Letter Sequence Approval |
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Administration
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Results
Other: ML20076E880, ML20079M106, ML20080E109, ML20100G880, ML20100G888, ML20100H212, ML20112G667, ML20127J807, ML20135B301, ML20135D754, ML20137H372, ML20137S741, ML20141P181, ML20154K144, ML20197C598, ML20197G513, ML20205C845, ML20206B459, ML20207K470, ML20211P495, ML20215E408, ML20215G100, ML20235G758
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MONTHYEARML20076E8801983-05-17017 May 1983 Responds to NRC 830413 Order Re Environ Qualification of safety-related Electrical Equipment,Per 10CFR50.49.Environ Qualification Records Audit Will Be Completed by 831231 Project stage: Other ML20080E1091983-08-15015 August 1983 Provides Followup to Util Re Environ Qualification of safety-related Electrical Equipment. Justification for Continued Operation W/Components Not Fully Qualified Provided Project stage: Other ML20079M1061984-01-0909 January 1984 Advises NRC Re Status of Three Commitments Made in Util Concerning Environ Qualification of safety-related Electrical Equipment.Valve Actuators Tested & Successfully Passed HELB Tests Project stage: Other ML20087D5261984-03-0202 March 1984 Requests Exemption from Requirements of Sections Iii.G,J,L & O to 10CFR50,App R.Fire Protection Provisions Believed Adequate to Protect Health & Safety of Public in Event of Accidents Involving Fires.Affidavit Encl Project stage: Other ML20091E6671984-05-10010 May 1984 Forwards List of Correspondence on Fire Protection,Per 840427 Request.List Identifies Ltrs Originated from NRC & Util Relevant to Fire protection,10CFR50,App R,Branch Technical Position 9.5-1,cable Separation & Plant Issues Project stage: Other ML20091E4271984-05-11011 May 1984 Forwards Summary of Fire Protection Review to Determine Conformance of Facility to Section Iii.G of 10CFR50,App R, Per 840427 Commitment.Fire Protection Provisions Adequate Project stage: Other ML20092M5471984-06-22022 June 1984 Responds to 840608 Meeting Re Application of 10CFR50,App R Fire Protection Requirements to Facility.Schedule for App R Review & Submittal & Proposed Fire Protection Regulatory Guidance Resolving HTGR Issues Encl Project stage: Meeting PNO-IV-84-014, on 840623,reactor Tripped on High Pressure Signal & 6 of 7 Control Rod Pairs Failed to Drop.Cause Unknown.Drive Mechanisms Will Be Removed for Exam1984-06-25025 June 1984 PNO-IV-84-014:on 840623,reactor Tripped on High Pressure Signal & 6 of 7 Control Rod Pairs Failed to Drop.Cause Unknown.Drive Mechanisms Will Be Removed for Exam Project stage: Request ML19318H9481984-06-26026 June 1984 Summary of 840608 Meeting W/Util in Bethesda,Md Re Fire Protection Issues at Plant.List of Attendees & Meeting Agenda Encl Project stage: Meeting ML20090C5261984-07-0606 July 1984 Responds to NRC Concerns Re Fire Protection Review,Bldg 10 Licensing Requirements,Control Rod Failure to Scram, Documentation of Disciplinary Actions,Clearance Tags & Radiological Emergency Exercise Scenario,Per 840625 Meeting Project stage: Meeting ML20096C2671984-08-17017 August 1984 Forwards Revised Schedule for App R Review,Submittals,Plant Mods & Fire Protection Safe Reactor Shutdown/Cooldown Capability Incorporating NRC Concerns & Comments Project stage: Other ML20100G8881984-09-11011 September 1984 Four-Minute Isolation of Postulated Steam Line Breaks at Fort St Vrain Nuclear Generating Station Project stage: Other ML20101P4551984-12-14014 December 1984 Advises That Final Installation of Oil Mist Detection Sys Completed Wk of 841105,per 840625 Commitment.Sys Inoperable During Initial Checkout.Manufacturer Repaired & Balanced Entire Sys on 841115,however,on 841121 Sys Inoperable Again Project stage: Other ML20112G6671984-12-27027 December 1984 Informs of Efforts to Environmentally Qualify Certain post-accident Monitoring Equipment Per 10CFR50.49.Equipment Identified in Reg Guide 1.97 & Existing in Harsh Environ Will Be Qualified by 850331 Project stage: Other ML20101T6731985-01-25025 January 1985 Forwards Table 5.0.1,omitted from Rept 3 of App R Fire Protection Evaluation,Originally Submitted by Project stage: Other ML20108A2121985-02-0404 February 1985 Informs of Receipt of Generic Ltr 84-24 on 850121 & Request for Addl Info on Environ Qualification of Electrical Equipment on 850128.Responses to Both Ltrs Will Be Provided by 850328 Project stage: Request ML20100H2121985-03-25025 March 1985 Forwards Response to NRC 841227 Order Re Certification of Compliance w/10CFR50.49 (Generic Ltr 84-24).Util Previously Submitted Ltrs Re Environ Qualification of safety-related Equipment in Response to IE Bulletin 79-01B Project stage: Other ML20100G8801985-03-28028 March 1985 Forwards Addl Info Re Environ Qualification Program. Response to NRC 850128 Concerns & Summary of Completion Schedule for Outstanding Items Encl Project stage: Other ML20237L1731985-03-29029 March 1985 Notification of 850403 Meeting W/Util in Bethesda,Md to Discuss Equipment Qualification Project stage: Meeting ML20128Q5231985-05-15015 May 1985 Responds to Re Contradictory Statements Submitted in Three Util Ltrs.Circulator Speed Instruments Not Relied Upon in 10CFR50,App R,Re Fire Protection Evaluation Because of Close Proximity Between Loops Project stage: Other ML20128N3241985-05-17017 May 1985 Informs of Completion of Mod Work to Automate G&J Wall Sprinkler Sys,Per 840817 App R Commitment Project stage: Other ML20127J8071985-06-11011 June 1985 Maintains Util Position of Full Compliance w/10CFR50.49 in Response to Eh Johnson 850611 Inquiry Re Environ Qualifications of Electrical Equipment Important to Safety. Responses to Each Concern Presented in Encl Project stage: Other ML20237L1551985-06-25025 June 1985 Submits Daily Highlight.Notifies of 850702 Meeting W/Util in Bethesda,Md to Discuss State of Compliance of Plant W/ Equipment Qualification Rule 10CFR50.49 Project stage: Meeting ML20244D4841985-07-10010 July 1985 Provides Feedback on Current NRR Conclusions Re Facility Compliance W/Equipment Qualification Rule & Operator Action Needed to Terminate Design Basis Events.Summary of 850702 Meeting W/Util in Bethesda,Md Encl Project stage: Meeting ML20132B9171985-07-11011 July 1985 Discusses Resolution of Technical Issues of Aging & Operability Times Per 850702 Meeting Re Environ Qualification Program.Hold on Reactor Power to 15% Proposed as Initial Limitation Project stage: Meeting ML20132D4611985-07-11011 July 1985 Documents 850708 Telcon Re Interim Fire Protection Measures Committed to in or Lee .Fire Watch Frequency Increased.Personnel Will Carry Flashlights at All Times Per Operating Order 85-11,prior to Plant Startup Project stage: Other ML20133G2641985-07-16016 July 1985 Documents 850715 Telcon Re App R Fire Protection Evaluation Schedule.Util Will Complete Mod Item 4.2 Re Penetration Seals by 850717.Revised Completion Date Allows for Installation of Final Seal,Surveillance Testing & Sign Offs Project stage: Other ML20132E6081985-07-19019 July 1985 Supplemental Safety Evaluation Supporting Licensee CRD Mechanisms & Associated Position Instrumentation,Per 850712 Safety Evaluation & Licensee 850710 & 18 Submittals.Control Rod Program Acceptable for Plant Restart Project stage: Request ML20132F0721985-07-19019 July 1985 Safety Evaluation Documenting Deficiencies in Licensee Program for Environ Qualification of Electric Equipment Important to Safety.Licensee Response to Generic Ltr 84-24 Inadequate.However,Operation at 15% Power Authorized Project stage: Approval ML20132F0231985-07-19019 July 1985 Forwards Safety Evaluation Re Environ Qualification of Electric Equipment Important to Safety & Authorizes Interim Operation in dry-out Mode at Max 15% of Rated Power,Based on Listed Conditions,Until Technical Review Completed Project stage: Approval ML20133H5331985-08-0202 August 1985 Requests Assessment of Consequences of Loss of Shutdown Sys Due to Fire in Bldg 10,as Part of Review of Fire Protection Features at Plant.Evaluation Requested within 30 Days of Ltr Date Project stage: Approval ML20134E3931985-08-0505 August 1985 Submits Info on Status of Mods Proposed in 850401 Rept 4 Re Exemptions & Mods to App R Fire Protection Evaluation.Listed Mods Complete Project stage: Other ML20137G0891985-08-0808 August 1985 Notifies of Delay in Obtaining All Replacement Fire Door Matls,Per ,Due to Door to Hardware Compatibility Problems W/Facility Security Sys.Matls Will Be Delivered by 851015 Project stage: Other ML20134M0161985-08-20020 August 1985 Submits Discussion of Technical Issues Re Environ Qualification Program Raised During Meetings W/Nrc.Aging & Operability Time Program Operator Response Time,Temp Profiles & Shutdown Cooling Paths & Equipment Evaluated Project stage: Meeting ML20135D7541985-08-30030 August 1985 Advises That Rev of Emergency Procedures Committed to in Deferred to Coincide W/Final Environ Qualification Program Documentation.Procedure Revs at This Time Will Cause More Confusion than Clarity for Operators Project stage: Other ML20135B3011985-08-30030 August 1985 Forwards Justification to Operate Facility at Reduced Power Level.Requests That NRC Provide Concurrence for Facility to Be Operated at 8% Power Level for Period of Time Not to Exceed 45 Days.Operation Does Not Pose Undue Safety Risk Project stage: Other IR 05000267/19850211985-08-30030 August 1985 Insp Rept 50-267/85-21 on 850721-31.No Violation or Deviation Noted.Major Areas Inspected:Operational Safety Verification Project stage: Request ML20135B2831985-08-30030 August 1985 Provides Info to Resolve Questions & Concerns Identified in Review of Repts 1-4 for App R Evaluation & Rept 5 for Branch Technical Position 9.5-1,App a Evaluation of Bldg 10.Page Changes for Repts 1-5,incorporating Resolutions,Encl Project stage: Other ML20205D2651985-09-0303 September 1985 Informs of Fire Detection Sys Design Status.Initial Change Notice Providing Detection Device Design & Location Issued on 850901,per 850401 Commitment.Installation Expected by 860201 Project stage: Other ML20205C8451985-09-10010 September 1985 Forwards Info Supporting 850830 Request to Operate at 8% Power to Facilitate Core Dryout for 45 Days,Per 850826,0903 & 04 Telcons.Moisture Removal Needed to Maintain Conditions Prescribed in FSAR & Tech Specs Project stage: Other ML20133E0651985-09-10010 September 1985 Responds to NRC Re Violations Noted in Insp Rept 50-267/85-16.Corrective Actions:Design for New Storage Ctr Initiated Project stage: Other ML20205C4811985-09-11011 September 1985 Provides Commitment That Operating Procedures & Operator Training Described in Providing Addl Info in Support of Request to Operate at Up to 8% Power Will Be Complete Prior to Withdrawal of Control Rods Project stage: Withdrawal ML20137S7411985-09-23023 September 1985 Forwards Addl Calculations,Clarifying Util Re Predicted Fuel/Pcrv Liner Temps Resulting from Design Basis Event from 8% Power & Subsequent Reactor Cooling Utilizing Liner Cooling Sys.Calculations Confirm Original Position Project stage: Other ML20137X1241985-09-30030 September 1985 Forwards Safety Evaluation Based on Util 850830,0910,11 & 23 Requests for Authorization to Operate at Max 8% Power,For Up to 45 Days,To Remove Moisture from Rcs.Authorization Granted,Subj to Listed Commitments Project stage: Approval ML20137X1411985-09-30030 September 1985 Safety Evaluation Supporting Util 850830,0910,11 & 23 Requests for Authorization to Operate at Max 8% Power,For Up to 45 Days,To Remove Moisture from RCS Project stage: Approval ML20138E3921985-10-11011 October 1985 Forwards Request for Addl Info on 850924 Request for Special Consideration & Schedule Extension to Equipment Qualification rule,10CFR50.49.Info Requested within 7 Days of Ltr Receipt Project stage: RAI ML20138M1841985-10-14014 October 1985 Clarifies Commitment Dates in Util Re Proposed Mods Per 10CFR50,App R Fire Protection Evaluation.Remaining Mods Expected to Be Completed During Refueling Outage Project stage: Other ML20138C8111985-10-21021 October 1985 Forwards Response to 851011 Request for Addl Info Re 850924 Request for Schedule Extension for Environ Qualification Program Under 10CFR50.49 from 851130 to 860331 Project stage: Request ML20138R7331985-10-31031 October 1985 Summary of 851029 Meeting W/Util & ORNL Re Schedule Extension to Equipment Qualification Rule.List of Attendees, Agenda & Matls Presented by Util Encl Project stage: Meeting ML20136J3161985-11-0101 November 1985 Forwards Questions Re Manual Operations & Instrumentation Based on Review of 841116-1217 & 850117 & 0401 Submittals of App R Safe Shutdown Models.Addl Info Requested within 30 Days of Ltr Receipt Project stage: Approval 1985-02-04
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Text
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UNITED STATES pN
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NUCLEAR REGULATORY COMMISSION
'.f REGloN IV 811 RYAN PLAZA DRIVE, SUITE 1000 ARLINGTON, TEXAS 70011 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PUBLIC SERIVCE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION DOCKET NO. 50-267 ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY
Background
As part of the ongoing review of licensees' conformance to the requirements for environmental qualification, the staff raised a number of issues concerning the adequacy of the Fort St. Vrain program.
By letter dated January 28, 1985, Public Service Company of Colorado (PSC) was requested to provide additional information in order to determine the extent of compliance with the requirements of 10 CFR 50.49, the rule on environmental qualification of electric equipment important to safety.
PSC provided a response to that request in a letter dated March 28, 1985.
Additional information on environmental qualification was provided by the licensee in a letter dated March 25, 1985 in response to Generic Letter 84-24, Certification of Compliance to 10 CFR 50.49.
A meeting with the licensee to discuss the status of the Fort St. Vrain equipment qualification was held in Bethesda, Maryland on April 3,1985.
As a result of the information provided at this meeting and the licensee's letter further clarifying information was requested by the staff in a letter dated May 7, 1985. The response to that request is a letter from PSC dated June 11, 1985.
On July 2, 1985 staff menbers from NRR and Region IV again met with the licensee to discuss the current status of the Fort St. Vrain equipment qualification program. A letter dated July 11, 1985 was sent by PSC to address followup issues.
Staff Evaluation A summary of the results of the staff review and evaluation of the information provided follows.
10 CFR 50.49 requires each holder of an operating license to establish a program for qualifying electric equipment important to safety. The program must include and be based on the time-dependent temperature and pressure conditions at the location of the equipment resulting from the most severe design basis accident during or following which the equipment is required to remain operable. The program must also include and consider, if applicable, the effects of humidity, chemical spray, radiation, aging, submergence, and synergism.
e50eo201 y h h 67 PDR ADO PDR P
In accordance with 10 CFR 50.49, equipment for Fort St. Vrain may be qualified to the criteria specified in either the D0R Guidelines or NUREG-0588, except for replacement equipment. Replacement equipment installed subsequent to 4
February 22, 1983 must be qualified in accordance with the provisions of 10 CFR 50.49, using the guidance of Regulatory Guide 1.89, unless there are sound reasons to the contrary.
The rule requires that operating reactors achieve environmental qualification of all equipment by no later than March 31, 1985 unless an extension is 1
granted by the Director of the Office of Nuclear Reactor Regulation. A record of qualification, including all necessary documentation, must be maintained in an auditable form for the period of time the covered item is installed or stored for future use.
The licensee's March 25, 1985 response to Generic Letter 84-24 concludes that all equipment which is required to be qualified has been qualified and that Fort St. Vrain is in full compliance with 10 CFR 50.49. This position was 4
reiterated in the letter of June 11, 1985. However, the staff review of the l
information provided by the licensee in support of this claim leads to the following observations:
1.
The Fort St. Vrain equipment qualification program is based on the environmental conditions which result from an assumption that a main steam line break can be isolated within 4 minutes.
If isolation cannot be accomplished within 4 minutes, the temperature continues to increase and could invalidate any claim of environmental qualification.
The adequacy of this assumption is under review by the staff and the results could have an impact on the equipment qualification program.
2.
For each equipment item, age-related degradation which could prevent operation of the equipment must be identified and the equipment replaced l
or repaired as necessary. The qualified life of the equipment cannot be l
exceeded before corrective action is taken.
i The licensee has stated that aging effects are not presently included in the qualification program but an effort in this area has begun. One necessary element which will establish the validity of the Fort St. Vrain qualification program is that the results of the aging analysis must be used to determine that equipment is currently qualified, and must be factored into the surveillance / replacement intervals to assure that i
equipment is maintained in a qualified state.
Corrective action must be taken before, not after, the equipment has exceeded its qualified life.
3.
Operability times have not been established for specific pieces of equipment in compliance with the requirement in 10 CFR 50.49 to demonstrate the capability to perform the required function for the time j
the equipment is required to remain operable.
The licensee has committed to perform a study to establish operability time requirements. Qualification cannot be considered demonstrated until the licensee determines that the equipment can perform its intended function for the period of time it is required to operate during and following an accident.
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. 4.
The licensee has identified a number of outstanding items to be completed as part of the qualification program and has provided a schedule for resolution of these items. The scheduled completion dates for these items extend to March 1986 and are inconsistent with the schedule requirements in 10 CFR 50.49.
Conclusion As summarized above, a number of deficiencies are evident in the qualification program and in the information provided to the NRC for review.
Also, guidance regarding the content and auditability of environmental qualification files was provided to licensees and applicants in IE Information Notice 85-39, dated May 22, 1985.
Based on the information provided by PSC, it is clear that documented evidence of qualification does not now exist for equipment in Fort St. Vrain. Therefore, contrary to the assertions made by the licensee, the NRC staff cannot at this time conclude that conformance to the requirements of 10 CFR 50.49 has been demonstrated for Fort St. Vrain.
As a result of the discussions during the July 2,1985 meeting and the licensee letter of July 11, 1985, the staff decided that the facility should not be allowed to go to full power operation until all environmental qualification issues are resolved to the extent that conformance with 10 CFR 50.49 can be demonstrated. The licensee is actively pursuing the means to resolve these issues.
For the interim period, the licensee has proposed a hold on reactor power to levels less than 15% of rated power to allow initiation of moisture dryout in
~
the reactor vessel stating that the lower energy release rates at these power levels result in significantly lower peak equipment temperatures.
The staff has reviewed the information provided by the licensee in support of the proposed low power operation. Based on the results of that review, we find that operation pending resolution of these issues is allowable. The staff agrees that operation of the plant at power levels not exceeding 15%
will preclude any significant effects on the equipment in question should an accident occur and that such interim operation will not adversely affect the health and safety of the public.
Date: July 19,1985 Principal Contributor:
A. Masciantonio, DE