ML20209F166

Proposed Changes to Tech Specs,Changing Titles of Senior Mgt Positions & Revising Surveillance Capsule Removal Schedule

ML20209F166
Person / Time
Site:	Fort Calhoun
Issue date:	07/08/1985
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20209F135	List: ML20209F132 ML20209F152 ML20209F166
References
TAC-59219, NUDOCS 8507120402
Download: ML20209F166 (10)

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TABLE 3-6 REACTOR COOLANT PUMP SURVEILLANCE REQUIREMENT METHOD FREQUENCY 1.1 Reactor Coolant Visual inspection of upper When motor is dis-Pump Flywheels surface of top disc.and assembled for mainten-bottom surface of bottom ance purposes.-

disc; volumetric inspection from circumference of all

' disc segments.

TABLE 3-7 CAPSULE REMOVAL SCHEDULE REMOVAL REFUELING SCHEDULE CAPSULE SEQUENCE EFPY** REMOVED 1 2.4 2250 2 5.9 2650 3 15 2750 4 20 450 5 21 .850 6 27 950 7- 32 2250*

8 Standby 2650*

• Replacement capsule assemblies were installed in the 2250 and 2650 loca-tions following early removal of the 2650 capsule. These capsules bench-mark the change in core loading design initiated at 5.9 EFPY.

• • Based on a rated power level of 1500 MWt.

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! Amendment No. A6, 83 3-27 ATTACHMENT A i

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r-5.6 ADMINISTRATIVE CONTROLS 5.5.1.7 b. Render determinations in writing with regard to whether or not each item considered under 5.5.1.6(a) through (e) above constitutes an unreviewed safety question.

c. Provide immediate written notification to the Division Manager -

Nuclear Production and the Safety Audit and Review Committee of disagreement between the Plant Review Committee and the Manager -

Fort Calhoun Station; however, the Manager - Fort Calhoun Station shall have responsibility for resolution of such disagreements pursuant to 5.1.1 above.

Records 5.5.1.8 The Plant Review Committee shall maintain written minutes of each meeting and copies shall be provided to the Division Manager Nuclear Production and Chairman of the Safety Audit and Review Comittee.

5.5.2 Safety Audit and Review Committee (SARC)

Function 5.5.2.1 The Safety Audit and Review Committee shall function to provide the independent review and audit of designated activities in the areas of:

a. nuclear power plant operation

b. nuclear engineering

c. chemistry and radiochemistry

d. metallurgy

e. instrumentation and control

f. radiological safety

g. mechanical and electrical engineering

h. quality assurance Composition 5.5.2.2 The Safety Audit and Review Committee shall be composed of:

Chairman: Division Manager - Quality Assurance and Regulatory Affairs Member: Vice President - Nuclear Production, Production Operations, l Fuels, and QA&RA Member: Senior Vice President - Electric Operations and Engineering l Member: Division Manager - Engineering Member: Division Manager - Nuclear Production Member: OPPD Operations, Engineering, and Technical Support staff Member: Qualified Non-District Affiliated Consultants as Required and as Determined by SARC Chairman 5-5 Amendment No. 9, 19, 60, 76, 84

I 5.0*. ADMINISTRATIVE' CONTROLS 5.5.2.8 e. ' The Fort Calhoun Station Emergency Plan and implementing procedures at least once every twelve months.

f. The Site Security Plan and implementing procedures at least once every twelve months.

g.- The' Safeguards Contingency Plan and implementing procedures at least once every twelve months'.

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h. The Radiological Effluent Program including the Radiological En-vironmental Montoring Program and the results thereof, the Off-site _ Dose Calculation Manual and implementing procedures, and the Process Control Program for the solidification of radioactive wastes

-at least once per 2 years,

i. Any other area of facility operation considered appropriate by the Safety Audit and Review Committee or the Vice President - Nuclear l Production, Production Operations, Fuels, and Quality Assurance &

Regulatory Affairs.

Authority 5.5.2.9 The Safety Audit and Review Committee shall report to and advise the Vice President - Nuclear Production, Production Operations, Fuels, and Quality Assurance & Regulatory Affairs on those areas of responsibility l- -

.specified in Sections 5.5.2.7 and 5.5.2.8.

Records 5.5.2.10 Records of Safety Audit and Review Committee activities shall.be prepared, approved and distributed as indicated below:

a .- Minutes of each Safety Audit and Review Conmittee meeting shall be prepared and forwarded to the Vice President'- Nuclear Production, l Production Operations, Fuels, and Quality Assurance & Regulatory Affairs within 14 days following each meeting.

b. Reports of reviews encompassed by Section 5.5.2.7 e, f, h, and i above shall be prepared, approved and forwarded to the Vice President - l Nuclear Production, Production Operations, Fuels, and Quality Assurance

& Regulatory Affairs within 14 days following completion'of the review.

c. Audit reports encompassed by Section 5.5.2.8 above shall be forwarded to the Vice President - Nuclear Production, Production Operations, l Fuels, and Quality Assurance & Regulatory Affairs and to the responsible management positions designated by the Safety Audit and Review Committee-within 30 days after completion of the audit.

5-8 Amendment No. 9, 19, 38, 60, 76, 84, 86

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5.0 ~ ADMINISTRATIVE CONTROLS 5.10.2 The following records shall be retained for the duration of the Facility Operating License:

a. ' Records of drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c.- Records of facility radiation and contamination surveys.

'd . Records of radiation exposure for all individuals entering radiation control areas.

e .- Records of gaseous and liquid radioactive material released to the environs.

-f. Records of transient or operational cycles for those facility compo-nents designed for a limited number of transients or cycles.

g. Records of training and qualification for current members of the plant staff.

h. -Records of in-service inspections performed pursuant to these. Technical Specifications.

i. -Records of Quality Assurance activities required by the QA Manual.

j. -Records of reviews performed for changes made to procedures or' equip-3 ment or reviews of tests and experiments pursuant to 10 CFR 50.59.

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. k. Records of meetings of the Plant Review Committee and the Safety. Audit and Review Comittee.

l 1. Records of Environmental Qualification of Electric Equipment pursuant L to 10 CFR 50.49.

! m. Records of the service lives of all hydraulic and mechanical snubbers listed on Table 2-6 (a) and (b) including the date at which the ser-

. vice life commences and associated installation and maintenance records.

!' n. Records of analyses required by the Radiological Environmental Monitor-

[ -ing Program, 5.11 Radiation Protection Program h

i. Procedures for personnel radiation protection shall be prepared consistent t with the requirements of 10 CFR Part'20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

t-i Of66tl66tt61//0tt666t/?Hl1980 Amendment No.-59, 86- 5-19 I

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5.d DMINISTRATIVE CONTROLS 5.12 Environmental Qualification (DELETED) 5.13 Secondary Water Chemistry A secondary water chemistry monitoring program to inhibit steam generator tube degradation shall be implemented. This program shall be described in the station chemistry manual and shall include:

1. Identification of a sampling schedule for the critical parameters and control points for these parameters;

2. Identification of the procedures used to measure the values of the critical parameters;

3. Identification of process sampling points;

4. Procedures for the recording and management of data;

5. Procedures defining corrective actions for off control point chemistry conditions; and

6. A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective actions.

OfMf/MtH/0tt%6t/2H/UBD FORT CALHOUN 5-20 Amendment No. 57

O Attachment B Discussion, Justification and No Significant Hazards Considerations I. Figure 5-1, Page 5-5 and Page 5-8 Title Changes: The Omaha Public Power District, effective April 1,1985, changed the titles of the senior management positions. Specifically, the title of the General Manager was changed to " President and Chief Executive Officer (CE0)" and (Senior /Special) Assistant General Manager titles were changed to "(Senior /Special) Vice President". Thus, these titles have been changed in the proposed Technical Specifications. The title changes are administrative and no function associated with any of these titles was altered as a result of the change.

Pursuant to 10 CFR 50.92, the following significant hazards considerations have been made:

(1) Will the change involve a significant increase in the probability or consequences of an accident previously analyzed?

No. This change only deals with title changes. These title changes in no way relate to either the probability or consequences of any accident.

(2) Will the change create the possibility of a new or different type of accident from any accident previously evaluated?

No. The title changes are administrative in nature and in no way in-volve any sort of accident.

(3) Will the change involve a significant reduction in a margin of safety?

No. This change only affects the titles of senior management. These changes in no way impact any margin of safety.

The Commission has provided guidance concerning the no significant hazards consideration determination. Examples of amendments which do not include significant hazards considerations have been provided (48 FR 14870). This proposed change is found to be similar to example (1) in that it is a purely administrative change, specifically, to accommodat,e a change in nomenclature.

II. Pages 5-19 and 5-20 The proposed changes to these pages are being made to delete reference to a deadline which was superseded and to correct an item which referred to that section.

As a result of IE Bulletin 79-01B, licensees were required to environmen-tally qualify certain electrical equipment. In an effort to assure that licensees were complying, the Commission modified licenses by issuing an Order which included the compliance deadline in the Technical Specifications.

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As that deadline approached, the Comission recognized that the deadline was arbitrary, and suspended it. Since that time, the rulemaking process has been completed, and 10 CFR 50.49 has become part of the Federal Regu-lations. The 10 CFR 50.49 ruling superceded all deadlines previously incorporated into licensee's Technical Specifications.

Since issuance of 10 CFR 50.49, it is no longer necessary to include the environmental qualification deadline in the Technical Specifications.

Thus, Section 5.12 has been deleted. Section 5.10.2.1 formerly required recordkeeping pursuant to Section 5.12. Since 5.12 is no longer inclu-ded, Item 5.10.2.1 now specifies recordkeeping pursuant to 10 CFR 50.49, the applicable regulation.

Pursuant to 10 CFR 50.92, the following significant hazards considera-tions have been made:

(1) Will the change involve a significant increase in the probability or consequences of an accident previously evaluated?

No. Deletion of Section 5.12 and rewording of the recordkeeping requirements have no impact upon the probability or consequences of any accident. These changes are administrative and only pro-vide for consistency between the Technical Specifications and Federal Regulations.

(2) Will the change create the possibility of a new or different type of accident from any accident previously evaluated?

No. These proposed changes do not constitute a change in any operation at the facility; these changes in no way create the possibility for a new or different accident.

(3) Will the change involve a signficant reduction in a margin of safety?

No. The proposed changes do not involve any margin of safety found in the Technical Specifications.

The Commission has provided guidance concerning the no significant hazards con-siderations determination. Examples of amendments which do not include signi-ficant hazards considerations have been provided (48 FR 14870). This proposed change is similar in part to example (i) in that it is an administrative change intended to achieve consistency throughout the Technical Specifications. Second-ly, it is much like example (vii) in that it is a change made to conform to changes in the regulations, resulting in minor changes to facility operations, ~ clearly in keeping with the regulations. Thus, we believe no significant hazards considerations are involved.

III. Table 3-7 The surveillance capsule removal schedule (Table 3-7) of the Technical

. Specifications, was revised to document the early withdrawal of surveil-lance capsule assembly W-265 and to document the installation of two replacement capsule assemblies; one at W-225 and one at W-265. The original W-265 capsule assembly was removed early, at 5.9 EFPY, to bench-mark the end of a core loading design used up to that time and the two replacement capsule assemblies were installed to document the reduced fluence expected as a result of a core loading design change.

The District revised Table 3-7 to conform to 10 CFR 50, Appendix H.

Since that capsule removal schedule was amended, the District has de-termined that these proposed changes would provide more useful infor-mation.

Removal Anticipated Seoumce __ Fluence Purpose 3 1.6 x 1019 50% E0L Fluence at vessel wall 4 3.3 x 1019 E0L fluence at vessel wall 5 2.0 x 10 19 EOL fluence at 1/4 thickness 6 2.5 x 1019 75% E0L fluence at vessel wall -

7 3.6 x 10 19 EOL Sample The peak E0L fluence anticipated at the vessel wall is 3.3 x 1019 n/cm2 and the peak FOL fluence at the 1/4 thickness location is anticipated to be 2.0 x 1019 n/cm2 This sequence is set up such that the requirements of 10 CFR 50, Appendix H, are satisfied. It is noted further that it may prove highly desirable to remove early the capsule scheduled for sequence 7 in order to provide additional material properties information which would be useful to the Pressurized Thermal Shock analysis program.

It is anticipated that further vessel wall neutron flux reduction will be achieved by fuel management schemes currently under investigation. This may necessitate another revision of the surveillance capsule removal schedule.

Pursuant to 10 CFR 50.92, the following significant hazards considerations have been made:

(1) Will the change involve a significant incre'ase in the probability or consequences of an accident previously evaluated?

No. The proposed change will not result in an increase in the pro-bability or consequence of a previously evaluated accident, but instead will provide better information on the fluence to the in-side surface of the reactor vessel.

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4 (2) Will the change create the possibility of a new or different type of accident from any accident previously evaluated?

No. The proposed capsule surveillance schedule will not create the possibility of a new or different kind of accident from any previously evaluated accident because the capsule assemblies have not changed, only their sequence of removal.

(3) Will the change involve a significant reduction in a margin of safety?

No. There is no change in any margin of safety involved in this Technical Specification change.

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