ML19327A455

Proposed Change to Tech Spec 2.0 Re Limiting Conditions for Operation & Term Operable.

ML19327A455
Person / Time
Site:	Fort Calhoun
Issue date:	08/01/1980
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML19327A449	List: ML19327A448 ML19327A452 ML19327A455
References
NUDOCS 8008060213
Download: ML19327A455 (6)

Text

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f ;W ' DEFINITIONS MISCELLANEOUS DEFINITIONS Operable - Operability A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it'.is capable'of. performing its specified function (s).

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Implicit in this definition shall be the assumption that all necessary attendant;instrunentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are' required for the system, subsystem, train, component or device

-to perform its function (s) are also capable of performing their related support. function (s).

j In Operation i

2 A system or component is in operation if it is performing its design function.

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CEA's

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All full length shutdown and regulating control rods.

. Part Length CEA's CEA's which contain neutron absorbing material only in the lower quarter of their length.

Containment Integrity Containment integrity is . defined to exist when all of the following are met:

'(1) -All' nonautomatic < containment isolation valves which are not required to f

be open during accident conditions and blind flenges:are' closed.

(2) The equipment hatch is properly closed and sealed.

(3) At least;one door in the personnel air lock is properly closed and sealed.

'(h) All. automatic containment isolation valves are operable or locked closed

~(or. isolated by locked closed valves or blind flanges.as permitted by

. limiting condition.for operation).

l(5)[ The uncontrolled containment leakage satisfies Specification 3.5

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2.0' LIMITING CONDITIONS FOR OPERATION 2.0.1- General' Requirements Applicability-Applies to the operable status of all systems, subsystems, trains,

-components, or devices covered by the Limiting Conditions for Oper-

'ation.

Objective ,

To specify corrective measures to be employed for sys;em conditions not covered by or in excess of the Limiting Conditions fcr Operation.

Specification (1) In the event a Limiting Condition for Operation and/or associated action requirements cannot be satisfied because of ci,rcumstances in excess of those addressed in the specification, the unit shall be placed in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in at least suberitical and < 3000F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least

-COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, unless corrective measures are completed that permit operation under the permissible action requirements for the specified time interval as measured from initial discovery or until the reactor is placed in an

-Operating Mode in which the specification is not applicable. Ex-

! ceptions.to these requirements shall be stated in the individual specifications.-

(2) When a system, subsystem, train, component, or device is deter-mined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its re-

, dundant system (s), subsystem (s), train (s), component (s), and device (s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied, the unit shall he placed in at least HOT SHUT-DOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in at least suberitical and < 3000F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. .This specification is not appli able in Operating Modes k or-5 Basis-(1) This specification delineates corrective measures to be taken for circumstances not directly provided for in the system

' specific specifications and whose occurrence would violate the intent of the specification. For example, Specification

2.3 requires each Low Pressure Safety Injection (LPSI) pump to be operable and provides explicit corrective measures to 2-0

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2. 0 . LIMITING CONDITIONS FOR OPERATION 2.0.1: General Requirements A

be followed if.one pump is inoperable. Under the-terms of Specification-2.0.1(1), if more than one LPSI pump is.in-

' operable, the unit must be placed in.at.least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in at least suberitical and < 3000 F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, unless at least one LPSI pump were restored to operability. It is assumed that the unit is i brought to the required mode within the required times by promptly initiating and carrying out the appropriate measures required by the specification.

'(2) This specification _ delineates what additional conditions must be satisfied to permit operation to continue, consistent with the system specific specifications for power sources, when a' normal or emergency power source is not OPERABLE.

It specifically prohibits operation when one division is a inoperable because its normal or emergency power source is inoperable and a system, subsystem, train, component, or device in another division is inoperable for another reason.

The provisions of this specification permit the requirements cssociated with individual systems, zubsystems, trains, com-ponents, or devices to be consistent with the specification of the associated electrical power source. It allows oper-i ation to be~ governed by the time limits of the requirements associated with the Limiting Condition for Operation for -

the normal or emergency power source, not the individual requirements for each system, subsystem, train, component, or device that is' determined to be inoperable solely be-cause of the inoperability of .its normal or emergency power source.

For example, Specification 2.7 requires in part that two emergency diesel generators be OPERABLE. The specifica-tion provides.for T days per month out-of-service time when one emergency diesel generator is not OPERABLE. If the definition of OPERABLE vere applied without consider-ation 'of Specification 2.0.1(2), all systems, subsystems, trains, components, and devices supplied by the inoperable

, - emergency power source would also be inoperable. This vould dictate invoking the applicable corrective measures for each of the applicable Limiting Conditions for Oper-ation.-lHowever, the' provisions of Specification 2.0.1(2) permit.the. time limits for continued operation to be con-sistent with the requirements for the inoperable emergency 1 diesel generator instead, provided the other specified

. conditions are satisfied. In this case, this would mean that-the correcponding normal power source must be OPERABLE, andiall redundant systems, subsystems, trains, components, and(devices must be OPERABLE, or otherwise satisfy Specifi-cation 2.0.1(2)'(i.e., be capable of performing their design 2-Ca g 7- -

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• 2.0 LIMITING CONDITIONS FOR OPERATION 2.0.1 General Requirements.

function and have at least one normal and one emergency power source'0PERABLE). If they are not satisfied, shutdown is re-

. quired in accordance with this specification.

'As a further example, Specification 2 7 requires in part _that two physically independent circuits between the offsite trans-mission network and the onsite Class IE distribution system be OPERABLE. The specification provides a 24-hour out-of-service time when both required offsite circuits are not OPERABLE. If the definition of OPERABLE vere applied with-out consideration of Specification 2.0.1(2), all systems, subsystems, trains, components, and devices. supplied by the inoperable normal power sources, both of the offsite circuits, would also be inoperable. This would dictate invoking the applicable measures for each of the applicable LCO's. How-ever, the provisions of Specification 2.0.l(2) permit the time limits for continued operation to be consistent with the corrective measures for the inoperable normal power sources instead, provided the other_specified conditions are satisfied. In this case, this would mean that for one divi-sion the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components, and devices in the other division must be OPERABLE, or likewise satisfy Specification 2.0.1(2) (i.e., be capable of performing their design functions and have an emergency

. power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components, and devices in both divi-sions must also be OPERABLE. If these conditions are not satisfied, shutdown is required in accordance with this specification.

In Operating Modes 4 or 5, Specification 2.0.l(2) is not applicable, and thus the individual requirements for each applicable Limiting Condition for Operation in_these modes must be adhered to.

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. ,, . . A DISCUSSION The Omaha Public Power District received a letter from the Nuclear Regulatory Commission, dated April 10, 1980, requesting that Technical' Specification revisions be proposed in order to define the use of the t'erm OPERABLE and to specify corrective actions to be taken when plant operating conditions have degraded beyond the circumstances addressed by existing Limiting Conditions for Operation (LCO). The specifications proposed herein are sub-mitted in response to the Commission's letter.

These specifications require that the plant be placed in a hot shutdown condition within six (6) hours from the time a con-dition is found which exceeds a LC0. Six (6) hours permit a con-trolled and orderly shutdown through the normal boration method at the maximum rampdown rate of approximately 20% per hour. Ef-fecting a shutdown in less than six (6) hours would require emer-gency boration and/or the use of reactor control rods which are used for shutdown purposes only when a rapid automatic or manual trip is required to protect operating equipment from damage or ensure public health and safety. The use of control rods or emergency boration to shutdown the plant when a LCO is violated could have the potential for causing an operational transient at a time when safety related equipment is degraded and defense in depth is not available to mitigate the consequences of the transient.

For example, in the event that two (2) trains of the safety in-jection system are inoperable, sound safety practice dictates that the plant be shutd .vn as carefully as possible in order that the safety injection system is not challenged. A safe, orderly shut-down can be accomplished within six (6) hours at the Fort Calhoun Station. The District's position on this subject was relayed to Mr. Wagner and Mr. Wetmore of the Commission's staff during a telephone conversation on July 24, 1980.

The proposed Technical Specifications are administrative.

They do not represent an unroviewed safety question, since no existing Technical Specifications are modified, except to clarify the term OPERABLE. The new Specification 2.0.1 also provides additional clarification in the application of the term OPERABLE /

OPERABILITY. The proposed changes are consistent with Combustion Engineering Standard Technical Specifications.

ATTACHMENT B

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l JUSTIFICATION FOR FEE CLASSIFICATION l The proposed amendment is deemed to be Class II, within the meaning of 10 CFR 170.22, because it is administrative in nature and has no safety or environmental significance. It only seeks

'to clarify the term OPERABLE and provide additional clarification in the application of the term OPERABLE /0PERABILITY.

ATTACHMENT C