ML20137H372

Memorandum & Order Granting Extension of 851130 Deadline for Environ Qualification of Electrical Equipment to 860531 & Approving Proposal to Allow Operation w/35% Reactor Power Limit During Interim.Served on 851127

ML20137H372
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/26/1985
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	PUBLIC SERVICE CO. OF COLORADO
References
CON-#485-333, CON-#485-353, CON-3485-333 GL-85-15, OL, TAC-42527, TAC-49787, TAC-59787, TAC-63576, NUDOCS 8512020377
Download: ML20137H372 (6)

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UNITED STATES OF AMERICA fiUCLEAR REGULATORY COMMISSION I:' ,

COMMISSIONERS:

Nunzio J. Palladino, Chairman SERVED NOV 2; Ica;~

Thomas M. Roberts James K. Asselstine Frederick M. Bernthal Lando W. Zech, Jr.

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PUBLIC SERVICE COMPANY OF COLORAD0 )

) Docket No. 50-267 O b (Fort St. Vrain Nuclear Generating )

Station) )

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MEMORANDUM AND ORDER By letters dated September 24, 1985, and October 22, 1985, the Public Service Company of Colorado (PSC) requested that the Commission grant an extension until March 31, 1986, for environmental qualification of electrical equipment at the Fort St. Vrain Nuclear Generating Station (FSV). In a subsequent meeting with the NRC staff on November 18, 1985, the licensee agreed to modify its position, and provided a revised request by letter dated November 22, 1985. The Commission met with the staff on November 19 to review the licensee's request; at this meeting utility representatives responded to several Conmission questions on equipment qualification and related matters.

The Commission has reviewed in detail the licensee's submittals, the staff's analysis and recommendation as set forth in SECY-85-370, and 0512020377 051126 PDR ADOCK 05000267

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2 has considered all additional information provided at the November 19 meeting. Based on this review the Conmission fir,is that the licensee has demonstrated exceptional circumstances warranting approval of its revised request. However, in accordance with the staff's request, the licensee will be required to provide an acceptable confirmatory submittal before plant operation is approved.

The Commission most recently addressed the environmental qualifica-tion issue in Generic Letter 85-15, issued August 6, 1985. In that letter the Commission stated that extensions from the November 30 deadline established in 10 C.F.R. 50.49(g) would be granted "only in rare circumstances." The Commission further stated that extension requests "must clearly identify the exceptional nature of the case, e.g. , why, through events entirely beyond its control, the licensee will not be in compliance on November 30; the date when compliance will be achieved; and a justification for continued operation until compliance will be achieved." The Commission also set forth an enforcement policy regarding failure to meet the deadline.

The Fort St. Vrain facility is a high-temperature gas-cooled reactor (HTGR) located in north-central Colorado. It is the only commercial reactor of its kind operating in the United States. This type of reactor utilizes helium as coolant and graphite as a moderator, and thus is very different in operating characteristics from other commercial power reactors, in which water performs the dual function of coolant and moderator. In its decision authorizing construction of this facility, the Conmission noted that this design incorporates certain unique safety features:

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These include: the strong prompt negative temperature coeffi-cient of the reactor; the ability of graphite, from which all structural members within the core are to be fabricated, to maintain mechanical integrity to very high temperatures; the chemically inert nature of the reactor's helium coolant and the fact that most of the radioactive fission products produced in operation will be retained inside the multiple layers of pyrolytic carbon and silicon carbide which will coat the fuel particles in the reactor core.

Public Service Cocoany of Colorado (Fort St. Vrain Nuclear Generating Station), 4 AEC 214, 215 (1969). These factors lead to a slow core thermal response to a loss of coolant circulation. While in a light-water reactor a loss-of-coolant accident must be recovered on the order of minutes and hours, the FSV design allows up to several days before fuel failure could be expected. This additional time would allow many more operator actions to be taken to restore coolant circulation in the event of an accident.

The licensee apparently relied on these inherent safety character-istics in maintaining, as early as 1980, that FSV met the Commission's requirements for environmental qualification of electrical equipment irarcrtant to safety. The licensee held to that position after the Commission promulgated 10 C.F.R. 50.49 in early 1983. The NkC staff did not undertake a detailed review of the licensee's position on equipment qualification until 1984. As this review progressed it became clear that there was substantial disagreement between the staff and the licensee on the applicability of 10 C.F.R. 50.49 requirements to FSV.

Numerous meetings have been held between the staff and licensee to resolve technical issues, and the licensee has made several major submittals in response to staff questions.

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This interchange, albeit late in the Commission's intended schedule for completion of the equipment qualification program, has now resulted in substantial agreement between the licensee and the staff on what steps must be taken to place FSV in compliance with 10 C.F.R. 50.49.

However, the licensee will be unable to complete all aspects of its equipment qualification program until the end of May 1986. The licensee has therefore requested an extension from the November 30 deadline [see 10 C.F.R. 50.49(g)] until May 31, 1986. Initially this request was for full-power operation, with an extension to March 31, 1986.

The staff, however, was unable to accept the licensee's justifica-tion for operation at 100 percent power given the current status of the FSV qualification program. Based upon engineering calculations performed independently by the licensee crd the staff, however, it became clear that operation at no greater than thirty-five percent power could be justified for the interim period until the environmental qualification program could be completed. The licensee modified its request for authorization to operate at or below the thirty-five percent level pending acceptance by the staff of the licensee's equipment qualification program. The licensee requested an extension of the November 30, 1985 deadline until May 31, 1986. The Commission discussed this approach with the staff at the November 19 meeting, and reviewed ,

the details of the proposal provided in SECY-85-370.

The record indicates that FSV's unique design contributed to its current difficulties, as did the lack of a detailed staff review of its equipment qualification program until late in the section 50.49(g) schedule. The record also shows that the licensee has in the recent

5 past devoted increased resources and management attention to this important safety matter, leading to an expected completion of the program within six months.

Under these circumstances, the Commission finds that the licensee has met the criteria for an exceptional case and grants an extension from the November 30 deadline to May 31, 1986. The Commission also concit. des that the proposal to allow operation in the interim with a limit on reactor power level of thirty-five percent will not present an undue risk to the public health and safety in the interim period, contingent upon the staff's acceptance of the licensee's confirmatory analyses. PSC will submit the results of its confirmatory analyses and the NRC staff will review and approve those analyses before FSV is permitted to operate at power levels up to the thirty-five percent power restriction. This extension of the environmental qualification deadline is subject to three conditions:

1. During the interim period, until the environmental qualification progran is complete, reactor power shall be limited to thirty-five percent.

2. Actual authorization of operation up to thirty-five percent shall be made by the Director, NRR, upon finding the licensee's confirmatory analyses acceptable.

3. Operation above thirty-five percent power is conditicnal upon completion of the equipment qualification program

6 and its approval by the Director, NRR, and the Director, IE.

It is so ORDERED.

40  ; 4f For the Comission

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SAMUEL J. CHILK h.x' 44,,, Secretary of tlie Comission Dated at Washington, D.C.

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