ML20040H360

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Discusses Telcon on Amended Tech Spec SL 3.1 Re Core Safety Limit.Records Not Maintained to Determine Time Utilized for New Portions of Tech Spec.Records Will Be Maintained from Effective Date of New Tech Spec SL 3.1
ML20040H360
Person / Time
Site: Fort Saint Vrain 
Issue date: 01/18/1982
From: Warembourg D
PUBLIC SERVICE CO. OF COLORADO
To: Kuzmycz G
NRC
References
P-82020, NUDOCS 8202180158
Download: ML20040H360 (2)


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SUBJECT:

Ft. Saint Vrain Unit No. 1 Core Safety Limit Technical Specification SL 3.1

Dear Mr. Kuzmycz:

This letter is writt:.

to confirm our. telephone conversations which took place with the issuance of Amendment 23 to the Technical Specifications, and more recently on January 12, 1982.

The subject Technical Specification was issued to clarify the core.

safety limits and the power-to-flow ratio for the lifetime of the reactor.

In revising this Technical Specification, however, several new areas were introduced into the specification, especially at the low and high ends of the power-to-flow 1imiting conditions, which

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were not previously a part of the core-safety limits.

Because of these new areas and because we have no records in these areas from which to determine any cumulative times for which the reactor may have been operated in these new conditions, we called you to clarify our~ position for operation under the new Technical Specification.

Since the Technical Specification is based on a segment of life time and our initial segment life times (prior to establishing an equilibrium core) vary from 200 EFPD's to 1800 EFPD's, we must maintain historical records for each segment which reflect cumulative time for which the reactor is operated in excess of the various ranges of the.

power-to-flow ratio dictated by the Technical Specifications.

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January 18, 1982 P-82020 Under the provisions of the previous core safety limits we did not maintain records for the Technical Specification for power-flow ratios in excess of 2.5 nor did we address ratios or times for power-tc-flow ratios in excess of 1.17.

In this respect, the only continuous record we have is for Item 3.1.3.4 of SL 3.1.

For Items 3.1.3.1 thru 3.1.3.3, we have no historical records.

Per our telephone conversations, we indicated that we did not have records for the above mentioned items, nor could we get records to determine any time that may have been utilized to date for the new portions of SL 3.1.

On this basis, we agreed to set the clock back to zero as of the effective date of the new SL 3.1 and maintain records from that point on.

We also agreed that we would retain the records accumulated under the provisions of the previous SL 3.1, and that should we approach any of the limits of new Technical Specifications, the records and time accumulated under the previous Specification would be factored into the total time as applicable.

(Item 3.1.3.4)

We are presently operating under these provisions.

Very truly yours, W Wlbst

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Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/skd cc: John T. Collins, (Region IV) l t