ML20215J903

Forwards Requests for Addl Info Re Nov 1985 Draft Tech Spec Section 3/4.8 Re Electrical Sys.Encl 1 Deals w/831230 & 840626 Proposed Tech Spec Change Requests.Encl 2 Encompasses Upgrade to Sts.Response Requested within 90 Days

ML20215J903
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/06/1987
From:	Heitner K Office of Nuclear Reactor Regulation
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
TAC-56565, NUDOCS 8705080323
Download: ML20215J903 (20)

Text

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May 6,1987 Docket No. 50-267 Mr.' R.' O. Williams, Jr.

Vice President, Nuclear Operations Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80202-0840

SUBJECT:

DRAFT UPDATED TECHNICAL SPECIFICATION SECTION 3/4.8, '

t REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 56565)

Please find in Enclosures 1 and 2, requests for additional information concerning the November 1985 Technical Specification draft, Section 3/4.8. This section covers the electrical systems at Fort St. Vrain. This letter supplements our letter of February 18, 1987 onthissubject. Enclosure 1 deals with previously proposed technical specification changes, described in your letters dated a' December'30, 1983 and June 26,1984(P-83415andP-84187). Enclosure 2 encom-passes upgrade to the Standard Technical S)ecifications, the July 1985 and l' December 1986 meetings with PSC, and Attac1 ment 2 to your letter of November 27, 1985 (P-85448).

PSC should review Enclosures 1 and 2 and prepare an a)propriate response.

This response should be submitted within 90 days of t1e date of this letter.

The information requested in this letter affects fewer than 10 respondents; therefore, OMB clearance is .not required under P.L.96-511.

Sincerely, j l al

)

Kenneth L. Heitner, Project Manager ProjectDirectorate-IV DivisionofReactorProjects-III, IV, V and Special Projects

Enclosures:

, As stated l cc w/ enclosures:

See next page DISTRIBUTION

~B5iEERiii NRC PDR Local PDR PD4 Reading F. Miraglia D. Crutchfield F. Schroeder 0GC E. Jordan B. Grimes J. Calvo 5 #"# K. Heitner P. Noonan ACRS (10) / PD Plant File <y D. Moses, ORNL J. Srtucher, INEL J.R. Miller,_INE F FfbA/ PD4/PM M PD4/ DIN Msii TSB J onan VHei cner: sr JCalvo tJRMller REmc 54/ j/87 S4/ EJ cher 4/p/87 5/ ' , /87 5 4/ I /87 7 3 /87 54 8705080323 870506 PDR ADOCK 05000267

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4 Docket No. 50-267 Mr. R. O. Williams, Jr. '

Vice President, Nuclear Operations ,

-Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80202-0840 l

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SUBJECT:

DRAFT UPDATED TECHNICAL SPECIFICATION SECTION 3/4.8, REQUEST FOR ADDITIONAL INFORMATION (TAC N0. 56565) 4 Please find in Enclosures 1 and 2, requests for additional information concerning.

the November 1985 Technical Specification draft, Section 3/4.8. This section covers the electrical systems at Fort St. Vrain. This letter supplements our

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4 letter of February 18, 1987 onthissubject. Enclosure 1 deals with previously l proposed i.echnical; specification changes, described in your letters dated i December 30, 1983 and June 26, 1984.(P-83415 and P-84187). Enclosure 2 encom-passes upgrade to the Standard Technical Specifications, the July 1985 and December 1986 meetings with PSC, and Attachment 2 to your letter of November 27, 1985 (P-85448).

PSC should review Enclosures 1 and 2 and prepare an a)propriate response.-

This response should be submitted within 90 days of tie date of this letter.- l The information requested in this letter affects fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, 4

l !st Kennet1 L. Heitner, Project Manager 1 ProjectDirectorate-IV Division of Reactor Projects - III, IV, V and Special Projects

Enclosures:

As stated 4

cc w/ enclosures:

See next page DISTRIBUTION Docket File NRC PDR Local PDR PD4 Reading F. Miraglia D. Crutchfield j

F.-Schroeder OGC -E. Jordan B. Grimes J. Calvo K. Heitner.

P. Noonan ACRS(10)- PD Plant File D. Moses, ORNL J. Stachew,-INEL J.R. Miller

*See Previous Concurrences: '

PD4/LA* PD4/PM* PD4/D* TSB* .TSB* -

PNoonan KHeitner

sr 'JCalvo- JRMiller REmch 4/30/87 5/01/87 5/01/87 5/04/87 5/05/87 l t

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. May 6,1987 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. R. O. Williams, Acting Manager GA Technologies, Inc. Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 13-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. P. F. Tomlinson, 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 Comission Mr. R. F. Walker P. 0. Box 840 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 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 Chairman, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative  !

Radiation Programs l Environmental Protection Agency  :

1 Denver Place 999 18th Street, Suite 1300  ;

Denver, Colorado 80202-2413 '

. l ENCLOSURE 1 FORT ST. VRAIN NUCLEAR GENERATING STATION DOCKET NO. 50-267 REVIEW OF NOVEMBER 1985 TECHNICAL SPECIFICATION DRAFT SECTION 3/

4.8 REFERENCES

1. NRC letter (P.C. Wagner) to Public Service Company (PSC) of Colorado (M. Holmes), August 28, 1985.

2. PSC letter (O. R. Lee) to NRC (E. H. Johnson), " Proposed Supplemental l Technical Specification Change to Sections 4.4 and 5.4," June 26, 1984, P-84187. -

3. PSC letter (O. R. Lee) to NRC (J. T. Collins), " Proposed Technical Specification Changes - Fort St. Vrain Electrical System Requirements,"

December 30, 1983, P-83415.

4. Final Draft Upgrade Technical Specifications for the Fort St. Vrain Nuclear Generating Station dated November 30, 1985, Section 3/4.8.

5. PSC letter (R. F. Walker) to NRC (H. N. Berkow), " Technical Specification Change Request to the Plant Protective System Trip Setpoints," May 15, 1986, P-86279.

This review is to compare, as directed by Action 1 of Reference 1, References 2 and 3 to the revised Technical Specification Draft (Reference 4).

Tables 4.4.5 and 5.4.5 and associated notes were to be added to the 1.

Technical Specifications by Reference 2. Reference 4 included these tables as Tables 3.3.1.5 and 4.3.1.5. We note that the time dial setting for Functional Unit 3 changed.from 6 to 5 in the process.

However, Reference 5 deleted these tables and notes, and provided no commitment to reinstate these tables regarding the bus undervoltage w-. , _, , ~ .

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protection. The licensee should verify the correct settings of these undervoltage relays and commit to having these tables and notes in the  :

upgraded Technical Specifications. It should include nominal setpoints and allowable limits (where voltage and time tolerances exist).

The following refer to Reference 3.

2. LCOs 4.6.1.1.b) and 4.6.1.2.b) parts 4)(one starting air compressor and receiver) and 5)(One Boiler Fuel Oil pump operable between the auxiliary fuel supply and the diesel fuel oil day tank (s)) were not included in Reference 4. The licensee should include these requirements in the corresponding sections.

3. LCO 4.6.1.1.d) 3) requires the DC bus to be energized from its associated battery. The corresponding section, 3.8.3.2c of Reference 4 1 does not include the words " energized from its associated battery."

The wording should be revised to include a battery that is connected to its DC bus during shutdown.

4. LCO 4.6.1.2.c) and d) require bus tie breakers to be open between buse's with different power sources. The corresponding section in Reference 4 does not include this restriction. A similar restriction in Section 4.6.2.f) for the DC system prohibits closed connections between

the DC sources. Corresponding sections of the updated Technical Specifications should prohibit the use of bus tie breakers that could prevent division independence and redundancy of the Class IE distribution system.

5. Notes from Specification LCO 4.6.1 i

2. One hour is specified to demonstrate the operability of the associated battery versus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> specified in the revised Action b under 3.8.2.1. The licensee should either continue the one hour requirement or justify extending the limit to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

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. i 6 & 11. Reference 4 does not verify that 1) the engine driven fire pump is operable or 2) that the emergency condensate header is operable as specified here. The licensee should either continue this operability verification or justify its deletion.

7. This requirement to shutdown the auxiliary boiler upon reaching the minimum fuel level is not carried over to Reference 4. The licensee should continue this requirement.

8. The conditioned allowance for the boiler fuel oil pumps to be inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not carried over to Reference 4. The licensee may want to continue this conditioned allowance.

10. This action requirement on operability of the 4160 V buses is not entirely covered by action a of 3.8.3.1 of Reference 4. The licensee should justify those differences.

11. This action requirement on the operability of these 480 VAC essential buses is not entirely covered by action a of 3.8.3.1. of Reference 4. The licensee should either justify these differences or continue these requirements.

13,14,15. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an equalizing charge is currently under discussion as Reference 4 would allow 5 days as required by the present battery design. The licensee should provide a satisfactory resolution to this issue.

6. Surveillance Requirement 5.6.1 2.a)4) The requirement to verify the operability of the boiler fuel oil pumps is not carried over to Reference 4. The licensee should continue this requirement.

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. 4) The requirement to verify the battery charger current supplying capability is not carried over to Section 4.8.2.1. The licensee should provide for this test in the upgraded technical specifications.

8. Table 5.6.2.1 (4.8.2-1)

The licensee is to provide battery specific values for this table.

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5) The option of either a manual start or an undervbitage relay test actuation signal start is not carried over to Reference 4. The licensee should explain why this option is deleted.

6) This requires a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded run time while the corresponding Section 4.8.1.1.2a.7 requires I hour. We note that the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> loaded run time is in accordance with Generic Letter 84-15 and therefore acceptable.

c) The impurity test per ASTM-D2274-70 (impurity > 2 mg insolubles

! per 100 ml) is not carried over to Section 4.8.1.1.2c.2. The licensee should either provide this requirement or justify its deletion.

d)3) This specified test is with the generator operating in parallel with the offsite power system. The corresponding section of Reference 4 (4.8.1.1.2d.4) does not specify parallel operation.

The licensee should resolve this discrepancy.

6) The verification of the diesel generator capability to transfer loads to offsite power and to be restored to standby status is not carried over to Reference 4. The licensee should justify this deletion of requirements.

i 8) The verification of the accuracy of the load sequence timers (load j sequencing programers) is not carried over to Reference 4. The 3

licensee should provide for this test in the upgraded technical specifications, for both sequence A and B and the determination of which diesel generator is first in service.

7. Surveillance Requirement 5.6.2 a

i c)3) The requirement to check the temperature difference of each j

cell-to-cell and terminal connection is not carried over to Section 4.8.2.1c of Reference 4. The licensee should justify this deletion.

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ENCLOSURE 2 FORT ST. VRAIN NUCLEAR GENERATING STATION DOCKET NO. 50-267 REVIEW 0F NOVEMBER 1985 UPGRADED TECHNICAL SPECIFICATION DRAFT SECTION 3/

4.8 REFERENCES

1. " Final Draft Upgrade Technical Specifications" for the Fort St. Vrair, Nuclear Generating Station, dated November 30, 1985, Section 3/4.8.

2. Fort St. Vrain No. 1 Technical Specifications, Amendment No. 34 dated March 21, 1983, Sections 4.6, 5.6.

3. Standard Technical Specifications for Westinghouse Pressurized Water Reactors, NUREG-0452, Revision 5 draft.

4. Attachment 2, " Justification for not Incorporating Certain NRC l Comments," to Public Service Company of Colorado (PSC) letter (O. R. Lee) to NRC (H. N. Berkow), " Upgraded Technical Specifications,"

November 27, 1985, P-85448.

5. Attachment 3, " Response to PSC Action Items Resulting From July 1985 Meeting With the NRC," IBID.

6. Meeting, PSC/NRC personnel at Fort St. Vrain, December 18, 1986.

l This review is to compare the sections regarding the auxiliary electric  ;

power system of the draft upgraded technical specifications (Reference 1) to f various criteria. These criteria are called out in the questions raised below.

. 1. Sections 3.8.1.1b.1 and 2 require the verification of fuel level in the

, day tank (minimum of 325 gallons, and in storage (minimum of 20,000 gallons). Section 3.8.1.2b.1 and 2 is similiar (325 and 10,000 gallons respectively). The surveillance section does not call out )

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this instrumentation, nor channel functional tests or a calibration check on the instrumentation used for this measurement. The licensee should describe how this measurement is done. If instrumen'tation (rather than sight glass or dip stick) is used, it should be included by the licensee in surveillance requirements for channel functional tests and calibration checks.

2. Section 3.8.1.lb does not have the following requirements for Section 4.6 of the existing Technical Specifications (Reference 2):

Section 4.6.1d.2 One starting air compressor and receiver per diesel generator set.

Section 4.6.1g Should the diesel fuel quantity be less than -

20,000 gallons, the auxiliary boiler is to be shut down.

Section 4.6.1h The requirement that at least one Boiler Fuel Oil Feed Pump is operable between the auxiliary boiler fuel supply and the day tanks.

The licensee should incorporate these existing requirements in the upgraded technical specifications.

3. Section 3.8.1.lb.4 was added per the Westinghouse Standard Technical Speci/ications (Reference 3) requiring 150 gallons of lubricating oil.

We understand that this lubricating oil is hand fed, and storage is in the shipping drums. We find this acceptable, however, the licensee should indicate that this is 150 gallons per diesel generator set.

4. Actions associated with LCO 3.8.1.1 o The requirement to "be in at least SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" is to be in HOT STANDBY (which is not an operating mode

at Fort St. Vrain) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to be in COLD SHUT 00WN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in the Westinghouse Standard Technical Specification (Reference 3). This change was justified by the licensee in their attachments 2 and 3 of their '

November 27, 1985 letter (References 4 & 5) as appropriate to the Final Safety Analysis Report, and having the unit auxiliary transformer out of service. It is also consistent with the existing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> technical specification requirement. Therefore, we find the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement acceptable.

o The statement regarding demonstrating the OPERABILITY of the

' diesel generators in Action a. is noted to be consistent with Generic Letter 84-15 and is, therefore, acceptable.

o The licensee had deleted the NRC comment regarding loss of both offsite sources in this draft. Discussion with the licensee in December 1986 (Reference 6) leaves this item to be resolved by the licensee by having some requirement regarding the loss of both offsite AC electrical power sources.

o The licensee had removed an action statement that would allow the unit auxiliary transformer to be out of service for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform switching. The justification (Reference 4) that this is covered by Action a is acceptable, o Action f is stated (Reference 5) to reflect comitments concerning the fuel oil composition. It would allow a second fuel oil sample to be taken if the first is out of tolerance, if the second is taken within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and the OPERABILITY of both diesel generators is shown in the same eight hours or has been shown in the previous seven days. We find this action acceptable.

5. Section 4.8.1.1.lb should read, per Reference 3, "At least once per 18 months during shutdown," instead of "At least once per 18 months."

! 6. Section 4.8.1.1.2a-- Reference 4 states that this is functionally equivalent to Reference 3. We find this to be so except as listed i below:

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a.3 the capability to transfer fuel oil from the storage system to the day tanks should include the Boiler Fuel 011 Feed Pumps (see comment 2 above).

i a.4 Reference 5 states that this requirement on water-jacket heaters I reflects the BWR standard technical specifications. We find this

.1 requirement acceptable, a.6 The amount of lubrication oil inventory in storage should be consistent with comment 3 above.

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7. Section 4.8.1.1.2c.2 tests on the diesel fuel oil are not directly equivalent with those called out in Reference 3. Reference 4 states i

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that they are consistent with the station's experience. The

! December 1986 meeting (Reference 6) discussed this item and left the action to the NRC to decide if the testing specified is functionally equivalent to that testing specified in Reference 3.

8. Section 4.8.1.1.2c should also include the existing SR 5.6.1d functional test of the diesel engine exhaust temperature " shutdown" and

. "declutch" functions on a 31 day basis, i

j j 9. Per Reference 3, Section 4.8.1.1.2d.4 should read "without tripping."

rather than "without tripping the diesel engines."

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10. Section 4.8.1.1.2d 5, concerning the simulated undervoltage relay l

i actuation signal, was added per Reference 3. Address the following (we note there is no ESF actuation of the diesels):

b. The words " energize the autosequenced loads," should be " energize

the autosequenced loads through the load sequencer," and "0PERATE"

' should be "0PERATES with permanently connected loads within i 10 seconds."

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.' 11. Section 4.8.1.1.2d 7, per Reference 3, should be divided into Section "a) be synchronized ...," and have added "b) transfer its loads to the offsite power source and c) be restored to its standby status."

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12. Section 4.8.1.1.2d, per Reference 3, should have the following additional sections (we note that there is no ESF actuation of the diesels):

10. Verify that the diesel fuel oil transfer pumps 1A & 18 and the Auxiliary boiler fuel oil feed pumps 1A & IB each transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines;

11. Verifying that the automatic load sequence timer is OPERABLE wfth ,

the interval between each load block within %10% of its design interval;

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! 12. Verifying that the following diesel generator lockout features i prevent diesel generator starting only when required:

(site specific)

13. Verifying that with all diesel generator air start receivers pressurized to less than or equal to psig and the compressors secured, the diesel generator starts at least (5) times from ambient conditions and accelerates to at least

( ) rpm in less than or equal to (10) seconds.

Additionally, due to the relaying used to energize bus 2 from the first l up diesel generator, a paragraph should be added to test the capability of this mechanism.

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13. Section 4.8.1.1.2f, per Reference 3, should have a pressure test added l

j on applicable portions of the diesel fuel oil system.

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14. Table 4.8.1-1

a. The test frequency at least once per 31 days isaat variance with the UFSAR, Section 8.2.3.3 which states weekly. The UFSAR should be changed accordingly,

b. For GTE 3, the test frequency should be "at least once per 7 days and see Table 4.8.1-2."

c. The last sentence for each of the table notes differs from both the standard technical specifications and Generic Letter 84-15.

For the first note the concluding sentence is not necessary for Fort St. Vrain. For the second note, there is no basis for los's of redundancy caused by not staggering the testing. Therefore, the tests should be done on a STAGGERED TEST BASIS.

15. Section 3.8.1.2b--Comment 2 also applies here, modified for startup, shutdown and refueling modes, even though existing technical specifications do not address AC power sources for these modes.

16. Section 3.8.1.2, 3.8.2.2 and 3.8.3.2, ACTION a, does not require depressurization and venting of the reactor coolant system as does Reference 3, nor suspension of crane operation with loads over the fuel storage pool. These actions are to be immediate with no 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> grace period. The standard technical specification " positive reactivity changes" has been changed to " control rod movements resulting in positive reactivity changes." This ACTION statement should more closely resemble that in Reference 3.

17. Section 3.8.2.1 and 3.8.2.2

b. The 2 hrs to demonstrate the operability of the associated battery ;

bank in ACTION b should be 1 hr per Reference 3. l l

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c. The licensee's 5 days to restore a battery due to an equalizing l charge is not adequate should the battery be inoperative due to l l

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other causes. Also there should be a cumulative limit on the number of 5 days inoperative actions each battery can use in a cycle.

18. Section 3.8.2.1 ACTION statements are being rewritten as discussed in Reference 6. Further discussion is inappropriate here.

19. Section 4.8.2.la does not measure the temperature of the cells adjacent to the pilot cell as presently required in SR 5.6.2a. The licensee l

should justify this deletion or incorporate it into the upgraded technical specifications.

20. Section 4.8.2.lb.2- " abnormal corrosion" should be " visible corrosion" per Reference 3.

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21. Section 4.8.2.1c--Per Reference 3, the following surveillance should be added- "The battery chargers will supply at least (200) amperes at (129) volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />."

22. Section 4.8.2.1d.--the words "all of the emergency loads" should be "all of the actual or simulated emergency loads" per Reference 3.

23. Table 4.8.2-1 in the Electrolyte Level row, "above indication mark" should be "above maximum level indication mark" per Reference 3.

24. Section 3.8.3.la, b, & c--the requirement for the tie breakers to be open between redundant buses is appropriate, however, for the 4160 V buses, our understanding is that one tie must be established when using the unit auxiliary transformer and two ties must be established when using the startup transformer. The 4160 V AC buses should therefore be addressed separately from the 480 V AC, the 120 V AC non-interruptible and the 125 V DC essential buses which must have the tie breakers open.

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. 8 As it now reads, operation could not occur without violating this specification.

25. 3.8.3.1 Actions

a. The following must be met according to present technical specifications:

o 4160 V bus 1B must be operable (LCO 4.6.1C.2).

o The diesel generator (s) supplying the remaining 480 V essential buses must be operable (LC0 4.6.1C.5).

o. The equipment supplied by the operable essential buses associated with safe shutdown cooling must be operable (LCO 4.6.1C.6).

o The reactor building exhaust fans supplied by the operable essential buses must be operable (LCO 4.6.1C.7).

The licensee should include these requirements or justify their deletion.

b. 1. The wording "from the alternate source should be deleted per Reference 3.- This would allow the repair of the inverter and reenergizing the bus from it.

2. The wording "the following" should be deleted per Reference 3.

c. The present technical specifications (LCO 4.6.le) allow a DC bus to be inoperable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if 5 conditions are met. A battery may be inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is less restrictive than the proposed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> /5 days. This limit needs to be resolved, i

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. -9 o The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to achieve SHUTDOWN is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in at least HOT STANDBY (which is not a Fort St. Vrain mode) and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in the Standard i Technical Specifications (Reference 3). This change was justified by the licensee in References 4 and 5 as appropriate to the Final Safety Analysis Report and having the unit auxiliary transformer out of service. It is also consistent with the existing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> battery, PPS battery and inverter requirements. Therefore, we find the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit I acceptable.

26. Section 3.8.3.2b, ends " connected to their respective battery banks,

! and" versus the Reference 3 " connected to their respective DC buses, and." Due to 120 V bus 1C/1C-1 connection to battery IC rather than a bus we suggest the following wording as the battery banks may be disconnected for an equalizing charge: " connected to their respective i DC bus (or battery bank for 120 V AC bus 1C/1C-1."

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27. Section 3.8.3.2b, to be consistent with Reference 3, should be changed

from "One 125 volt DC bus" to "One 125 volt DC bus energized from its associated battery bank."

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28. The licensee provided justification for not incorporating certain NRC i

comments on the previous (April 1985) upgraded draft technical I

specifications in Reference 4. The following address these comments.

! for Section 3/4.8 that were not addressed above and not incorporated.

a. The licensee's addition of STARTUP and SHUTDOWN but only when j

decay heat levels warrant multiple power sources being 0PERABLE (i.e., whenever CALCULATED BULK CORE TEMPERATURE is greater than 760_F) is being addressed separately by the NRC.

b. ACTION e for loss of both offsite sources of AC power was not incorporated as the general ACTION statements (3.0.3) would require thp plant to be in SHUTDOWN within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. We find this i justification acceptable .

i V

. e

. ,-,, ...m ~- ..-..,_v.,,,..+.r-. , , .,-. ,, . . _ , . . , - , , . , ,,.--.,,,.,--.,-.r..n_., _

, , - . , ,,n,,, , - . , ,--._..

c. The licensee has proposed a level of testing for diesel fuel oil that is consistent with past experience and is available locally.

This is being addressed separately by the NRC.

d. The licensee states that the definition of the word " verify" in the basis is consistent with Reference 3. We find this justification acceptable.

e. Reference to Generic Letter 84-15 rather than the Westinghouse Standard Technical Specification was left as is because the generic letter reflects the concern for diesel generator operability. We concur with the use of Generic Letter 84-15 in this instance.

f. The battery equalizing charge requires more than 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Per

! Reference 6, the issue of 5 days versus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for an inoperable i

battery is to be further addressed by the licensee. Inoperable batteries for causes other than equalizing charges should not be allowable per action statements for this length of time.

g. An ACTION statement proposed concerning 2 or more inoperable battery banks is stated to be covered by LCO 3.0.5, which would

! reduce the mode within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if existing LCOs cannot be met by existing action statements.

I l

h. The licensee states that the surveillances are equivalent to Reference 3 but are modified as necessary to correspond to Fort St. Vrain specific voltages, currents and similar parameters. We find this method of adapting plant specific requirements acceptable.

l

l

~

i. The licensee added a requirement to have 2 batteries operable after 5 days. This was discussed in Reference 6 as indicated in f) above.

)

= , - . - . . -

11

j. The suggested operability requirement on 125 V DC Bus 1C is not necessary as there is no 125 V DC Bus 1C. We concur.

e l

1 l

1

Docket No. 50-267 Mr. R. O. Williams, Jr.

Vice President, Nuclear Operations Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80202-0840

SUBJECT:

DRAFT UPDATED TECHNICAL SPECIFICATION SECTION 3/4.8, REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 56565)

Please find in Enclosures 1 and 2, requests for additional information concerning the November 1985 Technical Specification draft, Section 3/4.8. This section covers the electrical systems at Fort St. Vrain. This letter supplements our letter of February 18, 1987 onthissubject. Enclosure 1 deals with previously proposed technical specification changes, described in your letters dated December 30, 1983 and June 26, 1984 (P-83315 and P-84187). Enclosure 2 encom-passes upgrade to the Standard Technical Specifications, the July 1985 and December.1986 meetings with PSC, and Attachment 2 to your letter of November 27, 1985 (P-85448).

PSC should review Eaclosures 1 and 2 and prepare an appropriate response.

This response should be submitted within 90 days of the date of this letter.

The information requested in this letter affects fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, ist Kenneth L. Heitner, Project Manager )

ProjectDirectorate-IV l Division of Reactor Projects - III, IV, V and Special Projects

Enclosures:

l As stated cc w/ enclosures:

See next page DISTRIBUTION Docket File NRC PDR Local PDR PD4 Reading F. Miraglia D. Crutchfield F. Schroeder 0GC E. Jordan B. Grimes J. Calvo K. Heitner-P. Noonan ACRS (10) PD Plant File D. Moses, ORNL J. Stachew, INEL J.R. Miller

• See Previous Concurrences:

PD4/LA* PD4/PM* PD4/D* TSB* TSB*

PNoonan KHeitner:sr JCalvo JRMiller REmch 4/30/87 5/01/87 5/01/87 5/04/87 5/05/87

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