ML19312E104
| ML19312E104 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/10/1980 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| IEIN-80-06, IEIN-80-6, NUDOCS 8006030253 | |
| Download: ML19312E104 (3) | |
Text
.__
bec to DAC:ADM:
CENTRAL FILES PDR:HQ kb Service COtupany Ti LPDR 13.:,
q p
A 16805 ROAD 19%
NSIC i
h El PLATTEVILLE, COLORADO 80651
[ } j l L2 ?".. ;
y., j.
March 10, 1980 Ij.
1 i", i 7 g Fort St. Vrain Unit No. 1 s __
P-80046 i
Mr. Karl V. Seyfrit U. S. Nuclear Regulatory Commission Region IV Office of Inspection & Enforcement 611 Ryan Plaza Drive Suite 1000 Arlington, Texae 76012 Docket No. 50-267 Subj ect :
I & E Information Notice 80-06
Dear Mr. Seyfrit:
We are in receipt of the subject Information Notice. We recognize that the amendments are to be effective immediately and we are making every attempt to provide some procedural instructions to our operators to implement these requirements.
Given the broad scope of some of these reporting requirements, I am sure you can recognize that esta-blishing procedures and guidelines for use by operating personnel in interpreting these requirements will be difficult at best.
We also recognize that the amendment was not issued for comment, but we feel obligated to make the following comments anyway:
1.
The effective date of the reporting requirements was February 29, 1980. We received a copy from the Resident I & E Inspector at 3:00 p.m. on February 29, 1980 and did not receive a copy through official channels until March 4, 1980.
Issuance of a document of this magnitude for immediate implementation represents an impossible situation.
2.
The intent of the sentence in the second paragraph of SSINS 6870, page 1 of 1, that begins " Reports of events pursuant to K 50.72 that are similarly required by Technical Specifica-tions.
. " is not clear.
We assume that this sentence means that reporting requirements under K 50.72 are now interpreted to be one (1) hour response reporting require-ments and that the one (1) hour response fulfills the Tech Spec reporting within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, except that follow-up reports are still required by Telex or mail-gram.
8006030 M 3 9
Karl V. Seyfrit
-Page Two Nbrch 10, 1980 3.
We have no problems with reporting requirements under Items (1), (2), or (3) under subparagraph (a) of K 50.72.
4.
Subparagraph (4), however, is subj ect to many interpretations.
We do at times recieve intelligence information ccncerning possible threats or possible affects of activities that could have a bearing on our security.
From past experience this information has never led to sabotage or attempted sabotage.
In this light we interpret notification under this para-graph to mean those acts that are cause for us to initiate the security contingency plan or represent actual instances of sabotage or threatened sabotage.
5.
It is not clear when the clock starts for the one (1) hour response time sub,aragraph (5).
As you know LCO's generally have a grace y
.d associated with them that permits continued operation. We assume on this basis that the clock starte for the one (1) hour response time at the end of the grace period, when action is initiated to shutdown, rather than at the beginning, and that no prompt report is required if the LCO situation is corrected during the grace period.
6.
The scope of subparagraph (6) is so broad and open for in-terpretation it is felt that the NRC should provide more s
guidance and specific examples.
Operator interpretation of this subparagraph, especially on back shif ts will be extremely difficult to say the,least.
7.
We are interpreting subparagraph (7) as an event which results in actuation of a safety function.
For example, if only one of three logic channels of Reactor Protection System is manually or automatically tripped, alarms are received, but no protective action takes place. We would not report these types of trips.
8.
For subparagraph (11) some of the reporting criteria involves evaluation over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, some refers to assessment of damage in terms of dollars and some refers to assessment of radiological exposures. On the basis of the time involved for evaluation and/or assessment we are assuming that the clock starts for prompt reporting after completion of the necessary evaluations or assessments.
Karl V. Seyfrit Page Three March 10, 1980 9.
With reference to the requirement to maintain open and continuous communications with the NRC Operations Center, we assume that the intent is that the men stay on the phone continuously.
If this assumption is true the NRC position is not acceptable to PSC.
On back shifts where personnel may be needed to react or respond to emergency conditions we cannot have a man tied up on a phone continuously, especially within the first hour of the event.
Such a request is unreasonable.
It is also unreasonable to have a man tied up continuously over the entire course of an accident with a phone receiver stuck in his ear.
If this is the intent of the requirement we must request that the NRC install speaker phones that will permit communication between the site and the NRC Operations Centgr without tying up a man full time.
In general, it appears that the scope of many of the reporting requirements is in need of clarification and guidance or we will most certainly be in a constant position of interpretation with NRC I & E Inspectors.
Somewhat off the subject of prompt notification, but along the same lines, the NRC recently installed Health Physics phones at the site.
At the present time we have no idea how these phones are to be utilized or even the purpose of the phones.
If the NRC has some specific in-tended use for these phones it is requested that we be provided with necessary information.
Very truly yours, W&
Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW:dkm
--