ML20134P862

Responds to Request for Addl Info Re Alternate Shutdown Capabililty for Fire Area 34B,per 10CFR50,App R.Util Upgrading Emergency Operating Procedures Per NUREG-0737, Item 1.C.1

ML20134P862
Person / Time
Site:	Fort Calhoun
Issue date:	08/30/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Butcher E Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM LIC-85-364, NUDOCS 8509090074
Download: ML20134P862 (6)

Text

-- ______

i Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536-4000 August 30, 1985 L IC-85-364 Mr. Edward J. Butcher, Acting Chief Operating Reactors Branch #3 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

References:

(1) Docket No. 50-285 (2) Letter OPPD (R. L. Andrews) to NRC (J. R. Miller) dated January 9,1985 (LIC-84-338)

(3) Letter OPPD (R. L. Andrews) to NRC (J. R. Miller) dated April 8,1985 (LIC-85-142)

Dear Mr. Butcher:

Request for Addi tional Infomation Concerning 10 CFR 50 Appendix R Omaha Public Power District (0 PPD) described in Reference (2) its alternate shutdown capability for Fire Area 348. Additional information was requsted and OPPD responded via Reference (3). Mr. E. G. Tourigny, of your of fice, requested additional information concerning our Reference (3) submittal .

Please fi'id attached OPPD's response to these additional questions, and change pages, as appropriate.

Si cerely, Y%/wW R. L. Andrews Division Manager Nuclear Production RLA/DJM/rh Attachments cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 I l

Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Ir.spector 8509090074 esc 830 J PDR F

ADOCK 05000285 PDR 0 h j

' l

.s s 24 uncioumengngugonnononav

ATTACHMENT 1 NRC Questions on Appendix R and Responses

1. Verify that for a fire in Fire Area 348, the first action that will be taken by an individual will be to close the PORV's to prevent a LOCA.

Response The response to Iten 1.e of Reference (2) stated that the District, in response to NUREG-0737, Item 1.C.1, is upgrad-ing its Emergency Operating Procedures. This upgrade will

- be completed prior to Cycle 10 startup. The requirement to immediately close the PORV's upon detection of a fire in Fire Area 34B will be incorporated into the appropriate

Abnonnal Operating Procedure (which is entered into before a i reactor trip and whose followup actions are also carried out should a reactor trip occur.)

i 2. The response to Item 2 states from Technical Specification 5.2.2.e, in part, "...The minimum shift crew necessary for safe shutdown of the unit (2 menbers)." Later, in the same response, the minimum manpower require-ments identify the need for a minimum of five members. Verify that the technical specifications will be modified to reflect the five people needed to safely shut down the plant.

Response OPPD has reviewed the manpower requirements and procedures necessary to achieve safe shutdown of the unit in the event of a fire in Fire Area 34B. Results of this review indicate

! that a number of the procedural requirements can be com-bined, thus reducing the minimum number of operators re-quired to shut down the plant. Revised pages of Reference j (2) are provided in Attachment 2.

As shown in Attachment 2, only two members of the shif t crew i are required, as a minimum, for safe shutdown of the plant.

The Reactor Operator (RO) will remain in the Control Room.

The Assistant Reactor Operator ( ARO) will proceed immediate-ly to the switchgear room to isolate power feeds to and from j the affected fire area (including the requirenents of Re-sponse 1, above). The ARO will then proceed directly to Roon 81 to manually position valves HCV-1107B and HCV-1108B l as directed by the R0. Once this has been accomplished, he will return to the Control Room to assist the R0. The ARO will remain available to return to Room 81 as necessary to reposition the auxiliary feedwater valves.

The Shift Technical Advisor (STA) is available for guidance and as an aid in conmunication, but is not required. It should be noted that this is the minimum crew necessary to

safely shut down the plant. As shown in Attachment 2, two additional operators are available and procedures will be developed based on their presumed availability. The above outlined procedure is provided only to illustrate the fact that the plant can be shut down with only two shift crew members available.

4

, . , . . , , ~

, , , . - - - - - ---,,,,.,..-,,.-,_,,,---.-c,,--

- n---, - - - - - - , - - - - , . , ,.

3. Provided a commitment stating that no fuses will be pulled to bring the plant to a safe shutdown condition. Alternately, if circuit breakers will be installed, provide 1) a commitment to install the circuit breakers; 2) an installation schedule, and 3) justification for interim i operation.

Response (1) As stated in Reference (3), new instrument inverters are being installed at Fort Calhoun. Circuit breakers will be installed as part of this modification to pro-vide the required isolation.

(2) Installation of these inverters is currently scheduled for the 1985 refueling outage with a completion /imple-mentation date of 30 days following the end of the re-fueling outage.

(3) Interim operation is justified by the fact that the required isolation can currently be performed without pulling any fuses. This is accomplished by the use of various breakers as described in the response to Re-quest (3) in Reference (3). Plant operating staff has been informed of the concern and possible consequences of a fire in this fire area. Direction has been pro-vided to ensure that operators are aware of the proper method of isolating power to and from the affected fire area without the pulling of fuses.

4. Clarify the members of the Fire Brigade as cited in Reference (3)

Response Reference (3) contained a description and listing of the mem-bers of the Fort Calhoun Station Fire Brigade. The Shift Supervisor was identified as the Fire Brigade Leader. Based on an open item identified in an inspection report, steps have been taken to assign the responsibility of Fire Brigade Leader to the Licensed Equipment Operator-Nuclear. See Attachment 2 (pg.10) for the changes necessary to incor-porate this change.

4

Attachment 2 Revised Pages 9 and 10 to LIC-84-338

.g.

f. Verify that the inanpower required to perfom the shutdown functions using the procedures of e. as well as to provide fire brigade members to fight the fire is available as required by the fire brigade technical specift-cations.

Response: Technical Specification 5.2.2 defines the minimum operating crew and fire brigade size. During normal plant operation, a minimum oper-a ting crew of seven persons is maintained on all shifts. This includes shift supervi sor*, reactor opera tor * , assistant reactor operato r* , turbine building operator *, auxiliary building operator *,

water treatment plant operator *, and shif t technical advisor (STA).

Two of six security force personnel

• and one phone talker

• are avail-able for fire brigade duty. This ensures that technical specifica-tion requirenents for a minimum fire brigade size of five persons, and minimum operating crew of two persons necessary for safe shut-down, are available and that at least three addi tional persons are available to accomplish steps 1.e.2 and 1.e.3 above. In sunma ry, manpower allocation is as follows:

NOTE: Personnel who have received Fire Brigade training are indicated by an *.

Fire Brigade (per Standing Order G-28)

Licensed Equipment Operator - Nuclear (Leader) l Water Plant Operator Phone Talker 2 Security Personnel Control Room (Tech. Spec. 5.2)

Reactor Operator Assistant Reactor Operator Shif t Technical Advisor Room 81 (Auxiliary Feedwater Throttling as needed)

Assistant Reactor Operator Switchgear Room Assistant Reactor Operator Additional Personnel Available Turbine Building Operator Auxiliary Building Operator 4 Security Force Personnel

e. Verify that licensee procedures have been or will be developed which describe tasks to be perfomed to effect the shutdown method. Provide a summary of these procedures outlining operator actions.

Response: In response to NUREG 0737. Iten I.C.1, the District is upgrading its Emergency Operating Procedures. This upgrade process will be com-plete and implemented prior to Cycle 10 startup. The Functional Recovery Procedure will provide guidance on how to maintain the safety functions as outlined in the response to Question 1.a on page 4 and ensure a safe plant shu tdown for this fire. The expected operator response, utilizing the Function Recovery Procedure, is as follows:

1. A reactor shutdown or trip will be initiated manually fran the control room. The controll ed shutdown method is nomally preferable to a trip; howeve r, the severity of the fire will determine which method is appropriate. An automatic reactor trip may occur.

2. An operato r will proceed to the swi tchgear room to i sola te power feeds to and from Fire Area 34B-West.

3. He will then proceed to valves HCV-1107B and HCV-11088 in roon 81 and will take manual control of these valves per direction of the control roon operator. He will then return to the con-trol room, and will be available to return to room 81 to throttle valves HCV-1107B and HCV-1108B as required.

4. Using available indications (i.e., pressurizer pressure and level, steam generator pressure and level, auxiliary feedwater flow and neutron flux) control room operators will use auxi-11 ary feedwater pump, FW-6 (or FW-10), and will direct manual throttling of control valves HCV-1107B and HCV-1108B to suffi-ciently renove decay heat from the primary systen via the stean generators and thus control RCS pressure.

5. As decay heat drops with time, intennittent chanjing pump opera-tion may be used to maintain system pressure and pressurizer level if necessary.

6. Once RCS pressure and tenperature drop below 265 psia and 300*F, respectively, the shutdown cooling system will be utilized to achieve cold shutdown.

It should be noted that this alternative shutdown capability already exi sts. Fort Calhoun station operating personnel have been trained in the use of the auxiliary feedwater system to control RCS pressure as this is the method used in our alternate shutdown systen for the control room.