ML20207S198
| ML20207S198 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 03/09/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20207S190 | List: |
| References | |
| NUDOCS 8703190113 | |
| Download: ML20207S198 (10) | |
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UNITED STATES
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WASHINGTON, D. C. 20555
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SAFETY-EVALUATION BY THE OFFICE OF NUCLEAR REACTGP REGULATI0h SUPP0FTING AMENDMENT NO. 51 TO FACILITY OPERATING LICENSE NO. DPR-34 PUBLIC SERVICE COMPANY OF COLORADO FORT ST. YRAIN NUCLEAR GENERATING STATION DOCKET NO. 50-267 l
1.0 INTRODUCTION
By letter dated December 30,1983 (Reference 1), the Public Service Company of Colorado (PSC) proposed changes to the Fort St. Vrain Technical Specifications concerning inservice inspection and testing (ISIT) requirements. The proposed changes are a continuation of the ISIT upgrade program initiated in response to a commitment in Section 3.3 of the Safety Evaluation Report of January 20, 1972 l
(Reference 2), to review the inservice inspection program five years l
following the start of commercial operation. The Nuclear Regulatory i
Commission (NRC) and PSC agreed to a staged and prioritized upgrade program with those systems of highest priority id3ntified as j'
Category I (Reference 3). Our reviews and revisions of essentially
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all the Category I systems were issued on March 8, 1983 (Reference 4), as License Amendment No. 33 together with a sup?orting Safety i.
Evaluation. Reference 1 addressed a single Category I s,urveillance i
interval and certain Category II and III changes, but does not ecmplete the upgrade program.
During the week of July ?2,1985, the staff met with the licensee to discuss its review of Reference I and on August 27, 1985, transmitted its review of Reference I to PSC (Reference 5). PSC respended on November 27,1985 (Reference 6), with a proposed set of surveillance Technical Specifications and comments on the staff's evaluation and review. On May 30, 1986, the staff provided comments and a draft Safety Evaluation (Reference 7) in response to the November 27, 1985 document.
PSC responded to this document on September 4, 1986 (Reference 8), with proposed Technical Specifications based on the previcus correspondence and discussions with the staff. This Safety c
Evaluation approves the Technical Specifications proposed in Reference 8 with the exception of SR 5.3.9 - Safety Valve Surveillance. Five additional surveillance requirements were originally proposed in Reference 6.
These are SR 5.2.7 - Water Turbine Drive Surveillance.
SR 5.2.21 b) - ACM Transfer Switches, Valves and Instrument Surveillance, SR 5.4.5 - PCRV Cooling Water System Temperature Surveillance, SR 5.5.3 - Reactor Building Exhaust System Surveillance, and SR 5.7.2 a)
- Fuel Storage Facility Surveillance. The staff will address these six surveillance requirements separately in future communications with 0703190113 870309 PDR ADOCK 05000267 p
o PSC, making use of material being developed by the TecFrical Specificatior.s Upgrade Program (TSUP) now underway.
The staff used the ASME Boiler and Pressure Yessel Code,Section XI, Division 2, " Rules for Inspection and Testing of Components of Gas Cooled Reactors," as initial guidance in performing the reviews of the proposed Technical Specifications changes in References I and 6.
In Reference 8, PSC comeitted to follow the guidance of the ASME Code,Section XI, Divisions 1 and 2, as appropriate, in implementing detailed surveillance procedures. Because of this blanket commitment, the staff has not required explicit statements of Code conformance within the individual Technical Specifications.
GENERAL CONSIDERATIONS The fellowing items surrrnarire general considerations used throughout the staff's review:
1.
The NPC has not yet formally adopted Section XI, Division 2 of the ASME Code. This is due to both a lack of resources for the NRC to participate i'. the final stages in the Code's development and to a technical concern. The technical concerr.
pertains to Articles 1GB-1221, " Exemptions Based on Component Function," and IGB-1223, " Exemptions Based on Component Size,"
which would exempt from examinations those connections to the primary system for which failure would not result in a rate of depressurization greater than that used for the design basis accident. While the staff believes exemptions for connections of the size of instrument lines are acceptable, as is permitted for LWRs, substantially larger sizes, and certainly those approaching the reference cross-sectional area for a design basis accident, should not be exempted from review.
Although the Division 2 Code has not been adopted by the NRC, it is useful for guidance in many areas of gas reactor ISIT, and the staff has thus accepted the ccmmitment from PSC to use its guidance as appropriate.
In the present action, PSC has proposed changes and upgrading of many surveillance requirements for safety related water systems. For this reason, sections of the ASME Code in Division 1 are more relevant than Division 2 and will be used by the licensee as appropriate in its detailed surveillance plan. Procedures and requirements based on the ASME Code will be contained in the " Fort St. Vrain Ins'ervice and Testing Program Plan" now under preparation by PSC. This document will be reviewed by the NRC.
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As stated previously, the ISIT upgrade program is not yet complete.
In addition tc the six surveillance requirements identified above, the fcilowing systems listed in Table 1 remain outstanding:
TABLE 1 CATEGORY II SYSTEMS CONTROL AND ORIFICE ASSEMBLY (12*)
NITROGEN SYSTEM (25)
EMERGENCY FEED AND CONDENSATE SYSTEM (31)
PURIFICATION COOLING WATER SYSTEM (47)
' CATEGORY III SYSTEMS FUEL STORAGE FACILITY AUXILIARY SYSTEM (14)
CONTROL COMPLEX HVAC (75)
FIRE PUMP HOUSE HVAC (75)
AUXILIARY BOILER FUEL OIL SYSTEM (84)
ESSENTIAL ELECTRIC POWER SYSTEM (92)
CATEGORY IV SYSTEMS FEED AND CONDENSATE SYSTEMS (31, 32, 33)
DECAY HEAT REMOVAL HEAT EXCHANGEP (42)
FIRE PROTECTION SYSTEM (45)
CO SYSTEM (51) 2 TUPBINE STEAM SYSTEMS (52, 53, 54, 55)
- System number as per Reference Design Book
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TABLE 1 (cont'd)
CATEGORY IV SYSTEMS RADI0 ACTIVE LIQUID WASTE STORAGE SYSTEM (62)
PADI0 ACTIVE GAS WASTE SYSTEM (63)
FUEL STORAGE WELL HVAC (73)
PCRV ENVIRONMENT MONITORING (73)
C0hTROL COMPLEX ENVIRONMENTAL MONITORING (75)
AUXILIARY BOILER (84)
PRIMARY AND AUXILIARY ELECTRIC POWER SYSTEM (92)
COOLANT MEASUREMENT DISPLAY SYSTEM (93) i OVERALL PLANT CONTROL SYSTEM (93)
PCRV INSTRUMENTS AND DATA ACQUISITION SYSTEM (93)
FAST GAS AND IODINE SAMPLING SYSTEM (93)
CONTROLRODANDORIFICINGCONTROLSYSTEM(93)
STEAM GENERATOR THEPM0 COUPLE AND STRAIN GAUGE INSTRUMENTATION SYSTEM (93)
ANALYTICALINSTRUMENTATIONSYSTEM(93) 1 2
The review of the surveillance requirements for these systems is expected to be accomplished mainly in the comprehensive TSUF initiated by PSC (Reference 9).
In this program, the Technical Specifications are being reorganized in the general fonnat of NRC's PWR Standard i
Technical Specifications.
In Reference 3 PSC provided a listing, divided into the four priority categories, of all the systems to be reviewed in the context of the 1972 commitment regarding upgraded ISIT requirements given in Reference 2.
In Reference 5, the staff stated that before it can consider PSC to be in compliance with its 1972 comittent on
.I ISIT, PSC should review the listing of the surveillances given in j
all four priority categories, make modifications if needed, and then l
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- certify to the program's completeness. The staff also requestod that PSC reconsider the discussion and recommencations in the December 22, 1981 document, " Review of the Public Service Company of Colorado Proposed Inservice Inspection Progran," prepared by ASTA, Inc. While the staff is aware that PSC considered the ASTA document previously, the staff recommends that PSC reconsider this document in light of recent developments at FSV concerning corrosion due to moisture ingress, the commitments to the TSUP (regarding PCRV depressurization),
and its comments in Reference 2 with respect tc visual inspections of the lower plenum.
2.0 EVALUATION Changes to the following surveillance requirements were proposed by PSC in Reference 8 and are reviewed by this amendment action:
TABLE 2 CATEGORY II SYSTEMS SR 5.2 PRIMARY COOLANT SYSTEM-SURVEILLANCE REQUIREMENTS SR 5.2.8 HELIUM CIRCULATOR BEARING WATER PUMPS AND MAKEUP PUMP SURVEILLANCE SR 5.2.0 PELIUM CIRCULATOR BEARING WATER ACCUMULATOPS SURVEILLANCE SR 5.2.10 b,d) FIRE WATER SYSTEM / FIRE SUPPRESSION WATER SYSTEM SURVEILLANCE SR 5.2.16 g)
PCRV CLOSURE LEAKAGE SURVEILLANCE RE0VIREMENTS SR5.2.21a)
ACM TRANSFER SWITCHES, VALVES AND INSTRUMENT SURVEILLANCE SR 5.2.24 b,d, REACTOR AUXILIARY C00 'NG WATER SYSTEMS SURVEILLANCE e,f,g,h)
SR 5.3.4 SAFE SHUTDOWN COOLING.f1VES SURVEILLANCE SR 5.4.5 PCRV COOLING WATER SYSTEM FLOW INSTRUMENTS SURVEILLANCE
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- g e The staff's evaluation of each of these proposed changes is stated below:
1.
SR 5.2 - Primary Coolant System-Surveillance Requirements The addition of the phrase "and to the surveillance of the reactor auxiliary systems" to the section on Applicability is acceptable.
2.
SR 5.2.8 - Helium Circulator Bearing Water Pumps and Fakeup Pump Surveillance The bearing water makeup pumps were added to this survefilance in Reference 1.
In Reference 6, in response to the staff's comment, circulating bearing water pumps were added to the title.
a.
The inspection interval is now stated as 92 days which is consistent with the practice of the Standard Technical Specifications.
b.
The inspection interval is now stated as 92 days which is consistent with the practice of the Standard Technical Specifications, d.
The proposed surveillance for the bearing pumps provides for a functional test of the pumps and associated instruments and controls at each scheduled plant shutdown, or at the next scheduled plant shutdown if less thar, a year has elapsed from the previous test. This schedule would not disrupt normal plant operation and provides a test not previously required. The inspection interval is stated not to exceed 18 months.
As revised by Reference 6 and in accordance with the commitment to utilize the ASME Code in a Surveillance Procedures document, the staff finds SR 5.2.8 acceptable.
3.
SR 5.2.9 - Helium Circulator Bearing Water Accumulators Surveillance The proposed test interval for testing of the helium circulator bearing water accumulators, instruments and controls was extended from monthly to 92 days. The licensee justified this change on a review of prior test results which shows satisfactory performance with the accumulator checked quarterly. Based on this justification, the staff finds the proposed change acceptable.
A.
SR 5.2.10 - Fire Water System / Fire Suppression Water System Surveillance b)
A reduction by 5 percent in the flow and head testing requirements for the firewater pumps has been proposed to account for pump degradation. Degradation to this degree is
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. acceptable ur. der the ASPE Code and the pump perforrrance contir.ues to exceed the minimum performance requirements by a sufficient margin. The staff finds the proposed changes acceptable.
d)- The fire suppression water system pressure is changed to read "275 feet water gauge" from "125 psig." This is an acceptable change.
5.
SR 5.2.16 - PCRV Closure Leakage Surveillance Requirements g)
The change proposed in Reference 1 requires that a leakage test be perfomed once during each refueling cycle for each helium purification cooler well closure. This reference also proposes a calibration of the well pressure monitoring instruments and a functional test of the instruments and controls used to automatically isolate the purification system a.t the same frequency.
T'.e addition of this surveillance requirement verifies the operability of instruments used to monitor containment integrity.
In accordance with PSC's commitment to utilize the ASME Code in the Surveillance Procedures document (i.e.,Section XI, Article 1Gs-2000. " Examination and Testing"), the staff finds SR 5.2.16 acceptable.
6.
SR 5.2.21 - ACM Transfer Switches, Valves, and Instrument Surveillance The surveillance requirement has been retitled from the previous title of SR 5.2.21 - Handvalve and Transfer Switch Surveillance.
a)
For those valves and transfer switches that must be manually positioned for actuation of the Alternate Cooling Method (ACM) mode of operation, the licensee proposed in Reference I to change the surveillance interval to
" annually or at the next scheduled plant shutdown if such a test was not performed during the previous year." While the staff understands that full operation of these valves and switches is not possible during plant operation, the staff nevertheless believes that it is necessary to demonstrate operability of these components more frequertly.
In References 6 and.8, PSC prep)osed that the original surveillance interval (4 to 8 months for an operability check of this equipment be maintained and stated that a full functional test will be performed at refueling intervals not to exceed 18 months.
The staff finds SR 5.2.21 acceptable as stated in References 6 and 8.
7.
SR 5.2.?4 - Reacter Auxiliary Coolina Water Systems Surveillance The title of this surveillance requirement was changed in Reference 6 from Circulation Water Makeup System Surveillance.
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The surveillance interval for the functional testing of each circulatir.cJ water makeup pump was proposed in Reference 1 to be extended to monthly from weekly. As the monthly interval is in accordance with the ASME Code and surveillance requirements have been acced to the proposed change regarding instrument calibration, pump pteforn6nce cepability, and mechanical condition, the staff finds the proposed change acceptable, d)
The proposed surveillance requirement is a new requirement pertaining te the integrity of the circult. ting water makeup pond embankments. The proposed addition is consistent with LWR service water requirements and is acceptable, e)
The propcsed surveillance requirement is a new requirement pertaining to the testing of each water pump and the associated instruments. On the basis of PSC's commitment tc utilize the ASME Code in the Surveillance Procedures document, the staff finds SR 5.2.24 e) acceptable, f)
The proposed surveillance requirement is a new requirement pertaining to the testing of each reactor plant cooling water pump and the associated instruments and controls.
On the basis of PSC's commitment to utilize the ASME Code intheSurveillanceProceduresdocument,thestafffings SR 5.2.24 f) acceptable.
g)
The proposed surveillance requirement is a new requirement pertaining to the testing of each purification cooling water pump and the associated instruments and controls. On the basis of PSC's comitment to utilize the ASME Code in the Surveillance Procedures document, the stafffindsSR5.2.24g) acceptable.
h)
The proposed surveillance recuirement is a new requirerent pertaining to the testing and calibration of instruments i
and valves used for automatic isolation of portions of the reactor plant cooling water system. The staff finds that an interval of each refueling cycle not to exceed 18 months for a full stroke test of each valve is acceptable for those valves that cannot be tested during plant operation. In Reference 6 the licensee stated that the interval for a functional check of those valves and instruments capable of being tested by a partial stroke should be performed semi-annually in accordance with the precedent of SR 5.2.21, which is acceptable. On the additional basis of PSC's contritment to utilize the ASME Code in the Surveillance Procedures document, the staff finds SR 5.2.24 h) acceptable.
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SR 5.3.4 - Safe Shutdown Coolina Velves' Surveillance
-In Reference 1, the licensee proposed to test valves used for safe shutdown cooling on an annual basis or following scheduled plant shutdown. As this is not acceptable except for cases where it is not physically possible to perform a more frequent surveillance, the licensee identified, in Reference 6, those valves that would be partially stroked every 92 days in accordance with Paragraphs 1GV-3411 and 1GB-3412 of Section XI, Division 2 of the ASME Code. On the additional besis of PSC's commitment to utilize the ASME Code in the Surveillance Procedures document, the staff finds SR 5.3.4 acceptable as indicated.
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SR 5.4.5 - PCRV Cooling Water System Flow Instruments Surveillance The proposed surveillance extended annual calibration of the flow scanner. instruments and alarms and the six subheader flowmeters to the next scheduled plant shutdown if they were not calibrated during the previous year. 'The staff finds this extension acceptable up to a surveillance interval not exceeding 18 months since the potential for additional plant transients is reduced and since the LWR-STS, in general, specifies surveillance intervals not'to exceed 18 months when utilizing intervals of shutdown or refueling.
In References 6 and 8, the licensee proposed an acceptable revision to SR 5.4.5 which limited the surveillance interval to 18 months.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment relates to charoes in recordkeeping, reporting, or administrative procedures or requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR $51.22(c)(10). Pursuant to 10 CFR $51.22(b), no Environmental Impact Statement or Environmental Assess-ment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
1 The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety i
of the public will not be endangered by operation in the proposed i.
manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will L
not be inimical to the common defense and security or to the health L
and safety of the public.
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Dated: March 9, 1987 j
Principal Contributor:
P. Williams
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REFERENCES O'
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1.
O. R. Lee (PSC) letter to J. T. Collir:s (NR'C), " Proposed Technical
. Specification Changes - Inservice Inspection and Testing N, ? _
Requirements," No. P-83416, December 30, 1883.
Safety Evaluation by the Division of Reactor. Licensin
,3,;
2.
Energy Commission in the Matter of Public Service Compap/ of.
Colorado, Fort Sti Vrain NJ0 leer Genh*atied Station, Docket No.\\ 50-267,,
January 20, 1972.-
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. Inspection and Testing Pr[cgram," November J. X. Fuller (PSC) lette to S. 'A. Varga (NRC) " Fort StJ'/ rain inservice 3.
30, 1979.
P. C. Wagner. (NRC) letter and enclo,s(ure so L..
R. Lee (FSC),Y " Fort,,
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St. Vrain Nuclear Generator Station Amendment No. 33 to facility h
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Operating License DPR-34," March 8, 1983.
1 5.
D. R. Hunter (NRC) letter and enclosure to 0. R. Lee (PSC),
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" Evaluation of Technical Specification Changes for Inservice U
s' Inspection and Testing'.Tequircrents," August 27, N 65. N '
5(
'N O. R. Lee (PSC) letter to I,l. L'. Berkow (NRC), " Proposed Technical, 6.
Specification Changes - Inservice Inspection and Testing l
Requirements," November 27, 1985.
6 3
o' 7.
H. N. Berkow (NRC) letter to R. F. Walker (P'SC), " Fort StbVrai'i i' N
c Draft Safety Evaluation Report (SER) - Technical Specificatipn s
3 Changes for Category I and II Inservice Inspection and Testirp
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Program (ISIT) Surveillance Requirements," May 30, 1986.
N 8.
R. F. Walker (PSC) letter to H. N. Berkow (NRC), " Proposed sechn' cal V
Specification Changes - Inservice Inspection and Testing Y
Requirements," No. P-86498, September 4,1986.
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9.
O. R. Lee (PSC) letter to E. H. Johnson (NRC), " Technical Specification Upgrade Program," December 20, 1984.
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