ML20136H006
| ML20136H006 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/07/1986 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737 GL-82-33, LIC-86-001, TAC-60448, NUDOCS 8601090082 | |
| Download: ML20136H006 (5) | |
Text
.
~
Omaha Public Power District 1623 Hamey Omaha. Nebraska 68102-2247 402/536-4000 January 7, 1986 LIC-86-001 Mr. Frank J. Miraglia, Director Division of PWR Licensing - B Office of Nuclear Reactor Regulation U.
S.
Nuclear Regulatory Commission Washington D.C.
20555
References:
1.
Docket No. 50-285 2.
OPPD (Jones) to NRC (Clark) dated 4/15/83 (LIC-83-093).
3.
OPPD (Jones) to NRC (Miller) dated 10/28/83 (LIC-83-276).
4.
NRC (Miller) to OPPD (Jones) dated 2/22/84.
5.
OPPD (Andrews) to NRC (Miller) dated 9/28/84 (LIC-84-323).
6.
NRC (Butcher) to OPPD (Andrews) dated 6/7/85.
7.
OPPD (Andrews) to NRC (Butcher) dated 6/15/85 (LIC-85-233).
8.
NRC (Butcher) to OPPD (Andrews) dated 7/19/85.
9.
OPPD (Andrews) to NRC (Butcher) dated 8/15/85 (LIC-85-373).
- 10. OPPD (Andrews) to NRC (Butcher) dated 11/8/85 (LIC-85-494).
- 11. OPPD (Andrews) to NRC (Thadani) dated 12/9/85 (LIC-85-557).
- 12. OPPD (Andrews) to NRC (Thadani) dated 12/20/85 (LIC-85-523).
Dear Mr. Miraglia:
Request for Change to Order Confirming Licensee Commitments on Emergency Response Capability Schedules (Generic Letter 82-33)
The Omaha Public Power District (OPPD) received two letters (References 4 and 8) which provided the confirmatory orders for the emergency response capability items of NUREG-0737, Supplement 1.
The Reference 4 confirmatory order was amended by Reference 8 (concerning Regulatory Guide 1.97, and, as such, outside the scope of this letter).
Thus, references to confirmatory order throughout this letter refer to Reference 4.
The Reference 4 confirmatory order was based upon Reference 2.
Implementation of the Safety Par-ameter Display System (SPDS), item lb. of that order, required that the SPDS be fully operational and operators trained.
In addition, the confirmatory order provided a schedule with a completion date of the end of the 1985 refueling outage, originally estimated to be November 30, 1985.
OPPD is presently in the final stages of the 1985 refueling outage.
However, a final SPDS verification and validation test remains to be completed to allow OPPD to declare the SPDS fully operational.
The following information has been 9601090082 060107 m - n. cnurcumn (un. %,
hDR ADOCK0500g5 g[
g
[",ggym)
E!C58 (PARH)
- p FOR (w. atc43) as 5:24 Employmen h
sai opportunny
Mr.
F. J. Miraglia LIC-86-001 Page 2 i
discussed with Mr.
E.
Tourigny of your staff in telephone conversations on January 2 and 3, 1986.
Reference G requested additional confirmatory information concerning SPDS isolation devices.
Since June of 1985, several conference calls were held concerning this issue.
OPPD, in References 10 and 11, provided the requested information.
We also noted that replacement of several of the isolation devices would be necessary in order to meet the NRC's full qualification requirement.
As was noted in Reference 10, OPPD had made a good faith effort to implement the system.
Qualification of the isolators in order to meet the confirmatory order requirement was recognized as not being feasible (due to procurement time, etc.,) by both OPPD and the NRC.
Consequently, Reference 10 noted that this portion of the SPDS would remain outstanding until the 1987 refueling outage (scheduled to end June 1, 1987) when replacement could be accomplished.
Reference 6 also noted that the human factors review of the SPDS remained as a confirmatory item not yet reviewed.
Reference 7 stated that a Control Room Design Review (CRDR) Report Supplement would be issued by August 15, 1985.
Accordingly, Reference 9 was submitted.
As was noted, consistent with the CRDR, final resolution of the Human Engineering Discrepancies (HED's) will be accomplished by the end of the 1987 refueling outage (scheduled to end June 1, 1987).
At the present time, hardware and software installation of the SPDS is complete.
Connected inputs to the SPDS are processed, and can be displayed.
The system has been in operation since February, 1984.
Six one-week operator training sessions were conducted in January and February of 1984.
Retraining will be completed prior to declaring the system fully operational.
The SPDS project status has been monitored in monthly meetings of plant staff and engineering management to review all 1985 outage modifications.
In addition, regularly scheduled monthly project meetings of the project staff examined all aspects of the ERF computer project.
These examinations recognized that completion of the SPDS during the 1985 outage would be difficult but possible if all hardware and software portions were completed on schedule.
Management meetings with the software staff in early December of 1985 confirmed expected completion of the project in January, 1986, thirty days after the end of the outage, as noted in Reference 10.
Mr.
F. J. Miraglia LIC-86-001 Page 3 As stated in Attachment 1 of Reference 2, OPPD proceeded in good faith with the development of the SPDS without waiting for other related projects to be completed.
That is, the Generic Combustion Engineering Emergency Procedure Guidelines (EPG's) were utilized in place of the undeveloped Fort Calhoun specific Emergency Operating Procedures (EOP's).
During the 1984 refueling outage, we completed and documented a formal functional test on the EPG-based SPDS displays and software existing at that time.
This test was in addition to the two factory acceptance tests and one site demonstration test which were conducted by the system vendor as formal, documented tests.
In 1983 and 1984, two operational availability tests were also conducted.
The second test resulted in a satisfactory six-month run of the system with an availebility greater than 99%.
The second test was completed in November 1984.
At that time OPPD could have declared the system fully operational but elected to wait and revise the system to include changes to the software resulting from upgrade of the Emergency Operating Procedures.
Related to the implementation of the SPDS is item 4b. of the Reference 4 confirmatory order for upgrade of the EOP's.
The EOP's are currently undergoing final reviews and will be implemented prior to completion of the 1985 refueling outage.
The EOP's were developed in accordance with the Combustion Engineering Emergency Procedure-Guidelines (CEN-152, Rev. 02) i and rely on the maintenance of safety functions defined in the Safety Function Status Check (SFSC) contained in each EOP.
The EOP's were written with the flexibility that allows the SFSC to be performed without the use of the SPDS, should it be unavailable or inoperable for any reason.
In normal circumstances,' to effectively utilize the SPDS in con-junction with the EOP's, the alarms and displays of the SPDS should have one-to-one correspondence with the EOP Safety Function Status Check.
Upon finalizing the EOP SFSC, it was necessary to change (refine) and regroup the SPDS variables documented in Reference 3.
These changes were anticipated (see Reference 2) because the initial SPDS safety functions were based on Revision 0 of the Emergency Procedure Guidelines, not the Fort Calhoun specific EOP's.
In the future, as the EOP SFSC changes and evolves, the SPDS must also change.
Thus the ongoing improvement of the EOP SFSC will continue to necessitate changes to the SPDS.
As an example of required changes, recent work associated with the OPPD Electrical Equipment Qualification (EEQ) program resulted in the need for further work in the area of instrument uncertainty and inaccuracy.
This work resulted in changes to the EOP SFSC, which, in turn, affected the requirements of the SPDS.
These changes to the EOP's are currently being factored into the SPDS algorithms and displays.
Mr. F. J. Miraglia LIC-86-001 Page 4 Until this is complete, the final SPDS validation testing process cannot be written and conducted.
OPPD anticipates the last of the current changes to the SPDS will be made during this week.
The SPDS will then be ready for testing. The verification and validation procedure will take approximately three weeks to prepare.
(The testing procedures previously used cannot be utilized due to the substantial changes which have subsequently been made to the system).
After Plant Review Committee review and approval of the verification and validation procedures, testing is expected to take several weeks.
Unless required for testing or maintenance activities, OPPD will continue to leave the SPDS turned on during the interim.
The system will be capable of providing the operators with necessary accident information although this information would not have been subjected to final verification.
The operators will be notified that the SPDS information is available, but caution is warranted until verification is completed.
OPPD has also reviewed other items from the Reference 4 confirma-tory order to determine if the delay in operability of the SPDS will impact the completion of any other of those items.
The re-sults of this review indicate that item 5, full implementation of the Emergency Response Facilities is dependent upon data acquisition capability provided by the Emergency Response Facility Computer System in conjunction with the SPDS.
The CRT's are in place and data acquisition capabilities are available with the exception (as noted) of full verification of the SPDS.
No other Reference 4 Confirmatory Order item schedules are affected by these specific extension requests.
It should be noted that Reference 5 provided a milestone schedule for implementation of the Inadequate Core Cooling Instrumentation (ICCI) portion of the SPDS (consisting of the Core Exit Thermocouples, the Subcooled Margin Monitor, and the Reactor Vessel Level Monitoring System).
This schedule was subsequently modified by Reference 12, being delayed by one fuel cycle.
The ICCI was not a confirmatory order item and is noted only for your information.
In view of the foregoing, we believe a good faith effort has been made to comply with the Reference 4 confirmatory order.
Therefore, OPPD requests that the confirmatory order of Reference 4 be modified to reflect extension of time for good cause shown as follows:
(A) April 30, 1986 for declaration of full operability of the SPDS [with the exception of (B) and (C)]; (B) 1987 refueling outage (scheduled to end June 1, 1987)
~
Mr. F. J. Mir glin LIC-86-001 Page 5
.for isolation devices discussed in References 10 and 11; and (C) 1987 refueling outage (scheduled to end June 1, 1987) for completion of SPDS CRDR items.
Your approval of these specific extension requests is hereby respectfully solicited.
Sinc re y, m<L/
R.
L. Andrews Division Manager Nuclear Production RLA/DJM/me cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, D.
C.
20036 E. G. Tourigny, NRC Project Manager P. H. Harrell, Senior NRC Resident Inspector J
gg
- I' s
[
r,
- :.h b
__