ML20246K298
| ML20246K298 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/28/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20246K304 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM LIC-89-770, NUDOCS 8909050428 | |
| Download: ML20246K298 (2) | |
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4 Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402,536-4000 August 28, 1989 LIC-89-770-U. S. Nuclear P.egulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
SA0 89-002 3.
SA0 89-002, Rev 1.
Gentlemen:
SUBJECT:
Request for Enforcement Discretion relative to the Control Room HVAC System The Omaha Public Power District (OPPD) is currently completing modifications of the Control Room Heating, Ventilating, and Air Conditioning System at the Fort Calhoun Station. These modifications will bring the Fort Calhoun Station into compliance with NUREG-0737, item III.D.3.4.
To finish the modification, the charcoal filter train upgrade must be completed.
Installation of the new filter units requires removal of the existing filter unit for a period of time estimated to be fourteen to fifteen days.
Every effort has been made to reduce this interval, including prefabrication, around-the-clock work, and scheduling to maximize use of manpower.
The Technical Specifications (TS's) allow for continued reactor operation for a period of seven days if the existing filter unit is found or made to be inoperable. This allows time for corrective action in the event of inoperability.
Fort Calhoun Station has written and approved a revision to an existing Safety Assessment for Operability (SA0 89-002, Rev.1). This revision justifies intentionally rendering the existing filter unit inoperable for a period of time in excess of that allowed by TS's, while replacement of the filter unit is effected.
This activity cannot be completed within seven days.
Therefore, OPPD requests a ten day extension to the Limiting Condition for Operation (LCO) which will allow the filter unit to be inoperable for seventeen days.
l This is a one time only request and is not intended to permanently change the Technical Specifications.
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89-770 Pat 2 During this extension of the LCO, OPPD will maintain compensatory measures in place to alert the operators of increasing iodine level and provide guidance for donning respiratory protection. The conditions and scenarios of concern do not significantly change whether the charcoal filter is disabled for seven days or seventeen days.
Continuing operation does expose the plant to ten additional days of operation not permitted by the Technical Specification with the filter unit inoperable. However, waiting until the 1990 refueling outage to make the final tie-ins would result in four additional months of operation with the existing filter unit and consequently four additional months of operating within the restrictions of the previously approved SA0 89-002.
Therefore, OPPD respectfully requests enforcement discretion to operate outside the conditions of LCO 2.12 relative to seven days of operation with the control room filter unit out of service. This request is for ten additional days, beyond the seven days allowed by TS's, of allowable opera-tion without the filter unit in service to allow for final tie-ins for the upgraded filter modification.
If relief is granted, OPPD plans to enter the modified LCO during the October - November 1989 time frame. Additionally, OPPD will notify the Senior Resident Inspector prior to entering the modified seventeen day LCO.
If you have additional questions, or require further information, please do not hesitate to contact me or members of my staff.
Sincerely, K.
. Morris Division Manager Nuclear Operations Attachment KJM/DJM/pfc c: LeBoeuf, Lamb, Leiby, and MacRae R. D. Martin, NRC Regional Administrator A. Sournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector t_____________________________________________________________________
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