ML20086C658
| ML20086C658 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/15/1991 |
| From: | Gates W OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-91-267R, NUDOCS 9111250035 | |
| Download: ML20086C658 (3) | |
Text
l 4
e-y Noyember 15, 1991 Omaha Public Power District LIC-91-267R 444 South 16th Street Mall Omaha, Nebraska 68102-2247 402/630 2000 U. S. Nuclear Regul.atory Conunission attn: Document Cor, trol Desk Mail Station Pl-137 Washington, DC 20555
References:
i.
Docket No. 50-283 2
Letter from NRC (S. J. Collins) to O' (W. G. Gates) dated July 23, 1990, " Inspection Report 50-L 5/90-30" Gentlemen:
SbBJECT:
Interpretation of fort Calhoun Station Technical Specification 2.1.4(5)
Included in Inspection Report 50-285/90-30 was an NRC interpretation of the fort Calhoun Station (FCS) Unit No. 1 Technical Specification (IS) 2.1.4(5) ion is concerning oetection of primary-to-secondary leakage.
This interpretat inconsistent with Comoustion Engi.ieering and FCS Technical Specifications surveilla(CE) Standard Technical Specifications nce requirements.
Therefore, OPPD respectfully requests NRC concurrence with a revised interpretation concerning mode applicability for Specification 2.1.4 and the associated surveillance Specification.
The submittal of OPPD's interpretation of TS 2.1.4(5) was suggested during a meeting between the NRC and OPPD on October 9, 1991 attended by Mr. Wayne Walker and Mr. Dave Wigginton from the NRC and Mr. Ron.,hort and Mr. Tom Therkildsea from OPPD.
Attr.ched is OPPD's position that these Specifications are applicable only when the reactor coolant temperature is greater than 210*F, i.e., not when the plant is 'n Cold Shutdown (Mode 4) or Refueling Shutdown (Mode 5).
In order to support our 1992 refueling outage, NRC concurrence is requested by January 31, 1992.
If you should have any questions, please contact me.
Sincerely,
&. /1/d W. G. Gate Division Manager Nuclear Op rations WGG/sel Attachment c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV D. L. Wigginton, NRC Senior Droject Manager R. P. Mullikin, NRC Senior Resident Inspector w c ~1:111 n i 12mw; 2
w is run j
f
'j Ql }*
Impoyme 0;4at. trj j
l 45 5124 w
e r
--aw W"
- + - *
=r v-4rw'-
f U. S. Nuclear Regulatory Commission LIC-91-2r7q Page 2 AlIACHMENT PRESENT NRC INTERPRETATION Included in Inspection Report 50-285/90-30 is the following discussion concerning Technical Specification 2.1.4(5):
During a tour of the control room on May 17, 1990, the inspector noted that it did not appear that the licensee was complying with the requirements specified in TS 2.1,4(5). This TS states that, to determine leakage to the secondary system, one of the following must be operable at all times: (a) steam generator blowdown radiation sample instrument, (b) condenser offgas radiation monitor, or (c) periodic secondary samples analyzed for activity.
At the time the ins)ector identified this apparent probicn the plant was in Mode 5 (refueling slutdown) and none of the actions spec d by the TS were being performed.
To resolve this issue, the inspector contacted NRR for a clarification of L, 2.1.4(5). NRR stated that operaule, as related to this particular TS, was intended to mean:
In Mode 5, the licensee shall have the capability of performing one of the actions specified by the TS.
In Modes 1 through 4, the licensee was required to perform one of the actions specified by the TS.
DISCUSSION The fort Calhoun Station (FCS) Unit No 1 Technical Specifications are custom and do not have standardized definitions for modes of operation. A comparison with Combustion Engineering (CE) Standard Technical Specifications (STS) is presented below:
Fort Calhoun Tji LPakVLiion Enaineerina STS Mode 1 Power Operation Mode 1 Power Operation Mode 2 Hot Standby Mode 2 Startup Mode 3 Hot Shutdown Mode 3 Hot Standby Mode 4 Cold Shutdown Mode 4 Mot Shutdown Mode 5 Refueling Shutdown Mode 5 Cold Shutdown Mode 0 Refueling Shutdown Unlike the CE Stancard Technical Specifications, FCS lechnical Specification 2.1.4 does not have a mode applicability statement. The applicability statement indicates that Specification 2.1.4 applies to leakage rates of the reactor coolant system.
Specification 2.1.4 also states that the limiting conditions for operation must be met to assure safe reactor operation.
The action statements for primary-to-secondary leakage require that the leakage rate be reduced to within limits or the reactor t.ltimately be placed in the COLD SHUTDOWN Condition (Mode 4).
CE Standard Technical Specification 3.4.7.1, " Leakage Detection Systems," is applicable for Modes 1 through 4.
The action statement requires the plant be placed in HOT STANDBY (Mode 3) within six hours and COLD SHUTDOWN (Modc 5) within an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Due to differences in mode definitions between FCS Technical Specifications and CE Standard Technical Specifications, a comparison of the action statements indicates that the appropriate mode applicability for FCS Specification 2.1.4 i
includes Modes 1, 2, 3 and the reactor coolant temperature range from 210* F to l
515*F which does not have a mode designation.
~
U. S. Nuclear Regulatory Commission L]C-91-267R Page 3 Surveillance requirements contained within the FCS Techtical Specifications also disagree with the Inspection Report interpretation.
Specification 3.2
" Equipment ar.d Sampling Tests," Table 3-5, item 8 states that RCS leakage will l
be evaluated "whenever the ;ystem is at or above operating temperature and I
(T,.,) is greater than 515'f.FCS Hot Shutdown (FCS Cold Shutdown (Mode 4) is defined fressure."
Mode 3) is defined as when the reactor coolant reactor coolant is below 210*F; this corresponds with CE Standard Technical Specification Cold Shutdown (Mode 5) which is defined as below 200'f.
It is therefore OPPD's position that "at or above o reactor coolant temperature is above 210' f. perating temperature" is when the OPPD also interprets the requirement that a means be available "at all times",
Specification 2.1.4 is applicable (. )When differ (en)ces in Mode definitions areand 2.1.4 5, app as stated in Specifications 2.1.4 4 taken into effect, this interpretation is consistent with the CE Standard Technical Specifications.
CONCLUSION It is OPPD's position that FCS Technical Specifications Limiting conditions for Operation 2.1.4 and the corresponding surveillance Specification 3.2, Table 3 5, item 8 apply only when the temperature of the reactor coolant is greater than 210'f.
Therefore, Specification 2.1.4 is not applicable in Modes 4 and 5.
i l
. -, - -,. -. - - - - - ~.
-.,