ML20207Q364

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Requests That Date for Completion of Mods to Comply W/Reg Guide 1.97,per 850719 Confirming Order,Be Changed for Listed Pressurizer Level Instrumentation Until End of 1988 Refueling Outage
ML20207Q364
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 01/12/1987
From: Andrews R
OMAHA PUBLIC POWER DISTRICT
To:
NRC OFFICE OF ADMINISTRATION (ADM)
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.075, RTR-REGGD-01.097, RTR-REGGD-1.075, RTR-REGGD-1.097 GL-82-33, LIC-86-700, TAC-64447, NUDOCS 8701270220
Download: ML20207Q364 (2)


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I Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 January 12, 1987 LIC-86-700 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

References:

1.

Docket No. 50-285 2.

NUREG 0737, Supplement 1 (Generic Letter 82-33) dated December 17, 1982 3.

Letter OPPD (W. C. Jones) to NRC (R. A. Clark) dated April 15, 1983 (LIC-83-093) 4.

Letter NRC (E. J. Butcher) to OPPD (R. L. Andrews) dated July 19, 1985 5.

Letter OPPD (R. L. Andrews) to NRC (D. E. Sells) dated October 21, 1986 (LIC-86-532)

SUBJECT:

Compliance with Regulatory Guide 1.97, Revision 2, Gentlemen:

OPPD's letter dated April 15, 1983, Reference 3, provided our response outlining actions to be taken to bring Fort Calhoun Station into compliance with the provision of Reg. Guide 1.97.

Your confirming order, Reference 4, required that modifications to comply with Reg. Guide 1.97, be completed during the 1987 Refueling Outage.

The purpose of this letter is to request that the dates of your confirming order be changed for the items discussed below.

In Reference 3, OPPD indicated that the pressurizer level instrumentation was a type A variable - primary information required to permit operator manual action to accomplish a safety function - for Fort Calhoun Station.

I OPPD has performed a review of our responses to Reg. Guide 1.97 and the status of related modifications. The review of instrument loops L-10lX and L-10lY indicates that the installed pressurizer level instrumentation presently meets 10 CFR 50.49 criteria inside of containment.

However, outside of containment, the installation is a control grade and does not meet the seismic or separation criteria given in Reg. Guide 1.97.

OPPD has determined that it will be necessary to modify the pressurizer level instrumentation loops to provide full compliance with the Category 1 Criteria.

It will not be possible to design and install the modification of the pressurizer level instrumentation loops during the 1987 refueling outage d$$85 PDR h0 d

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Document Control Desk LIC-86-700 Page 2 without impacting other important modifications which are planned. Therefore, OPPD requests that an extension be granted until the end of the 1988 refueling outage for design and installation of the modification of the pressurizer level instrumentation loops.

Please revise the confirming order to reflect the 1988 refueling outage date.

Additionally, as a result of our status review of the information submitted with the referenced letter, it was noted that the Redundancy Section 2.3.3.A2 of the Design and Qualification Criteria requires clarification. The submittal position states that two channels of redundant indication are adequate and that the instrument loops are in compliance with Reg. Guide 1.75 Physical Indepen-dence of Electric Systems.

Reg. Guide 1.75 endorses IEEE 279-1971. However, the Fort Calhoun Station USAR states that the redundant instrument systems were designed to IEEE 279-1968. OPPD will provide a revision to our submittal Reg.

Guide 1.97, to incorporate the positions given above. Also, please note that in Reference 5, page 33, paragraph 6.2.6, Containment Sump Temperature, the Category 2 temperature loop was scheduled to be added during the 1988 refuel-ing.

Please revise the confirming order accordingly.

If you have questions or require additional information please contact me.

XL R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.

Washington, DC 20036 A. C. Thadani, NRC Project Director W. A. Paulson, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector

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