ML20211B855
| ML20211B855 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/30/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20211B839 | List: |
| References | |
| TAC-53417, NUDOCS 8606120097 | |
| Download: ML20211B855 (21) | |
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ENCLOSURE 2 Draft Safety Evaluation Report 8606120097 860530 i
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DRAFT SAFETY EVALUATION REPORT TECHNICAL SPECIFICATION CHANGES FOR CATEGORY I AND II INSERVICE INSPECTION AND TESTING PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION DOCKET 50-267 INTRODtlCTION By letter dated December 30, 1983, (Reference 1) the Public Service Company of Colorado (PSC) proposed changes to the Fort St. Vrain Technical Specifica-tions concerning inservice inspection and testing requirements (ISIT). These proposed changes are a continuation of the ISIT cpgrade program initiated in response to a commitment in Section 3.3 of the Safety Evaluation Report of January 20, 1972, (Reference 2) to review the in-service inspection program five years following the start of commercial operation. The Nuclear Regulatory Commission (NRC) and PSC agreed to a staged and prioritized upgrade program with those systems of highest priority identified as Category I (Reference 3). Our reviews and revisions of essentially all the Category I systems were issued on March 8, 1983, (Reference 4) as License Amendment No.
33 together with a supporting Safety Evaluation Report. Reference 1 addressed a single Category I surveillance interval and certain Category II and III changes but does not complete the upgrade program.
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. During the week of July 22, 1985, we met with the licensee to discuss our review of Reference 1 and on August 27, 1985, we transmitted by letter our review of Reference 1 to PSC (Reference 5). PSC responded on November 27, f
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1985, (Reference 6) with a proposed set of surveillance Technical Specifications and comments on our evaluation and review. This draft Safety Evaluation Report provides our comments on the proposed Technical Specifications in Reference 6, with the exception of five surveillance requirements for which we need additional information. These are SR 5.2.7 - Water Turbine Drive Surveillance, SR 5.2.21 b) - ACM Transfer Switches, Valves, and Instrument Surveillance, SR 5.4.4 - PCRV Cooling Water System Temperature Surveillance, SR 5.5.3 - Reactor Building Exhaust System Surveillance and SR 5.7.2 -
Fuel Storage Facility Surveillance. We will address these specifications separately in future communications with PSC, making use of material being developed by the Technical Specification Upgrade Program (TSUP) ncw underway.
We used the ASME Boiler and Pressure Vessel Code,Section XI, Division 2,
" Rules for Inspection and Testing of Components of Gas Cooled Reactors," as guidance in performing our reviews of the proposed technical specification changes in Reference 1 and Reference 6. In Reference 6, PSC committed to use the detailed provisions of the Code, including testing procedures and accep-tance criteria, in developing a formal and detailed Surveillance Procedures document for plant use and our later review. We have added statements to the applicable Technical Specifications that conform these surveillance require-ments to the commitments made in. Reference 6. This was done in addition to
4 our usual custom review practice for Fort St. Vrain, which is based upon the accumulated operating experience, as well as consideration of the safety ,
importance of systems or determined by the safety analyses and the unique design features of the facility.
GENERAL CONSIDERATIONS .
The following items summarize general considerations used throughout our review:
- 1. The NRC 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 in the final stages in the Code's development and to a technical concern.
The technical concern pertains to Articles 1GB-1221, " Exemptions Based on Component Function," and 1GB-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 we believe that exemptions for connections of the size of instrument lines are acceptable, as is permitted for LWRs, substantially larger size connections, especially 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 cooled reactor ISIT, and we have accepted commitments from PSC where its use is practical and warranted. In the present action, PSC has proposed changes and upgrading of many surveillance requirements for safety related water systems. For this reason, sections
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, of the ASME Code dealing with pumps (Article 1GP) and valves (Article IGV) were particularly relevant to our review and in the development of acceptable Technical Specifications. In general, these sections were modeled after corresponding sections of the ASME code for LWRs and were judged, in many cases, to be directly pertinent to inspection and testing of the safety related water systems of Fort St. Vrain.
The licensee plans to continue to commit to referencing applicable sections of the Division 2 ASME Code to deal, as appropriate, with the remaining portions of ISIT upgrading. This reference to the Code, where applicable, allows for a more expeditious staff review of the surveillance Technical Specifications. The Code procedures and require-ments will be contained in the Surveillance Procedures document now under preparation by PSC.
, 2. As stated previously, the inservice inspection upgrade program is not yet complete. In addition to the five surveillance requirements identified
, above, the following systems listed in Table I remain outstanding.
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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 HX (42)
FIRE PROTECTION SYSTEM (45)
CO2 SYSTEM (51)
TURBINE STEAM SYSTEMS (52, 53, 54, 55)
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. TABLE 1 (cont'd) i RADI0 ACTIVE LIQUID WASTE STORAGE SYSTEM (62)
RADI0 ACTIVE GAS WASTE SYSTEM (63)
FUEL STORAGE WELL HVAC (73)
PCRV ENVIRONMENT MONITORING (73)
CONTROL COMPLEX ENVIRONMENT MONITORING (75)
AUXILIARY BOILER (84)
PRIMARY AND AUXILIARY ELECTRIC POWER SYSTEM (92)
COOLANT MEASUREMENT DISPLAY SYSTEM (93) ,
OVERALL PLANT CONTROL SYSTEM (93)
PCRV INSTRUMENTS AND DATA ACQUISITION SYSTEM (93)
FAST GAS AND IODINE SAMPLING SYSTEM (93) {
CONTROL R0D AND ORIFICING CONTROL SYSTEM (93)
S/G T/C AND S/G INSTRUMENTATION SYSTEM (93)
ANALYTICAL INSTRUMENTATION SYSTEM (93) {
The review of the surveillance requirements for these systems is expected to t
be accomplished mainly in the comprehensive Technical Specification Upgrade Program initiated by PSC (Reference 7). In this program the Techr;ical Speci-fications are being reorganized in the general format of NRC's PWR Standard Technical Specifications.
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o In Reference 3, PSC provided a listing, divided into the four priority cate-gories, of all the systems to be reviewed in the context of the 1972 commit-ment regarding upgraded ISIT requirements given in Reference 2. In Reference ,
5, we stated to PSC that before we can consider PSC to be in compliance with its 1972 commitment, PSC should review this listing, make modifications if needed, and then certify to its completeness. The staff also requested that PSC review the December 22, 1981 document prepared by ASTA, Inc., " Review of the Public Service Company of Colorado Proposed Inservice Inspection Program," and incorporate the guidance of this document in their response. While we are aware that PSC reviewed the ASTA document previously, we recommend that PSC ,
reconsider this docv;ent in light of recent developments at FSV concerning:
corrosion due to moisture ingress; the comitments to the TSUP (regarding PCRV ,
depressurization); and our comments in Reference 2 with respect to visual inspections of the lower plenum.
EVALUATION Changes to the following surveillance requirements were submitted by PSC and are reviewed by this amendment action:
TABLE 2 CATEGORY I SYSTEMS SR 5.3.9 SAFETY VALVES SURVEILLANCE CATEGORY II SYSTEMS SR 5.2 PRIMARY COOLANT SYSTEM-SURVEILLANCE REQUIREMENTS SR 5.2.7 WATER TURBINE DRIVE SURVEILLANCE SR 5.2.8 CIRCULATOR BEARING WATER PUMP AND MAKEUP PUMP SURVEILLANCE ,
SR 5.2.9 HELIUM CIRCULATOR BEARING WATER ACCUMULATORS SURVEILLANCE SR 5.2.10 (b,d) FIRE WATER SYSTEM / FIRE SUPPRESSION WATER SYSTEM SURVEILLANCE .
To be completed later making use of material being developed by the Technical Specifications Upgrade Program (TSUP) now underway.
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. I TABLE 2 (cont'd) i CATEGORY II SYSTEMS SR 5.2.16 g) PCRV CLOSURE LEAKAGE SURVEILLANCE REQUIREME4TS SR 5.2.21 ACM TRANSFER SWITCHES, VALVES, AND INSTRUMENTS SURVEILLANCE
- SR 5.2.24 REACTOR AUXILIARY COOLING WATER SYSTEMS SURVEILLANCE SR 5.3.4 SAFE SHUTDOWN COOLING VALVES SURVEILLANCE SR 5.4.4 PCRV COOLING WATER SYSTEM TEMPERATURE INSTRUMENTS SURVEILLANCE SR 5.4.5 PCRV COOLING WATER SYSTEM FLOW INSTRUMENTS SURVEILLANCE
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SR 5.5.3 REACTOR BUILDING EX'tAUST SYSTEM SURVEILLANCE CATEGORY III SYSTEMS SR 5.7.2 FUEL STORAGE FACILITY SURVEILLANCE Our 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 5.2.7 - Water Turbine Drive Surveillance We will review this surveillance requirement in accordance with material being developed in the TSUP, Specification 4.5.1, " Helium Circulators,"
and Will provide our evaluation at a later date, s
To be completed later making use of material being developed by the Technical Specifications Upgrade Program (TSUP) now underway.
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- 3. SR 5.2.8 . C1rculator_ Rearing %'eter Pumps and Makeup Pump Surveillance The bearing water makeup cumps were added to this surveillance in Refer-ence 1. In P3ference e, in response to our co9snsnt, circulatihg . bearing water pumps were addsd to the title. Iri regard to utiliidtic'n of the ASME Code, we added the following phrase to tlie first ser)tence of this requirement; "with the detailed survei'ilance requirements in general
. accord with the provisions of the ASME Code,Section XI, Division 2, subsectic!) IGP."
- a. The inspection interval is now stated as 92 43ys which is consistent with the practice of the Standard Technical Specifications.
The inspection interval is now stated as 92 days which is b.
consistent with the practige of the Standard Techijical Specificaticos.
- d. Tne proposed surveillance for the b6aring pumps provides for a functional test of the pumps and associated instruments and con-trols at each scheduled plant shutdown, or at the next scheduled plant shutdown if less than 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 as modified by the stated requirements pertaining to the ASME Code, we find Surveillance 5.2.8 acceptable.
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- 4. SR 5.2,9 - H_elium 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 we find the proposed change acceptable.
- 5. 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 degra-dation. Degradation to this degree is acceptable under the ASME Code and the pump performance continues to exceed the minimum per-formance requirements by a sufficient margin. We find the proposed changes acceptable.
d) The fire suppression water system pressure is changed to read "275 feet water gpuge" from "125 psig." This is an acceptable change.
- 6. SR 5.2.16 . PCPN Closure Leakage Survaillance Requirements g) The change proposed in Reference 1 requires that a leakage test be performed once during each refueling cycle for each helium purification cooler well closure. This reference also proposes a calibrstion of tne well pressure monitoring instruments and
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. a functional test of the instruments and controls used to automati-cally isolate the purification system at the same frequency. The addition of this surveillance requirement verifies the operability of instruments used to monitor containment integrity. In accordance with PSC's comment in Reference 6, we request PSC add the statement; "The proposed leakage test will be in general accord with the ASME Code,Section XI, Article 1G8-2000, Examination and Testing." As thus modified we find SR 5.2.16 acceptable.
- 7. 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 posi-tioned for actuation of the Alternate Cooling Method (ACM) mode of operation, the licensee proposed in Reference 1 to change the sur-veillance interval to annually or at the next scheduled plant shut-down if such a test was not performed during the previous year.
While we understand that full operation of these valves and switches is not possible during plant operation, we nevertheless believe that it is necessary to demonstrate operability of these components more frequently. In Reference 6, PSC proposed 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. We find SR 5.2.21 acceptable as stated in Reference 6.
b) A new surveillance requirement for calibration at each refueling interval has been proposed for local indicators for the helium purification dryer inlet temperature, for the helium purification pumpdown line pressure and for the reactor plant cooling water surge tank cover gas pressure. From the information provided by both References 1 and 6 it is not clear that: (1) these proposed surveillances are sufficient to assure operational readiness of these components, and (2) the components to be given surveillance provide a complete set to assure operational readiness of the sys-tems they serve. Therefore, we cannot agree to this surveillance until further information is provided. We plan to make use of material being developed by the TSUP, including Surveillance 4.7.5,
" Primary Coolant Depressurization" to resolve this issue.
- 8. SR 5.2.24 - Reactor Auxiliary Cooling Water Systems Surveillance The title of this surveillance requirement was changed in Reference 6 from Circulation Water Makeup System Surveillance, b) The surveillance interval for the functional testing of each circu-lating water makeup pump was proposed in Reference I to be extended to monthly from weekly. As the monthly interval is in accordance with the ASME Code and surveillance requirements have been added to the proposed change regarding instrument calibration, pump performance capability and mechanical condition, we find the proposed change acceptable with the addition to the Technical Specification of the
words: '"The detailed surveillance requirements for the circulating
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bearing water pumps shall be in general accord with the ASME Code,Section XI, Division 2, Subsection IGP."
d) The proposed surveillance requirement is a new requirement pertaining to the integrity of the circulating water makeup pond embankments.
The proposed addition is consistent with LWR requirements and is acceptable.
e) The proposed surveillance requirement is a new requirement pertain-ing to the testidg of each service water pump and the associated instruments. On the basis of Reference 6, we have added the following statement to this requirement; "The detailed surveillance requirements
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shall be in general accord with the provisions of the ASME Code,Section XI, Division 2, Subsection 1GP." As thus modified, we find SR 5.2.21 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 Reference 6, we have added the following statement to this requirement; "The detailed surveillance requirements shall be in general accord with the provisions of the ASME Code,Section XI, Division 2, Subsection 1GP." As thus modified, we find SR 5.2.24 f) acceptable.
g) The proposed surveillance requirement is a new requirement pertain-ing to the testing of each purification cooling water pump and the associated instruments and controls. On the basis of Reference 6, we have added the following statement to this requirement; "The detailed surveillance requirements shall be in general accord with the provisions of the ASME code,Section XI, Division 2, Subsection IGP." As thus modified, we find SR 5.2.24 g) acceptable.
h) The proposed surveillance requirement is a new requirement pertaining to the testing and calibration of instruments and valves used for automatic isolation of portions of the reactor plant cooling water system. We find 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 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 basis of Reference 6, we have added the following statement to this requirement: "The detailed surveillance requirement for valves should be in general accord with the provisions of the ASME Code,Section XI, Subsection 1GV." As thus modified, we find SR 5.2.24 g) acceptable.
- 9. SR 5.3.4 - Safe Shutdown Cooling Valves Surveillance In Reference 1, the licensee proposed to test valves used for safe shut-down cooling on an annual basis or following scheduled plant shutdown.
As this is not acceptable, c.n.ept for cases where it is not physically possible to perform a more frequent surveillance, the licensee in Refer-ence 6 identified 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. We find this acceptable with the addition of the statement; "The detailed surveillance requirements shall be per-formed in general accord with the provisions of the ASME Code,Section XI, Division 2, Subsection 1GV."
- 10. SR 5.3.9 - Safety Valves Surveillance a) The surveillance proposed in Reference 1 required verification of safety valve setpoints at five year intervals for the steam genera-tor superheater and steam / water dump tank. The requirement was judged acceptable provided (1) that a schedule for additional test-ing was developed for any valve in a system that fails to function on a regular test and (2) that an acceptable test procedure was developed and referenced. PSC committed to these changes ir.
Reference 6. The following statement was added to this requirement; "The detailed surveillance requirements shall be performed in general accord with the provisions of the ASME Code,Section XI, Division 2, Subsection IGV."
, b. In Amendment 39(01/25/84) the licensee removed SR 5.3.9 b) which addressed all other Class I safety valves. We have restored and reworded SR 5.3.9 b) on the basis of the commitments given in Refer-ence 6.
On the basis of the added statement to part a), and the restora-tion of part b), we find SR 5.3.9 acceptable.
- 11. SR 5.4.4 - PCRV Cooling Water System Temperature Instruments Surveillance This surveillance requirement will be revised and approved in accordance with material being developed in the Technical Specification Upgrade Program (TSUP), Specification 4.6.2.1, " Reactor Plant Cooling Water /PCRV Liner Cooling System."
- 12. SR 5.4.5 - PCRV Cooling Water System Flow Instruments Surveillance The proposed surveillance extended annual calibration of the flow scanner l instruments and alarms and the six subheader flowmeters to the next l
! scheduled plant shutdown if they were not calibrated during the previous '
year. We find 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 Reference 6, the licensee proposed an acceptable revi-sion to SR 5.4.5 which limited the surveillance interval to 18 months.
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- 13. SR 5.5.3 - Reactor Building Exhaust System Surveillance This surveillance requirement will be revised and approved in accordance with material being developed in the TSUP, Surveillance 4.6.5.C.3,
" Reactor Building Exhaust System."
- 14. SR 5.7.2 - Fuel Storage Facility Surveillance This surveillance requirement will be revised and approved in accordance ,
with material being developed in the TSUP, Surveillance 4.9.3, " Fuel Storage Well."
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i REFERENCES
- 1. O. R. Lee (PSC) letter to J. T. Collins (NRC), " Proposed Technical Specification Changes - Inservice Inspection and Testing Requirements," No. P-83416, December 30, 1983.
- 2. Safety Evaluation by the Division of Reactor Licensing, U.S. Atomic Energy Comission in the Matter of Public Service Company of Colorado, Fort St. Vrain Nuclear Generating Station, Docket No. 50-267, January 20, 1972.
- 3. J. K. Fuller (PSC) letter to S. A. Varga (NRC), " Fort St. Vrain Inservice Inspection and Testing Program," No. P-79289, November 30, 1979.
- 4. P. C. Wagner (NRC) letter and enclosure to 0. R. Lee (PSC), " Fort St.
Vrain Nuclear Generator Station, Amendment No. 33 to Facility Operating License DPR-34," March 8, 1983.
- 5. D. R. Hunter (NRC) letter and enclosure to 0. R. Lee (PSC),
" Evaluation of Technical Specification Changes for Inservice Inspection and Testing Requirements," August 27, 1985.
- 6. O. R. Lee (PSC) letter to H. N. Berkow (NRC), Proposed Technical Specification Changes - Inservice Inspection and Testing Requirements,"
November 27, 1985.
- 7. O. R. Lee (PSC) letter to E. H. Johnson (NRC), " Technical Specification l
Upgrade Program," December 20, 1984.
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DISTRIBUTION: '
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Local PDR SSPD Reading PNoonan CHinson 0 Lynch HBerkow OELD EJordan BGrimes _
GPlumlee ,
JPartlow ACRS (10) ,
PWilliams 1
May 30, 1986 Surveillance Procedures document. In order to reinforce this commitment, and to document the use of the ASME Code, we have added reference to the ASME Code to the affected sections of the Technical Specifications. These references to the ASME Code should be incorporated into the current plant Technical Specifications.
In addition to the five unreviewed Category II and III surveillance requirements mentioned above, the balance of the Category III and IV surveillance requirements remains outstanding. Because of the lower priorities of these Category III and IV surveillance requirements, they will be reviewed as part of the FSV TSUP.
This is a change from our originally agreed upon ISIT upgrade plan described in the November 30, 1979 letter from J. K. Fuller (PSC) to S. A. Varga (NRC).
In Reference 2, we stated that before we can consider PSC to be in compliance with its 1972 commitment on ISIT, PSC must review the listing of the surveillance requirements given in all four priority categories, make modifications if needed, and then certify to the program's completeness. In this regard, PSC should reconsider the discussion and recommendations contained in the December 22, 1981 document, " Review of the Public Service Company of Colorado Proposed Inservice Inspection Program," prepared by ASTA, Inc. This document contains several recommendations for ISIT at FSV. While we are aware that PSC has reviewed the ASTA document previously, we recommend that PSC reconsider this document in light of recent developments at FSV concerning: corrosion due to moisture ingress; the commitments of the TSUP (regarding PCRV depressurization); and our comments in Reference 2 with respect to visual inspections of the lower plenum. We request that ycu incorporate the changes and recommendations to the nine surveillance requirements contained in the enclosed draft SER and resubmit your proposed Technical Specification changes within 45 days of the date of this letter.
If you have any questions or comments regarding the above, please contact Charles Hinson, NRC Co-Project Manager for your facility, at (301) 492-7930.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, i original signed b
! Herbert N. B'erkow,y Director Standardization and Special Projects Directorate Division of PWR Licensing-B
Enclosures:
- 1. Approved Technical Specification Changes
- 2. Draft Safety Evaluation Report cc w/ enclosures:
See,next page l D SPD f SPD D -B:SSPD DP . SPD PH r DPWRl(h:cw CHinsc 0 ch HBe 0 6 05/$/86 05/< /86 05/y./86
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