ML20071Q684

Forwards Proposed Revisions to Tech Specs Re Organization, Review & audit-administrative Controls.Clarifications of Submittals,Ltrs & Discussions Provided

ML20071Q684
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/13/1982
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20071Q688	List: ML20071Q684 ML20071Q695
References
P-82546, NUDOCS 8212290403
Download: ML20071Q684 (4)

Text

, .

Public Servlee Company FCdondo 8 -

16805 Road 19 1/2, Platteville, Colorado 80651-9298 December 13, 1982 Fort St. Vrain Unit No. 1 P-82546 U. S. Nuclear Regulatory Commission ATTN: Mr. Philip C. Wagner Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

References:

(1) G-82328, Note from Wagner to Warembourg, dated 10-28-82 *

(2) P-82391, Technical Specifi-cation submittal, dated 9-14-82.

(3) P-82112, Technical Specifi-cation submittal, dated 4-20-82 (4) G-82178, Generic Letter 82-12 (5) G-82357, Letter from Diggs to Lee, dated 11-17-82

Dear Mr. Wagner:

Attached for your reivew and comments are proposed revisions to Section 7.1 of the Fort St. Vrain Technical Specifications. Per our previous discussions, these proposed revisions incorporate the formal Technical Specification change submittals that have recently been made and the additions you suggested in your note to me dated October 28, 1982.

Since the attachment to this letter is a composite of many  ;

submittals, letters, and discussions, the following clarifications  !

are provided. '

1. The page numbering for Section 7.1 was changed to accomodate the  ;

proposed revisions. i 8212290403 021213 PDR ADOCK 05000267 i

P PDR a

Mr. Philip Wagner 2. In Section 7.1.1 (2) UNIT STAFF, a new statement has been added

.to cross reference this section to the new Table 7.1-1 concerning

he minimum shift crew composition. This statement was added in

-response to the recommendation you made via your note to me of October 28, 1982 (G-82328).

3. Section 7.1.1 (2)(1) is a new section that was added to address staff working hour guidelines. The text in this section is identical to that previously made in our formal submittal dned September 14, 1982 (P-82391).

4. Section 7.1.1 (3)(c) is a new section that was added to address the qualification and training. requirements for the Technical Advisors. The text in this section is identical to that made in our formal submittal dated April 20, 1982 (P-82112). In your note dated October 28, 1982, you indicated that this change was acceptable, and would be included with other changes.

5. Section 7.1.2 (1) MEMBERSHIP is a revised section to reflect job title changes in the plant organization which affect PORC membership. The text in this section is identical to that previously made in our formal submittal dated September 14, 1982 (P-82391).

6. Section 7.1.3 (2) MEMBERSHIP is a revised section to reflect job title changes which affect the N?SC membership. The text in this section is identical to that previously made in our formal submittal dated September 14, 1982 (P-82391).

7. A new Table 7.1-1 has been added to address the minimum shift I crew composition, as recommended in your note to me dated October 28, 1982 (G-82328). Note that we have used applicability modes that are more appropriate for' Fort St. Vrain operation than the temperature criteria suggested in your note. Refer to the discussion that follows.

8. Figure 7.1-2 has been revised to reflect the job title changes addressed in item 5 above. This figure is identical to that previously made in our submittal dated September 14, 1982 (P-82391).

Of the eight items listed above, the only one of consequence which you have not previously seen is the new Table 7.1-1. The criteria which we have used to determine applicability " modes" for Fort St.

Vrain are based on the definitions that are presently in the Technical Specifications for Hot Shutdown, Cold Shutdown, and Refueling Shttdown conditions. Clearly, the modes used by PWR's and BWR's (Modes 1 through 6) are not appropriate for Fort St. Vrain since they are not defined for an HTGR. Additionally, establishing a temperature criteira to defihe the staff manning requirements is not appropriate; for example, the Technical Specifications define a Cold

q Mr. Philip Wagner i Shutdown as having sufficient reactivity inserted to assure that a shutdown margin of at least 0.01 Ap would be achieved if the core temperature were 80 F, but that the actual core temperature is any

. temperature greater than or equal to-80 F. _It is not unusual for the actual coolant temperature to be well above 220 F and for the. reactor to be in a Cold Shutdown condition. Therefore, if the temperature criteria were used, we would be required to supplement our operational staff even though the reactor was in a Cold Shutdown condition.

A review of the various possible combinations of the Reactor Mode Switch ("Off,'"' Fuel Loading," and "Run" positions) and the Interlock Sequence Switch ("Startup,"" Low Power," and " Power" positions) has shown that these switch -positions, alone,- are not sufficient to satisfy the intent of the proposed 10CFR50.54 change.

?

j It is our position that the best criteria for the staff manning i requirements should be keyed to the shutdown conditions currently defined in the Technical Specifications. This approach removes the 1 ambiguity associated with a temperature criteria, and guarantees a specific reactor " mode" in combination with a minimum required shutdown margin. We request that you give this approach careful <

l consideration for the proposed revision to 10CFR50.54 in general, and j Fort St. Vrain in particular.

Due to the number of changes that have been submitted and/or l requested to Section 7.1 in the recent past, it is apparent that a L methodical approach should be taken with regards to license

, amendments concerning these subjects. I suggest that the NRC and PSC l concentrate their efforts on reviewing the composite attachment to j this letter and withhold all licensing actions on previous submittals j to Section 7.1. Subsequent to this review, I will obtain the plant

and corporate approvals necessary for a formal Technical l Specification change submittal.

l A fee of 51,200 was deemed to be necessary for our previous submittal  !

j of September 14, 1982. A voucher for this amount has been obtained

, in response to a letter from the License Fee Management Branch

! (G-82357). However, since the fees associated with the changes to Section 7.1 in its entirety have not been established, I am ,

j withholding the 51,200 payment until a final determination of the fee i is made. The appropriate fee will then accompany our formal i

composite submittal.

I Please be aware that consistent with our NUREG-0737 commitments, the

changes proposed by the attached Technical Specification are being

(

administratively enforced at the present time. The Technical i Specification, then, is merely a means of formalizing these commitments. In this respect, any delays experienced in finalizing

the Technical Specification have no safety implications as far as i

plant operations or emergency response is concerned.

l 2

Mr. Philip Wagner If you have any questions, please give me a call on (303) 785-2223, extension 200.

Very truly yours, j

,b- JYnAcw(

Don Warembourg Manager, Nuclear Production DW/cls Attachment l

l l

l I