ML20205P886
| ML20205P886 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/02/1988 |
| From: | Heitner K Office of Nuclear Reactor Regulation |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| TAC-65242, NUDOCS 8811090004 | |
| Download: ML20205P886 (7) | |
Text
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NUCLEAR REGULATORY COMMISSION E
.. I WASHING TON, D. C. 20666
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November 2, 1988 Docket No. 50-267 fir. R. O. Williams, Jr.
Vice President, Nuclear Operattor.s Public Service Cortpany of Colorado Post Office Eox C40 Denver, Colorado 80201-0840 l
Dear !'r. Williars:
l STAFFCOWEf.TSOilF0FTST.VFAIN(FSV)(TACNO.65242)
SUEJECT:
INSERVICE IhSFECTIONANDTESTitG(1511)PROGRAP The staff has reviewed your recent subtrittal dated June 17, 1988 (P-88440),
W tr miier sutrittei dated February 12,1987 (F-57016) concernir.g the FSV ISIT prograt. The staff's corrents on these semittel are as follows:
1.
Tre staff cer.siders the store of the FSV !$1T to be as defined in your sutn.ittels of August 28 and I:overber 30, 1979 (P-79176 and P-79289). If l
Fublic Service Corpary of Colorado (PSC) wishes to revise the scope of the progrei.., differer.ces with the scupe as defined above should be justified.
pSC shculd also note the Tables 1.4-1 and 1.4-2 of the FSV Final Safety
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pnelysis repvrt (FSAF:) shculd be considered it: n fit.ing tre scope of the ISIT prograri.
F.
The ISIT progr6ti shculd cor.tain a surmary of instrusentation syster.s to be covered by administrative controls. This is especially true for thost systers identified in 1979 as being in the prograri.
FSC should alsc.
clarify its scredule for itiplerenting thest adtvinistrative controls.
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3.
The developrent of the ISIT prograr. should rat solely lir.iit itself to referencing the FSAR. The FSAR is considere.1 supportes* 'y its references.
v The staff corisiders the licer. sing basis to include all app *41 cable regula-tiens, and all plant specific safety evaluations written oy the staff on FSV. Where systems are not adequately docunented in the F3AR, the ISIT prograr. docucent should provide appropriate refereoces.
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4 The staff position is that all deviations frorn code requirtirents rust be docueented in the FSV !$1T prograrr documents.
Forexample,10CFR50.55a(s) applies to all puttps and valves that are classified as ASP.E Code Classes 1, 2 and 3, and that perform a safety-related function to be included in i
the ISIT program and tested in accordance with the ASME Code Section XI.
i SRP 3.9.6 reiterates this position.
In documenting deviations, the i
licensee should derrenstrate that (1) the pro acceptable level of quality and safety, (7.) posed alternatives provide an compliance would result in hardship or unusual difficulties without a corpensating increase in the
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level of quality and cafety, or (3) conforr..arice with certain requirerrents of the applicable Code edition ard adderda is itpractical for its facility.
Exarples of irtpracticality include personnel hazard, testing that ir.ay result in dartage to equiptent go\\
8011090004 001102 l
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F.. O. Williems, Jr. and testing that tray result in plent trensients.
Inconvenience is not a basis for a determination of icpracticality. The staff's position is that this approach is applicable to FSV even though the regulaticns do not require FSV to request relief from the ASPE Code. The staff v:ill audit or inspect these proposed deviatier.s as subinitted in the FSV ISIT program. Subsequent deviations irrplwented by PSC under 10 CFR 50.59 should also be docurrented, so that the staff can audit suth changes. Enclosed is en eutline of how such deviations can be documented.
5.
Deviations fror, the code should not be justifiet, solely by the availability of properly qualified pe,sonnel on the PSC staii.
The staff is prepared to rieet with you to further discuss ycur program.
Sincerely,
\\S K< nneth L. Heitner, Project l'anager Project Directerete - IV l
Division of Reactor Projects - !!!,
IV, Y and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated t
cc w/ enclosure:
I See next page i
1 01991BUT10tl McWtTTF i;RC PDR Local PDP F04 Feading j
L. Rubenstein J. Celvo P. t'cenan K. Peitnet i
C. Y. Cheng L. C. ?!arsh OGC-Rockville E. Jordan B. Grires ACRS (10)
PD4 Plant file
- See previous cencurrences:
i PO4/LA*
PD4/Fli*
PD4/D EMTB*
EMTD*
Piloonan KPeitoer:sr JCalvo CYCheng LLf'o r sh 10/17/00 10/17/f8 11/ pf,8 10/31/88 10/ES/tS
R. O. Willians, Jr.
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and testing that may result in plant transients.
Inconvenience is not a basis for a deter 1rination of inpracticality.
The staff's position is that this approach is applicable to FSV even though the regulations do not require FSV to request relief from the ASME Code. The staff will audit or inspect these proposed deviations as submitted in the FSV ISIT program.
Subsequent deviations inplerrented by PSC under 10 Cr'P 50.59 shculd also be docurrented, so that the staff can audit such changes.
Enclosed is an outline of hcw such deviaticns can be docurei'ed.
5.
Deviatioris frcm the code should not be justified solely by the availability of properly qualified personnel on the PSC staff.
PSC always has the optiin of suitably qualify ~ng its personnel in lieu of using a third party it.Jvection agency.
The staff is prepared to rrect with you to further discuss your program.
Sincerely, Kenneth L. Peitner, Project Panager Project Directorate - IV Divisicn of Reactor Projects - !!!,
IV, V anc Special Projects Office of fiuclear Peactor Regulation
Enclosure:
As stated cc w/ enclosure:
See next page D15TRIBilT10N i
Do Wet rTTe~
FFC FOR Local FDR 004 Peading
~
L. Rubenstein
.. Calvo P. ficonan V. Peitner C. Y. Cheng L. D. Vorsh OGC-Pockville E. Jcrdan P. Grirres ACP5(10)
F04 Plant File s.
PD4/ift I
PD k
E' F04/LA 1 5I F?iocnan VPeitner:sr JCalvo C Cheng L FP'a rs h 10/IT/ff:
10/4 1/F8 1(/p/f 8 10/p/fB 10/N/f8
i t
t E. O. W111 tans, Jr. :
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and testirig that reay result in plant transients.
Inconvenience is not a basis l
for a deterr.iriotion of impracticality. The staff's positier is that this i
approach is applicable to FSV even though the regulations do not require FSV l
to reque.st relief f'.e the ASME Code. The staff will audit or inspect these i
l proposed deviations es subtittes in the FSV ISIT program. Subsequent l
deviations implemented by PSC under 10 CFR 50.59 should also be documented, i
so that the staff can audit such changes. Enclosed is an outline of how q
such deviations can be documented.
J 5.
Deviations from the code should not be justified solely l'y the availability of properly qu61ified persornel on the PSC staff.
l The staff is prtrared to teet with you to further discuss your prograri, f
l, Sincerely, 1
i Kerr.cth L. Weitner, Project l'ariager 3
Freject Directcrate - !Y 4
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Division of Reactor Projects - !!!,
t IV, Y and Special Projects l
Office of Nuclear Reactor Regulation 1
l Er.clo sure :
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As stated i
cc w/ enclosure:
See r. ext page I
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Mr. R. O. Williams, Jr.
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 Depattment of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201-0840 Mr. David Alberstein, 14/159A Mr. R. O. Williams, Jr., Acting Panager GA Technologies, Inc.
Nuclear Production tiivision Post Office Box 85608 Public Service Comptny of Colorade SLn Diego, California 92138 16805 Weld County Road 19-1/2 Platteville Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. P. F. Tomlinson, Manager Public Servi:e Company of Colorado Quality Assurance Division P. O. Box 640 Public Service Company of Colorado Denver, Colorado 80201-0840 16805 Weld County Road 19-1/2 Platteville, Colcrado 80651 Senior Resident Inspector U.S. Nuclear Regulatory Commission Mr. R. F. Walker P. O. Fox 640 Public Service Company of Colorado Platteville, Colorado 80651 Post Office Box 840 Denver, Colorado 80201-0840 Kelley, Stansfield & 0'Donnell Public Service Company Building Comitment Control Program Room 900 Coordinator 550 15th Street Public Service.ampany of Colorado Denver, Colorado 80202 2420 W. 26th Ave. Suite 100-D Denver, Colorado 80211 Regional Administrator, Region IV U.S. Nuclear Regf,Rory Comission 611 Ryan Plaza De m, Suite 1000 Arlington, Texas 76011 Chairinan, Board of Co'..nty Comissioners of Weld County, Colorado Greeley, Colorado 80631 Pegional Representative Radia':fon Programs Environmental Protection Agency 1 Denver Place 999 lath Street, Suite 1300 Denver, Colorado 80202-2413 v
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EfjCLOSURE Documentation of Deviations from the ASf1E Code Section XI Subsections IWP and IWV A.
The proposed alternatives would provide an acceptable level of quality and safety.
1.
Describe Code requirement.
2.
Describe proposed titernative.
3.
Explain either equivalency or explain how alternative provides and acceptable level uf quality in most cases this should mean equivalent protection as provided by Code.
B.
Compliance woulo result in hardship or unusual difficulty witnout a compensating ircrease in the level or quality of safety.
1.
Describe Code requirement.
2.
Describe citernative, if any, 3.
Describe why the Code requirements would result in hardship (as opposedtoimpracticability).
4.
Explain basis for conclusion that (1) the proposed testing provides reasonable assurance of operational readiness, and (2) compliance would result in hardship without a compensating increase in safety.
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Alterr.3tive testing is performed in cases where the Code requirements are impracticable... giving due consideration to the burden upon the licensee if the requirements had to be met.
1.
Describe the Code requirement.
2.
Describe the proposed alternative, if any.
3.
Describe why the Code requirements are impractical.
4.
Describe the burden if the Code requirements had to be met, e.g.,
system would have to be redesigned or a component would have tu be reploced.
5.
Explain basis for conclusion that the proposed testing provides reasonable assurance of operational readiness based on the impracticability of complying with the Code requirements and the
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burden if the Code requirements had to be met.
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