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| By letter dated August 16, 2010, as supplemented by letter dated September 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102290067 and ML102720964), Omaha Public Power District (OPPD, the licensee) proposed changes to the Technical Specifications (TS) for Fort Calhoun Station Unit 1 (FCS). The proposed changes would relocate operating and surveillance requirements (SR) for the power operated relief valve (PORV) position, safety valve position (PSV) and tailpipe temperature instrumentation from FCS TS to FCS Updated Safety Analysis Report (USAR). Specifically the proposed changes would revise: | | By letter dated August 16, 2010, as supplemented by letter dated September 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102290067 and ML102720964), Omaha Public Power District (OPPD, the licensee) proposed changes to the Technical Specifications (TS) for Fort Calhoun Station Unit 1 (FCS). The proposed changes would relocate operating and surveillance requirements (SR) for the power operated relief valve (PORV) position, safety valve position (PSV) and tailpipe temperature instrumentation from FCS TS to FCS Updated Safety Analysis Report (USAR). Specifically the proposed changes would revise: |
| * TS Table 2-5, "Instrumentation Operating Requirements for Other Safety Feature Functions" | | * TS Table 2-5, "Instrumentation Operating Requirements for Other Safety Feature Functions" |
| * TS Table 3-3, "Minimum Frequencies for Checks, Calibrations and Testing of Miscellaneous Instrumentation and Controls" The NRC staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its review of the relief request. | | * TS Table 3-3, "Minimum Frequencies for Checks, Calibrations and Testing of Miscellaneous Instrumentation and Controls" The NRC staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its review of the relief request. |
| : 1. By letter dater August 16, 2010, the licensee states, "The loss of this instrumentation has no effect on the probabilistic risk assessment [PRA] and has not been shown to be significant to public health and safety (Criterion 4)." | | : 1. By letter dater August 16, 2010, the licensee states, "The loss of this instrumentation has no effect on the probabilistic risk assessment [PRA] and has not been shown to be significant to public health and safety (Criterion 4)." |
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| Please provide details on how this statement was concluded. Specifically, discuss any operating experience involving the failure of this equipment at the plant (or similar experience within the industry) and how this experience is determined to be insignificant. Also, describe the impact of the failure of this equipment on the base PRA results, including the risk achievement worth (RAW) and risk reduction worth (RRW) [or Fussell-Vesely (FV) importance] for this equipment (or surrogate PRA component if this equipment is not modeled directly in the PRA), and how these impacts are determined to be insignificant. | | Please provide details on how this statement was concluded. Specifically, discuss any operating experience involving the failure of this equipment at the plant (or similar experience within the industry) and how this experience is determined to be insignificant. Also, describe the impact of the failure of this equipment on the base PRA results, including the risk achievement worth (RAW) and risk reduction worth (RRW) [or Fussell-Vesely (FV) importance] for this equipment (or surrogate PRA component if this equipment is not modeled directly in the PRA), and how these impacts are determined to be insignificant. |
| : 2. In letter dated July 12, 2010, (ADAMS Accession Numbers ML101930443), OPPD submitted a license amendment request (LAR) to add Note e to TS LCO 2.15, Table 2-5, Item 1. The July 12, 2010 LAR is under separate review by the NRC staff. In letter dated August 16, 2010, OPPD submitted a LAR which requests deletion of TS 2.15, Table 2-5 Notes a through d. The August 16, 2010 LAR also requests re-lettering TS 2.15, Table 2-5 Note e to Note a upon subsequent NRC approval of both LARs. Since the re-lettering of TS 2.15, Table 2-5 Note e to Note a was not reflected on TS 2.15, Table 2-5 in Enclosure Attachment 1, "Technical Specifications Pages Markup," the NRC staff is concerned that the reference to Note e in TS 2.15, Table 2-5 item 1 will not be re-lettered when TS 2.15, Table 2-5 Note e is re-lettered to Note a. | | : 2. In letter dated July 12, 2010, (ADAMS Accession Numbers ML101930443), OPPD submitted a license amendment request (LAR) to add Note e to TS LCO 2.15, Table 2-5, Item 1. The July 12, 2010 LAR is under separate review by the NRC staff. In letter dated August 16, 2010, OPPD submitted a LAR which requests deletion of TS 2.15, Table 2-5 Notes a through d. The August 16, 2010 LAR also requests re-lettering TS 2.15, Table 2-5 Note e to Note a upon subsequent NRC approval of both LARs. Since the re-lettering of TS 2.15, Table 2-5 Note e to Note a was not reflected on TS 2.15, Table 2-5 in Enclosure Attachment 1, "Technical Specifications Pages Markup," the NRC staff is concerned that the reference to Note e in TS 2.15, Table 2-5 item 1 will not be re-lettered when TS 2.15, Table 2-5 Note e is re-lettered to Note a. |
| Please provide an integrated TS markup that will show all the changes proposed by the July 12, 2010 and August 16, 2010 LARs and include the clean TS pages. | | Please provide an integrated TS markup that will show all the changes proposed by the July 12, 2010 and August 16, 2010 LARs and include the clean TS pages. |
| : 3. In letters dated May 31, 2010 and June 1, 2010, (ADAMS Accession Numbers ML101520198 and ML101530319) OPPD requested an emergency amendment to modify TS 2.15, Table 2-5 Note c to allow a onetime extension of the 7-day allowed outage time for the inoperability of Function 4 regarding safety valve acoustic position indication for RC-142 to allow repair prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown). The onetime extension was applied through footnote 'i' associated with Note c. This change allowed FCS to continue power operations with inoperable safety valve acoustic position indication on safety valve RC-142. The NRC staff approved the license amendment request on July 12, 2010 in TS amendment number 265 (ADAMS Accession Numbers ML101520296). In your LAR dated August 16, 2010 you propose to delete footnote 'i' associated with Note c. However, it is unclear if FCS has used the onetime extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142 and if RC-142 was repaired prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown). | | : 3. In letters dated May 31, 2010 and June 1, 2010, (ADAMS Accession Numbers ML101520198 and ML101530319) OPPD requested an emergency amendment to modify TS 2.15, Table 2-5 Note c to allow a onetime extension of the 7-day allowed outage time for the inoperability of Function 4 regarding safety valve acoustic position indication for RC-142 to allow repair prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown). The onetime extension was applied through footnote 'i' associated with Note c. This change allowed FCS to continue power operations with inoperable safety valve acoustic position indication on safety valve RC-142. The NRC staff approved the license amendment request on July 12, 2010 in TS amendment number 265 (ADAMS Accession Numbers ML101520296). In your LAR dated August 16, 2010 you propose to delete footnote 'i' associated with Note c. However, it is unclear if FCS has used the onetime extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142 and if RC-142 was repaired prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown). |
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| Since July 12, 2010, has FCS either used the onetime extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142, or determined that it was no longer needed.}} | | Since July 12, 2010, has FCS either used the onetime extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142, or determined that it was no longer needed.}} |
Letter Sequence Draft RAI |
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MONTHYEARML1015201982010-05-31031 May 2010
Emergency License Amendment Request (Lar), Revision to Technical Specification (TS) 2.15, Table 2-5 Footnote (C) for Safety Valve Acoustic Position Indication
Project stage: Request
LIC-10-0043, Supplement to Emergency License Amendment Request Revision to Technical Specification 2.15, Table 2-5 Note (C) for Safety Valve Acoustic Position Indication2010-06-0101 June 2010
Supplement to Emergency License Amendment Request Revision to Technical Specification 2.15, Table 2-5 Note (C) for Safety Valve Acoustic Position Indication
Project stage: Supplement
LIC-10-0034, License Amendment Request (LAR) Revision to Technical Specification (TS) 2.15, Table 2-5, Item 1 and TS 3.1, Table 3-3, Items 1, 2 and 4 Control Element Assembly Position Indication and Correction of TS 2.10.2(7)c.2010-07-12012 July 2010
License Amendment Request (LAR) Revision to Technical Specification (TS) 2.15, Table 2-5, Item 1 and TS 3.1, Table 3-3, Items 1, 2 and 4 Control Element Assembly Position Indication and Correction of TS 2.10.2(7)c.
Project stage: Request
LIC-10-0053, License Amendment Request (LAR) 10-04, Proposed Changes to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve and Safety Valve Position and Tail Pipe Temperature Instrumentation2010-08-16016 August 2010
License Amendment Request (LAR) 10-04, Proposed Changes to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve and Safety Valve Position and Tail Pipe Temperature Instrumentation
Project stage: Request
ML1025801292010-09-17017 September 2010
Supplemental Information Needed for Acceptance of Requested Licensing Action, Amendment to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Acceptance Review
LIC-10-0085, Supplement to License Amendment Request (LAR) 10-04, Proposed Changes to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve and Safety Valve Position and Tail Pipe Temperature Instrumentation2010-09-27027 September 2010
Supplement to License Amendment Request (LAR) 10-04, Proposed Changes to Relocate Operating and Surveillance Requirements for the Power Operated Relief Valve and Safety Valve Position and Tail Pipe Temperature Instrumentation
Project stage: Supplement
ML1034001892010-12-14014 December 2010
Acceptance Following Review of Supplemental Information, License Amendment Request to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Approval
ML1104801342011-02-17017 February 2011
Email, Draft Request for Additional Information, Amendment Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Draft RAI
ML1104801392011-02-17017 February 2011
Draft Request for Additional Information, Amendment Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Draft RAI
ML1106301792011-03-0707 March 2011
Request for Additional Information, Amendment Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: RAI
ML1106703782011-03-0808 March 2011
E-mail to Correct Due Date for Response to Request for Additional Information, Amendment to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: RAI
LIC-11-0030, Response to Request for Additional Information License Amendment Request to Relocate Operating & Surveillance Requirements for Power Operated Relief Valve, Safety Valve Position, & Tail Pipe Temperature Instrumentation from Technical Spe2011-04-0606 April 2011
Response to Request for Additional Information License Amendment Request to Relocate Operating & Surveillance Requirements for Power Operated Relief Valve, Safety Valve Position, & Tail Pipe Temperature Instrumentation from Technical Specif
Project stage: Response to RAI
ML1113005282011-05-10010 May 2011
Email, Draft Request for Additional Information, Round 2, Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Draft RAI
ML1113005392011-05-10010 May 2011
Draft Request for Additional Information, Round 2, Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Draft RAI
ML1114307242011-05-26026 May 2011
Request for Additional Information, Round 2, Amendment Request to Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: RAI
LIC-11-0067, Response to Second NRC Request for Additional Information License Amendment Request to Relocate Operating & Surveillance Requirements for Power-Operated Relief Valve, Safety Valve Position, & Tail Pipe Temperature Instrumentation from Te2011-06-30030 June 2011
Response to Second NRC Request for Additional Information License Amendment Request to Relocate Operating & Surveillance Requirements for Power-Operated Relief Valve, Safety Valve Position, & Tail Pipe Temperature Instrumentation from Techn
Project stage: Request
ML1126204022011-09-30030 September 2011
Issuance of Amendment No. 268, Revise Updated Safety Analysis Report to Relocate Acoustic Position and Tail Pipe Temperature Indication Surveillance Requirements from Technical Specifications
Project stage: Approval
2011-02-17
[Table View] |
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Category:Request for Additional Information (RAI)
MONTHYEARML24243A1042024-09-12012 September 2024
Proposed Revision to the OPPD FCS DQAP - Request for Additional Information (License No. DPR-40, Docket Nos. 50-285, 72-054, and 71-0256)
ML24180A2062024-07-0808 July 2024
Phase 1 Final Status Survey Reports Request for Additional Information
ML23151A0042023-06-0606 June 2023
Second Set RAIs Rev 4
ML22357A0672022-12-30030 December 2022
Enclosure RAI Re Approval of License Termination Plan
ML22119A2472022-05-0303 May 2022
Review of Amendment Request to Add a LC to Include LTP Requirements, RAI for Environmental Review
ML20111A2162020-05-20020 May 2020
Revised PSDAR Request for Additional Information - RAI
ML19241A1812019-08-21021 August 2019
Request for Additional Information on Proposed Changes to the FCS Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-only Status
ML18067A1432018-03-0808 March 2018
Enclosurequest for Additional Information (Letter to M. J. Fisher Request for Additional Information Regarding Omaha Public Power District'S Decommissioning Funding Plan Update for Fort Calhoun Station ISFSI)
ML17236A3462017-08-24024 August 2017
NRR E-mail Capture - Final RAI for Fort Calhoun LAR Regarding Permanently Defueled TS (MF9567)
ML17236A3442017-08-24024 August 2017
NRR E-mail Capture - Final RAI for Fort Calhoun Exemption from 10 CFR 140.11(a)(4), Off-site Primary and Secondary Liability Insurance (MF9664)
ML17234A4692017-08-22022 August 2017
NRR E-mail Capture - Final RAI for Fort Calhoun LAR Regarding Removal of Dry Cask Loading Limits (MF9831)
ML17194A9732017-07-13013 July 2017
NRR E-mail Capture - Final RAI for Fort Calhoun Ultimate Strength Design for Aux. Bldg LAR (MF8525)
ML17112A0362017-04-20020 April 2017
NRR E-mail Capture - Fort Calhoun Station - Final RAI Regarding Permanently Defueled EP and EAL Scheme Change LAR
ML17090A3942017-03-31031 March 2017
NRR E-mail Capture - Fort Calhoun - Final RAI Regarding Administrative Control TS Change LAR (MF8437)
ML17082A0022017-03-22022 March 2017
NRR E-mail Capture - Fort Calhoun Station - Final Nsir/Dpr RAI Regarding Proposed Emergency Planning Exemption
ML17081A0192017-03-21021 March 2017
NRR E-mail Capture - Fort Calhoun Station - Final RAI Regarding Proposed Emergency Planning Exemption
ML17067A3862017-03-15015 March 2017
Request for Additional Information, Request for Approval of Certified Fuel Handler Training and Retraining Program to Facilitate Activities Associated with Decommissioning and Irradiated Fuel Handling Management
ML17033A9692017-02-0202 February 2017
NRR E-mail Capture - Fort Calhoun Station - Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment
ML16263A0492016-09-20020 September 2016
Request for Additional Information, Request for Approval of Certified Fuel Handler Training and Retraining Program to Facilitate Activities Associated with Decommissioning and Irradiated Fuel Handling Management
ML16174A1502016-06-27027 June 2016
Request for Additional Information, Relief Request, Use of Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1
ML16146A1782016-05-27027 May 2016
Request for Additional Information, Round 2, Request to Revise Current Licensing Basis as Described in the Final Safety Analysis Report to Allow Equipment Classification Methodology from ANSI/ANS-58.14-2011
ML16106A0232016-04-29029 April 2016
Request for Additional Information, Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
ML16104A2872016-04-25025 April 2016
Request for Additional Information, License Amendment Request to Revise Current Licensing Basis to Use American Concrete Institute (Aci) Ultimate Strength Requirements
ML16048A1542016-02-23023 February 2016
Request for Additional Information, License Amendment Request, Revise Current Licensing Basis as Described in the Final Safety Analysis Report to Allow Equipment Classification Methodology from ANSI/ANS-58.14-2011
ML16048A0242016-02-23023 February 2016
Request for Additional Information, License Amendment Request to Adopt Technical Specification Task Force (TSTF)-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control
ML15343A1082015-12-15015 December 2015
Request for Additional Information, License Amendment Request to Make Administrative Changes to the Technical Specifications to Update Titles, Delete Obsolete Actions in Appendix B, and Relocate a Definition
ML15323A0362015-11-24024 November 2015
Request for Additional Information, Relief Requests P-1 - LPSI and CS Pumps and P-2 - Adjusting Hydraulic Parameters Consistent W/Code Case OMN-21, Fifth 10-Year Inservice Testing Interval
ML15194A2722015-07-14014 July 2015
Request for Additional Information, Adopt Emergency Action Level Scheme Pursuant to Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors
ML15057A0152015-03-0303 March 2015
Request for Additional Information, Materials Reliability Program (MRP)-227-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, Implementation Review
ML15043A0612015-02-25025 February 2015
Request for Additional Information, Round 2, License Amendment Request to Revise Updated Safety Analysis Report to Allow Pipe Stress Analysis to Be Performed in Accordance with ASME Code Section III
ML14353A0512014-12-22022 December 2014
Request for Additional Information, Request to Revise Updated Safety Analysis Report, Design and Evaluation of Seismic Class I Structures Using Ascm (Alternate Seismic Criteria and Methodologies) Developed Floor Response Spectra
ML14259A3652014-09-24024 September 2014
Request for Additional Information, License Amendment Request to Revise Updated Safety Analysis Report to Allow Pipe Stress Analysis to Be Performed in Accordance with ASME Code Section III
ML14195A0862014-07-16016 July 2014
Request for Additional Information Associated with Near-Term Task Force Recommendation 2.1, Seismic Hazard and Screening Report
ML13317A5832013-11-25025 November 2013
Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML13304B4182013-11-0101 November 2013
Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns
ML13290A0022013-10-0909 October 2013
Request for Additional Information Email, License Amendment Request to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Line Breaks
ML13282A5362013-10-0909 October 2013
Request for Additional Information Email, Round 2, Exemption Request, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage, in Lieu of 10 CFR 26.205(d)(7)
ML13270A2872013-09-27027 September 2013
Email, Request for Additional Information Round 4 (Apla), Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (2001 Edition)
ML13261A2122013-09-18018 September 2013
Request for Additional Information Email, Exemption Request, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage, in Lieu of 10 CFR 26.205(d)(7)
ML13233A2482013-08-26026 August 2013
Supplemental Information Needed for Acceptance of Requested Licensing Action; Request for Exemption, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage in Lieu of 10 CFR 26.205(d)(7)
ML13235A1682013-08-23023 August 2013
Draft Request for Additional Information Email, Overall Integrated Plan in Response to 3/12/2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)
ML13234A4352013-08-22022 August 2013
Request for Additional Information Email, Round 2, Request to Revise TS 2.0.1, General Requirements, and TS 2.7, Electrical Systems, for Inoperable System, Subsystem. or Component Due to Inoperable Power Source
ML13226A1222013-08-14014 August 2013
Email, Request for Additional Information Round 3 (Apla), Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Generating Plants (2001 Edition)
ML13212A0092013-07-30030 July 2013
Request for Additional Information Email, Request to Revise Technical Specification (TS) 2.0.1, General Requirements, and TS 2.7, Electrical Systems, for Inoperable System, Subsystem, or Component Due to Inoperable Power Source
ML13205A1252013-07-24024 July 2013
Request for Additional Information Email Round 2, Exigent Amendment Request to Revise Current Licensing Basis to Adopt Revised Design Basis/Methodology for Addressing Design-Basis Tornado/Tornado Missile Impact
ML13205A0182013-07-23023 July 2013
Request for Additional Information Email, Exigent License Amendment Request to Revise Current Licensing Basis to Adopt Revised Design Basis/Methodology for Addressing Design-Basis Tornado/Tornado Missile Impact
ML13144A4822013-05-23023 May 2013
Request for Additional Information Email, Decommissioning Funding Status Report
ML13100A1752013-04-10010 April 2013
Request for Additional Information Email, Request for One-Time Exemption from Requirements of 10 CFR 26.205(d)(7) to Allow Less Restrictive Working Hour Limitations to Support Activities for Plant Startup
ML13086A4732013-03-27027 March 2013
Request for Additional Information Email, Request to Revise Technical Specification 2.16, River Level, and Establish EAL Classification Criteria for External Flooding Events Under Radiological Emergency Response Plan
ML13120A0842013-03-22022 March 2013
Request for Additional Information Email Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 20 (TAC No. D91660)
2024-09-12
[Table view] |
Text
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION
By letter dated August 16, 2010, as supplemented by letter dated September 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102290067 and ML102720964), Omaha Public Power District (OPPD, the licensee) proposed changes to the Technical Specifications (TS) for Fort Calhoun Station Unit 1 (FCS). The proposed changes would relocate operating and surveillance requirements (SR) for the power operated relief valve (PORV) position, safety valve position (PSV) and tailpipe temperature instrumentation from FCS TS to FCS Updated Safety Analysis Report (USAR). Specifically the proposed changes would revise:
- TS Table 2-5, "Instrumentation Operating Requirements for Other Safety Feature Functions"
- TS Table 3-3, "Minimum Frequencies for Checks, Calibrations and Testing of Miscellaneous Instrumentation and Controls" The NRC staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its review of the relief request.
- 1. By letter dater August 16, 2010, the licensee states, "The loss of this instrumentation has no effect on the probabilistic risk assessment [PRA] and has not been shown to be significant to public health and safety (Criterion 4)."
Please provide details on how this statement was concluded. Specifically, discuss any operating experience involving the failure of this equipment at the plant (or similar experience within the industry) and how this experience is determined to be insignificant. Also, describe the impact of the failure of this equipment on the base PRA results, including the risk achievement worth (RAW) and risk reduction worth (RRW) [or Fussell-Vesely (FV) importance] for this equipment (or surrogate PRA component if this equipment is not modeled directly in the PRA), and how these impacts are determined to be insignificant.
- 2. In letter dated July 12, 2010, (ADAMS Accession Numbers ML101930443), OPPD submitted a license amendment request (LAR) to add Note e to TS LCO 2.15, Table 2-5, Item 1. The July 12, 2010 LAR is under separate review by the NRC staff. In letter dated August 16, 2010, OPPD submitted a LAR which requests deletion of TS 2.15, Table 2-5 Notes a through d. The August 16, 2010 LAR also requests re-lettering TS 2.15, Table 2-5 Note e to Note a upon subsequent NRC approval of both LARs. Since the re-lettering of TS 2.15, Table 2-5 Note e to Note a was not reflected on TS 2.15, Table 2-5 in Enclosure Attachment 1, "Technical Specifications Pages Markup," the NRC staff is concerned that the reference to Note e in TS 2.15, Table 2-5 item 1 will not be re-lettered when TS 2.15, Table 2-5 Note e is re-lettered to Note a.
Please provide an integrated TS markup that will show all the changes proposed by the July 12, 2010 and August 16, 2010 LARs and include the clean TS pages.
- 3. In letters dated May 31, 2010 and June 1, 2010, (ADAMS Accession Numbers ML101520198 and ML101530319) OPPD requested an emergency amendment to modify TS 2.15, Table 2-5 Note c to allow a onetime extension of the 7-day allowed outage time for the inoperability of Function 4 regarding safety valve acoustic position indication for RC-142 to allow repair prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown). The onetime extension was applied through footnote 'i' associated with Note c. This change allowed FCS to continue power operations with inoperable safety valve acoustic position indication on safety valve RC-142. The NRC staff approved the license amendment request on July 12, 2010 in TS amendment number 265 (ADAMS Accession Numbers ML101520296). In your LAR dated August 16, 2010 you propose to delete footnote 'i' associated with Note c. However, it is unclear if FCS has used the onetime extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142 and if RC-142 was repaired prior to the next entry into Operating Mode 3 (Hot Shutdown) from Operating Mode 4 (Cold Shutdown).
Since July 12, 2010, has FCS either used the onetime extension of the 7-day allowed outage time for the inoperability of safety valve acoustic position indication for RC-142, or determined that it was no longer needed.
