ML20197B865

Summary of 861001-02 Meetings W/Util,Inel & ORNL Re Staff Comments on Plant Tech Spec Upgrade Program.Nrc Comments Not Intended to Require Plant Mod or Changes to Licensing Basis of Plant

ML20197B865
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/28/1986
From:	Hinson C Office of Nuclear Reactor Regulation
To:	Berkow H Office of Nuclear Reactor Regulation
References
NUDOCS 8610310008
Download: ML20197B865 (9)

Text

E

/

UNITED STATES p

NUCLEAR REGULATORY COMMISSION o

g WASHINGTON, D. C. 70555 k.....

October 28, 1986 Docket No. 50-267 MEMORANDUM FOR: Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B THRU:

0. D. T. Lynch, Jr., Section ad Standardization and Special1 Projects Directorate Division of PWR Licensing-B FROM:

Charles S. Hinson, Project Manager Standardization and Special Projects Directorate Division of PWR Licensing-B

SUMMARY

OF OCTOBER 1-2, 1986 MEETING WITH PUBLIC SERVICE COMPANY OF COLORADO (PSC) TO DISCUSS STAFF COMMENTS ON THE FORT ST. VRAIN (FSV) TECHNICAL SPECIFICATION UPGRADE PROGRAM (TSUP)

On October 1-2, 1986, the NRC staff met with the PSC staff and NRC contractors from Idaho National Engineering Laboratory and Oak Ridge National Laboratory to discuss the status of the FSV TSUP. The attendees of the meeting are listed in Enclosure 1.

The objective of this meeting was to further clarify the intent of the staff's comments on the FSV TSUP (NRC letter from Heitner to Walker, May 30,1986).

The meeting began with a discussion of the PSC-and NRC-agreed upon ground rules and scope for the TSUP. Both parties agreed that these rules still applied to the TSUP and should be followed.

The staff then discussed in detail PSC's August 15, 1986 letter to NRC in which PSC identified four programmatic concerns that they had with the NRC comments on the TSUP and gave seven examples of NRC comments which exemplified these concerns. The staff stressed the fact that the NRC comments were not intended to require plant modification or changes to the Licensing Basis of FSV.

For many of the comments, a brief explanation by PSC was all that was required to resolve the staff's concerns.

For other comments, the staff only required that PSC reference the basis for the Limiting Condition 'oY Operation in the Basis section of the Technical Specifications (TSs) or the Final Safety Analysis Report. PSC stated that many of the documents which formed these bases were proprietary in nature. The staff stated that the documents should still be referenced.

koo$ $

7 P

.'. W I

The staff also mentioned the fact that there are several licensing actions that are being reviewed as part of the TSUP, but which fall outside the scope of the TSUP, since they are being reviewed as separate licensing actions (see NRC letter from Wagner to Holmes (PSC) dated 8/25/85 and PSC letter from Brey toButcher(NRC) dated 11/8/85). These licensing actions concern NUREG-0737 TSs circulator operability requirements, electrical TSs, the restart requirements regarding tendon wire surveillance, and the revised interim control rod drive mechanism and reactivity control TSs. PSC acknowledged the fact that the counents related to these licensing actions could be outside the scope of the TSUP.

FSV's electrical TSs are being rereviewed by the staff, and PSC was advised to ignore the electrical comments (Specification 3/4.8) contained in the NRC letter dated May 30, 1986, and await a revised set of comments in this area.

In order to reduce the number of staff comments that would require detailed discussion and resolution, each of the comments contained in the May 30, 1986 -

NRC letter was reviewed and categorized into one of the six categories listed below.

Within TSUP Scope a.

Incorporate "as is" b.

No action needed (resolved by discussion and/or incorporation) c.

PSC to explain in proposed TSUP amendment safety evaluation d.

PSC/NRC discussion needed to resolve Outside TSUP Scope I

e.

No further discussion planned f.

Further discussion possible Of the 364 comments (seven of which have split resolutions) listed in this letter, 314 (86%) were judged to be inside the scope of the TSUP. Of these 314, 213 comments (category d) require further discussion. An individual breakdown of each coment by category is provided in Enclosure 2.

The staff has agreed to meet with PSC at FSV the week of October 27th to discuss these 213 comments in greater detail.

Following the discussion and categorization of the TSUP coments, the staff gave PSC a copy of the Technical Evaluation Report (TER) performed by Oak Ridge National Laboratories entitled Technical Evaluation of the Redrafted Technical Specifications for Subsystems / Components of the Fort St. Vrain Safe Shutdown Cooling Systems and PCRV and Confinement Systems. This report documents a comprehensive review and technical evaluation of the safety-related cooling functions at FSV, and how these cooling functionsJere addressed in the FSV TSUP in comparison with the Standard Technical Specifications (STSs)'

for Light Water Reactors. The major finding of this review and technical evaluation is that the proposed upgraded TSs for FSV are written based on an apparent nirrow view of what actions are necessary to preclude an immediate threat to public health and safety. The report suggests a number of revisions to the proposed Upgrade Technical Specifications to make them more consistent with the STSs for Light Water Reactors. The staff asked that PSC review this TER and attached comments and discuss any concerns they may have at a later date.

..d The staff also discussed with the licensee its concerns with PSC's interpretation of LC0 4.1.9 regarding the 760 F bulk core temperature concept. The staff is concerned that potentially all decay heat removal paths from the core would be interrupted based solely on a calculation that the bulk core temperature was less than 760 F.

During this period when the heat removal paths were interrupted, there could be no monitoring of core temperatures. The staff believes that a more conservative approach would be to maintain at least one decay heat removal path operating and a second path operable, except for a specified period where operation was not possible (i.e.,

circulatorremoval,etc.). We agreed to discuss this issue further with the licensee at a later date.

s a (J harles S.

inson Project Manager 4r Standardization and Special Projects Directorate Division of PWR Licensing-B

Enclosures:

As stated cc w/ enclosures:

See next page i

f

g Mr. R. O. Williams Public Service Company of Colorado Fort St. Vrain cc:

Mr. D. W. Warembourg, Manager Albert J. Hazle, Director Nuclear Engineering Division Radiation Control Division Public Service Company Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201 Mr. David Alberstein, 14/159A Mr. J. W. Gahm, Manager GA Technologies, Inc.

Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. L. W. Singleton, Manager Public Service Company of Colorado Quality Assurance Division P. O. Box 840 Public Service Company of Colorado Denver, Colorado 80201 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Senior Resident Inspector U.S. Nuclear Regulatory Commission Mr. R. F. Walker P. 0. Box 840 Public Service Company of Colorado Platteville, Colorado 80651 Post Office Box 840 Denver, Colorado 92138 Kelley, Stansfield & 0'Donnell Public Service Company Building Commitment Control Program Room 900 Coordinator 550 15th Street Public Service Company of Colorado Denver, Colorado 80202 2420 W. 26th Ave. Suite 100-D Denver, Colorado 80211 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Chainnan, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency 1 Denver Place 999 18th Street, Suite 1300 Denver, Colorado 80202-2413

i y

NRC-PSC TSUP Meeting <

Oct. 1-2, 1986 ATTENDANCE LIST Name Affiliation Charles Hinson NRC/0PLB/PBSS Ken Heftner NRC/DPLB/PBSS Joe Stachew EG&G, WEL David Moses ORNL G. L. Plumlee, III NRR/DPLB/F0B Wm. H. Regan, Jr.

NRR/DPLB/F0B Herb Berkow NRR/DPLB/PBSS O. D. T. Lynch, Jr.

NRR/DPLB/PBSS R. E. Ireland NRC/RIV R. O. Williams, Jr.

PSC H. L. Brey PSC M. H. Holmes PSC J. M. Gramling PSC Donald R. Hoffman PSC Sam Chesnutt PSC O

l j

l l

l

~v Categorization of NRC Comments Incorporate "as is" (32)

General Comment #4 3.1.6-4 Definition 1.17

-5 1.24 3.1.7-4 SL 2.1.1-2 3.3.2.1-2

-3*

3.3.2.3-1

-4

-4 SL 2.2.1-3*

3.3.2.4 3.0-4 3.3.3 3.1.1-1*

3.6.1.2-1

-8

-6

-16 3.7.1.3-1 3.1.2.2-12 3.7.6.5 3.1.4.1-1 3.9.2-4

-3 5.0

-8*

5.1-4

-9 5.3-2 No Action Needed (67)

General Comment #3 3.1.2.1-1 3.1.3-3 3.2.2-1 3.6.1.2-3 SL 2.1.1-1

-2

-6

-3 3.6.5.2-6

-3*

-3 3.2.3-1 3.7.2-5 SL 2.2.1-2

-4 3.1.3-9 3.2.4 3.10.1

-3*

-6 3.1.4.1-2 3.2.6-2 5.2

-5

-7

-4 3.3.2.1-3 5.3-4

-6 3.1.2.2-1

-5 3.3.2.2-2

-6 3.1.1-1*

-2

-6 3.4.1-4

-5*

-3 3.1.4.2-1 3.4.2-1

-7

-6

-2 3.4.3-2 3.1.1-10*

-8

-4 3.5.4-1

-11

-9

-5

-4

-17

-10 3.1.6-2 3.6.1.1-1

-14

-11 3.1.6-3

-3

-15 3.1.3-1 3.1.7-1 3.6.1.2-2 PSC To Explain In Safety Evaluation (2) 3.1.1-9 3.7.6.4-1 1

/ "v PSC/NRC Discussion Needed To Resolve (213)

General Comment #5 3.3.2.8-1 thru 4 3.6.5.2-4 3.7.6.4-2

1. 6 3.4.1-5

-5 3.7.7 Definition 1.11

-6

-7 3.7.8-1 thru 6 1.14 3.4.2-2

-8 3.7.9-1 thru 8 Table 1.0-1

-3

-9 3.7.10-1 thru 6 SL 2.1.1-5 3.4.3-3

-10 3.8.1.1-1 thru 9 SL 2.2.1-1

-4

-11 4.8.1.2-1 thru 7 3.0-3 3.5.4-2

-12 3.8.1.2

" -5

-3 3.6.5.3-1 3.8.2.1

-5

-2 4.8.2.1.1 thru 3 3.6.1.1-2 3.7.1.1-1 3.8.3.2 3.1.1-2

-4

-2 3.9.1-2

-3 3.6.1.2-4

-3

-3

-4'

-5 3.7.1.2-1 thru 9

-4

-5*

-7 3.7.1.3-2

-5

-6 3.6.1.3-1 3.7.1.4

-6 3.1.2.2-13

-3

3. 7. 23d

-7 3.1.3-2 3.6.1.4-1

-2 3.9.2-1

-4*

-4

-3

-2

-8 3.6.1.5-1 thru 4

-4

-3 3.1.4.2-3 3.6.4-1

-6

-5

-6

-2

-7

-6 3.1.6-1

-3

-8 3.9.3-1 thru 8 3.1.7-10

-4

-9 5.1-1 3.2.1-1

-5

-10

-2 3.3.1

-6

". -11 5.3-1 3.3.2.1-1

-7 3.7.3-1

-3 3.3.2.2-1

-8

-2

-5 3.3.2.3-2

-9 3.7.4.1-1 thru 4 6.1-1

-3 3.6.5.1-1 thru 6 3.7.5-1 thru 3

-2 3.3.2.7-1 3.6.5.2-1 3.7.6.1 6.2.3

-2

-2 3.7.6.2-1 thru 3 6.3-1 thru 3

-3

-3 3.7.6.3-1 thru 4 6.5-1 thru 2 6.8 6.9-1 thru 6 6.10-1 thru 2 6.12 6.17 No Further Discussion Planned (Outside TSUP) (11)

General Comment #1 SL 2.2.1-4 5.1-3

1. 2 3.0-1 Index 3.0-2 Definition 1.22 Primary Coolant-1 Definition Slave Relay Test 3.9.1-1

6 /'

1 Further Discussion Possible (Outside TSUP1 (46) 3.1.7-2 3.4.3-1 Definition 1.16

-3 Primary Coolant -2 Definition Response Time

-3

-5 3.1.1-10*

-6 3.6.1.3-2

-13

-7 3.6.1.4-2 3.1.2.1-5

-8

-3

-8

-9 3.9.1-8 3.1.2.2-4 3.2.1-2

-5

-3

-7

-4 3.1.3-4*

3.2.2-2

-5 3.2.3-2

-10

-3 3.1.4.1-7 3.2.6-1

-8*

3.3.2.7-4

-10 3.4.1-1 3.1.4.2-7

-2

-8

-3

-9 3.1.5.-1

-2 3

Comment resolution split into more than one category.

October 28, 1986 The staff also discussed with the licensee its concerns with PSC's interpretation of LC0 4.1.9 regarding the 760 F bulk core temperature concept. The staff is concerned that potentially all decay heat removal paths from the core would be interrupted based solely on a calculation that the bulk core temperature was less than 760 F.

During this period when the heat removal paths were interrupted, there could be no monitoring of core temperatures. The staff believes that a more conservative approach would be to maintain at least one decay heat removal path operating and a second path operable, except for a specified period where operation was not possible (i.e.,

circulator removal, etc.). We agreed to discuss this issue further with the licensee at a later date.

original signed b Charles S. Hinson,y 0. D. T. Lynch, Jr., for Project Manager Standardization and Special Projects Directorate Division of PWR Licensing-B

Enclosures:

As stated cc w/ enclosures:

See next page DISTRIBUTION:

Docket File-NRC PDR Local PDR PBSS Reading FMiraglia OGC-Bethesda EJordan BGrimes JPartlow HThomspan ACRS (10)

PNoonan CHinson KHeitner Olynch HBerk0w FJ$$b PBSSpSh P

P PB S P)obnan CHinson:cw KH tner 0

ph He ow 10/)R/86 10/ n/86 fl0/d'86 10/ o/86 10/ f/86

. -..