ML20217N394

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Responds to 960306 Relief Request from ASME Boiler & Pressure Vessel Code Section Iii,Overpressure Protection Requirements.Based on Review,Authorization Unnecessary & Inappropriate for Fort Calhoun Station,Unit 1
ML20217N394
Person / Time
Site: Fort Calhoun 
Issue date: 04/03/1998
From: Bateman W
NRC (Affiliation Not Assigned)
To: Gambhir S
OMAHA PUBLIC POWER DISTRICT
References
TAC-M95548, NUDOCS 9804090092
Download: ML20217N394 (4)


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April 3,1998 Mr. S. K. Gambhir Division Manager - Production Engineering Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

Post Office Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399

SUBJECT:

FORT CALHOUN STATION, UNIT NO.1, RELIEF FROM ASME BOILER AND PRESSURE VESSEL CODE SECTION lil, OVERPRESSURE PROTECTION REQUIREMENTS (TAC 95548)

Dear Mr. Gambhir:

By letter dated March 6,1996, Omaha Public Power District (OPPD) requested permanent relief from the requirements of Article 9, Paragraph N-910.8 of the 1968 Edition of the ASME Code, Section 111. The requirements pertain to the regenerative heat exchanger which was constructed as a Class C vessel per the 1968 Edition of the ASME Code, Section Ill. The relief 1

would allow OPPD to permsnently retain the installation of a manual locked open isolation valve and a remote-operated valve located in series with an overpressure protection relief device in j

the chemical and volume control system and use specific administrative controls to verify their positions at Fort Calhoun Station (FCS).

In its March 6,1996, letter, OPPD requested that the NRC staff authorize the installed valve configuration at FCS as an attemative to the above ASME Code design requirements pursuant to 10 CFR 50.55a(a)(3). OPPD stated that the manual isolation valve and relief valve configurations provide an acceptable level of quality and safety because administrative controls are in place to ensure that the stop valves remain in the open position. OPPD also stated that compliance with the above Code requirements would result in difficulties without a compensating increase in the level of quality and safety. OPPD further stated that mispositioning of these isolation valves would not impair the capability of plant shutdown or operation of the emergency core cooling system.

The NRC staff has reviewed OPPD's request for the NRC staff to authorize its proposed alternative pursuant to 10 CFR 50.55a(a)(3). The NRC staff finds that ASME Code, Section ill g

requirements for Quality Group C components (ASME Code Class 3 corr.ponents) such as the

'7 regenerative heat exchanger as stated in 10 CFR 50.55a(e), apply to nuclear power plants whose applications for construction permits (cps) were docketed afte May 14,1984. The CP 3g for FCS was docketed prior to May 14,1984. Therefore, the regulatiora in 10 CFR 50.55a(e) 1 conceming ASME Code, Section 111 design requirements for Class 3 components do not apply to FCS. Accordingly, authorization of an attemative to ASME Code, Section ill design requirements pursuant to 10 CFR 50.55a(a)(3) is unnecessarv and inappiupriate for FCS.

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In its Updated Safety Analysis Report, OPPD committed to design and construct FCS in accordance with ASME Code, Section lli design provisions, in its March 6,1996, letter, OPPD identified isolation valves installed in FCS that did not meet the design requirements of ASME Code for a Class 3 (or Class C) component. The NRC staff views the licensee's discovered condition of non-compliance with the ASME Code, Section ill design provisions as a deviation from plant licensing commitments. Accordingly, OPPD may either modify the plant to conform to the provisions of the current licensing and design basis information, or change the current licensing and design basis information to accurately reflect the existing plant design.

Action may be taken pursuant to the provisions of 10 CFR 50.59; and depending on the results of OPPD's evaluation, a license amendment may be required.

On the basis of the above evaluation, the NRC staff concludes that authorization of an alternative or relief from ASME Code, Section lil design provisions for ASME Code Class 3 components is unnecessary and inappropriate for FCS. OPPD may resolve the existing deviation by modifying the plant, or by revising the licensing and design information.

This completes our review for TAC No. M95548. Please contact L. Raynard Wharton at (301) 415-1396 if you have any questions regarding this issue.

Sincerely, ORIGINAL SIGNED BY:

William H. Bateman, Director Project Directorate IV-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation i

Docket No. 50-285 DISTRIBUTION:

Docket cc: See next page PD!V-2 Reading PUBLIC EAdensam WBateman RWharton MKotzalas EPeyton ACRS j

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WJohnson, Region IV PGwynn, Region IV

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NAME DATE 3 /l4/ 98 343/93 3/l( /98 3 /M/ 98 MJ6/98 I

OFFICIAL RECORD COPY

Mr. S.~ K. Gambhir In its Updated Safety Analysis Report, OPPD committed to design and construct FCS in accordance with ASME Code, Section Ill design provisions. In its March 6,1996, letter OPPD identified isolation valves installed in FCS that did not meet the design requirements of ASME Code for a Class 3 (or Class C) component. The NRC staff views the licensee's discovered condition of non-compliance with the ASME Code, Section lli design provisions as 'a deviation from plant licensing commitments. Accordingly, OPPD may either modify the plant to conform to the provisions of the current licensing and design basis information, or change the current licerising and design basis information to accurately reflect the existing plant design.

Action may be taken pursuant to the provisions of 10 CFR 50.59; and depending on the results of OFPD's evaluation, a license amendment may be required.

On the basis of the above evaluation, the NRC staff concludes that authorization of an attemative or relief from ASME Code, Section lll desigri provisions for ASME Code Class 3 components is unnecessary and inappropriate for FCS. OPPD may resolve the existing deviation by modifying the plant, or by revising the licensing and design information.

- This completes our review for TAC No, M95548. Please contact L. Raynard Wharton at (301) 415-1396 if you have any questions regarding this issue.

Sincerely, h

William H. Bateman, Director-Project Directorate IV-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket No. 50-285 cc: See next page

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Mr. S. K. Gambhir cc:

Winston & Strawn.

l ATTN: Pe:ry D. Robinson, Esq.-

1400 L Street, N.W.

Washington, DC 20005-3502 Mr. Jack Jensen, Chairman Washington County Board of Supervisors Blair, Nebraska 68008 Mr. Wayne Walker, Resident inspector U.S. Nuclear Regulatory Commission Post Office Box 309 Fort Calhoun, Nebraska 68023 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000

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Arlington, Texas 76011 j

l Ms. Cheryl Rodgers, LLRW Program Manager Environmental Protection Section l

Nebraska Department of Health

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l 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Mr. James W. Chase, Manager l

Fort Calhoun Station l

Post Office Box 399 Fort Calhoun, Nebraska 68023 i

Mr. James W. Tills Manager-Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2J Adm.

Post Office Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399

.