ML14041A408

License Amendment Request (LAR) 14-01, One-Time Extension of Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3

ML14041A408
Person / Time
Site:	Fort Calhoun
Issue date:	02/10/2014
From:	Cortopassi L P Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LlC-14-0011
Download: ML14041A408 (13)

Text

jjjjjjjj --Omaha Public Power Oistrict 444 South 1e h Street Mall Omaha, NE 68102-2247 LlC-14-0011 February 10, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No.1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 10 CFR 50.90

SUBJECT:

License Amendment Request (LAR) 14-01 , One-Time Extension of Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3 Pursuant to 10 CFR 50.90, the Omaha Public Power District (OPPD) hereby requests an amendment to the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No.1. The proposed amendment would allow a one-time extension of the surveillance frequency for the pressurizer safety valves from a refueling frequency (Le., 18 months +25%) to a maximum of 28 months. The proposed change is necessary due to the extended shutdown of Fort Calhoun Station for the refueling outage that commenced in April 2011. Testing of the safety valves is performed by shipping the valves offsite to a vendor facility.

The last performance of the test was completed on January 14, 2013. Due to the extended shutdown, the valves will be required to be tested prior to the next scheduled refueling outage of April 13, 2015. These components are the only components that will not meet the required refueling frequency due to the extended outage and cannot be performed while the Unit is at power. OPPD has determined that this LAR does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The enclosure contains a description of the proposed changes, the supporting technical analyses, and the significant hazards consideration determination.

Attachment 1 of the enclosure provides the existing TS pages marked-up to show the proposed changes. Attachment 2 of the enclosure provides the retyped (clean) TS pages. OPPD requests approval of the proposed amendment by November 1, 2014. Once approved, the amendment shall be implemented upon issuance.

Employment with Equal Opportunity U. S. Nuclear Regulatory Commission LlC-14-0011 Page 2 There are no regulatory commitments associated with this proposed change. In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska official.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at (402) 533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 10, 2014. Louis P. Cortopassi Site Vice President and CNO LPC/brh

Enclosure:

OPPD's Evaluat i on of the Proposed Change c: M. L. Dapas, NRC Regional Administrator, Region IV J. W. Sebrosky, NRC Senior Project Manager J. C. Kirkland, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska LlC-14-0011 Enclosure Page 1 OPPD's Evaluation of the Proposed Change License Amendment Request (LAR) 14-01, One-Time Extension of Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3 1.0

SUMMARY

DESCRIPTION

2.0 DETAILED

DESCRIPTION

3.0 TECHNICAL

EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable

Regulatory Requirements/Criteria

4.3 Significant

Hazards Consideration

4.4 Conclusions

5.0 ENVIRONMENTAL-CONSIDERATION

6.0 REFERENCES

ATTACHMENTS: 1 . Technical Specification Page Markups 2. Retyped ("Clean")

Technical Specifications Pages LlC-14-0011 Enclosure Page 2 1.0

SUMMARY

DESCRIPTION License amendment request (LAR) 14-01 proposes a change to the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No.1. The Omaha Public Power District (OPPD) proposes to allow a one-time extension of the surveillance frequency for the pressurizer safety valves from a refueling frequency (L e., 18 months +25%) to a maximum of 28 months. 2.0 DETAILED DESCRIPTION The proposed TS changes for LAR 14-01 are as follows: SR 3.2. Table 3-5. Item 3 Add footnote "During PLANT OPERATING CYCLE 27 only , in lieu of the Technical Specification specified refueling frequency and 4.5 month grace period allowance, the maximum allowed surveillance test interval shall not exceed 28 months." P l ant Operating Cycle is a defined term in the FCS Unit No.1 Technical Specifications and is defined as, The time period from a REFUELING SHUTDOWN to the next REFUELING SHUTDOWN." 3.0 T EC H NICAL EVALUATION The Fort Calhoun Station , Unit No.1 (FCS) has two installed pressurizer safety valves. Technical Specification 3.2, Table 3-5, Item 3, requires that the pressurizer safety valves be tested to "Verify each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program. Following testing, lift settings shall be 2485 psig +/-1% and 2530 psig +/-1% respectively." The table specifies a frequency of "R", designating a "Refueling" interval.

The FCS Inservice Testing Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda. Appendix I of the ASME OM Code specifies frequency requirements for testing of pressure relief valves. Requirements applicable to the Fort Calhoun Station pressurizer safety valves appear in Section 1-1330, Test Frequencies, Class 1 Pressure Relief Valves. This section specifies that the test interval for any individual valve shall not exceed 5-years. In addition, it indicates that at least 20% of the valves from each valve group shall be tested within any 24-month interval.

Testing requirements may be satisfied by installing pre-tested valves if certain additional requirements are met regarding testing of the removed valves. Both FCS pressurizer safety valves were removed from service in April 2011 at the end of the last operating cycle (i.e., Operating Cycle 26). At that time , both valves were tested and found to open with i n the lift settings specified in TS 2.1.6(1} (Le., 2485 psig +1%/-3% and 2530 psig +1%/-3% respectively).

In January 2013, in anticipation of plant restart in 2013, the two pressurizer safety valves that had been removed and tested in April 2011 were re-tested.

The as-left lift settings for these two valves were demonstrated by testing at a vendor facility on January 14, 2013, and January 15, 2013 respectively.

The lift settings of both valves were within a tolerance of +/-1 % of setpoint, as discussed i n the TS 2.1.6 Basis. These pre-tested replacement valves were subsequently installed and are now inservice.

The proposed one-time frequency change would allow performance of the next valve tests during the next scheduled refueling outage that is scheduled to begin April 13, 2015. Techn i cal Specification 2.1.6(1}, requires two pressurizer safety valves to be operab l e in Modes 1 and 2. The valves were required to be operable beginning in December 2013, when the plant was first LlC-14-0011 Enclosure Page 3 returned to Mode 2 after the extended plant shutdown.

With the proposed one-time frequency change, the period during which the valves are required to be operable will be less than 18 months (i.e., from December 2013 to April 2015). Therefore, the period of required operability will be no longer than a typical operating cycle. Also, the time interval between tests with the proposed frequency change remains well within the maximum 5-year test interval for any individual valve as specified by the ASME Code and Inservice Testing Program. As the valves are sent offsite to a vendor facility, the setpoints were last set in January 2013 with the expectation of startup from the refueling outage in the spring of 2013; therefore, the need for this extension was not expected.

4.0 REGULATORY EVALUATION

4.1 Applicable

Requlatory Requirements/Criteria

4.1.1 Regulations

Code of Federal Regulations 10 CFR Part 50.55a Codes and Standards

4.1.2 Design

Basis As stated in USAR Section 4.3.10, two safety valves located on the pressurizer provide overpressure protection for the reactor coolant system. They are totally enclosed, backpressure-compensated, spring-loaded safety valves meeting ASME Code requirements.

4.1.3 Approved

Methodologies The approved testing methods as contained in the Inservice Testing Program are: ASME Code for Operation and Maintenance of Nuclear Power Plants, 1998 Edition (ASME OM Code -1998), through 2000 Addenda ASME SECTION XI, 1989 Edition, Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices and the ASME/ANSI O&M Manual, Part 1, 1987 Edition 4.1.4 Analysis No analyses were conducted in support of the proposed amendment.

4.2 Precedent

A number of plants have previously submitted LARs for extension of surveillance intervals due to extended refueling outages. Recently approved and/or submitted applications include the following:

LlC-14-0011 Enclosure Page 4 4.2.1 License Amendment Request (LAR 2008-08) Surveillance Frequency Extension Request, River Bend Station, Unit 1, dated December 8, 2008 (Reference 6.1). 4.2.2 River Bend Station, Unit 1 -Issuance of Amendment 162 Re: One-time Surveillance Interval Extension (TAC No. ME0215), dated April 1, 2009 (Reference 6.2). 4.2.3 License Amendment Request No. 225 Regarding One-Time Extension for Unit 3 Technical Specification Surveillance Requirement 4.5.1.1.d, Turkey Point Unit 3, dated March 8, 2013 (Reference 6.3). 4.3 Significant Hazards Consideration The proposed change would allow a one-time extension of the surveillance frequency for the pressurizer safety valves from refueling frequency (18 months +25%) to a maximum of 28 months. The Omaha Public Power District (OPPD) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No. The requested change is a one-time extension to the performance interval of one TS surveillance requirement.

The performance of the surveillance, or the failure to perform the surveillance, is not a precursor to an accident.

Performing the surveillance or failing to perform the surveillance does not affect the probability of an accident.

Even with the requested extension, the period during which the plant is in Modes 1 or 2 and the valves are required to be operable will be no longer than a typical operating cycle. Also, the proposed interval between tests will remain well within the maximum 5-year test interval for this type of valve specified by the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda, Appendix I, frequency requirements for testing of pressure relief valves. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No. The proposed change does not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Hence, the proposed change does not introduce any new accident initiators, nor does it reduce or adversely affect the capabilities of any plant structure or system in the performance of their safety function.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

LlC-14-0011 Enclosure Page 5 3. Does the proposed amendment involve a significant reduction in a margin of safety? Response:

No. The proposed change is a one-time extension of the periormance interval for one surveillance requirement.

Even with the proposed change in interval, the extended interval remains well within the maximum 5-year test interval for this type of valve specified by the ASME OM Code, 1998 Edition, through 2000 Addenda. Also, the period during which the plant is in Modes 1 or 2 and the valves are required to be operable will be no longer than a typical operating cycle. This change does not alter any safety margins. Therefore, the proposed change does not involve a significant reduction in a margin of safety. Based on the above, OPPD concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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. 5.0 ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a Significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 Letter

from Entergy (J. C. Roberts) to NRC (Document Control Desk) ,"License Amendment Request (LAR 2008-08) Surveillance Frequency Extension Request, River Bend Station -Unit 1," dated December 8, 2008 (ML083460043)

6.2 Letter

from NRC (C. F. Lyon) to Entergy (Vice President, Operations),"River Bend Station, Unit 1 -Issuance of Amendment Re: One-time Surveillance Interval Extension (TAC No. ME0215)," dated April 1 , 2009 (ML090270163)

6.3 Letter

from Florida Power & Light (M. Kiley) to NRC (Document Control Desk), "License Amendment Request No. 225 Regarding One-Time Extension for Unit 3 Technical Specification Surveillance Requirement 4.5.1.1.d," dated March 8, 2013 (ML 13071 A469)

LlC-14-0011 Enclosure, Attachment 1 Page 1 Technical Specification Page Markups [Word-processor mark-ups using "double underline/strJkool:Jt" feature for "new text/deleted text" respectively.]

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS 1. 2. 3. 4. Control Element Assemblies Control Element Assemblies Pressurizer Safety Valves Main Steam Safety Valves 5. DELETED 6. DELETED 7. DELETED Test Drop times of all full-length CEA's Partial movement of all CEA's (Minimum of 6 in) Verify each Bressurizer safety valve is OPERAS E in accordance with the Inservice Testing Program. Following liff settings shall be 2485 psig +/-1 Yo and 2530 psig +/-1% respectively.

Set Point 8a. Reactor Coolant Evaluate System Leakage***

8b. Primary to Secondary Continuous process Leakage **** radiation monitors or radiochemical grab sampling 9a Diesel Fuel Supply Fuel Inventory 9b. Diesel Lubricating Oil Lube Oil Inventory Inventory 9c. Diesel Fuel Oil Properties Test Properties 9d. Required Diesel Air Pressure Generator Air Start Receiver Sank Pressure Frequency Prior to reactor criticality after each removal of the reactor vessel closure head Q Rill R D* D* M M In accordance with the Diesel Fuel Oil Testing Program M USAR Section Reference 7.5.3 7 7 4 4 4 8.4 8.4 8.4 8.4 3.2 -Page 8 o 16,24,128.160.166.169.171.219.229.

Amendment N . 246, 2e7 TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS

• Whenever the system is at or above operating temperature and pressure.

• • • Not applicable to primary to secondary LEAKAGE. **** Verify primary to secondary LEAKAGE is:S; 150 gallons per day through anyone SG. This surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

(1) During PLANT OPERATING CYCLE 27. in lieu of the Technical Specification specified 18 month refueling frequency and 4.5 month grace period allowance.

the maximum allowed surveillance test interyal will be extended to no more than 28 months. 3.2 -Page 9 Amendment No. aa7 LlC-14-0011 Enclosure, Attachment 2 Page 1 Retyped ("Clean")

Technical Specification Pages TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS 1. 2. 3. 4. 5. 6. 7. 8a. 8b. 9a 9b. 9c. Control Element Assemblies Control Element Assemblies Pressurizer Safety Valves Main Steam Safety Valves DELETED DELETED DELETED Reactor Coolant System Leakage***

Test Drop times of all full-length CEA's Partial movement of all CEA's (Minimum of 6 in) Verify each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program. Following lift settings shall be 2485 psig +/-1 Yo and 2530 psig +/-1% respectively.

Set Point Evaluate Primary to Secondary Continuous process Leakage **** radiation monitors or radiochemical grab sampling Diesel Fuel Supply Fuel Inventory Diesel Lubricating Oil Lube Oil Inventory Inventory Diesel Fuel Oil Properties Test Properties 9d. Required Diesel Air Pressure Generator Air Start Receiver Bank Pressure Frequency Prior to reactor criticality after each removal of the reactor vessel closure head Q R(1) R D* D* M M In accordance with the Diesel Fuel Oil Testing Program M USAR Section Reference 7.5.3 7 7 4 4 4 8.4 8.4 8.4 8.4 3.2 -Page 8 o 16,24,128.160.166.169.171.219.

229. Amendment N .

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS

• Whenever the system is at or above operating temperature and pressure.

• • • Not applicable to primary to secondary LEAKAGE. **** Verify primary to secondary LEAKAGE is::; 150 gallons per day through anyone SG. This surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

(1) During PLANT OPERATING CYCLE 27, in lieu of the Technical Specification specified 18 month refueling frequency and 4.5 month grace period allowance, the maximum allowed surveillance test interval will be extended to no more than 28 months. 3.2 -Page 9 Amendment No. 246, 2&7