ML19256G334
| ML19256G334 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/30/1979 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| RTR-NUREG-0610, RTR-NUREG-610 P-79290, NUDOCS 7912310074 | |
| Download: ML19256G334 (4) | |
Text
yt. 6 h*
- d f R L y g p g m q.4, f
. / o ocou m, 3C emm.au c 1
puhuc service company e cenende 16805 Road 19 1/2, Platteville, Colorado 80651
>)
a N
- 8?$
g I ggf.S P 3 November 30, 1979
~
7 DEC Fort St. Vrain
- . gj
)
Unit No. 1 ca**'ske P-79290 s
9 os Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attn:
Docketing and Service Branch Docket No. 50-267
Subject:
NUREG-0610 Gentlemen:
We have reviewed NUREG-0610 as it applies to High Temperature Gas Cooled Reactors, and we offer the following comments.
Notification of Unusual Events The following comments are keyed to the item numbers on pages 4 and 5 of NUREG-0610.
1.
Not applicable to Fort St. Vrain.
2.
Radiological effluent technical specifications control the reporting requirements which are set forth by the technical specifications. We are also required by the nature of our discharge permit to report to the EPA.
We have reached agreement with the state to report any uncontrolled release of radioactivity without regard to technical specification limits which we feel is more in line with the intent of prompt response rather than keying the release to radiological technical spacifica-tions.
In this respect Item 2 should reference uncontrolled or unplanned radiological releases which are below the limits set forth by the Alert Classification and reference to radiological technical specifications should be eliminated.
3.
The limits set forth for fuel daaage are developed on the basis of water reactor technology and are not directly applicable to Fort St. Vrain.
Indication of fuel failure is set forth by Fort St. Vrain Technical Specifications 1660 341 ms.. app,
,ons1o OW
- w
Decketing and Service Branch Page Two November 30, 1979 (i.e., 25% increase in circulating activity over previous equilibrium values), and we have reached agreement with the state for prompt notification should we experience such an increase in circulating activity.
4.
The term " abnormal" as referenced in this item is not clear and time periods are not defined.
If reporting under this item is to be implemented further classifica-tion is required.
Due to the difficulty in quantifying the term " abnormal" it is recommended that this item be eliminated on the basis that reporting actions under Item 3 are the controlling elements for the health and safety of the public.
5.
This item is not directly applicable to Fort St. Vrain in that primary and secondary leak rates by themselves are not of immediate concern to the health and safety of the public especially with reference to the Fort St. Vrain design.
6.
The term " safety relief valve" is all encompassing. There are obviously many safety relief valves in a plant that could fail to close with no consequence to the safety of the plant or the health and safety of public.
As written this item represents and undue reporting burden, and develops reporting requirements that are insignificant.
7.
We fail to see the significance of the reporting require-ments set forth by this item unless other significant events are coupled with the event such that safety systems may be degraded.
8.
This item is not applicable to Fort St. Vrain.
9.
Items that would be encompassed under this are controlled by Technical Specification LCO's all of which allow a time period for restoration (i.e., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, etc.)
This item requiring " prompt" notification of the state therefore does not mesh with the time frames allowed by technical specifications before plant shutdown is initiated.
This item as written is too broad and will no doubt result in ambiguous reporting, confusion and unnecessary reporting.
For example if the plant is brought down under controlled conditions within the provisions of the technical specifica-tions and the associated safety requirements we can see no justification for prompt notification of state and/or local entitities.
10.
We have agreement with the state that meets the intent of this item.
1660 342
Docketing and Service Branch Page Three November 30, 1979 11.
We feel this item falls in the same category as Item 9.
12.
We have agreement with the state that meets the intent of this item.
13.
We have agreement with the state that meets the intent of this item.
14.
We have agreement with the state that meets the intent of this item with the exception of sub-item e.
It is not clear what is intended by the term turbine failure.
15.
This item is apparently a catch all item, and as such, becomes very difficult to implement and enforce. Judge-ment items such as this will only result in dif ferences of opinion and will be a source of confusion and argument.
We suggest that the other items adequately cover the major notification items and recommend that this item be elimina-ted.
16.
We have agreement with the state on this item.
17.
This item is not directly applicable to Fort St. Vrain.
Alert Notification It is extremely difficult to correlate the examples of the initiating condition with the release potential.
It is not clear for example whether the initiating condition is cause for reporting to the state or whether the initiating condition is to be tempered with the release potential.
It is our opinion (and our emergency procedures have been developedassuch)thatthealertclassificationissgchthatan activity release of up 10 curies of I-131 or up to 10 curies of Xe-133 has occurred or that there is some reason to believe that such a release is imminent.
Otherwise, the event falls into the classi-fication of an unusual event.
Many of the initiating conditions, of course, are not applicable to Fort St. Vrain, and without considering site specifics the initiating conditions cannot be implemented.
Under " Licensee Actions" a requirement for a written summary within eight (8) hours has been imposed.
Under many circumstances this relatively short time frame will be impossible to meet given the analysis that is usually required.
It is suggested that this time frame be evaluated in terms of obtaining and processing off site radiological samples, sequence of events and other conditions.
1660 343
Docketing and Service Branch Page Four November 30, 1979 Site Emergency The same general comments is expressed for the Alert Classi-fications are applicable to a site emergency.
General Emergency We have no conceivable conditions or accidents at Fort St.
Vrain that would result in the release of activity in quantities sufficient to get us to a General Emergency category. Setting this fact aside, however, the same general comments expressed for the Alert Classifications also apply to this classification.
General Comment In general, it is obvious that NUREG-0610 has been developed based on water reactor technology. The guidance therefore can only be applied partially and with some interpretation to Fort St. Vrain.
Our main concern with the NUREG is that Fort St. Vrain should not be penalized with unnecessary reporting requirements based on water reactor accident scenarios and that application of the NUREG to Fort St. Vrain must take into consideration the major differences associated with gas cooled technology and the inherent safety features of Fort St. Vrain.
Very truly yours, W TY m' Don W. Warembourg y
Manager, Nuclear Production DWW:dkm i660 344
.