ML20071Q575
| ML20071Q575 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/18/1982 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM P-82526, TAC-46448, NUDOCS 8212290374 | |
| Download: ML20071Q575 (2) | |
Text
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Public Service Company *2 ConoIrade s
16805 WCR 19 1/2, Platt'eville, Coforado 80651 N
L t-November 18, 1982
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Fort St. Vrain
- Unit #1 P-82526 j
.66-2G7 y
1 Mr. Robert A. Clark, Chief U
Operating Reactors Branch #3
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v U. S. Nuclear Regulatory Commission j
Washington, DC 20555
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SUBJECT:
Fort St. Vrain Unit No. 1 NUREG 0737, Item III.D.2.4
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Control Room Inhabitability.$
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REFERENCE:
- 1) P-804383 t
- 2) P-81213 l
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- 3) P-81263
- 4) NRC Letter December 23, 1981 l
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- 5) NRC Letter March 24, 1982
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- 6) P-82288 q
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Dear Mr. Clark:
In response to telephone inquiries bE ~both Phil Wagner an'd
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George Kuzmycz concerning the status of Item III.D.3.4 of NUREG 0737,=
I have gathered all of the referenced correspondence and haye
- d attached excerpts of this correspondence for your convenience..
s In our letter, P-80438, Attachment A, we addressed the Control Roore '
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habitabiUty requirements in detail, and' outlined how we met th'e' requirements or how we met the intent of the requirements.
The only modification to be'made was the addition of a chlorine detecter in the chlorine storage. facility.
This work,has been completed.
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In P-81213, Augu'st'26, 1981, we referenced letter P-80438 indicating s
that we felt we had addressed the issues at hand, and having no esponse from thes NRC to the contrary, we assumed the item to be closed.
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In P-81263 in response to ORNL's September 30, 1981.repon, we
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w indicated we had no specific comment on ' Item III.O.3.4.
The ORNL report gave no indication as to any further action being required on
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our part to meet Iten III'.d.3.4.
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- - 1.'x.e In NRC's letter of December 23, 1981, it was indicated that our response to (P-80438) needed additional evaluation from a human factors viewpoint.
O This same position was reflected in NRC's letter for March 24, 1982, U
and therefore, our position that the NRC still had the matter under
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review was reflected in our letter P-82288, July 30, J82.
1 Mr.
Kuzmycz had requested in a recent telephone conversation that we
<f provide more information on the matter. After reviewing our response J,I in P-80438 I'really don't know what additional information we could add at this time.
- If, however, you have some specific questions we will be happy to address them.
Very truly yours,
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L$ JY @uu Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear
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DWW/skr Attacha nts y'
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Phil Wagner 1,;x
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,, y December 20, 1980
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Fort St. Vrain Unit No. 1 l
P-80438 Mr. Darrel G. Eisenhut, Direbtor Division of Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Fort St. Vrain Unit No. 1 TMI Action Plan Requirements NUREG 0737
REFERENCE:
NRC Letter Dated 10-31-80
Dear Mr. Eisenhut:
We have completed our review of the subject NUREG transmitted by the above referenced letter. The cttachment contains our response to each of the action requirements that are applicable to Fort St.
____ _ ____ __ ___._.~~Vrain~. ~0ur response to the' various~ action ~ Tequirements generally -
falls into four (4) categories.
1.
Those action requirements for which we have provided previous response which we feel is still applicable in light of the clarification provided by NUREG 0737. Other than previous commitments that may have been made as a pa-t of our response, we do not plan on any further action.
2.
Those action requirements and schedules which for various reasons we will be unable to meet, o-which for various reasons we have taken exception as to the applicability of the requirements to gas cooled technology as opposed to water cooled technology.
3.
Those action requirements and s:hedules which we intend to meet.
4.
Those action recuirements whi:h are clearly not applicable to Fort St. Vrain.
As we have pointed out in previous correspondence we have had a difficult time appiying the criteria, guidance and reouirements to Fort St.
Vrain, and in many cases have had little if any guidance that was clearly applicable to gas cooled technology.
In aadition, we were consistently excluded from receipt of various letters, bulletins, and orders resulting from the TM1 action requirements, and in this respe:t, we find that we were not afforded the same time schedule to plan and complete various activities by comparison to the water rea: tors.
WyoLi
4 '
We met with the Special Projects Division along with other members of the staff on December 10, 1o30, in an attempt to obtain some further clarification c' the appli ability of many of the action requirements to gas cooled technology. While we were able to obtain some general clarification we found t, hat we were unable to obtain any clarification with reference to the technical differences involving gas cooled reactors versus water cooled reactors which is a continuing problem that has been with us since the onset of TMI, and which because of a lack of guidance, has impeded our progress in many areas.
We have continued in our efforts te justify certain exceptions from the various criteria on the basis of distinct d'ffe ences between a gas cooled reactor and a water cooled reactcr. We believe that adequs'.e technical justification has been provided in many areas, but it 1: obvious that the te:hnical justification provided is not being considered in the various staff reviews, and it is elso obvious that various technical justifications which were reviewed by one group in
- the past are not being considered as new review groups are formed.
As a result we appear to be in a continual education process and in our opinion, continue _t.o_,be penali, zed _wi_th the inapplicable criteria.
Very truly yours, W We e k
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Don W. Warembourg
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Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/alk Attachment t
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l ATTACHMENT 4 REFERENCE ITEM III.D.3.4 The control room emergency zone at Fort St. Vrain consists of the control room and adjacent areas such as the kitchen and washroom.
The control room under normal conditions is staffed with two (2) people at all times. Various other people are entering end leaving as required for plant operations.
During an emergency, the Personnel Emergency Response Plan (Administrative Procedure G-5) requires five (5) people to be in the control room full time.
Additionally, a health physics person is assigned to the control room while fcur (4) other Operations Department Personnel will be in and out as required.
During an emergency, which requires the personnel to use the Breathable Air System, the control room occupancy is limited to six (6) to match the number of air supply connections. Other personnel will be requested to use Scott Air Pacs if they are in the control room.
In addition to the protection offered by self-contained Scott Air Pacs and the breathable Air System, the control room ventilation system utilizes the Control Room Makeup Ventilation Filter (F-7502) which is of the CBR type and is rated at 1500 cfm but operates at a flow of 480 cfm. The filter consists of a particulate filter in series with a gas absorber containing activated charcoal. The filter is designed to meet all the requirements of
- -the U.S. Army-Chemical Corps Specification MIL-F-50052. In addition, Control Room Ventilation Filter (F-7503) has a filter efficiency of 45% by the NBS atmosphere dust spot test, and is rated at 21.160 cfm. The filter is equipped with an upstream prefilter to trap large particles. In conjunction with filters F-7502 and F-7503, Control Room Charcoal Filter (F-7504) has elements with a nominal 1" thickness and is rated at 21,160 cfm. Particulate matter is removed by ventilation filter (F-7503) before passing through the charcoal.
Figure 1 (attached) is a schematic of the Control Room Ventilation System.
The following is a detailed comparison of existing FSV conditions to Standard Review Plans 2.2.1, 2.2.2, 2.2.3 and 6.4:
A.
SRP's 2.2.1-2.2.2 and 2.2.3 - Hazard Identification 9
1.
Guidelines These SRP's address the identification of potential hazards and accidents within 5 miles of the plant.
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- - - - - - - - - - - - - - -. -., - ~ -. -. - -,
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1 ATTACHMENT 4 REFERENCE ITEM III.D.3.4 2.
FSV Existino Condition On site: Chlorine is stored in liquid form in 1-ton bottles outside the Chemical Building, about 360 feet from the Control Room. Also, various chemicals such as 29% concentrated ammonia, 93% sulfuric acid, and 50% caustic are stored in the demineralizer room on the ground floor of the turbine building. There is an indoor turbine lube oil storage tank and outdoor underground storage tanks for gasoline, diesel fuel, and No. 2 fuel oil; these could produce hazardous combustion products if they were ignited. In addition, there is Halon and CO2 for the fire protection systems.
Within 5 miles: There is a Union Pacific RR track about 3 miles east that is the main north-south line between Denver, Colorado and Cheyenne, Wyoming; it carries LP Gas and occasionally liquid chlorine.
Another tract 3/4 mil West of FSV carries mostly coal. Also, there are two oil lines, one 3.1 miles and one 4.7 miles from FSV, and a 4" to 6" medium pressure (140-150 psi) natural gas transmission line about 3/4 mile south of FSV._.There_are numerous anhydrous annonia tanks used for fertilizer storage on adjacent farms, but there are no industrial activities that use chemicals or toxic naterials.
3.
Comments a.
As will be discussed with the specific guidelines, chlorine storage and the proximity to the railroad tracks are in accordance with Regulatory Guide 1.95.
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ATTACHMENT 4 REFERENCE ITEM III.D.3.4 b.
Chemicals are properly stored at the Plant inside closed systems in a room with outside vents two floors below the Control Room. The Control Room ventilation intake is 60' above the elevation of the demineralizer (chemical storage) room vent; with ammonia's toxicity level of 100 ppm and its acrid smell that is detectable at a much lower level, it is concluded that the intake dampers could be closed and the respirators donned before personnel inju./.
c.
The fire protection systens are designed to minimize fires in the petroleum tanks and to alert personnel so that breathing apparatus can be used, if necessary.
d.
The oil and gas line hazards due to explosions and fires are far entugh away that there can be adeq; ate warning to control ventilation as required.
B.
SRP 5.4 - Control Room Habitability 1.
Breathing Apparatus a.
Guideline Paragraph 6.4.II.4 states that self-contained breathing apparatus for an emergency team (at least 5 men) should be on hand in the Control Room. Also, a six-hour on site bottled air supply, 30-man-hours should-be available-with unlimited off-site --
replenishment capability from nearby locations.
b.
Existing FSV Condition There are 6 Scott Air Pacs in or immediately outside the Control Room, with 12 spare air bottles. There is also a Breathable Air system with 2 independent compressors and purifiers, each of which can provide 20 scfm to 6 masks in the Control Room. This system will remove chlorine and other noxious gases. There is also a 1140 scf 2400 psig storage volume that can recharge 2 Scott Air Pacs and supply 5 respirators for 45 minutes without recharging. This is about 24 man-hours of available air, in addition 'to which there is about 10 man-hours of air in reserve air pacs located in the rest of the plant.
It is noted here that the Breathtble Air System compressors have a suction point about 8' abcVe grade. This keeps out e
dust and minimizes the amount of heavy, dense gases (like chlorine) that get drawn in.
The filter canisterg of the Breathable Air Compressors are rated for 40,000 ft of air, minimum. At the normal 20 CFM, each set of canisters could filter for at least 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> and in a dry environment, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> could be expected.
FSV monitors the compressor elapsed time meters to insure that there is r,ufficient remaining capacity to handle accidents and replacement cartridges are available locally.
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ATTACHMENT 4 REFERENCE ITEM III.D.3.4 2.
Emergency Team Support a.
Guideline Paragraph 6.4.II.2 states that food, water and medical supplies should be sufficient to maintain the emergency team for 5
- days, b.
Existing FSV Condition FSV does not have this material stored. For the FSV facility all analyzed accidents are of short duration so that these l
supplies will not be required.
In the event of a long term accident, these materials are available nearby and could be j
obtained as required.
C.
Regulatory Guides 1.95 and 1.78 are referenced by SRP 6.4 and they provide the following:
1.
Regulatory Guide 1.95 pos;tulates two basic chlorine accident types:
l l
a long-term low-leakage-rate release, or a short-term puff release.
i For the first type, only breathing apparatus is necessary to protect the control room operator, if he is given warning. For the second type, the control room should be automatically isolated. For the 1:b.eakage-rate accident, FSV has adequate breathing apparatus (see B.1 above) and is installing a chlorine leak detector at the chlorine storage facility. Although this-leak detector-is inside the builidng while the chlorine storage bottles are outside, most of the connections are inside so most slow leaks will be detected.
The pv'f release would mest likely occur during loading and unicading the cylinders, which occurs about 350 feet, from the Control Room v?ntilation intakes. There is not a direct path between the chlorine bottle storage area and the Control Room intake, chlorine gas is heavy and would have to rise 75' to the Control Room air f
intakes, and significant diffusion would take place over this distance. For these reasons, the puff release is not considered to be a significant Control Room hazard. FSV meets the guidelines as discussed below.
2.
Material Storace a.
Guidelines Liquified chlorine should not be stored within 100 meters of a control room or its fresh air inlets. Also, the largest container should have an inventory of 2000 lbs, and there should be a capability for manual isolation of the ventilation system. For large quantities as would be in RR tankers, they should be over 2000 meters (6560') away. Specific criteria is not provided for other substances.
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ATTACHMENT 4 REFERENCE ITEM III.D.3.4 It is noted that the design concept for the Control Room ventilation system includes a full flow activated carbon filter that is norwally bypassed but would be put on line when the inlet dampers are closed. Also, the makeup filter includes an activated carbon section that is rated for chemical, biological and radiological service. The full flow carbon filter has the capcity to absorb about 20 pounds of chlorine or about 100 ft of pure chlorine gas at STP. Since the filter is not placed in service until after an accident, this capacity is considered adequate for cleanup of.the initial concentrations of chlorine in the control room that entered before the area could be isolated.
4.
Breathino System Assurance Level a.
Guidelines The emergency air supply should meet single failure criteria and be Seismic Category I.
For self-contained apparatus, there should be one extra unit for every three required.
b.
Existino FSV Conditions The Breathable Air System has two cumpressor/ purifier trains, and it was designed and installed to Class I requirements. There are six Scott Air Pacs installed at the Control Room where, for five
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-men, there should be seven. There are other units in the planti so-this is not considered a deficiency.
5.
Emergency procedures a.
Guidelines Emergency procedures to be initiated in the event of a hazardous chemical release should be written. Also, the Control Room leakage characteristics should be periodically verified.
b.
Existino FSV Conditions FSV procedure G-5 covers personne1' Emergency Responses to various accidents, including chemical spills. This procedure essentially designates an emergency coordinator who will provide direction in the event of a hazardous chemical release. There is no periodic control room leakage test program. However, the amount of leakage is not considered critical to habitability because of the breathable air system and because of the charcoal filters on the ventilation system.
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ATTACHMENT 4 REFERENCE ITEM III.D.3.4 b.
Existing FSV Condition Liquid chlorine is stored in one-ton containers approximately 130 meters from the control room or its air intakes. All air inlet and outlet dampers can be closed with switch HS75184.
Per the Union Pacific Traffic Agent, the RR track that carries liquid chlorine tankers is about 3 miles from FSV; the RR track 3/4 miles West of FSV carries mosty coal and miscellaneous freight but no chlorine.
3.
Automatic Isolation & Ventilation System Desian a.
Guidelines The control room should be protected by quick response chlorine detectors located in the fresh air inlets that will automatically close the ventilation dampers. Also, the normal fresh air makeup rate should be less than 0.3 air change per hour and the fresh air inlet should be at least 15 meters above grade.
an equivalent exchange rate of less than 0.06 hr-yction, with Finally, the room should be of low leakage constr
, and low leakage dampers should be located upstream of recirculation fans or at other negative pressure locations.
b.
Existing FSV Conditions
_. ---There-are no-chlorine detectors in the Control Room Ventilation-System fresh air inlets; however, chlorine and other toxic materials at FSV have a strong odor that can be detected before they build up to toxic concentrations. ">1orine is toxic at about 15 ppm, and can be smelled before 5 ppm. With the ventilation system bringing 11,400 cfm of makeup into a 40,000 cubic foot control room, it would take over three minutes to replace all the clean air with chlorinated air.
Since the dampers can be isolated in 5 seconds and the respirators can be donned in less than 2 minutes, it is concluded that there would be adequate time to manually isolate the ventilation system, don respirators, and switch the ventilation system to recirculate air through charcoal filters, so that plant control would not suffer. With the control room vent inlet located 75' above grade (22 meters), it is hard to envision an accident that would introduce highly toxic chlorine concentrations into the Control Room.
Also, tge fresh air makeup rate with gutside dampers closed is
.39 hr, the leakage rate is.09 hr, and the dampers are bubble tight with an 8" water differential. These flow rates are slightly greater than recommended but meet the intent of the recommendations.
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La PLATTEV1LLE, COLOR ADO 80651-9298 August 26, 1981 Fort St. Vrain Unit No. 1 P-81213 Mr. James R. Miller Chief Standardization & Sg tial Projects Branch Division of Licensing Nuclear Regulatory Commission Washington, D. C.
20555
Subject:
NUFIG 0737 Ref: NRC Order Dated August 6, 1981
Dear Mr. Miller:
We are in receipt of the above referenced order, but we are somewhat confused in the implications the order may have with specific refer-ence to page 4 wherin it is stated that:
"The licensee shall satisfy the specific requirements described in the Attachment to this Order, as appropri-ate to the licensee's f acility, as early as practice-able but no later than 60 days after the effective date of the Order."
As you are aware there has been considerable correspondence involv-ing the various items of TMI-2 enf the associated guidelines of NUPIG 0737 concerning the applicability of these requirenents to Fort Saint Vrain. In scue cases the requirements are clearly not applicable to Fort Saint Vrain and other' cases the applicability did not provide a well defined path of action. We have evaluated, and responded accordingly, to the individual NUP2G 0737 items, but we have not, to date, received any NRC response relative to the various positions we have taken. In order to clarify the impli-cation associated with the Order we believe it is necessary to clarify the various items of the Attachment to the Order.
In this respect we have provided in the attachment to this letter an update of the various NUREG 0737 guidelines which delineates the present status of the items. In many cases, i=plementation has i
l been completed or will be completed within 60 days. In other cases a
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MR. JAMES R. WTT'R, Ch!ET Aug tst 26, 1981 j
P-81213 Page 2 implementation has not and cannot be accomplished without further resolution. These latter items primarily involve areas where ex-captions have been teken, alternatives have been proposed, or ex-isting methods and/or procedures are, in our opinion, adequate to meet the intent cf NUREG 0737 as these items are applicable, partially applicable, or unapplicable to It:. St. Vrain.
You will note from the attachment that we have responded to each item, and with few exceptions our responses were submitted within the schedules set forth by the requesting documents. We were re-cently informed that the entire review of our responses as well as an overall evaluation of applicability of NUREG 0737 to gas cooled reactor technology has been contracted by the NRC to Oak Ridge National Laboratory.
The key to the Order is the interpretation of the words "as appro-priate to the licensee's facility" and the. issue at hand,and the intent of our clarification is to provide further information with regard to that. wording, and to point out that we obviously e=nnat implement some of the items which are subject to further action and/or resolution on the part of the NRC.
V Very truly yours,
$ WW Don W. Warambourg Manager Nuclear Production DW/skd Attachment cc: George Kuzmycz Jim Miller I
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Page 2 Impl/poe Men Title
$pplic ability Specifle seguiement Sube Dee Dates PSC Statue 88.3.2 shielJing AIJ.
(a) llave evallet.le design 1/1/01 Isla get response asiJ evaluet tene submitted Jetalle for vital eres vle p-79299 December 12, 1979 and F-79112 modifications.
December 27, 1979. rusther clarlficatten la r-404)S, December 20, 1990 ladicates cisc-19 C.stdelines een be met without fur-ther action.
(b) submit technisal I/Ilst devlettone to staff positions.
II.R.)
root-AcclJent ALL Submit description of 1/1/01 Initial resposee P-79299, P-79312 and Sampling devletloans from staff F-80028.
Folloie-up reopense F-80434 in-positions, dicates compilance by Jammary 1982.
II.R.4 Training to ALI.
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core Jamage (no documen-tot ion submittet requiseJ) 1he revloed p
- stem wee embalated via F-51002, Jesuesy 2, 1981 and le moie In (b) Implement training progree 4/1/88 effect.
(no documentetton sulmittal seguired).
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(a) Sul.mit test program (botle F/1/80 (rums)
Beelmise prevlJed by F-30028 beye Ft. St.
1enting of mult/rWR's).
10/3/80 (ause)
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av/sav's (b) submit quellfication prossem for FWR's bloch valve.
1/1/01 (rwus) ll.E.I.2 Aus FeeJ PWee (a) Sul.mit final deelen enJ 1/1/81 Altloingh not specifically designated as initiatlose Jocumentation on oefety being applicable to Pt. St. Vrain oier and Flow grade flou leiJlcotton inittet twelmation was forwarded via F-79299, December 12, 1979.
(t.) Sulait final Jesign and 1/1/51 Fiss tlier clarlfication prowlJed by F-804)S.
Jacumcantation on enfely laJlcates enleting inetsiementation meets gr.Je flow Inttletion.
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l Attaciument P-Sl2tl page 5 Impt/poe l
Iten Title gplicability Sn.ectile Requirement Sube Thea Dates PSC Statue l
II.E.).18 ADS Ingic EWE Subelt report of fematbility 4/3/81 Isot opplicable to Fort St. Vrain.
HuJifications of ADS system logic cleanges to eliminate need for manuel actuntloo.
II.E.1.28 CSS /t.pCI Restest BWR Sulait report of evaluation, 1/1/81 Ile* applicable to Fort St. Vrelm.
proposed modificatluna amJ analyele to setlefy staff posittene.
II.E.1.22 NCic Suetion BWR w/ACIC Implement proceJures a.iJ 1/1/88 Ilot applicable to Fort St. Vrain.
Jocument verificatloa of title cliange.
18.l.1.27 Commmuu Deference for BWR Implesment cl.ange and outelt aft /81
. Ilot applicable to Fort St. Vrale.
It O I4 vel lastrumente Jocumentat less of cleanges.
II.E.1.29 laulation condenaar SWa w/lce sut.elt evaluation of I.f'.
4/3/88 leut app!! cable to Fest St. Vrain.
Fes tusmance performance.
I I. E.1.10 Sp inca HettioJa AI t.
Submit outilas of progree 11/15/80 Ilst applicable to Fort St.. Vrain.
for moJet.
II.E.).44 Fuel Falluse SWR Sulett evaluettoen to verify 1/1/88 IInt applicable to Fort St. Vrain.
ne fuel failure.
81.5.1.4%
Hanual hepresour-SWE Submit evaluation on otlier 1/1/JB llot appitcable to Fort St. Vrata.
i S a at lose these ADS method for Jerressurisatloa.
Ill.p.).)
leproved luplant AIL Have available means to l/3/81 Inittet response prov8Jed by F-29)l2 anJ loJine Honitoring accurately measure alsborne p-80020. Interim procederse were estab-nadioloJine luplant Juring liehed. F-SO418 Indicated the new Radio-an acclJent.
cbee I.ab would be available ty March 15, 1988. the Radle-ches I.ab le now oper-attonal. AJJitional smetrumentation le on order with an espected delivery date of October - Isovember,1988.
188.11.1.4 Contsul Room Habitability All (a) Submit control room 1/1/81 peepense siebsitted via F-80418, leecember 12, 3
liabitability evaluation 1980 indicates malottes conditions are In f os mat ions.
aJeesuat e.
Ilo furtleer actium is antici-t patad.
[
4 (b) Sulett modificatlose 1/1/88 e
g necesenry so samure CR l
I lieteltability with e esteeJule for complettua, l
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__ '.k. fig 16805 WCR 19 1/2, Platteville, Colorado 80651-9298 October 22, 1981 Fort St. Vrain Unit #1 P-81263 Mr. S. J. Ball Instrumentation and Controls Division Oak Ridge National Laboratory P. O. Box Y Oak Ridge, Tennessee 37830
SUBJECT:
Fort St. Vrain Unit No. 1 ORNL Report NUREG 0737
Dear Mr. Ball:
We have received your September 30,
- 1981, report concerning applicability of the TMI action plan requirements to Fort St.
Vrain.
In general, the report is well written and reflects, for the most part, the results of our meetings with you and your staff.
We do, however, have several comments that we believe are necessary to clarify some apparent misconceptions and to clarify some of the conclusions and recommendations.
Our comments are contained in the attachments to this letter and are keyed to the action items listed in Table I and Attachments 1 and 2 of your September 30,
- 1981, report.
We would request that these comments be considered in the finalization of your report.
We note in your October 15, 1981, letter that you plan to meet with NRR in the near future.
We believe that a joint meeting between PSC,
issues at hand.
Very truly yours, i
h ?Y 7bt.ed l
' Don W. Warembourg l
Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/alk
2-l cc:
R. Tedesco, Division of Licensing NRR James R. Miller, NRR George Kuzmycz, NRR R. Ireland, NRR Bill Dickerson, I & E 4
O e
w,.
i Page 11 ATTACHMENT 1 P-81263 III.D.1.1 Integrity of Systems Outside Containment We have no specific comment.
III.D.3.3 Improved Iodine Instrumentation Apparently some further clarification of this item is necessary.
Based on other documents (NUREG's 0654 and 0696) the capability of the portable iodine monitor is stated as 10E-8 microcuries per cubic centimater. The shielding required for the monitor to get 10E-8 microcuries per cubic centimeter almost negates the term " portable", and it was in this light that we stated an
" acceptable portsble" monitor is not available.
As an alternative, however, we agreed to obtain additional portable air samplers capable of accommodating a silver zeolite cartridge. We would then count that cartridge utilzing the fixed multi-channel analyzer in our radiochemistry facility.
In our letter P-80430 we stated that our new radiochemistry (low background) facility which is located outside of the plant itself would be complete by March 15, 1981.
This facility is complete and is fully operational. We also have two (2) cart mounted iodine monitors (Eberline Ping 1A) with a dedicated single channel analyzer, for monitoring inside the reactor building in addition to the capability of monitoring iodine with air samplers using silver zeolite cartridges and using the multi-channel analyzer.
In our opinion this more than adequately meets the intent of item III.D.3.3, and in fact because our air samplers are more portable, we have more flexibility in sampling various areas than a heavily shielded so called portable iodine monitor indicated in NUREG 0737.
We agree with your statement that NUREG 0737 is not clear as to the requirement for the portable iodine monitor, and we believe the requirement was intended to be limited to Liconsecs that had not yet loaded fuel but were applicants for fuel loading prior to January 1,1981.
Regardless of the clarification, however, we believe we are in full compliance with Item III.D.3.3 with the methods described above.
III.D.3.4 Control Room Habitability Requirements We have no specific comment.
7 Wgl0 OAK RIDGE NATIONAL LABORATORY OPERATED SV UNION CAR 8lDE CORPORATION NUCLEAR DIVIS10ll POST OFFICE sox Y oAE Rf DcE, TENNES$EE 37830 September 30, 1981 Mr. Darrel G. Eisenhut, Director Division of Licensing, ONRR U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Eisenhut:
Subject:
Applicability of NUREG-0737 to the Fort St. Vrain Reactor (B0762)
The enclosed report covers our work to date on the applicability of the
'IMI action plan requirements, as specified in NUREG-0737, to the Fort St. Vrain (FSV) HTGR.
The report addresses each of the action items in NUREG-0737. Our evaluations took account of the fact that even though action items may have been written to apply to specific LWR hardware or procedures and could not apply directly
}
to an HTGR, the intent of the requirement must still be honored. Where applicable, the unique HTGR design and safety features were factored into our evaluations.
Most of the writeups on individual action items were submitted previously to NRC as enclosures to our five monthly reports (May-Sept. 1981). Our intention was to rewrite thess as appropriate upon receipt of feedback from NRC and the FSV utility, Public Service Co. of Colorado (PSC). Extensive discussions were held with PSC on many of the items (as noted in the repcrt); however (verbal) feedback on only one item has been received to date from NRC.
As noted in our proposal, we had committed to submitting a review of the FSV emergency plans and facilities by Dec. 31, 1981. While much of that review is included here, a more complete report will be submitted on that subject later.
Other action plan evaluations will be revised and resubmitted cs we receive more feedback from NRC and PSC.
Our proposal also had committed us to submitting a preliminary planning report on the development of a program for generating a document comparable to NUREG-0660 for HTGRs. Due to both a lack of suitable personpower and a lack of sufficient
~
information on specific NRC nc.eds for this document, we now plan to submit the planning report in the first quarter of FY 1982. This slip in schedule was approved by the program's NRC technical monitor.
1 y
m
e If you have any questions or comrsents on the report, please let me know.
Yours truly, S.
. Ball Instrumentation and Controls Division Attachment cc:
R. Tedesco, Division of Licensing, NRR J. L. Anderson B. L. Crenier, NRR N. E. Clapp James R. Miller, NRR J. C. Conklin G. Kuzmycz, NRR R. M. Davis R. Ireland, NRR A. M. Fullerton '
R. Foulds, RSR R. M. Harrington M. H. Holmes, PSC P. R. Kasten D. M. Warembourg, PSC F. C. Kornegay Bill Dickerson, NRC/FSV A. L. Lotts J. P. Sanders J. H. Sorensen 9
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Technical Letter Report on the APPLICABILITY OF THE TMI ACTION PLAN REQUIREMENTS:
TO THE FORT ST. VRAIN HTGR S. J. Ball, Program Manager (FTS 624-0415)
Contributors:
S. J. Ball J. C. Conklin A. M. Fullerton R. M. Harrington F. C. Kornegay J. H. Sorensen Prepared by the Oak Ridge National Laboratory for the U.S.
Nuclear Regulatory Commission (FIN No. B0762)
September 30, 1981 O
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DRAFT J. C. Conklin 9/28/81 III.D.3.4 Control-Room Habitability Requirements This action item is entirely appropriate for FSV. The control room must be habitable for essential personnel under site and off-site acccident conditions.
Fort St. Vrain is similiar to all other reactors is this aspect.
PSC has responded (P-80438) to this action item and claims that although they disagree with a few specific figures of the guidelines, they meet the intent of all the listed regulatory guides. For this particular action item, Fort St. Vrain has no unique characteristics and should be treated as any other nuclear reactor in the licensing process. ORNL proposes no further work.
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NUCLEAR REGULATORY COMMISSION
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MAR 241982
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-h2Ob Docket No. 50-267 ge d 3-SD-82 Mr. Don Warembourg Neclear Production Manager Public Service Company of Colorado 16805 WCR 191/2 Platteville, Colorado 80651-9298
Dear Mr. Warembourg:
As you know, our review of NUREG-0737 items as they apply to your facility has progressed quite well, with a majority of the items either resolved or near resolution. Enclosure 1 presents the itemized resolution of NUREG-0737 and lists what remains to be completed. Enclosure 2 presents the same information but in tabular, sumary fom.
If you are ready to close out any item as stipulated in Enclosure 1, please let us know so that we may schedule the appropriate review for resolution.
Sincerely, c
Robert A. Clark, Chief Operating Reactors Branch f3 Division of Licensing Enclosure.:
As stated cc: See next page eIn e'
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cc list
,,e C. K. Millen Senior Vice President Public Service Company af Colorado
", c. Box 840
',ver, Colorado 80201 James B. Graham, Manager Licensing and Regulation East Coast Office General Atomic Company
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2021 K Street, N.W.
Suite 709 Washington, D. C.
20006 Mr. J. K. Fuller Vice President Public Service Company of Colorado P. O. Box 840 i
Denver, Colorado 80201 Mr. W. Dickerson NRC Resident Inspector 16805 Weld County Road 191/2 Platteville, Colorado 80651 Director, Division of Planning Department of Local Affairs 615 Columbine Building 1845 Sherman Street Denver, Colorado 80203 Chaiman, Board of County Commissioners l
Greeley, Colorado 80631 Regional Representative, Radiation Programs Environmental Protection Agency 1860 Lincoln Street Denver, Colorado 80203 Mr. Don Warembourg Nuclear Production Manager i
E Public Service Company of Colorado 16805 Weld County Road 191/2 Platteville, Colorado 80651 Regional Administrator Nuclear Regulatory Comission, Region IV Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 l
Arlington, Texas 76011 i
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Ene10:uro 2 TABLE 1.
SUttiARY CF NUREC-0737 ACTION ITFM REVIEWS
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l Item No.
Brief Title Apply to FSV Status 1.A.1.1 Shift Tech. Advisor yes Closed. STA on one-hour c'all.
I 1.A.I.3 Shift Hanning yes Overtiste leeue closed; shif t constituency being reviewed by Division of Ilumen Fact ors.
I.A.2.1 Training Upgrades yes Closed. Sissulator training reviewing separately; col-lege level equiv. training fo.r ehlft personnel waived.
I I.A.2.3 Training Programs yes Closed. In compilence.
i 1.A.3.1 Simulator Exains yes To be reviewed by Division of Human Factors.
I 1.B.1.2 Safety Engr. Group no Closed.
I.C.1 Accident Procedures yes Emergency Procedures under review by ORNL.
I 1.C.5 Feedback of Experience yes Closed. In compliance.
1.C.6 Verify Operations yes IEE, R IV will review.
1.D.1 control Room Design yes Closed.
i I.D.2 Safety Param. Display yes PSC reviewing ORNL recomunendations.
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II.B.1 Coolant Syst. Vente no Closed.
l 11.8.2 Postaccident Shielding yes ORNL is reviewing source term calculatione; will compare Il.B.3 Postaccident Sampling yes.J II.B.4 Trng. for Core Damage yes PSC reviewing ORNL recosamendations.
II.D.1 Test Relief Valves yes Closed; PSC will follow EPRI recosumendatione as applicable.
II.D.3 Valve Pos. Indication no Closed.
I I. E.1'.1 Aux. Feedwater Eval.
yes Closed.
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7 Tchie 1 Cont'd.
Item No.
Brief Title Apply to FSV Statra II.E.1.2 Aux. FW Indicators no Closed.
II.E.3.1 Press. lienter Power co Closed.
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II.E.4.1 liydrogen Penetration no Closed.
II.E.4.2 containment Isol.
yes closed.
II.F.1 Noble Gas Honitor yes II.F.1.1 and II.F.1.3.
ORNL will determine upper limits for FSV.
II.F.2 Detect Inadequate Cooling yes Closed; PRC is in compliance..
II.C.1 Pressurizer Power no Closed.
1 I1.K.2 B&W orders no Closed.
1 II.K.3.x B&O Task Force no Closed.
II.K.3.17 ECCS outages yes PSC will monitor outages but will develop trend analysis at a later date.
-l 1 1I.K.3.18 Auto. Depressurization no Closel.
II.K.3.30 Small-break LOCA no Closed.
II.K.3.31 10 CFR 50.46 no closed.
III.A.2 F5ergency Preparedness yes Most aspects incorporated.
i III.D.1.1 llot System Integrity yes closed; PSC in compliance.
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III.D.3.3 Iodine Instruments yes Closed; PSC in compliance.
III.D.3.4 Control Rs. liabitable yes PSC response needs llumen Factor Engineering review;
_f most aspects incorporated.
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UNITED STATES -
NUCLEAR REGULATORY COMMISSION g
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DEC 2 31981 Oocket No. 50-267
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LICENSEE: Public Service Company of Colorado
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FACILITY:
Ft. St. Vrain i
SUEJECT:
SLW.ARY OF IEETING HELD ON DECEMBER 3,1981.
On December 3, 19S1 a cesting was held at the site of the Fort St. Vrain reactor amosg representatives of Public Service Co=pany o'f Colorado and the Nuclear Regulatory Co==ission. The object of the meeting was to discuss the results of an Oak Ridge National Laboratory report on the applicability of NUREC-0737 requirements to Fort St. Vrain. The list of attendees is included as Enclosure 1.
The folleving is an ite=ized listing of the requirements of FUREG-0737 and their resolution as discussed at the meeting.
I.A.1.1 Shift Technical Advisor.
PSC has a trcining program for STAS that includes the major equip-cent of plant systems. Also implementing porcedures are in place governing STA presence in the plant and contingencies. I=plementation of technical specifications as per PSC co=ments (P-81263) is acceptable.
Use of accident simulation codes by STA in analyzing plant transients and postulated accidents is acceptable. The PSC proposal for keeping the STA position (long tern) and upgrading SR0s, but using college level expertise as nonshift assisrance is acceptable.
I.A.1.3 Shift Panning.
As per previous I&E RIV SER, the 16 consecutive day cycle for operators i
is acceptable. Table B.1.will be addressed in the January re-
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view by Emereeney Plannine Licensine Branch. PSC will eenerate a new Table B.1 that will be applicable for FSV with appropriate times and supporting studies. A specific request vill be made by PSC to have the H.P. technician cover rvo functions.
i I.A.2.3 Administration of training i
PSC is in compliance.
I.A.3.1 Sinulatore Exams.
Paul Collins vill hold a meetine with PSC to resolve this issue.
Simulators have been shown to be useful in L*n'R trainine for operator respcases siong with the tracking of an event. FSV does not recuire quick responses for the health and safety of the public but for pro-tecticn of plant equip =ent.
PSC provides training in accident analyses ar.d behavior durin: transients and vill, in the future, provide more hends-en experience and accident siculation codes.
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-3 I.C 1 Accident and Procedures Review.
PSC issued a cet of Emergency Procedures on November 16, 1981. These procedures will'be reviewed to determine their completeness and com-prehensiveness to the plant operators.
I.C.5 Feedback of Operating Experience.
As per SER written by I&E, R IV, PSC is in compliance.
I.C 6 Verify Correct Performance of Operatin' Activities.
g I&E, R IV will continue their dialog with PSC. Systems necessary for safe shutdown will need independent verification. In FSV, some systems needed for safe shutdown are also used during nor=al operation; their operability can be demonstrated by proper normal operation. PSC agrees and will provide input to Region IV.
I.D.2 Plant Safe'ty Parameter Display Console.
PSC is reviewing the recommendation made by ORNL and will continue their dialog for proper resolution.
II.B.2 and 11.3.3 Plant Shiedling and Postaccident Sampling.
ORNL will review the source tarm calculations and co= pare the FSAR values with those resulting from the GA fuel model. The two scurce term calculations are only for comparison purposes.
II.E.4 Training for Mitigating Core Damage.
ORNL rececaended several items that might be useful for severe accident mitigation and control at FSV. PSC will review the items and possibly include them in a training manual and for management decisions along with a decision tree to evaluate the asscciated risxs.
II.D.1 and II.D.3 Relief and. Safety-valve Test Requirements. Valve Position Indication.
PSC will rely upon the EPRI qualification testing program reccc=endations as they may apply to FSV.
II.E.1.1 and II.E.1.2 Auxiliary Feedwater Systems Evaluation. Auxiliary Feedwater System Initiation and Flow.
These two items are not applicable to Fort St. Vrain.
II.E.4.2 Containment Isolation Dependability.
PSC is in compliance.
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Accident'onitoring.
II.F.1 M
5 ~MC/cc and 108 rad /hr cannot be met with exist-The upper limits of 10 ing instrumentation. ORNL will determine the upper limits for monitoring of noble gas effluent activity and reactor building radiation level appropriate for FSV. These upper limit values for instrumentation should be based on the physical properties of the reactor and not on the fact that high level radiation monitors are commercially available.
II.F. 2 Instrumentation for Dettetion of Inadequate Core Cooling.
PSC'is in compliance.
II.K.3.17 ECCS System Outages.
PSC will determine what systems or parts thereof constitute the ECCS for FSV and will continue to monitor ECCS outages. PSC develop a trend ana' lysis system et a later date.
I1.7. 3.18 ADS Actuation. Not Applicable.
II.K.3.30..S3 LOCA Methods. Not Applicable.
II.K.3.31 Compliance with 10. CFR.50.46. Not Applicable.
II.D.l.1 Primary Coolant Outside Containment.
PSC. Es in qompliance II.D.3.3 Inplant Radiation Monitoring.
PSC.is in cc:plianca.
l III.D.3.4 Control Room Habitability.
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PSC response wilt be evaluated from a human factors viewpoint.
Most other aspects have been incorporated by PSC.
III.A.2 Early Warnine Alert System.
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. Exemption from the 15 minute public notification has been denied.
This tras a eeneral action and was published in the Federal Recister Vol. 46, #182, September 21, 1981 pace 46587. PSc will evalusta the option of for=al rppeal.
I.A.2 1 We reco==end that, because of the unique safety characteristics of the HTCR which allow more time for corrective actions to be taken in an accident and thus allow college trained STA to be on callrather than on shift, the requirements for college level equivalent training for shift personnel be wa* ed.
M Georg,,eKu==vez,,NojectManaser Operating Reactors Branch 93 Division of Licensing
Enclosures:
- 1. List of Attendees cc: See next page
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ENCLOSURE 1 MEETING ATTENDEES ~
NRC T.. M. Novak, AD/OR/DL R. A. Clark ORBf3/DL G. Kuzmycz. ORB!3/DL i
D. M. Rohrer, IE/DEP/EPLB T. F.* Westerman, IE/R IV M. W. Dickerson, Sr. Resident inspector G. L. Plumlee, Resident Inspector ORNL S. J. Ball R. M. Harrington
?EEC.
Don Warenbourg, Mgr - Nuclear Production Ed Hill FSV Station Manager
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H. L. Brey, Mgr -
Nuclear Engineering J. R. Reesy, Mgr -
Nuclear Design L. M. McBride, Mgr - Tech / Admin. Services Ted Borst, Mgr -
Radiation Protection W. Franek, Mgr -
Nuclear Site Engineering M. H. Holmes Nuclear Engineering C. Fuller Tech. Services Engineering J. M. Sills Ms E. Niehoff Nuclear Projects m.
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Ft. St. Vrain cc list C. K. Millen
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Senior Vice President Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201 James B'. Graham, Manager Licensing and Regulation East Coast Office General Atomic Company 2021 K Street, N.W.
Suite 709 Washington, D. C.
20006 Mr. J. K. Fuller, Vice President Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201 Mr. W. Dicke
'n NRC Res'
.,raetor 16805 P ad 19 1/2 Pl attev ^.
a 80651
' Director, D1 vision of Planning
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Department of Local Affairs 615 Columbine Building 1845 Sherman Street Denver, Colorado 80203 Chairman, 3 card of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative, Radiation Programt Environnental Protection Agency 1860 Lincoln. Street Denver, Colorado 80203 Mr. Don Warembourg Nuclear Production Manager Public Service Company of Colorado 16805 Weld County Road 191/2 Platteyille, Colorado 80651
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MEETING
SUMMARY
DISTRIBUTION i
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i Licensee: Public. Service Company of Co'icrado
- Copies also sent to those people on service (cc) list for subject plant (s).
t Docket File NRC PDR L PDR NSIC TERA OR8f3 Rdg 001shinski JHeltemes, AE0D BGrimes RClark Project Manager Licensing Assistant ACRS (10)
Mtg Sum: nary Dist.
NRC Participants e.
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p'.foile 5erviee. Company F CoHomde
!Id.J 16805 WCR 19 1/2, Platteville, Colorado 80651 J.
July 30, 1982 Fert St. Vrain Unit #1 P-82288 Mr John T. Collins, Regional Administrator U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76012
SUBJECT:
Fort St. Vrain Unit No. 1 NUREG 0737 Status Daar Mr. Collins:
As discussed in a recent meeting with Mr. Tom Westerman of your staff, we were requested to provide an updated status of the NUREG 0737 items.
I have attempted to provide a brief summary of the status of each item in the attachment to this letter.
Hopefully, this table will fulfill your needs.
The comments are
- brief, and -should you require additional information, please let me know.
Very truly yours, Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/skr Attachments
- r Item Title Status II.K.3.31 10 CFR 50.46
- Not applicable to FSV.
III.A.1.1
- Complete.
Short Term III.A.1.2 Upgrade EOF's Interim TSC, OSC, & EOF Complete.
PSC is proceeding with plans as outlined in
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P-81178, June 30, 1982, for the various EOF's required by NUREG 0696.
PSC has not, however, received any response to P-81178.
III.A.2 Emergency Preparedness Class A model complete and utilized in last emergency exercise.
Meteorolugical Towers
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(60 meter and 10 meter) complete but tie into Control is not yet complete.
Anticipate completion by October 1, 1982.
Prompt notification system installed.
No action on Class B model.
NRC telephone access to meteorological data is not installed pending NRC guidance.
III.D.1.1 Primary Coolant Outside
" Complete.
Containment III.D.3.3 In Plant Radiation Monitoring
- Complete.
III.O.3.4 Control Room Habitability
- PSC has responded and considers response to be satisfactory. NRC still has'this item under review.
See NRC Letter March 24, 1982, Clark to Warembourg.
See NRC Letter December 23, 1981, Summary of Meeting December 3,1981.
Short Term Items, See NRC Letter March 20, 1980.
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