ML20093K827
| ML20093K827 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/27/1984 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.1, TASK-TM GL-83-37, LIC-84-237, NUDOCS 8407310206 | |
| Download: ML20093K827 (2) | |
Text
Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 July 27, 1984 LIC-84-237 Mr. James R. Miller, Chief U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch No. 3 Washington, D.C.
20555
Reference:
Docket No. 50-285
Dear Mr. Miller:
NUREG-0737 Technical Specifications (Generic Letter 83-37)
NUREG-0737, " Clarification of TMI Action Plan Requirements," identified those items for which Technical Specifications would be required. Generic Letter 83-37, dated November 1, 1983, provided guidance concerning the scope of Tech-nical Specifications the staff would find acceptable, and also provided samples in Standard Technical Specification format. Accordingly, the Omaha Public Power District, in a letter dated March 27, 1984, provided discussion concerning these recommended specifications for Fort Calhoun Station's auxiliary feedwater system.
Subsequently, the District received your letter dated June 15, 1984, which pro-vided the Safety Evaluation Report (SER) for this issue. That SER found, in part, that the District's quarterly surveillance testing requirements for the Auxiliary Feedwater Pumps was in disagreement with the Generic Letter's monthly specifications. The SER stated that the District's current program was accept-able pending a change from a quarterly to a monthly test frequency.
The Omaha Public Power District h&s reviewed the SER and believes the quarterly test frequency provides adequate assurance that the auxiliary feedwater system will function as required for design base acciaents.
Discussions concerning the SER have been held with members of your staff and are documented in the attach-ment to this letter.
In accordance with this, the District believes the quarter-ly test frequency is sufficient and requests that the SER be revised accordingly.
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8407310206 840727
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pon R. L. Andrews Division Manager Nuclear Production RLA/DJM/rh-B Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington D.D.
20036
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Mr. E. G. Tourigny, NRC Project Manager O
Mr. L. A. Yandell, Senior Resident Inspector 3\\
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A'x111ary Feedwater System h~ k/f u
Technical Specification Changes (NUREG-0737, Item II.E.1.1 h 1
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t Sections 4.7.1.2.a.1 and 4.7.1.2.a.2 of Genet c Letter. 83-37 'equire licensees i
r to perfom monthly surveiljance testing of the auxiliary feedwater system.
Fort Calhoun Station Unit No.1 Technical Specifications require quarterly
. surveillance testing. The Constission's SER dated June 15, 1984, stated that a
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" Quarterly testing is not acceptable."
The Omaha 'Public Power District believes that quarterly testing 'is acceptable.
This belief is based upon the following dicussion. The testing of the auxil-f ary feedwater pump falls under the District's Inservice Inspection Program as submitted to the Commission. Specifically, Part 2: Class 1, Class 2 and.
Class 3 Pump and Yalve Tests, Section 2.2.1 states "The inservice test fre-quency for Class 1 Class 2 and Class 3 pumps are in accordance with Article IWP-3000 of Section XI."
'o Appendix 2A of the ISI Program Plan goes on to define the pumps requiring in-service testing. Among these are the Auxiliary Feedwater Pumps FW-6 and FW-10.
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The District's Inservice Inspection Program is conducted in accordance with y
Section XI of the ASME Boiler and Pressure Vessel Code. The acceptability of utilizing the Code is based upon Commission approval of the ASME Code as pro-
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vided in 10 CFR 50.55(a). The ASE Section XI code is based on sound engineer-
';b ing principles and has been accepted by the NRC. The,0maha Public Power Dis-s trict either complies fu7ly'with 10 CFR 50.55(a) or'has submitted requests for relief from the requirements of the Code. Therefore, we believe that devia-tion from the Code requirements is unnecessary as our quarterly test frequency provides full compliance with the regulation.
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Additionally, this testing frequency isccorisistent with that currently incor-
,. porated into the Fort Calhoun'Stattoll'Technjcal Specifications for pumps util-
'Ized in similar safety functions;such is the safety injection pumps (See Tech-
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,nical Specification 3.6(3)(ail. 'The basis for this specification states, in p3rt:v
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p' "the active components (pumps a valves) are to be tested every three months to check'the operation of the starting circuits q
and to verify that the pumps are in satisfactory running order.
g' The test interval'of three months is based on the judgement that more frequent testing Would not significantly increase the reliability (i.e., the probability that the component would oper-ate when required),'yet more frequent tests would result in in-creased wear over a long period of time."
The quarterly testing hahr'emained an acceptable Technical Specification and an acceptable portion of'the ISI Program, both approved by the Conmiission.
Plant personnel monitor the results of the Fort Calhoun Surveillance Testing i
Program and their reviews have not indicated the need to increase the testing i
quarterjf'%The District believes that the current Technical Specification for frequency.
testf ra of the auxiliary feedwater pumps is acceptable and no viable i
safety concern exists which would mandate changing to a monthly surveillance i
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