ML20087N428
| ML20087N428 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/27/1984 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.E.1.1, TASK-2.F.2, TASK-3.D.3.4, TASK-TM GL-83-37, LIC-84-071, LIC-84-71, NUDOCS 8404030447 | |
| Download: ML20087N428 (5) | |
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l Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536 4000 March 27, 1984 LIC-84-071 Mr. Darrell G.
Eisenhut, Director l
U.S.
Nuclear Regulatory Commission l
Of fice of Nuclear Reactor Regulation Division of Licensing Washington, D.C.
20555
Reference:
Docket No. 50-285
Dear Mr. Eisenhut:
NUREG-0737 Technical Specifications (Generic Letter 83-37)
Generic Letter 83-37, dated November 1, 1983, required Omaha Public Power District to submit Technical Specifications required for NUREG-0737 items.
The schedule for the District's response to Generic Letter 83-37 was established in a letter to the Commission dated December 6, 1983.
Pursuant to that schedule, the District has submitted a license amendment application for several of the items discussed in Enclosure I of Generic Letter 83-37.
The pur-pose of this letter is to address the NUREG-0737 items listed in Enclosure I of the subject generic letter which are not addressed in the District's license amendment application.
The status of those items is as follows:
(1)
Post Accident Sampling (II.B.3)
In the District's December 6, 1983 letter to the Commission, the post accident sampling system Technical Specification was scheduled to be submitted to the Commission by March 1, 1984.
However, since the post accident sampling system is 3@@
not fully operable, the Technical Specifications have not QQL been, submitted.
A license amendment application will be sub-oc mitted on the post accident sampling system when it is de-clared fully operable.
This is in accordance with Generic o
Letter 83-37 and pursuant to discussions held with Mr.
E.
G.
eg Tourigny of your staff.
38 QQ (2)
Long Term Auxiliary Feedwater System Evaluation (II.E.1.1) e The District believes the existing Fort Calhoun Station WEL Technical Specifications covering the auxiliary feedwater system ensure the same level of systern reliability as do the recommended Combustion Engineering Standard Technical Speci-fications.
Attached is a discussion supporting this con LO g
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Mr._Darrell G. Eisenhut JLIC-84-071-Page Two p--
- (3).
Instrumentation for Detection of Inadequate Core Cooling (II.F.2)
Installation of the_ inadequate core cooling system is pre-sently ongoing, with installation scheduled during the 1985 refueling outage.
A license amendment application will be i.
made on'a schedule consistent with that date.
(4)
Control. Room Habitability (III.D.3.4)
Modifications necessary to resolve the control room habit-ability _ issue are currently ongoing, with a scheduled com-pletion date of June 30, 1984.
A license amendment appli-cation will be made on a schedule consistent with that date.
The District believes the response supplied by this letter and the license amendment application adequately address the requirements of Generic Letter 83-37.
Sincerely, t.
%W W. C.
ones Divisi%n Manager Production Operations l
WCJ/JCB: jam-Attachment-cc:
'LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
. Washington,_D.C.
20036 Mr.
E. G._Tourigny, Project Manager Mr. L. A. Yandell,-Senior Resident Inspector
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i Attachment 4
LONG TERM AUXILIARY FEEDWATER TECHNICAL SPECIFICATION EVALUATION (NUREG-0737, SECTION II.E.1)
In~ response to NUREG-0737 TechnicalLSpecifications Generic Letter 83-37, which' required licensees to submit proposed Technical Speci-4 fications for items scheduled after December 31, 1981, the follow-ing discussion is' submitted which reviews and compares the exist-ing' Fort Calhoun Station Technical Specifications to points cover-ed in the typical generic Technical Specifications as they relate to-the auxiliary feedwater system.
The Technical Specifications section~ numbers used in the following discussion refer to the sections as they are numbered in the generic Technical Specifi-cations.-
Limiting Conditions for Operation The limiting conditions for operation, Section 3.7.1.2 in the generic Technical Specifications, specify that it is necessary for all auxiliary'feedwater pumps and associated flow paths to'be oper-able.
This_can-be compared to the limiting conditions for oper-ationifor the Fort Calhoun Station which specify "The reactor coolant system shall'not.be heated above 300*F unless (refer
- to the Fort Calhoun-Station Technical-Specifications, Section 2.5, t
- for detailed specifications'of the following):
^
(1)
Both auxiliary feed-pumps are operable.
(2)
There is a minimum of 55,000 gallons of water in the emer-gency feedwater storage tank, with a backup supply to the Missouri River.
2 (3)
All valves, interlocks,-and piping associated with the system are operable and. all-manual-valves are locked in the required-position.
(4)
The main steam isolation valves are operable and capable of closing in"~4 seconds or less.
. The action to be taken in the event of-surpassing liadtva9 condi-
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tions for operation for the Fort Calhoun Station is also con-sistent.with that of,the generic specifications.
The action for i
. the Fort Calhoun Station is that the unit will be placed in hot-shutdown-within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, be at least subcritical and 300*F within-the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and be in at.least cold shutdown within the fol-lowing;30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (refer to the Fort Calhoun Station Technical Speci-
. fications, Section.2.0.1, for detailed specifications of the.
' above).
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.- Surveillance Requirements For each applicabla section in the generic specifications, the
. equivalent Fort Calhoun Station Technical Specifications can be compared as follows:
a.1:
The generic specifications have to verify that the motor driven pump capabilities exceed certain limits.
This cor-responds to the_ Fort Calhoun Station Technical Specifi-cations, Sections 3.9.2 and 3.9.3, which verify the oper-ability and capability of both auxiliary feedwater pumps, respectively.
The generic. specifications indicated that this be done monthly.
The Fort Calhoun Station Technical Specifications require this to.be done only quarterly.
The Fort.Calhoun Station Technical Specifications are based on
'the latest inservice test procedures which specify that the pumps and valves be tested quarterly.
Specifically, Article IWP-3400 states the frequency of inservice testing for pumps and Article IWV-3411 states the frequency for valve exer-cising..The actual test performed is ST-FW-1 F.2, which verifies that each pump operates at least 40 psig above steam generator pressure.
-a.2:
This section has to verify the capability of the steam driven pump.
This section is also covered by the Fort Calhoun Station Technical Specifications, Section 3.9.3, and Surveil 3ance Test ST-FW-1 F.2.
The Fort Calhoun Station Technical Specifications,'Section 3.9.2, also-verify the operability of'the steam driven pump every 3 months, as governed by.the latest inservice test procedures.
- a.3:
This section verifies that.each non-automatic valve in the flow path is in its correct position.
This is covered by Section 3.9.1 of the Fort Calhoun Station Technical Speci-fications.
The Fort Calhoun' Station Technical Specifi-Leations verify the position'of all valves monthly and pro-vides a double operator verification of valve position after any maintenance work.
The actual surveillance test is ST-FW-1 F.1, which performs a double operator verification of all auxiliary feedwater valves monthly.
i
_ a.4 :. 'The verification of all automatic valves opening is covered in.this.section.
The Fort Calhoun Station Technical Specifi-cations,1Section 3.9.2, cover confirming that the automatic valves and auxiliary feedwater cross-tie valve are all oper-able on a. quarterly _ basis.
However, Surveillance Test ST-FW-1 F.1 performs a double' operator valve checklist
- monthly.. This covers all auxiliary feedwater valves.
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For plants with only 'one auxiliary feedwater train available during testing, this section provides for a dedicated indivi-dual to be stationed near any manually realigned valves.
At the Fort Calhoun Station, a train is not lost during testing because there are 2 actuation relays in parallel in each channel.
This ensures that a single failure will not in-hibit the : auxiliary feedwater system.
Each channel is cap-able of starting both trains regardless of the status of the other channel.
When a channel is tested, the matrix auto-matically goes to a 2-out-of-3 logic.
On-line testing is performed by placing the channel A and B "AFWS Auto Signal override" switches in the override position for one gener-ator at a time and closing the related actuation relay con-tacts one at a time.
The turbine driven pump is actually started -and all the auxiliary feedwater valves kept closed.
During testing of the valves, one valve at a time is opened by its own steam generator actuation relay contact.
How-ever, there is normally an I&C Technician in contact with someone in the control room during testing.
b.1 &
b.2:
These sections specify that at least once per 18 months during shutdown, the automatic valve operation and auxiliary feedwater pump starts are verified.
These sections cor-respond identically to the Fort Calhoun Station Technical Specifications, Sections 3.9.5a and 3.9.5b.
An auxiliary feedwater system functional test, as well as sensor cali-bration, is performed each refueling according to ST-FW-3 F.4 and ST-FW-3 F.3, respectively.
- The only discrepancy is the quarterly versus monthly testing of the auxiliary feedwater pumps and valves.
The District believes that quarterly testing justification provided in the inservice in-spection. code is met and no change is required.
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