ML20195D885
| ML20195D885 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/17/1988 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| P-88140, NUDOCS 8806230233 | |
| Download: ML20195D885 (5) | |
Text
.
O eubiic service-
- =::r' P.O. Box 840 Denver, CO 80201 0840 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 R.O. WILLIAMS, JR.
VICE PRESIDENT NUCLEAR OPERATIONS June 17, 1988 Fort St. Vrain Unit No. 1 P-88140 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Attention:
Mr. Jose A. Calvo Director, Project Directorate IV Docket No. 50-267
SUBJECT:
Inservice Inspection and Testing Program Plan
REFERENCES:
- 1) PSC letter, Brey to Berkow, dated 2/13/87 (P-87018)
- 2) NRC Letter, Wagner to Lee, dated 3/8/83 (G-83104)
- 3) NRC Letter, Heitner to Williams, dated 3/9/87 (G-87073)
Dear Mr. Calvo:
This letter provides the NRC with the current status of the Public Service Company of Colorado (PSC) efforts to enhance the Inservice
!nspection and Testing (ISIT) Program at Fort St. Vrain (FSV).
Presently the FSV Inservice Inspection and Testing Program primarily consists of certain surveillance requirements (ISIT Phase I,
Reference 2 and ISIT Phase II, Reference 3) incorporated in the Technical Specifications. These surveillance requirements provide a
continuing assurance of plant safety and reliability.
Public Service Company of Colorado (PSC) is currently developing an ISIT Program Plan, as discussed in Reference 1.
This Program P 1,,
will identify and control the FSV inservice inspections and tests separate from the Technical Specifications.
The proposed scope or 8806230233 080617 f
i l
o P-88140 June 17, 1988 this Program Plan and the guidelines for its dcvelopment are provided in Attachment 1, for your review and comment.
The ISIT Program Plan will require initial NRC approval and any subsequer.t changes will be evaluated and approved as described in Attachment 1.
PSC proposes to implement this ISIT Program Plan prior to plant operation above 30%
power af ter the fif th refueling outage.
If you have any questions or comments concerning this letter please contact Mr. M. H. Holmes at {303) 480-6960.
Very truly yours, s
/
R. O. Williams, Jr.
Vice President Nuclear Operations R0W:RT/lp Attachment cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westerman, Chief Projects Section B Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain
=_-
Attachment'1 d
To P-88140 i
ISIT PROGRAM PLAN PROPOSED SCOPE AND GUIDELINES INTRODUCTION The Inservice Inspection and Testing'(ISIT) Program Plan Development Project is intended to identify and consolidate Fort St. Vrain's ISIT requirements.
The ISIT Program Plan will supplement ~ existing Technical Specification
' surveillance requirements
.to.
provide continuing assurance that components, systems and structures are available to perform their safety functions when required.
' SCOPE 1.
The population of equipment to be addressed within the ISIT Program Plan will be based on the equipment included in the FSV-upgraded Technical Specifications with consideration-for
.i accessibility, safety function and service conditions.
i j
2.
The ISIT Program Plan will require initial NRC approval prior to
. i t
implementation. Gnce implemented, the ISIT Program Plan will be administrative 1y controlled by the FSV Technical Specifications.
l Proposed changes to the ISIT Program Plan will be evaluated per the criteria of 10 CFR 50.59, and any proposed changes involving an unreviewed safety question will be submitted to the Commission for approval prior to implementation.
Proposed changes not involving an unreviewed safety question may 'be implemented without prior Commission approval, but all such changes shall be reported to the Commission in the annual 10 CFR 50.59 summary.
report.
3.
The ISIT Program Plan will include those ISIT requirements that.
are presently included within the Technical Specifications but are more appropriate for inclusion within the ISIT Program Plan, Upon approval and implementation of.the ISIT Program Plan, PSC l
will consider removal of these requirements from the Technical Specifications.
4.
The ISIT Program Plan shall include as a minimum thi following:
f A.
Adequate background and introduction.
B.
A reference list of applicable documents affecting the inspection program.
I C.
Detailed examination requirements including the areas subject to examination, frequency of examination, examination i
techniques, and examination acceptance criteria.
D.
Detailed testing requirements including the components to be tested, the type of test to be performed, test schedule, and t
j testing acceptance criteria, i
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' Attachment 1 To P-88140 E.
A description of the system employed for mat'ntaining records and status of the inspection and testing activities.
5.
The following programs or evaluations that are not required by the ASME Boiler and Pressure Vessel Code,Section XI, (referred to hereafter as the ASME Code) will be considered for establishing inspection requirements to be included within the ISIT Program Plan.
A.
The high energy piping inspection program established in response to EQ Confirmatory Action 6 (Reference PSC letter, i
Warembourg to Berkow, dated 3/3/86, P-86105).
B.
An evaluation of high energy seamed pipe to determine the need for additional inspection requirements to assure piping integrity.
C.
An evaluation of potential erosion / corrosion degradation in single phase flow systems.
D.
An evaluation of various General Atomics reports that provide information regarding component cycle life and system structural analysis to determine the need for additional inspections to assure continued pressure boundary integrity.
6.
Surveillance testing of the following items will remain in the i
Technical Specifications and will be beyond the scope of the ISIT Program Plan.
A.
PCRV B.
Reactor Internals C.
Elevated temperature structural material associated with the i
reactor D.
Graphite and thermal insulation material in the reactor internal components E.
PCRV Tendons F.
Helium Circulators G.
Control Rod Drive Mechanisms H.
Snubbers I.
7.
Calibration and testing of
'istruments and controls will be accomplished via an administratively controlled calibration progra, as opposed to coverage in the ISIT Program Plan. j l
To P-88140 8.
The ISIT Program Plan Development Project will utilize the current licensing basis of the Fort St. Vrain plant as embodied in the FSAR, without further justification or analysis.
9.
The extent of ASME Code applicability will be determined based upon currently available design documentation, without further significant analytical investigation.
- 10. Consistent with FSV practice, the ISIT Program Plan will utilize PSC inspection personnel and will not require the involvement of a third party inspection agency during inspection and testing.
GUIDELINES 1.
The ISIT Program Plan will use the ASME Code, Division 1 or 2, as appropriate and to the extent practical for the inspection requirements, methodology and acceptance criteria to be applied to the equipment included within the ISIT Program Plan.
2.
Exemption requests and/or justification for deviations from or exceptions to the ASME Code will not be required.
The ASME Code does not take into account many of the unique features of the FSV design and the ASME Code requirements are not specifically applied to FSV by 10 CFR 50.55a(g).
3.
Present plant equipment, including instrumentation and testing equipment, will be used to the extent practical. Any additional instrumentation or other plant modifications which PSC considers necessary will be accomplished over an extended schedule (e.g.,
10 years) that takes into account PSC's resources and other commitments.
4.
Baseline data for examinations or tests that have not been previously performed at FSV will be developed during the initial inspection interval.
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