ML19341C968
| ML19341C968 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 02/27/1981 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM P-81075, NUDOCS 8103040634 | |
| Download: ML19341C968 (4) | |
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February 27, 1981 Fort St. Vrain Unit No. 1 P-31075 Mr. Darrell G. Eisenhut, Director Division of Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20E55 Docket No. 50-267
SUBJECT:
TMI Action Plan Requirements NUREG 0737
Dear Mr. Eisenhut:
In the above referenced letter we indicated in our response to item I.C.6 that we were evaluating the proposed Draft 2 to ANS 3.2 and that we would acdress the subject in more detail in future correspondence.
We have reviewed Section 5.2.6 of the aforementioned ANS 3.2 and the supplemental provisions of NUREG 0737 set forth under Item 1.C.6.
Our position on this matter is as follows:
1.
Our existing procedures for ecuipment control and tagging meet the general intent of Section 5.2.6 of ANS 3.2 and the supplemtal provisions of NUREG 0737 in the following manner:
a.
Release of plant systems or equipment for maintenance or surveillance tests is controlled by operating personnel holding a senior license and the Shif t Supervisor is either directly responsible for such a release or is kept cognizant of such g \\I
'D, releases and the system status.
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b.
Our procedures do provide for ensuring protection 4y of equipment and workers.
Systems and/or equipment
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-a h" are tagged out utili:ing predetermined and approved
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standard clearance points forms.
Individual
/s components which may require only a few clearance q
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/ci poin*.s are handled on a case by case basis in liev j(x of the standard clearance forms. At the time of
's A clearance, jobs are evaluated for the need to issue 3
to j,
,s a radiation work permit.
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Before equipment or systems are released the Shift Supervisor or the SRO has the responsibility to ensure that such clearances can be released within the confines of the Technical Specifications and the overall plant status'.
d.
The tagging system utilizes long established procedures to ensure equipment can be maintained in a controlled status, e.
Temporary modifications such as jumper installatic.n, lifted electrical
- leads, temporary instrumentation, bypass lines etc. are controlled by procedures which require; appropriate identification, appropriate evaluation, safety analyses, approvals and provides a controlled mechanism for returning the system to normal.
f.
Non-conformance procedures e1tablish control of equipment and/or systems that cannot be relied upon to perform their. intended function.
g.
Abnormal system status is controlled by a system operating deviation report which is approved and kept in the control room to ensure the operating staff is aware of all abnormal conditions.
h.
For the majority of the cases functional tests are conducted on equipment or systems prior to their return to service.
Exceptions to functional testing as an example may involve individual components cr small portions of larger systems wherein the functional test is not warranted due to the gerational nature of the equipment or component or wherein conduct of a functional test is not practical without upsetting other plant operating systems.
2.
The pritary exception that our procedures do not address is independent verification by a
second qualified operator.
In this respect we have taken a somewhat different approach to operating verification based on the following:
a.
Almost all of the safety related systems at Fort St. Vrain that are utili:ed for reactor protection or for mitigating the consequences of accidents are in operation during routine plant operation (i.e.,
i the PCRV line cooling syscem, tne reactor plant exhaust system, the plant protective system, the helium circulators, the steam generators, various i
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' auxiliary systems).
Exceptions to this general rule are systems such as the Emergency Diesel Generators, tne fire water back-up system, and redundant equipment which is in stand-by service.
b.
On this basis we have constant monitoring of system status and performance of such systems at all times when the plant is in operation.
c.
Systems such as the emergency diesel generators are ope' rationally verified by Tech Spec surveillance.
Systems such as the fire water back op system require specific operator action to bring them into service.
Because of the time it takes for accidents to develop more than adequate time exists for such operator action.
Redundant ecuipment in stand-by service generally requires specific operator action to bring this equipment into service.
d.
In this respect we are not faced with ECCS systems in stand-by service and are not dependent on equipment which is not in normal, routine operation to mitigate the consequences of an accident.
e.
Independent verification of the tagging system is performed to ensure the tagging system is wo rki ng.
Independent verification is obtained by the use of the standard clearance points form which must ce signed off by the equipment operator and the Shift Supervisor in releasing the system -to service.
Regular surveillances are performed by the QA Department on system status and valve line ups to ensure the tagging system and/or equipment control systems are working.
4here practical, system func+4cnal tests are conoucted. As mentioned above rout.
,peration at Fort St.
Vrain verifies the i
operat. :al aspects of the n.ajority of our safety systen..
Periodic audits conducted by the QA Department and the NFSC also provide independent verification of the equipment control system, f.
Following a major maintenance outage the plant start-up is controlled by C"9rall Plant Operating Procedures (OPOP's) wnich :antain operational hold points at various power levels, prerequisites at these hold poi"ts and valve line up check sheets.
3.
Based or tne above and given the unicue characteristics of Fort Si. Vrain we believe our procedures for operational veri:ication meet the full intent of Oraft 2, ANS 3.2.
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Requiring further independent verification involving equally qualified operators will necessarily require a major increase -in the operating staff.
Given these positions outlined above we do not feel that such an l
increase in staff is justified.
If in fact the position outlined above is not acceptable and we are forced to-increase the staff, it will take considerable time to hire new personnel and train and license these personnel to meet the letter of Draft 2, ANS 3.2.
In this respect it is not as simple as Just changing a few precedures to meet the requirements.
It requires people to implement procedures, and if in fact we are faced with licensed people, these people cannot be obtained overnight especially since the source of licensed people for an HTGR is non-existent.
Very truly yours, h }Y /%d Don W. Warembourg Manager, Nuclear Production 4
For+ St. Vrain Nuclear Generating Station DWW/dkm
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