTION:
Docket File NRC & Local PDRs PD4-1 r/f l
J. Roe T. Murley/F. Miraglia J. Partlow l
M. Virgilio G. Hubbard P.:Noonan S. Bloom ACRS (10) l A. B. Beach j
J. Lieberman E. Jordan-i G. Hill (2)
OPA l
i OC/LFDCB J. Mitchell, EDO (MS17G21)
OGC PD4-1 p/f
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FC79675.EXE A
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Mr. Terry L. Patterson containment isolation valves associated with penetration M-3 acceptable.
Therefore, we consider the issue of Type C testing requirements for the above cited containment isolation valve resolved.
l Sincerely, l
Steven Bloom, Project Manager Project Directorate IV-1 r
Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
Exemption cc w/ enclosure:
l See next page l
DISTRIBUTION:
Docket File NRC & Local PDRs PD4-1 r/f J. Roe T. Murley/F. Miraglia l
J. Partlow M. Virgilio G. Hubbard P. Noonan S. Bloom ACRS (10)
A. B. Beach J. Lieberman E. Jordan i
G. Hill (2)
OPA OC/LFDCB J. Mitchell, EDO (MS17G21)
OGC PD4-1 p/f 0FC LA:PD4-1 1:PD4 PS:PD4-1 D:PD4-1,
OGC ADR4/5 D:DRPW NAME
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0FFICIAL RECORD COPY FILE NAME:
FC79675.EXE
Mr. Terry L. Patterson containment isolation valves associated with penetration M-3 is acceptable.
Therefore, we consider the issue of Type C testing requirements for the above cited containment isolation valve resolved.
Sincerely, WD ysJ Steven Bloom, Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
Exemption cc w/ enclosure:
See next page
t Mr. Terry L. Patterson Omaha Public Power District Fort Calhoun Station, Unit I i
cc:
Harry H. Voigt, Esg.
LeBoeuf, Lamb, Leiby & MacRae l
1875 Connecticut Avenue, NW Washington, D.C. 20009-5728 Mr. Jack Jensen, Chairman Washington County Board of Supervisors Blair, Nebraska 68008 Mr. Raymond P.'Mullikin, Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 309 Fort Calhoun, Nebraska 68023 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations i
Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington,' Texas 76011 Harold Borchert, Director Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South Post Office Box 95007 Lincoln, Nebraska 68509 Mr. James W. Chase, Manager Fort Calhoun Station Post Office Box 399 Fort Calhoun, Nebraska 68023
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of
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l OMAHA PUBLIC POWER DISTRICT Docket No. 50-285
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(Fort Calhoun Station, Unit-1)
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i EXEMPTION I.
i The Omaha.Public Power District (OPPD/the licensee) is the holder of l
Facility Operating License No. DPR-40, which authorizes operation of the Fort Calhoun Station, Unit 1 (the facility), at ' steady state reactor core power levels not in excess of 1500 megawatts thermal. This facility is a pressurized water reactor located in Washington County. Nebraska. The license provides, among other things, that Fort Calhoun Station, Unit 1, is subject to all rules, regulations, and Orders of the Commission now or hereafter in effect.
By letter dated January 26, 1983, the licensee (Omaha Public Power District) of Fort Calhoun Station, Unit No.1, requested an exemption from the requirements of Appendix J for Type C leakage tests on the containment isolation valve (check valve CH-198) associated with the charging pump discharge header (penetration M-3). Subsequently, by letter dated November 27, 1985, the licensee proposed technical specification changes to i
reflect the requested exemption.
The justification for not performing Type C tests on this valve was that, following a loss-of-coolant accident (LOCA), all the charging. pumps would remain operational or would be automatically started and aligned to the fd
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i boric acid storage tanks, which would provide a source of supply to the pumps for approximately 80 minutes. After the-tanks were empty, all these pumps would be shutdown and a 14-ft water head (equivalent to approximately 6 psig)
I would exist on the suction side of the charging pumps for the duration of the J
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i accident. The containment pressure (as originally calculated and presented in i
the previous facility's Updated Safety Analysis Report) would be reduced from the calculated peak pressure of 60 psig to approximately 2 psig within 50 minutes. Thus, the fluid in the suction side of the charging pumps would provide a seal barrier against any potential leakage of the containment atmosphere through this penetration.
L Based on the supporting documentation from the November 27, 1985, letter, the Commission in a safety Evaluation (SE) dated January 10, 1986, concluded that containment isolation valve CH-198 met all requirements provided in Section III.C.2.(b) of 10 CFR Part 50 Appendix J for valves pressurized with fluid from a water seal system. Accordingly, the Commission
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concluded that the proposed technical specification was acceptable and no exemption was needed.
By letter dated February 14, 1991, the licensee notified the Commission of a revised containment pressure analysis indicating that for certain accident scenarios the post-LOCA containment pressure would remain above 6 psig for the initial 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and would remain above'the water head existing in the charging pump system for the duration of the accident. Therefore, penetration M-3 would be a potential leakage path. Consequently, the.
exclusion of penetration M-3 from the Appendix J Type C test requirement was invalidated.
In Licensee Event Report (LER) 91-03, dated March 6, 1991, the
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licensee provided the detailed interim corrective actions taken and the 1
history of subsequent' changes (e.g., containment spray nozzle blockage, containment spray pump power, containment spray pump run-out, degraded containment air cooler performance, etc.) that led to the revised containment pressure analyses.
I By letter dated May 1,1992, the licensee stated that the final corrective actions, which will require operator actions and associated procedures to isolate this potential containment leakage path, had been implemented.
II.
The licensee revised the appropriate emergency operating procedures (EOPs) and abnormal operating procedures (AOPs) to ensure that penetration M-3 would be maintained with water at a pressure higher than the containment j
pressure for the duration of a postulated accident. The plant E0Ps and AOPs now require alignment of either charging pump or high-pressure safety injection pump discharge through penetration M-3 into a cold leg-following a LOCA. The implementation of these procedures with specified operator actions will assure that fluid pressure through penetration M-3 will always be above the post-LOCA containment pressure, and therefore, will prevent any potential containment leakage through penetration M-3.
III.
The Commission has reviewed the licensee's rationale for excluding the containment isolation valve (CH-198) from the Type C tests and the operator actions described in the plant E0Ps and AOPs. The underlying purpose of i
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Section III.C.2(b) of 10 CFR Part 50 Appendix J is to ensure that valves that j
are sealed with fluid from a seal system shall be pressurized with that fluid to a pressure not less than 1.10 Pa. Based on its review, the Commission finds the basis for the exclusion of the containment isolation valve i
associated ~with penetration M-3 acceptable. The special circumstances required by 10 CFR 50.12(a)(2)(ii) are present since the application of the Type C Testing requirements to the valve associated with penetration M-3-is i
not required to achieve the underlying purpose of the rule. The Commission further considers the issue of Type C testing requirements for the above cited containment isolation valve resolved.
t However, the licensee should recognize that granting the exemption for l
the containment isolation valve (CH-198) from Type C testing requirements does not mean that the licensee can delete it as a containment isolation valve, i
because a water seal in a penetration is not accepted as a containment isolation barrier.
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l IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12(a), the exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest and hereby grants an exemption from the requirements of Section III of Appendix J to 10 CFR Part 50 to the extent discussed in Section I above.
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' Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this Exemption will have no significant impact on the quality of the human environment (58 FR 5765).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY:
Jack W. Roe, Director Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 6th day of April 1993 i
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Pursuant to 10 CFR 51.32, the Connission has determined that the granting of this Exemption will have no significant impact on the quality of the human environment (58 FR 5765).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
,o.r.k Q k ack W. Roe, Director Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 6th day of April 1993 i
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