ML20245C436
| ML20245C436 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/16/1989 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | Hebdon F NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-89218, NUDOCS 8906260183 | |
| Download: ML20245C436 (30) | |
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O Public Service'
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P.O. Box 840 Denver CO 80201-0840 A. Clegg Crawiord June 16, 1989
$0.78pe* Eon.
d Fort St. Vrain-Unit No. 1 P-89218 i
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 ATTN: Mr. Frederick J. Hebdon, Director Project Directorate IV Docket No. 50-267 l
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SUBJECT:
Request to Change Current l
Commitments
REFERENCE:
See Attachment 1
Dear Mr. Hebdon:
In Reference 1, Public Service Company of Colorado (PSC) recommended various changes to current commitments to the NRC, based upon -PSC's plans to terminate Fort St. Vrain operations on or_before June 30, 1990.
In Reference 2, the NRC indicated that PSC should formally submit requests to change those commitments discussed in Reference 1.
i By letter dated June 9,
1989, (Reference 3), PSC requested an i
amendment to the Facility Operating License which would prohibit operation of the reactor above 2 percent of full power after June 30, l
1990.
In Attachment 2 to this letter, PSC now requests relief from those confirmatory action commitments identified in Reference 1.
These requests specifically reference the NRC Order involved.
l provides additional information related to Technical Assignment Control List commitments and other NRC commitments also requested by the NRC in Reference 2.
.B906260183 890616 PDR ADOCK 05000267 i
P PNU-
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. W Should you have any-questions concerning:this letter, please contact.
Mr. M. H. Holmes at (303):480-6960-for further information.
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.Very truly yo'urs,.
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- a. e.y 1
A.-C. Crawford-Vice President.
1 Nuclear Operations ACC/PJA:drg Attachment-cc:
1 Regional Administrator, Region IV Attn: Mr. T. F. Westerman, Chief, Projects Sectio ~n B i
J Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain 1
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' Attachment l' P-89218
' June 16,-2989-Page 1 l
References:
(1) -PSC' Letter, Williams to' Document Control. Desk, dated January 20,-
1989,(P-89026).
J (2) NRC Letter, Heitner to Williams, dated April 19,1989,(G-89137)
-(3) PSC Letter, Crawford to Hebdon, j
. dated June 9, 1989, (P-89216)
(4) NRC Letter Heitner to Williams, dated September 15,'1988,(G-88375)-
(5) NRC Letter, Miraglia to Williams,
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dated November 18,1986,(G-86609)
(6) NRC Letter, Butcher to Lee, datedAugust2,1985,(G-85345) a (7) PSC Letter, Williams to.Hebdon, dated May 15,1989,(P-89183)-
1 (6} PiC Letter,~Crawford to Document Control ~
Desk, dated. June 13,1989,(P-89222)
(9) PSC Letter', Crawford to Document Control Desk, dated June 15, 1985, (P-89231)-
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' Attachment 2 P-89218 June 2fi, 1989
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Page 1 NRC CONFIRMATORY ORDER COMMITMENTS J
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NOTE: All "NRC Comments" in Attachments 2 and 3 are l
taken from Reference 2, 1
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l A?2achment 2' P-89218' Jene.16,1989 I
Page 2 I.A. Fire Protection Modifications
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NRC Coments l
The staff will accept PSC's recommendations as submitted. PSC should 1
provide.a written commitment to the proposed. schedule.
It is the staff's intention to confirm by Order selected items, including the completion of Emergency Lighting and Fire Detection.
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PSC Commitment The following fire protection modifications are complete, to be deleted, or PSC commits to their completion by the schedule dates indicated:
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-Emergency Lighting 10-01-89(a)
-Fire Detection 08-15-89
-Third Turbine Water Removal Pump Complete
-New Radiochemistry Storage Cabinets Complete q
-Three' Room Control Complex Fan:
1 Evaluation Complete Power Supplies 10-15 89(b) 1 Procedure 10-01-89
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-Control Room Pressure Control 10-01 89
-Acid Trench Fire Barrier Complete
-Bearing Water Pump Cable Reroute Delete (c)
-Additional Shields on Hot Surfaces Complete 1
Adjacent to System 91 Components J
-Installation of Diesel Fire Pcmp 06-30-90(d)
I Cooling Water Valves
-Evaluation of 125 VDC Power Supplies Complete
-Upgrade Inplant Communications Systems 10-31-89(b)
-Revise Shutdown /Cooldown Procedure and 07-22-89 Pre-Fire Plans based on NRC Inspection 88-21
-Evaluate Need for Firewater Isolation at Complete 90 Minutes
-Valve Operability Complete (a) Four 8-hour battery packs need to be relocated and six new 8-hour battery packs need to be installed to_ complete the Emergency Lighting System. PSC will have the four battery packs relocated to their f1nal positions with their permanent power supplies installed by 06-30-89.
PSC will also have the six new battery packs installed in their final positions by 06-30-89, but only temporary power supplies will be installed via Temporary Change Request (TCR)by 06-30-89. The permanent power supplies will be installed by 10-01-89.
The Emergency Lighting System will be functionally tested by 06-30-89, at which time the system will be operational, and any final corrections will be implemented by 10-01-89.
(b) PSC experienced equipment delivery problerr which extended this schedule date.
= Attachment'2 H
1 P-89218
' June'16, 1989 Pager3 i
(c)A.' loop shutdown is required to: perform this modification..
Therefore, this modification'is being deleted.
Use of bearing i
water pump P-2101-S as a back up to bearing water pumps P-2101 l
and P-2106 is covered in'EE-FP-0015,. Revision B.
This item is
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l' discussed more fully in Reference 9.
'(d)This~ work requires an outage and will be' completed _at the next 1
l extended outage or.upon termination of operations.
PSC Request 3
PSC requests that the'NRC revise the September 15, 1988 listing of-commitments (Reference 4) to reflect the above completion dates for'
-the. fire protection modifications.
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. P-89228 June 16, 1989 Page 4 I.B.
Upgrade Emergency Operating Procedures (EOPs)
'NRC Comments-The staff will accept PSC's recommendations as submitted.
PSC should provide a written request to modify the August 2, 1985 Confirmatory Order to indicate that the upgraded E0Ps will be. implemented by September'30, 1989. TAC No. 44304 is closed.
PSC Commitment
'PSC commits to complete the implementation of the upgraded E0P's by i
September 30, 1989. The preparation of the new E0Ps. covering the five critical safety functions is complete. The User's Guide has-been written, and training on the upgraded E0P's has been initiated and should be completed by June 30, 1989. Following the completion of training, the E0Ps will be finalized, approved and implemented.
Although not directly required for E0P implementation, PSC plans to complete additional procedure work involving changes to the Fort St.
Vrain Abnormal Operating Procedures, System Operating Procedures, and Safe Shutdown Cooling procedures to be compatible with the enhanced E0P concept.
These additional procedure changes will also be completed and implemented by September 30, 1989.
PSC Request PSC requests the NRC modify the August 2, 1985 Confirmatory Order (Reference 6),asamendedby NRC letter dated November 18, 1986 (Reference 5), to indicate that the upgraded E0Ps will be implemented i
by September 30, 1989, i
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~ Attachment 2
,-P-89218 June 16, 1989 9
Page 5.
I.C.
Submit Annual Reports on the Control of Moisture Ingress NRC Coments The staff will accept PSC's recommendations as' submitted.- PSC should i
provide a written request to modify the September 15, 1988 listing of 1
commitments to reflect this change.
PSC Request PSC requests the NRC revise the September. 15, 1988 listing of comitments (Reference 4) to read that PSC will-submit' annual. reports concerning the control of moisture ingress during the sumers of 1989 and 1990.
The scheduled date for submission of the next report is f
July 15, 1989 and the scheduled date for submission of the final moisture ingress report is July 15, 1990.
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P-89218
- June 16, 1989 Page 6 i
l'.D. Evaluate Control of' Moisture in CRDM Purge System NRC Comments j
The staff will accept PSC's recommendations as. submitted.
PSC should provide a written request to modify the September.15,1988 listing of commitments to reflect this change.
PSC Request q
PSC requests the NRC revise. the September 15,. 1988 listing of.
commitments (Reference 4) to read ' that ' PSC will submit a letter.
report on the effectiveness of the CRDM moisture control measures and the impact of the most recent moisture ingress events on CRDMs. This report will be included with the annual report concerning the control of moisture ingress. The schedule date for submission of the. report
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is July 15., 1989. Please note that this date has-been changed from I
the January 20, 1989, PSC letter (Reference 1) which' read June 30, 1989, in order to combine this with the annual report on moisture ingress (ItemI.C.)dueJuly 15, 1989.
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l P-89218 June 16, 1989
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Page'7 1
I.E.
Technical Specification Upgrade Program 4
i NRC Comments f
The staff will accept PSC's recommendations as submitted.
PSC should provide a written request to modify the September 15, 1988 listing of commitments to reflect this change. However, the staff notes that at the proposed time for submittal, all technical issues related to defueling may not be resolved.
In that case, the staff notes that j
supplementary submittals may be required.
PSC Response
-In the January 20, 1989, submittal of proposed changes to current commitments (Reference 1), PSC identified our intent to submit a set of Defueling Technical Specifications to address plant defueling activities after a 100 day cooldown period.
During subsequent planning and analysis activities, PSC has determined that defueling i
activities can be safely accomplished under the requirements of the existing Technical Specifications.
This determination was discussed in a meeting between PSC and NRC management on May 11, 1989, and was identified in our letter of May 15, 1989 (Reference 7).
j As background, the concerns that resulted in the Tech Spec Upgrade Program (TSUP) were directed at assuring long term safe operations of Fort St. Vrain.
Many of the resolutions, including the use of the TSUP drafts to interpret the existing Technical Specifications, have already been implemented.
The implementation of the interim reactivity control specifications has substantially improved the controls in this area.
The correctness of the -Technical Specifications relative to the FSAR has been significantly improved through various analyses and several revisions to the FSAR to address identified inconsistencies.
j Both PSC and the NRC exerted good faith efforts to complete the program in support of continued safe plant operation, and implementation was planned for the startup after the fourth refueling outage. The use of the existing Technical Specifications for fourth i
refueling activities was accepted. After the current fuel operating j
cycle and coastdown, PSC will be defueling the plant instead of 1
refueling the plant.
As fuel elements are removed, the decay heat source continues to decrease and the plant is actually in a progressively safer condition than in a normal refueling.
As described in Reference 7, Fort St. Vrain defueling activities will be conducted in a manner much like the normal refueling process. PSC considers that overall safety would be enhanced by retaining the procedures and controls that have been used during previous shut down and refueling conditions, and not by introducing an entirely new set of Defueling Technical Specifications.
Att$chment2 P-89228
' June 16, 1989 Page 8 PSC' has reviewed the current Technical Specifications relative to-defueling concerns and considers that sufficient requirements ~ are
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to assure a safe defueling.
Some of the.' principal-
~ considerations are the fol)owing:
The ' current Interim Technical Specifications. for -reactivity
. control require adequate. shutdown. margins and operable reserve-shutdown hoppers.
Technical..
Specification.
4.7.1
. restricts fuel handling -to conditions.where.the reactor is depressurized, average. helium gas in.let temperature is 165 degrees F or less, and two neutron flux
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monitors are continuously monitoring.the core.
-Technical' Specification 4.2.15 provides PCRV liner cooling system temperature requirements that are applicable at all times, to assure liner integrity.
Technical Specification 4.4.1 provides requirements for PPS instrumentation to assure that reactor' and equipment' design-limits-are not exceeded.
Technical.
Specifications 4.7.2,.
4.7.3 and.4.7.4 provide requirements'for the Fuel Handling Machine, the Fuel Storage Facility,-and the Spent Fuel Shipping Container, all of which'are critical to defuel bg operations.
In addition to the Technical Specification requirements, PSC's established practice is to assure a safe shutdown' cooling capability (including auxiliary electric power) during shutdown conditions. PSC' plans to maintain this practice during defueling, consistent with the-amount of available decay heat. This practice introduces substantial conservatism in that the Defueling Safety Analysis Report concludes that no. forced circulation cooling -is required' to ensure fuel particle integrity in the event of a loss of forced ' circulation durin the defueling period (100 equivalant days after plant shut down)g PSC Request With the permanent shutdown of Fort St. Vrain, the. benefits of the upgraded Technical Specifications would be greatly diminished, and introducing an ' entirely new set of Technical Specifications for use during defueling only is not warrented.
More importantly, PSC considers that overall-safety.is enhanced by retaining the procedures, organization and controls that have been utilized for previous Fort-St. Vrain shutdowns and refuelings. The operators'and plant staff will be better able to. focus proper attention on important defueling issues if they can use procedures and administrative controls with which they are familiar and experienced.
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P-89218-June 16, 1989 Page.9
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Based'.on the acceptability of.the existing Techinical Specifications
-for the defueling operation -and on the complexities inherent in' implementing a new set of Technical Specification, PSC requests that NRC revise the September 15, 1988 listing of commitments (Reference
- 4) to delete the implementation of the Technical Specification Upgrade Program (TSUP).
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Attachment ?
P-89218
'. June 16, 1989 Page 10-I.F.
PCRV Tendon Surveillance NRC Comments Pending acceptable results from the current (1989) surveillance program, the staff will accept PSC's. recommendations as submitted.
.PSC should provide a written request to modify the September 15, 1988 listing of comitments to reflect this change.
2 PSC Request PSC requests 'the NRC revise the September 15, 1988 listing of commitments.(Reference 4) to read that PSC.will:
a.
Provide the results of the revised Tendon Surveillance Program for the annual period ending June 30, 1989. The schedule.date for submission of the results is July 21, 1989.
b.
Submit a ~ final report on Tendon Surveillance activities to the-NRC within one month after final depressurization.
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P-89218-
. June 16, 1989 Page 11 I.G..
Regulatory Guide 1.97 Post Accident Monitoring NRC Comments The. staff will accept. PSC's recommendation-of no further upgrades except as allowed without a plant outage.
PSC must provide the staff a complete status report of all the RG 1.97 instrumentation, clearly indicating'its current status. PSC should request that the August 2, 1985 Confirmatory. Order be modified to read " Complete as per the l
status report submitted.on..."
PSC' Request A complete status of all the'.RG 1.97 instrumentation will be submitted to the NRC by July 15, 1989. PSC requests. the NRC modify the August 2,
1985 Confirmatory Order.(Reference 6), as amended by NRC letter dated November 18, 1986 (Reference 5), to reflect the status and completion dates that will be contained in the PSC submittal.
P-69218
' June 16, 1989 Page 12 II.A.
SafetyParameterDisplaySystem(SPDS)'
NRC Comments The staff will accept PSC's recommendations as submitted.
PSC should' provide a written request to modify the August 2, 1985 Confirmatory Order to indicate that-the SPDS will not be implemented. All currently-operable computer systems. used by the operators should be maintained for the balance of plant life.
PSC Connitments PSC hereby commits to maintain all currently operable computer systems used by the operators for the balance of plant ~ life i.e.
until the completion of defueling. PSC reported the status of SPDS l
development in response to Generic Letter 89-06 in Reference 8.
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PSC Request j
i PSC requests the NRC modify the August 2 1985 Confirmatory. Order (Reference 6), as amended by NRC letter dated November 18, 1986 (Reference 5), to delete the requirement that the SPDS be fully
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operational and operators trained, and insert that the SPDS will not i
be completed.
For additional information, see Reference'8.
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. P-89218 June 16, 1989.
Page 13 1
1 II.B ACM Backfeed' Enhancements
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NRC Comments
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The staff will accept PSC's recommendations as submitted..PSC should.
provide a written request-to modify the September 15, 1988 listing of j
commitments to reflect this change.
- However, the staff will i
reconsider the vulnerabilities of.the plant to station blackout 1
during' the' defueling period and may consider retention-of the ACM in that evaluation.
PSC Request PSC' requests the NRC. modify the September 15, 1988 listing of.
commitments (Reference 4) to delete the performance of modifications involving ACM backfeed.!
PSC currently plans to retain the ACM
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generator as part of the fire protection shutdown cooling trains and emergency lighting during defueling, but does not plan to enhance l
the interim backfeed capability.
The ACM generator would remain 1
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available for station blackout conditions as a matter of good practice.
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' Attachment 2
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P-89218-
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June 16,~1989 j
Page 14 '
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II.C.
Control Rod Drive and Orifice Assembly NRC Comments The Staff will accept PSC's reconunendations as schmitted.
PSC should j
provide a written request to modify the September 15, 1988 listing of I
commitments to reflect this change.
PSC Request
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PSC requests the NRC modify the September 15, 1988 listing of consnitments (Reference 4) ' to reflect that PSC will continue to implement the SHUTDOWN and REFUELING portions of the existing interim control-rod drive Technical Specifications.
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- Attachment 2 t
P-89218
.l June 36, 1989-Page 15 j
II.D. Fuel Surveillance Program 1
NRC Comments j
i The staff notes that certain' aspects of the fuel surveillance program potentially could support the licensing of an Independent. Spent Fuel Storage Installation- (ISFSI).
(The Surry ISFSI had certain limits placed on the condition of.the fuel that the ISFSI could accept.)
The staff is still' evaluating the proposal to cancel this program and may issue further correspondence on this topic.
PSC Response PSC will~ await the NRC's evaluation of the. fuel surveillance program.
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Atsachment 3 P-89218
. June 16, 1989 Page 1 NRC TECHNICAL ASSIGNMENT CONTROL LIST COMMITMENTS
,l AND OTHER NRC COMMITMENTS l
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l P-89218 i
June 16, 1989-
-.Page 2' i
NRC TECHNICAL' ASSIGNMENT CONTROL LIST COMMITMENTS i
l In the NRC letter. dated April 19. 1989, (Reference 2), the NRC found PSC's commitments on the following Technical Assignment Control List Commitments acceptable:
1.A.
Safeguards
. Miscellaneous Amendments I.B.
Fire Protection -Program Plan Approval & Deletion of Fire Protection Technical Specifications I.C.
EQ Temperature Profiles III.B.
Control Rod Drive Orifice and Assembly (CRD0A) j III.C.
Individual Plant Examination for Severe Accident f
Vulnerabilities III.D.
Third DC Distribution Bus III.G.
Seismic Qualification Utility Group (SQUG) Walkdown i
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l P-89218,
June 16, 1989 Page 3 II.A.
Operator Requalification Program NRCCommer$
PSC must continue to meet the requirements for licensed operators as per the 10 CFR Part 55 and the Technical Specifications until all i
fuel is removed from the reactor. A conference call was held on
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March 3, 1989 with the PSC staff (M. Holmes and T. Borst) to discuss this issue.
PSC Response 1
PSC understands.that the requirements for licensed operators per 10 i
CFR Part 55 and the Technical Specifications must be met until all fuel is removed from the reactor.
In the event that PSC is not able to fully comply with certain features of the current regulations (e.g.
plant specific simulator training), PSC will seek appropriate NRC approval for relief.
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II.B.
Control Room Habitability NRC Comments PSC should clarify the status of continued use of ' chlorine. gas at the s
. site following the shutdown of.the reactor.
If chlorine gas use is continued, it is the staff's position that the proposed May 31,1989-j submittal could be considered an interim measure. The staff intends 1
to ' reevaluate the need for PSC to fully comply with the requirements
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of GL 83-36 and 83-37 concerning control room habitability.
PSC Response i
At 'the present time, PSC has not decided to delete use.of gaseous chlorine at Fort St. Vrain.. During defueling, as heat removal needs permit,.the Circulating Water System may be shutdown and not require
'j chlorination. The smaller Service Water System will be retained for heat removal but its chlorination requirements are a sisbstantial j
reduction of the current chlorine usage.
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To assure control room habitability. as long as. gaseous chlorine is j
used on site, PSC will submit a proposed amendment to the existing j
Technical Specifications to add specifications for a chlorine detector and for the control room emergency ventilation system. ~The proposed amendment will be based on the latest draft TSUP l
specifications for this equipment, Technical Specifications l3/4.3.2.6 1
and 3/4.7.9, respectively.
This submittal will be provided by September 30, 1989.
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' Attachment 3-1
, P-89218 June 16 '1989 i
Page 5 II.C.
10 CFR 50.62 Operating Reactor Reviews (ATWS)
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. NRC Cominents i
The ' staff accepts PSC's proposals. However, PSC should complete all actions for which it has made previous written commitments, including i
its responses to GL 83-28.
l PSC Response PSC has reviewed its responses to GL 83-28 and the related comitments. At this point PSC has completed all actions for which I'
previous written comitments were made.
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P-89218 June 26, 1989 Page 6 II.D.
Station Blackout Analysis NRC Comments The staff accepts PSC's proposals. However, PSC should not take any act's.' for final disablement or removal of the ACM system until this is .ialized in the shutdown Technical Specifications.
PSC Response PSC will not take any action to disable or remove the ACM system.
without prior notification to NRC.
As noted. in Item II.B of,
the ACM generator will be retained as a part of the fire ;rotection shutdown cooling trains during defueling and will remain available for station blackout conditions as a matter of good practice.
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. P-89218 June 16, 1989 Page 7-III.A..
Control' Room Design Review (CRDR) Modifications NRC Commer+,
The' staff ~ accepts PSC's proposals. However, PSC should prepare.and retain or-site. documentation sumarizing the changes' made and the items identified as Human -Engineering Deficiencies,'but left unresolved.
. Improvements made to the control room should' _be maintained for the balance of plant life. TAC No. 56125 is closed.
PSC Response PSC presently has. on-site, detailed documentation of all CRDR activities, including completed modifications.
An activity-is currently-in progress to prepare a summary document, in tabular form, which lists all Human Engineering Deficiencies, those items resolved, the resolution, the resolving document reference (change notice number) and those items left unresolved. This summary document' will be completed by December 15, 1989, and will be retained on site for the balance of plant life, i.e. until the completion of defueling.
All control room improvements completed to date will be maintained for the balance of plant life. Any control room changes implemented in the future will be in accordance with the procedures and directives which define the design basis established as a result of the Control Room Design Review.
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-P-89218 June 16, 1989 l
.Page 8 III.E.
PlantProtectiveSystem(PPS)'InstrumentSetpoints NRC Coments The staff accepts.PSC's proposals.
PSC Response The NRC accepted PSC's proposal to delete the Phase 2 PPS Instrument-Setpoint comitments with the exception of the programed and fixed low feedwater trip analyses.
General Atomics has completed their analyses to support revised analysis values for the programmed and fixed low feedwater instrumentation'and has submitted the associated documentation to PSC. Following Plant Operations Review ' Comittee (PORC) approval, PSC will submit this analysis documentation to the NRC for review, together with a recommendation. on' whether the-Technical Specifications should be revised.as a result of the j
analyses.
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P-89218 June 16, 1989 Page 9 III.F.
Inservice Inspection and Testing (ISIT) Program NRC Comments The staff notes that PSC has stated it will continue to use specific facilities that were to be addressed by future upgrades to the Technical Specifications as part of the ongoing ISIT efforts.
Specific areas to be addressed included:
Fuel Storage Facility Surveillance Fuel Storage Facility Auxiliary Category III Systems System, and - Category IV Systems - Fuel Storage Well HVAC Other systems noted in the staff's safety evaluation for. Amendment No. 51 dated March 9, 1987, which PSC intends to utilize following the final reactor shutdown and cooldown, should also be addressed by the ISIT program.
Additionally, the fuel handling machine will see extensive service during the proposed defueling operations. The fuel handling machine is a Class I system as per the FSAR and should be cevered by an appropriate ISIT program. PSC should rapidly develop and submit for staff review an ISIT program to cover these systems. This could be either at part of the Technical Specifications or as a separate, but NRC approved program plan.
PSC's response to this letter should contain a specific schedule and commitment to an appropriate ISIT-program upgrade. The balance of PSC's proposal is acceptable.
PSC Response PSC is currently finalizing the Defueling Safety Analysis Report and reviewing the plant systems and equipment that will be needed to support defueling activities.
PSC considers that to support defueling activities, certain additional inspections and testing activities beyond those inspection and surveillance activities currently in FSV Technical Specifications are appropriate.
The discussion below will describe PSC's plans for inspection of: (A) certain equipment included in Amendment 51 of the Technical Specifications but not currently scheduled for implementation;-(B) certain equipment not yet addressed in the Technical Specifications; and (C) the Fuel Handling Machine.
Based on preliminary analyses in the Defueling Safety Analysis Report, the integrity of all fission product barriers is assured during defueling by use of the PCRV liner cooling system, with no forced circulation cooling. The ISIT program for defueling will be directed to the reactor plant cooling water system, which includes the PCRV liner cooling system and cooling for the fuel storage facility and fuel handling machine.
PSC considers the functional testing of pumps and the exercising of valves to be the major activities of the defueling inspection program.
All of the systems needed for defueling are considered low
P-89218 June 16, 1989 j
Page'10 1
energy systems such that any pressure boundary failure would not have j
significant safety consequences, either to the plant's ability to j
maintain safe shutdown conditions or to personnel safety.
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inspections of pressure boundaries, as provided in the inservice l
inspection and testing guidance of ASME Section XI, are not part of this proposed program.
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Systems Included in Amendment 51 but Not Currently Scheduled for.
I Implementation Many of the ISIT surveillance added to the Technical Specifications d
in Amendment 51 were required to be implemented by the start of fuel cycle 5.
These. surveillance are not explicitly required during defueling. To assure liner cooling capability, PSC will initiate the implementation following Amendment 51 surveillance within 90 days after final shutdown:
h SR 5.2.21 ACM Transfer Switches and Valves SR 5.2.24.e Service Water Pumps SR 5.2.24.f Reactor Plant Cooling Water Pumps B.
Systems Not Included in Technical Specification Surveillance The following additional ISIT actions are proposed:
i Fuel Storage Facility Cooling i
Exercise valves used to isolate cooling water to the fuel storage l
wells and fuel handling machine. Similar to the valve cycling requirements of SR 5.3.4, this will include partial stroke j
testing once per 92 days and functional testing once per year.
J Fuel Storage Facility Ventilation System Perform functional test once per 18 months, similar to the Technical Specification Upgrade Program surveillance 4.9.4.c.
PSC will initiate the above ISIT enhancements within 90 days after final plant shutdown.
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P-89218 June 16, 1989 Page 11 i
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Fuel Handling Machine The Fuel Handling Machine (FHM) is a Class I component designed for low pressure service (8 psig).
PSC considers that additional inspections are needed to ensure its continued operrSility and reliability during the entire dcheling period.
- However, PSC cor.siders that the additional inspections are more appropriately covered in a preventive maintenance (PM) program than in a ASME Code-based ISIT program. This is based on the considerations that the FHM is used in a low pressure application, the Reactor Isolation Valve (RIV) can be closed to isolata any pressure boundary failures, and Technical Specification SR 5.7.1 provides functional testing requirements for both the FHM and the RIV.
PSC is developing a comprehensive PM program for the FHM that includes functional tests and inspections of various mechanical components and their controls.
The initial inspections per this program will be performed prior to initiating fuel handling activities for defueling.
Based on these inspections, PSC will develop an ongoing PM program that will include periodic inspections during defueling.
PSC REQUEST PSC requests NRC approval of the above defueling ISIT actions, with no additional Technical Specification amendments required.
PSC commits to develop procedures and implement this ISIT program, in accordance with the schedules identified above, to assure system and component integrity for a safe defueling.
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P-89218
. June 16e 1989 4
Page 12 DISPOSITION OF OTHER NRC COMMITMENTS The NRC accepted PSC's proposals for all commitments in Appendix 3 of PSC letter dated January 20, 1989 (Reference 1).
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