ML20064A917
| ML20064A917 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/28/1990 |
| From: | OMAHA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20064A915 | List: |
| References | |
| NUDOCS 9010030026 | |
| Download: ML20064A917 (6) | |
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1 3.0 SURVEILLAECE REOUIREMENTS 3.6 SafetyIn!!ectionandCentainmentCoolinaSystemsTests(Continued)
(3) hEti av The-safety-4ndest4en-pumpst-shutdown-soo44mg-pumpsy-and-sen-tainment-spray-pwmps-sha44-be-started-at-4ntervals-net-te j
exceed-three-months,--Alternate-manua4-starting-between-sen-tre4-room-sensele-and-the-4ecal-panel-sha44-be-praet4eed dur4mg-refwe44ng-outages, b,
Aseeptable-4evels-of-performance-sha44-be-that-the-pumps starty-reach-the4r-rated-heads-at-m4n4 mum-res4rew4at4en J
flowr-and-operate-for-at-least-f4fteen-m4 mutes, (4) Valves a,
The-SIRW-sterage-tank-outlet-valves-and-conta4nment-sump 4selat4en-valves-sha44-he-stroked-during-the-pump-test, b,
The-SI-tank-Eheek-valves-sha44-be-shetked-for-operab444ty.
dur4ng-each-refwe14mg-shutdown, (S) Containment Recirculatina Air Coolina and Filterina System i
a.
Emergency mode damper, automatic valve, fan, fusible link automatic dainper,. and raw water backu) valve operation will be checked for operability during eac1 refueling outage.
j b.
Each fan and remotely operated damper required to function during accident conditions will be exercised at intervals not to exceed three months, c.
Each air filtering circuit will be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month, d.
A visual examination of the HEPA and charcoal filters will be made during each refueling outage to insure that leek i
paths do not exist, e.
Measurement of pressure drop across the combined HEPA and charcoal adsorber banks shall be performed at least once )er plant operating cycle to verify a pressure drop of less tlan 6 inches of water at system design flow, f.
Fans shall be shown to operate within +/-10% design flow during each refueling outage.
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3-55 i
Amendment No.-15 -24 7
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3.0' SURVEILLANCE REOUIREMENTS 3.6 Safety in:!ection and Containment Coolino Systems Tests (Continued)
(3) Containment Recirculatino Air Coolino and Filterino System a.
Emergency mode damper, automatic valve, fan, fusible link automatic damper, and raw water backu) valve operation will be checked for operability during eac1 refueling outage, b.
Each fan and remotely operated damper required to function during accident conditions will be exercised at intervals not to exceed three months.
c.
Each air filtering circuit will be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month, d.
A visual examination of the HEPA and charcoal filters will be made during each refueling outage to insure that leak oaths do not exist.
e.
Measurement of pressure drop across the combined HEPA and charcoal adsorber banks shall be performed at least once
>er plant operating cycle to verify a pressure drop of less t1an 6 inches of water at system design flow, f.
Fr's shall be shown to operate within +/-10% design flow di Ing each refueling outage.
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3-55 Amendment No. 15. H i
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l DISCUSSION, JUSTIFICATION, AND N0 SIZIFICANT HAZARDS CONSIDERATIONS DISCUSSION AND JUSTIFICATION The Omaha Public Power District proposes to delete Specifications 3.6(3) and 3.6(4). These specifications delineate the surveillance requirements for the Safety Injection and Containment Cooling Systems pumps and valves.
The proposed change would delete redundant surveillance requirements and an i
error contained in the-Technical Specifications.
Specification 3.6(3) Pumps The current specification defines the frequency for testing and the
. acceptable level of performance of the Safety Injection, Shutdown Cooling, and Containmeat Spray pumps.
In addition, this specification requires that starting of the pumps be alternated between the control room panel and the local panel.
This specification would be deleted in its entirety.
The pumps are currently tested to meet the requirement of Specification 3.3(1)a.
Specification 3.3(1)a states that inservice testing of ASME Code Class 1, Class 2, and Class 3 pumps and valves shall be in accordance with Section XI of the ASME Boiler and Pressure Vessel Code as required by 10 CFR Part 50, Section 50.55a(g), except where specific relief has been granted by the Commission.
Article IWP-3400,Section XI of the ASME Code requires testing to be completed every 3 months which is consistent with the current specification.
Article IWP-3100 defines the acceptable performance of pump testing and requires test parameters in addition to those in the current specification.
Therefore this proposed change would retain the more restrictive specification.
There is no local panel installed in the Fort Calhoun Station Unit No I which supports the requirement to alternate testing between the control room panel and the local panel. This situation was reported to the NRC in 1.icensee Event Report 50-285/90-17 dated June 27, 1990. There is no current design requirement or licensing basis for a local panel and therefore this statement is to be deleted.
Specification 3.6(4) Valves The current specification defines the frequency for testing the outlet valves on the Safety Injection and Refueling Water Tank (SIRWT), the i
containment sump isolation valvos and the Safety Injection tank check valves.
This specification would be deleted in its entirety.
The valves are currently' tested to meet the requirement of Specification 3.3(1)a.
Specification 3.3(1)a states that inservice testing of ASME Code Class 1, Class 2, and Class 3 pumps and valves shall be in accordance with Section t
l XI of the ASME Boiler and Pressure Vessel Code as required by 10 CFR Part 50, Section 50.55a(g), except where specific relief has been granted by the t
Commission.
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a Article IWV 3411,Section XI of the ASME Code requires testing to be completed every 3 months for valves classified as Category A or B which is consistent with the current specification for the SIRWT outlet valves and
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the containment sump isolation valves. Article IWV-3521 requires testing of check valves at least once every 3 months, except as provided by Article j
IWV-3522.
The SI check valves have an NRC approved relief from this i
requirerent to test these valves at a refueling outage frequency which is
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consistent with the current specification. Therefore this proposed change would not reduce current requirements and is only deleting redundant i
requirements.
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Specification 3.6(5)
Specification 3.6(5) is renumbered to reflect the deletion of Specifications 3.6(3) and 3.6(4).
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BASIS FOR N0 SIGNIFICANT HAZARDS CONSIDERATI~]:
The proposed change does not involve a significant hazards consideration because operation of Fort Calhoun Station Unit 1 in accordance with this change would not:
(1)
Involve a significant increase in the probability or consequences of an accident previously evaluated.
This change merely eliminates redundant administrative requirements contained within the Technical Specifications concerning the surveillance requirements of the safety injection and containment cooling pumps and valves and corrects an error concerning a requirement for a panel which is not present at the Station.
Therefore this change cannot increase the probability or consequences of an accident.
l (2)
Create the possibility of a new or different kind of accident from any previously analyzed.
It has been determined that no new or different kind of accident will be possible due to this change. No new or different modes of operation are proposed for the plant as a result of this change.
The elimination of redundant administrative requirements and deletion of a requirement for equipment that is not present at the Station does not create the possibility of a new or different kind of accident, t
(3)
Involve a significant reduction in a margin of safety.
Elimination of redundant administrative requirements and the deletion of a requirement for equipment that is not present at the Station will i
not reduce the margin of safety.
The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration.
Example (1) relates to a t
purely administrative change to Technical Specifications:
for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature.
The proposed change described above is similar to Example (i) in that the deletion of the requirement to test the pumps by starting them from the local i
panel corrects an error contained within the Technical Specifications and that Specification 3.3(1)a contains NRC approved testing requirements which are L
redundant to Specifications 3.6(3) and 3.6(4).
Therefore based on the above considerations, OPPD does not believe that this proposed amendment involves a significant hazards consideration as defined by 10 CFR 50.92 and the proposed changes will not result in a condition which I
significantly alters the impact of the Station on the environment.
Thus, the L
proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(e)(9) and pursuant to 1( Z R 51.22(b) no environmental i
assessment need be prepared.
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