ML20099H636

Forwards Summary of Proposed Tech Spec Upgrade Program & Guidelines for Utilization of STS for Upgrade Program,Per NRC

ML20099H636
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/16/1984
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-84498, NUDOCS 8411280225
Download: ML20099H636 (5)

Text

7 PUBLIC SERVICE COMPANY OF COLORADO P.

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BOX 840 DENVER, COLORADO 80203 OSCAR R. LEE November 16, 1984 va 'm'=

Fort St. Vrain Unit No. 1 P-84498

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Regional Administration l

Region IV U.S. Nuclear Regulatory Commission s

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L Attn: Mr. Eric Johnson DOCKET N0.: 50-267

SUBJECT:

Technical Specification Upgrade Program

REFERENCE:

(1) MC Letter from H. R. Denton to R. F. Walker dated October 16, 1984 (G-84392)

Dear Mr. Johnson:

In response to the NRC's concerns expressed in Reference (1) regarding the need to upgrade the Fort St.

Vrain Technical Specifications, PSC has formulated a brief summary of a proposed Tschnical Specification Upgrade Program which is included herein as.

By way of clarifying and defining the scope of the proposed Technical Specification Upgrade Program, PSC has also prepared Attachment 2 to illustrate the extent to which the Standard Technical Specifications for light water reactors would be taken into consideration during the Technical Specification Upgrade Program.

Both Attachment 1 and Attachment 2 were discussed with Messrs. Wagner and Ireland of the NRC by Messrs. Brey and Holmes of PSC during a telephone conversation on November 16, 1984.

At the request of Mr. Wagner, these summary Technical Specification Upgrade Program scoping documents are being submitted for your review.

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P-84498 Page 2 We believe the Technical Specification Upgrade Program described in Attachment I will be fully responsive to the NRC's concerns stated in Reference (1).

PSC representatives will be prepared to discuss any questions or comments you may have concerning the Technical Specification Upgrade Program at the meeting scheduled for November 28-29, 1984 at Fort St. Vrain.

If you should have any questions in the interim, please contact Mr. M.H. Holmes at (303) 571-8404.

Very truly yours, hA

0. R. Lee. Vice President Electric Production ORL/MHH:bb Attachments l

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. to P-84498 Scope of the Technical Specification Upgrade Program PSC will revise the Fort St. Vrain Technical Specifications,according to the following comitments:

1.

LC0's will be revised to identify the applicable operating modes, limiting condition and action statements defining remedial actions to be taken if the limiting condition is exceeded.

2.

All applicable operating modes will be clearly identified for each LC0.

3.

Limiting conditions and action statements will agree with FSAR accident and safety analyses.

l 4.

LC0's will cross reference the applicable SR and SR's will cross reference the applicable LCO. All LC0's will have associated with them one or more SR's and all SR's will have associated with them one or more LCO's.

5.

Surveillances will be specified as necessary and sufficient to verify compliance with the associated LC0(s).

6.

SR's will describe the associated acceptance criteria.

7.

Technical Specification statements will be unambiguous with a singular interpretation.

8.

Terminology used in the Technical Specifications will be clearly defined.

9.

Technical Specifications will be simplified if possible.

10. LC0 format will be revised to include the LC0 number and statement, LC0 statement, action statement (plicabilityand cross reference to the associated SR(s).

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11. Technical Specifications will be reviewed and expanded as necessary to assure accuracy, completeness and consistency with existing design and safety analysis documentation.

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12. The Technical Specifications will account for and utilize existing plant equipment and safety systems.

13. The initial draft of the upgraded Technical Specifications will be submitted to the NRC by April 1,1985.

14. A schedule for the Technical Specification Upgrade Program will be submitted to the NRC for information by December 14, 1984.

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Attachm:nt 2 to P-84498 Guidelines for the Utilization of the Standard Technical Specifications for the Fort St. Vrain Technical Specification Upgrade Program.

INTRODUCTION The Fort St. Vrain Technical Specification Upgrade Program is primarily intended to upgrade the accuracy, completeness and clarity of the existing Fort St. Vrain Technical Specifications, consistent with the licensing basis of the Fort St. Vrain plant as embodied in the FSAR. Standard Technical Specifications for light water reactors will be considered during the Fort St. Vrain Technical Specification Upgrade Program as indicated by these guidelines.

Consideration of the Standard Technical Specifications during the Technical Specification Upgrade Program is not intended to be a requirement whose utilization or non-utilization must be substantiated or justified.

If instances arise whereby Fort St. Vrain's design features and Technical Specification requirements may represent a possible safety concern relative to Standard Technical Specification requirements, these instances will be addressed as separate licensing issues outside of the scope of the Fort St. Vrain Technical Specification Upgrade Program.

GUIDELINES 1.

Plant modifications and backfits would not be undertaken to permit the adoption of any Standard Technical Specification requirement.

2.

It is outside the scope of the Fort St. Vrain Technical Specification Upgrade Program to utilize or consider any Standard Technical Specification requirement which opens the licensing basis of the Fort St. Vrain plant for further justification or analysis.

3.

Significant research and development efforts or analytical investigations would not be undertaken to determine how to

utilize, or whether or not a Standard Technical Specification requirement can be utilized at Fort St.

Vrain.

Questionable Standard Technical Specifications requiring such efforts and iavestigations would not be utilized or given further consideration.

4.

The numbering system of the Standard Technical Specifications and the Standard Technical Specification format, whereby each LCO is juxtaposed to its associated SR, would not be utilized for the Fort St. Vrain Technical Specification Upgrade Program.

5.

The Fort St. Vrain Technical Specification Upgrade Program will adopt relevant Standard Technical Specification definitions where the definitions are cor.sistent with existing plant features and the licensing basis of the Fort St. Vrain plant, i.e. FSAR terminology and analyses.

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The-Fort St. Vrain Technical Specification Upgrade Program will adopt relevant Standard Technical Specification requirements, including limiting conditions for operation, surveillance requirements, and surveillance frequencies, which are consistent with existing plant features and the licensing basis of the Fort St. Vrain plant as embodied in the FSAR.

-7.

Each Fort St. Vrain Upgraded Technical Specification requirement need only be supported and justified relative to the licensing basis of the Fort St. Vrain plant as embodied in the FSAR, and justification would not be required regarding the Standard Technical Specification treatment of the same or similar requirements for light water reactor plants, i

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