ML14328A814

Issuance of Amendment No. 278, Revise Technical Specification 2.5, Auxiliary Feedwater (AFW) System to Allow 7-Day Completion Time for Turbine-Driven AFW Pump Based on TSTF-340, Revision 3

ML14328A814
Person / Time
Site:	Fort Calhoun
Issue date:	12/22/2014
From:	Lyon C Plant Licensing Branch IV
To:	Cortopassi L Omaha Public Power District
Lyon C
References
TAC MF3788
Download: ML14328A814 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 22, 2014 Mr. Louis P. Cortopassi Site Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station 9610 Power Lane, Mail Stop FC-2-4 Blair, NE 68008

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 -ISSUANCE OF AMENDMENT RE:

CHANGE TO TECHNICAL SPECIFICATION 2.5 (TAC NO. MF3788)

Dear Mr. Cortopassi:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 278 to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station, Unit No. 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated March 31, 2014.

The amendment revised TS 2.5, "Steam and Feedwater Systems," to allow a 7-day completion time for the turbine-driven auxiliary feedwater pump if the inoperability occurs following a refueling outage and if Mode 2 has not been entered based on Technical Specification Task Force (TSTF) Change Traveler TSTF-340, Revision 3.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosures:

1. Amendment No. 278 to DPR-40

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OMAHA PUBLIC POWER DISTRICT DOCKET NO. 50-285 FORT CALHOUN STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 278 Renewed License No. DPR-40

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Omaha Public Power District (the licensee), dated March 31, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, Renewed Facility Operating License No. DPR-40 is amended by changes as indicated in the attachment to this license amendment, and paragraph 3. B. of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 278, are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-40 and Technical Specifications Date of Issuance: December 22, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 278 RENEWED FACILITY OPERATING LICENSE NO. DPR-40 DOCKET NO. 50-285 Replace the following pages of the Renewed Facility Operating License No. DPR-40 and the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

License Page REMOVE INSERT Technical Specifications REMOVE INSERT 2.5- Page 1 2.5- Page 1 2.5- Page 2 2.5- Page 2 2.5- Page 3

(4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or when associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is, subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A Maximum Power Level Omaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1, at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 278 are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

C. Security and Safeguards Contingency Plans The Omaha Public Power District shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.

OPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The OPPD CSP was approved by License Amendment No. 266.

Renewed Operating License No. DPR-40 Amendment No. 278

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems Applicability When steam generators are relied upon for reactor coolant system heat removal.

Objective To define certain conditions for the steam and feedwater system necessary to assure adequate decay heat removal.

Specifications (1) Two AFW trains shall be OPERABLE when Tcold is above 300°F.

A. With one steam supply to the turbine driven AFW pump inoperable, or

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Note--------------------------------------------------:

Only applicable if MODE 2 has not been entered following refueling the turbine driven AFW pump inoperable following refueling, restore the affected equipment to OPERABLE status within 7 days and within 8 days from discovery of failure to meet the LCO.

B. With one AFW train inoperable for reasons other than condition A, restore the AFW train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

C. If the required action and associated completion times of condition A or B are not met, then the unit shall be placed in MODE 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in MODE 3 in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and less than 300°F without reliance on the steam generators for decay heat removal within the next 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

D. With both AFW trains inoperable, then initiate actions to restore one AFW train to OPERABLE status immediately. Technical Specification (TS) 2.0.1 and all TS actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

(2) The motor driven train is required to be OPERABLE when Tcold is below 300°F and the steam generators are relied upon for heat removal. With the motor driven AFW train inoperable, then initiate actions to restore one AFW train to OPERABLE status immediately. Technical Specifications (TS) 2.0.1 and all TS actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

2.5- Page 1 Amendment No. 49, 127, 1eQ, ~ 278

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems (3) A minimum of 55,000 gallons of water in the emergency feedwater storage tank (EFWST) and a backup water supply to the emergency feedwater storage tank shall be available. With the EFWST inoperable, verify operability of the backup water supply within four hours and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and restore the EFWST to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If these action requirements cannot be satisfied, then the unit shall be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and less than 300°F without reliance on the steam generators for decay heat removal within the next 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

(4) The main steam stop valves are OPERABLE when Tcald is above 300°F and capable of closing in four seconds or less under no-flow conditions.

Basis A reactor shutdown from power requires a removal of core decay heat. Immediate decay heat removal requirements are normally satisfied by the steam bypass to the condenser.

Therefore, core decay heat can be continuously dissipated via the steam bypass to the condenser as long as feedwater to the steam generator is available. Normally, the capability to supply feedwater to the steam generators is provided by operation of the turbine cycle feedwater system. In the unlikely event of complete loss of electrical power to the station, decay heat removal is by steam discharge to the atmosphere via the main steam safety and atmospheric dump valves. Either auxiliary feed pump can supply sufficient feedwater for removal of decay heat from the plant. Technical Specification 2.1.1 establishes when the steam generators are required for heat removal. Each train includes the pump, piping, instruments, and controls to ensure the availability of an OPERABLE flow path capable of taking suction from the EFWST and delivering water to the steam generators.

If one of the two steam supplies to the turbine driven AFW pump is inoperable, or if the turbine driven pump is inoperable while the reactor coolant temperature Tcold is above 300°F immediately following refueling, action must be taken to restore the inoperable equipment to OPERABLE status within 7 days. The 7 day completion time is reasonable based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven AFW pump, the 7 day completion time is reasonable since there is a redundant steam supply line for the turbine driven pump.

b. For the inoperability of the turbine driven AFW pump while the reactor coolant temperature Tcald is above 300oF immediately subsequent to a refueling, the 7 day completion time is reasonable due to the minimal decay heat levels in this situation.

2.5- Page 2 Amendment No. ~.~ 278

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.5 Steam and Feedwater Systems Basis (Continued)

c. For both the inoperability of a steam supply line to the turbine driven pump and an inoperable turbine driven AFW pump while the reactor coolant temperature Tcord is above 300°F immediately subsequent to a refueling, the 7 day completion time is reasonable due to the availability of the redundant OPERABLE motor driven AFW pump, and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The eight day completion time for 2.5(1 )A provides a limit in the maximum time allowed for any combination to be inoperable during any continuous failure to meet the LCO.

With one of the required AFW trains inoperable, actions must be taken to restore OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With no AFW trains OPERABLE the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting cooldown with nonsafety grade equipment. In such a condition the unit should not be perturbed by any action, including a power change, that might result in a trip.

The minimum amount of water in the emergency feedwater storage tank is the amount needed for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of such operation. The tank can be resupplied with water from the raw water system.( 1l A closure time of 4 seconds for the main steam stop valves is considered adequate time and was selected as being consistent with expected response time for instrumentation as detailed in the steam line break analysis.(2)(3J References (1) USAR, Section 9.4.6 (2) USAR, Section 10.3 (3) USAR, Section 14.12 2.5- Page 3 Amendment No. 278

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 278 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285

1.0 INTRODUCTION

By application dated March 31, 2014 (Agencywide Documents Access and Management System Accession (ADAMS) No. ML14090A417), Omaha Public Power District (OPPD) requested changes to the Technical Specifications (TS, Appendix A to Renewed Facility Operating License No. DPR-40) for the Fort Calhoun Station, Unit No. 1 (FCS).

The proposed amendment would revise TS 2.5, "Steam and Feedwater Systems," based on U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Change Traveler TSTF-340, Revision 3, "Allow 7 Day Completion Time for a Turbine-driven AFW Pump Inoperable," March 2000. Specifically, the proposed changes would revise TS 2.5 to allow a 7-day completion time for the turbine-driven (TO) auxiliary feedwater (AFW) pump, if the pump becomes inoperable in reactor Mode 3 following a refueling outage and prior to entry into Mode 2.

2.0 REGULATORY EVALUATION

The NRC staff considered the following regulatory requirements in its review of the licensee's application.

The Commission's regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.36. Specifically, 10 CFR 50.36(c)(2)(ii)(B) requires that limiting conditions for operation (LCOs) be established for a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The NRC staff evaluated the proposed change to the current LCO for the TDAFW pump in accordance with the requirements of 10 CFR 50.36(c)(2)(ii)(B). The AFW system is an engineered safeguards system and is described in Sections 6.1.2.1 and 9.4 of the FCS Updated Safety Analysis Report.

Enclosure 2

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes Current TS 2.5 Applicability includes a note which states:

NOTE: When heating the reactor coolant above 300°F the steam driven auxiliary feedwater (AFW) pump is only required to be OPERABLE prior to making the reactor critical.

The licensee proposed to delete the above Applicability note.

Current TS 2.5 (1 )A states:

A. With one steam supply to the turbine driven AFW pump inoperable, restore the steam supply to OPERABLE status within 7 days and within 8 days from discovery of failure to meet the LCO.

Revised TS 2.5 (1 )A would state:

A. With one steam supply to the turbine driven AFW pump inoperable, or

---

Note---------------------------------------------

Only applicable if MODE 2 has not been entered following refueling the turbine driven AFW pump inoperable following refueling, restore the affected equipment to OPERABLE status within 7 days and within 8 days from discovery of failure to meet the LCO.

3.2 Background FCS has two safety-related AFW pumps, one motor-driven and one turbine-driven. The TSs require the AFW system to be operable when the reactor coolant temperature T cold is greater than 300 degrees Fahrenheit (°F). The AFW system is designed to supply feedwater to the steam generators whenever the main feedwater system is not in operation (e.g., during startup, cooldown, or emergency conditions resulting in a loss of main feedwater). One AFW pump provides sufficient flow to remove decay heat and cool the unit to shutdown cooling system entry conditions. The specification, however, requires both trains to be operable. The allowance for the TDAFW pump to be operable prior to making the reactor critical was approved by the NRC in Amendment No. 127 dafed April 9, 1990 (ADAMS Legacy Library No. 9004240140). As stated in the safety evaluation for the amendment:

The 300°F coolant temperature will not provide enough steam for a normal operability test for the steam driven [turbine-driven] AFW pump. Also, the present TSs do allow either the electrical or steam driven AFW pump to be operable when the reactor coolant temperature is above 300°F for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This was thought to be sufficient time for the plant to heat up to the point that a normal operability test for the steam driven AFW pump could be run.

However, for the steam driven AFW pump, a longer time is required due to the

steam generator soak period which affects the steam system's ability to heat up.

This issue was resolved and approved by the NRC staff at the Palisades Plant by requiring that the steam driven pump be operable prior to making the reactor critical. This allows sufficient heatup of the plant to be able to perform a normal operability test using non-nuclear heat. Therefore, the staff finds this change acceptable.

The current TS Note as written resolved the issue of having sufficient time for the plant to heat up in order to test the pump, but does not specifically restrict its applicability to following a refueling or provide an allowed time to be in this condition. Therefore, the licensee proposed to incorporate the guidance in TSTF-340, Revision 3 to clarify the TS requirements. OPPD has not converted the FCS TSs from the original custom TSs to NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants"; however, the NRC staff determined that the application of TSTF-340 to FCS TS 2.5 did not depend on the remainder of the FCS TSs aligning with NUREG-1432.

3.3 NRC Staff Evaluation The proposed change would change TS 2.5 to allow a 7-day completion time for the TDAFW pump if the inoperability occurs following a refueling outage and if Mode 2 had not been entered. In its application, the licensee proposed a change toTS 2.5 to conform to the changes made in TSTF-340, Revision 3. The.licensee stated that the change was needed to prevent unnecessary reactor mode changes and requests for enforcement discretion during startup following refueling. The proposed change achieves this by allowing additional time in Mode 3, prior to entering Mode 2, to repair and retest the TDAFW pump if the pump is declared inoperable because the surveillance requirements could not be met.

With the proposed change, if a condition exists in which the unit is in Mode 3 and repairs to the TDAFW system are required, and the 7-day completion time expires for Specification 2.5 (1)A, then the requirements of Specification 2.5 (1 )C would apply, and the licensee must cool down the unit to T cold less than 300 oF without reliance on the steam generators for decay heat removal within the next 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

The NRC staff concludes that the proposed change for conditions with T cold above 300 °F and before entering Mode 2 is acceptable because (1) the AFW design (one motor-driven AFW pumps and one TDAFW pump) affords adequate redundancy to allow the TDAFW pump to remain inoperable for the proposed completion time, and (2) the restriction of the completion time after a refueling outage without having entered Mode 2 assures the core decay heat load is at a minimal level. The low decay heat in the post refueling outage core is because of the low decay heat of the remaining fuel assemblies in the core, and the lack of decay heat from new fuel assemblies added to the core during the outage. The justification is the same as that approved by the NRC staff for TSTF-340, Revision 3, for incorporation into NUREG-1432. The proposed change continues to comply with 10 CFR 50.36 and is therefore acceptable.

The licensee also submitted TS Bases changes corresponding to the proposed TS changes.

The TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification as required by 10 CFR 50.36(a)(1 ). The proposed Bases changes are consistent with the Commission's Final Policy Statement on Technical

Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132).

Therefore, the NRC staff has no objection to the proposed changes to the TS Bases.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on July 8, 2014 (79 FR 38592). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: L. Wheeler, NRR/DSS/SBPB Date: December 22, 2014

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