ML20133E155

Forwards Comments on Proposed Fuel Surveillance Program Submitted by .Response to Comments & Revised Program Should Be Submitted within 60 Days of Ltr Receipt. Problems Must Be Corrected Prior to Program Approval

ML20133E155
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/02/1985
From:	Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Lee O PUBLIC SERVICE CO. OF COLORADO
References
TAC-57625, NUDOCS 8510090296
Download: ML20133E155 (5)

Text

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Docket: 50-267 OCT 0 31985 Public Service Company of Colorado ATTN: 0. R. Lee, Vice President Electric Production P. O. box 840 Denver, Colorado 80201-0840 Gentlemen:

We have reviewed the proposed Fort St. Vrain Fuel Surveillance Program which you submitted by letter dated May 3,1985 (P-85151) and find that a number of problems must be corrected prior to our approval. Our comments on the proposed program are contained in the enclosure to this letter. We request that you respond to these comments and provide a revised program within 60 days of your receipt of this letter.

If you have any questions on this subject, please contact the NRC Project Manager.

Since this request relates solely to the Fort St. Vrain Station, OMB clearance is not required under P.L.96-511.

Sincerely, "OriMr i: 9 cd By-E. !<. HUNT ER" D. R. Hunter, Chief Reactor Safety Branch

Enclosure:

Comments on Program cc:

Mr. D. W. Warembourg, Manager Nuclear Enginee ing Division Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201 Mr. David Alberstein, 14/159A GA Technologies, Inc.

P. O. Box 85608 San Diego, California 92138 RIV:ESh ES N. RSB M PCWagner:gb REIreland EBu . er DRHthfter CJ /30/85 10/ 2./85 >5 go/t/85 8510090296 851002 h/ g g d'f' l PDR ADOCK 05000267 '

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Pub 11c Service Company of Colorado Kelley, Stansfield & 0'Donnell Public Service Company Building 550 15th Street, Room 900 Denver, Colorado 80202 Chcirman, Board of County Comm.

of Weld County, Colorado Greeley, Colorado 80631 Rogional Representative Radiation Programs Environmental Protection Agency 1860 Lincoln Street Denver, Colorado 80203 Mr. H. L. Brey, Manager Nuclear Licensing / Fuels Div.

Public Service Company o.f Colorado P. O. Box 840 Denver, Colorado 80201 J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 191 Platteville, Colorado 80651 L. Singleton, Manager, Quality Assurance Division (same address)

Colorado Radiation Control Program Director

bec distrib. by RIV

j RPB Resident Inspector R. D. Martin, RA RSB Section Chief, RSB/ES EP&RPB P. Wagner, RSB/ES R. Denise, DRSP E. Haycraft, DRSP/LA RIV Official Reading File E. Butcher, ORB 3 ~

CPB/NRR D. Eisenhut, D/DL G. Lainas, DL K. Heitner, ORB 3 J. Taylor, IE E. Jordan, IE M. Tokar, NMSS CPB/NRR

l COMMENTS ON THE FUEL SURVEILLANCE PROGRAM

1. As we have stated in our January 3,1979, February 28,1983, and October 19, 1984 letters, we do not find it acceptable for changes to be made to the Post Irradiation Examination (PIE) program based only on the availability of DOE funding. Therefore, changes to the previously approved program must be explained, justified, and approved. (i.e.,The deletion of PIE for SURV-2 was authorized in our February 28, 1983 Safety l Evaluation.)

a. The deletion of a destructive PIE for elements SURV-4 and SURV-6, following refueling outages 4 an 6 respectively, may be acceptable provided no significant changes occur in parameters which are indicative of fuel performance. We, therefore, propose that you

. commit to a destructive PIE of those selected surveillance fuel i elements (SURV-4 and SURV-6) if the circulating primary coolant l activity increases to a preselected level or by a predetermined factor

! over previous equilibrium levels. Similar considerations should be

. incorporated into the nondestructive PIE program for refuelings subsequent to the tenth refueling outage.

b. The proposed destructive PIE program does not include all of the 13 1

tasks that were committed to in your June 20,1978(P-78102)

! response to our May 10, 1978 requirement for a PIE program of the fuel test elements (FTEs). Many of the deleted tasks do not appear

to be extremely difficult to perform and should be included in the

! PIE program. Provide an evaluation, including a cost-benefit study,

! for any of the 13 tasks which are not incorporated (as stated in P-78102) into the proposed program.

2. Items 2) and 3) of the proposed program indicate that "significant abnormalities" will be evaluated and reported. A revision to the program should define what is intended by "significant abnormalities."

3. The reporting of program results (Items 4), 6), and 7)) to the NRC needs to be changed from "as it becomes available" to a specific time following i restart from the refueling outage (i.e., 120 or 180 days following restart).

4. The commitment (Item 5)) to visually examine the " canyon walls" of the Segment 9, H-451 elements needs to be revised to indicate that records of these examinations shall be established and maintained. (The approval of the use of H-451 graphite in License Amendment No. 40 was based, in part, on previous commitments to perform these visual examinations and other PIE.)

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5. Item 6) c) stipulates that gamma scanning is subject to the availability of the gama scanning robot. Since, as stated in your June 20, 1978 submittal, the development of this device by General Atomic was funded by i

00E for FSV fuel examinations, we were under the assumption that it would always be available for these examinations. In addition, we stated in our January 24, 1983, that gamma scanning was a necessary element of an acceptable PIE program. Therefore, provide: a) an explanation of what is meant by the availability of the robot, and b) if gamma scanning is not to be included in the examination, the justification for this deletion.

6. The commitment to perform destructive PIE on FTE-2 contained in your February 10, 1983 response to our January 24, 1983 position needs to be fulfilled. Provide your schedule for completion of subitems d, e, f, and 9 l

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