ML20247J223
| ML20247J223 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 09/14/1989 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | Weiss S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20247J229 | List: |
| References | |
| P-89344, NUDOCS 8909200222 | |
| Download: ML20247J223 (13) | |
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4 PubHc Service 0 Publ. ic . Serv i=ce' September 14, 1989 c.- ... .< ceie,.o.
P.O. Box 840 Denver co 80201- 0840 Fort St. Vrain Unit No. 1
- i. P-89344 A. Clegg crawford vic, p,,,;oent Nuclear Operations i
U. S > clear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 ATTN: Seymour H. Weiss, Director Non-Power Reactor, Decommissioning and Environmental Project Directorate Docket No. 50-267
SUBJECT:
Proposed Technical Specification Change -
Sections 4.7 & 5.7 -
Fuel Handling and Storage
REFERENCES:
See Attachment 4
Dear Mr. Weiss:
This 'is an amendment request to the Fort St. Vrain Technical Specifications, Sections 4.7 and 5.7, to incorporate Technical Specification Upgrade Program (TSUP) items as requested by the NRC in Reference 6. These sections include requirements for the Fuel Handling Machine operation and for fuel storage at Fort St. Vrain.
Specifications for Reactivity Control will be provided separately.
With these submittals, PSC considers the commitment to upgrade the Fort St. Vrain Technical Specifications (References I and 2) to be closed.
Public Service Company of Colorado (PSC) has been working with the NRC to develop upgraded Technical Specifications since 1985. In May and June of 1988, PSC submitted the TSUP document and the justification for the TSUP changes (References 1 and 2). In April of 1989, the NRC responded with the Tcchnical Evaluation Report (TER) ,
(Reference 3). In late 1988, PSC . m unced that Fort St. Vrain would be shutdown no later than June .0, 1990. In May and June of 1989, PSC informed the NRC that, in their opinion, no Technical Specification improvements were required to safely operate Fort St.
Vrain through June 30, 1990, and to proceed with de fueling the reactor after that time (References 4 and 5). The NRC transmitted a Staff Safety Evaluation of PSC's proposals regarding the TSUP on August 8, '1989 (Reference 6). This submittal is a response to the request in that ' safety evaluation that PSC submit upgrades for the Fuel Handling and Storage sections of the Fort St. Vrain Technical MI I
Specifications in accordance with the TSUP within 30 days. Y 8909200222 890914 PDR ADOCK 05000267 P PDC
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l P-89344 2 September 14, 1989 Four attachments are included with this proposed amendment:
Attachment 'l - Summary of Proposed Changes l Attachment 2 - Proposed Changes Attachment 3 - No Significant Hazards Consideration Analysis Attachment 4 - References On August 29, 1989, PSC announced the end of operations for Fort St.
Vrain. The NRC requested in Reference 6 (G-89261) that the Technical Specification changes reflected in the attached amendment proposal be made prior to commencing defueling. PSC is pursuing a high priority effort to submit these changes, obtain NRC approval, and implement these changes. However, PSC is concerned that an approved amendment may not be issued in time to support current plans to start Defueling by November 27, 1989. Therefore, PSC requests that defueling activities be allowed to co:rnience without final approval of the attached Technical Specification changes. In order to permit timely initiation of safe defueling activities, PSC commits to actively pursue approval of the attached Technical Specification changes, and to conduct any defueling activities in full compliance with the existing Technical Specifications and the more conservative requirements in the attached Proposed Technical Specification Changes until an approved amendment is issued.
Should you have any questions concerning this matter, please contact Mr. M. H. Holmes at (303) 480-6960, l
Very truly yours, d- l >
A. Clegg rawfor Vice President Nuclear Operations ACC/JMW/km i
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F P-89344 3 September 14, 1989 u
Attachments cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westerman, Chief Projects Section B Robert M. Quillen, Director Radiation Control Division Colorado Department of Health
'Mr. Robert Farrell Senior Resident Inspector
. Fort St. Vrain
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter )
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Public Service Company of Colorado ) Docket No. 50-267 Fort St. Vrain Unit No. 1 )
AFFIDAVIT A. Clegg Crawford, being first duly sworn, deposes and says: That he is Vice President, Nuclear Operations, of Public Service Company of Colorado, the Licensee herein, that he has read the foregoing Application for Amendment to Appendix A of Facility Operating License and knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
A-A. Clegg ifawfordV Vice President, Nuclear Operations STATE OF COLORADO )
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COUNTY OF DENVER )
Subscribe and sworn to before me, a Notary Public on this 14th day of September ,
1989, cOAzd ente > h o Notary Public My commission expires January 6 , 1993.
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BEFORE ThE l UNITED STATES NUCLEAP, REGULATORY COMMISSION In the Matter of the Facility Operating License)
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of )
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PUBLIC SERVICE COMPANY OF COLORADO )
Application for Amendment to Appendix A of Facility Operating License License No. DPR-34 0F THE PUBLIC SERVICE COMPANY OF COLORADO FOR THE FORT ST. VRAIN NUCLEAR GENERATING STATION This application for Amendment to Appendix A of l Facility Operating License, License No. DPR-34, is submitted for NRC review and approval.
Respectfully submitted, PUBLIC SERVICE COMPANY OF COLORADO By A. Clegg Crawford Vice President, Nuclear Operations KELLY, STANSFIELD & 0'DONNELL James K. Tarpey Mark A. Davidson Public Service Company Building Denver, Colorado 80202 Attorneys for Applicant r
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ATTACHMENT 1 TO P-89344
SUMMARY
OF PROPOSED CHANGES 4
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P-89344 Page 1 of 7
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? Section Description of Change l- 2.26 Add definition for CORE ALTERATIONS. The words
" activities" and " reactor" have been added to the TSUP definitions to improve readability.
2.30 Add definition for SHUTDOWN MARGIN. The definition is identical to that contained in the TSUP.
LCO 4.4.1 Add note (u) to Page 4.4-7b under permissable bypass conditions for the startup channels. The explanation of note (u) is added to Page 4.4-9. This note explains a condition where the low count rate startup channel rod withdrawal prohibit is no longer required.
The Basis of LCO 4.4.1 is also revised to discuss the permissable bypass of the startup channel rod withdrawal prohibit.
LCO 4.5.2 This LCO 4.5.2 is to be deleted. The conditions addressed by it, Reactor Internal Maintenance being performed with both primary and secondary PCRV closures removed from any penetration, are adequately addressed by LCO 4.7.1.
4.7 Revise entire section to include requirements of Technical Specification Upgrade Program (TSUP). LC0 numbers have been maintained consistent with the present LCO numbers to minimize retraining and to minimize renumbering of references and associated procedures. The objectives section is identical to the current Section 4.7, but new to TSUP. The general applicability statement in the current Section 4.7 has been deleted as applicability is addressed in the individual LCO's.
LCO 4.7.1 Change format and revise item a. to define atmospheric pressure as <1 psig. This is a change from the current LCO 4.7.1 and TSUP LCO 3.9.1.
Revise item b. to add footnote for applicability only when Fuel Handling Machine or Auxiliary Transfer Cask is mounted on the reactor vessel and the cask and reactor isolation valves are open. This is similar to TSUP LCO 3.9.1 and changed from the present LC0 4.7.1.
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Attachment 1 L P-89344 Page 2 of 7 LCO 4.7.1 Change item c. to continue the requirement (Cont.) to maintain proper SHUTDOWN MARGIN. The requirement for proper monitoring of neutron flux in_ current LCO 4.7.1 has been moved to a separate LCO (4.7.5). This-is the same as TSUP LCO 3.9.1 and changed from the present LCO 4.7.1.
Revise " Specification 3.1.3" to "LCO 3.1.4".
An applicability statement is added to specify applicability whenever both primary and seconda ry closures are open on any PCRV penetration. This is the same as TSUP LCO 3.9.1.
An action statement is added very similar to the current LCO 4.7.1 requirement. In addition, a reference to LCO 3.1.4 has been added for SHUT 00WN MARGIN requirements. This is very similar to TSUP LCO 3.9.1 and different from the present LCO 4.7.1.
Reference is changed from " Specification 3.1.3" to "LC0 3.1.4". -
Action item a. is modified to add additional assurance of maintaining reactor closure should the core average inlet temperature approach 400 degrees F. This is a modification to the current LCO 4.7.1 and TSUP 3.9.1.
A reference to the associated surveillance requirement (SR 5.7.3) is added.
The wording of the Basis is slightly different than the current Technical Specifications and ve ry similar to the TSUP Basis for LCO 3.9.1 except that minor editorial changes have been made and an explanation of Action item a. is added.
LCO 4.7.2 Revised entire section to TSUP format, revised item a.
to define atmospheric pressure as <1 psig, and changed
" helium pressure" to " helium atmosphere" These are changes from the present LC0 4.7.2 and from TSUP LCO 3.9.3. {
A note has been added to the current Technical Specifications to describe a condition where a helium atmosphere is not required in the FHM. This note is the same as that included in TSUP LCO 3.9.3. {
Item b. is reworded to retain the purge flow requirement and to add the requirement for the gas waste system to be available. This is a change from the present LC0 4.7.2 and identical to TSUP LCO 3.9.3.
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.4-Attachment 1 P-89344 Page 3 of 7 LCO 4.7.2 Revised item c. to require an additional (Cont.) cooling water coil to be operable or to have backup fire water connections and hose operable.
This is an additional precaution added to present LCO 4.7.2 and identical to TSUP LCO 3.9.3 A requirement to keep the reactor building crane attached unless the Fuel Handling Machine is bolted to a seismically qualified location is added as item d.
This is an additional requirement to the present LCO 4.7.2 and adds the opportunity to attach the Fuel Handling Machine to another seismically qualified location to TSUP LCO 3.9.3.
The requirement to maintain the operability of switches and alarms that verify correct orientation and placement of fuel element! has been added as item e.
This is an addition to present LC0 4.7.2 and is identical to TSUP LCO 3.9.3.
An applicability statement has been added to define applicability very similar to the existing Technical Specifications. This is a rewording of the requirements of present LC0 4.7.2 and identical to TSUP LCO 3.9.3.
Action statemer.ts are added to describe the actions required if the LCO requirements are not met. These action requirements are very similar to those in the present Technical Specification LCO 4.7.2 and adds the possibility of putting fuel in a Fuel Shipping Cask to action item c. of TSUP LCO 3.9.3. ]
Action statements are added for items d. and e. which are new additions to the present LCO 4.7.2 and are -
identical to TSUP LCO 3.9.3. J l
The associated surveillance requirements of SR 5.7.1 l are referenced to retain format similar to TSUP. ]
The Basis for LCO 4.7.2 has been completely rearranged to explain the Basis for each item. The new Basis is very similar to that of TSUP LCO 3.9.3. The B3 sis has been revised to include the possibility of reflector elements or defueling elements being inserted into the core instead of fuel elements. Several editorial changes have also been included.
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Attachment 1 P-89344 Page 4 of 7 LCO 4.7.3 Changed title of specification from " Fuel Storage Facility" to " Fuel Storage Wells" in keeping with the TSUP wording.
Changed format of entire LCO to be similar to TSUP LCO 3.9.4 except for a rearrangement of the requirements to 4 items instead of 3.
Defined atmospheric pressure as being less than 1-psig.
This is a change from current LCO 4.7.3 and a c'ange
'from TSUP LCO 3.9.4.
Revised item b. to require that both cooling water coils must be OPERABLE versus " operating" Thi s is a change from current LCO 4.7.3 and is identical to TSUP LCO 3.9.4.
Revised item c. to allow for the minimum of 9000 cfm air flow instead of 12000 cfm. This follows from another revision which requires that one coil must be ,
" operating" versus " operable". These revisions are in keeping with the TSUP LCO 3.9.4 and FSAR Section 14.6.3.2.
Moved information from item c to item a. and added a i new item d. regarding the prohibition of storing !
IRRADIATED FUEL in the central column of a fuel storage well. This is a change from current LCO 4.7.3 and is identical to TSUP LCO 3.9.4.
An Applicability Statement has been added to the current LCO 4.7.3. This statement is revised from TSUP LCO 3.9.4 to include a condition where stored fuel element surface temperatures cannot reach 750 degrees.
Re-formatted the action statements in the current Technical Specification into a separate, more visible section. Added two additional action statements to incorporate TSUP and FSAR Section 14.6.3.2 analyses.
This is a change from current LCO 4.7.3 and is identical to TSUP LCO 3.9.4.
Added associated surveillance requirement to reference SR 5.7.2.
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Attachment 1 P-89344 Page 5 of 7 LCO 4.7.3 Revised the Basis for LCO 4.7.3 to address (Cont.). each action statement, including the new ones and to address the analysis in FSAR Section 14.6.3.2.
Most of the current Basis is retained. The Basis is similar to that of TSUP LCO 3.9.4 with the addition of a discussion concerning the storing of spent fuel in the central column of a storage well.
LCO 4.7.4 Changed title of LCO from " Spent Fuel Shipping Container" to " Spent Fuel Shipping Cask" as per the TSUP LCO 3.9.5.
LCO 4.7.4 and the Basis are very similar to TSUP LCO 3.9.5 with only a change of referenced LCO to LCO 4.0.3.
LCO-4.7.5 This 1. a new LCO presenting the requirements for monitoring the core while refueling. These requirements are included in LCO 4.7.1 of the current Technical Specifications and TSUP LCO 3.9.2.
The Applicability Statement from TSUP LCO 3,9.2 has been revised to address the potential situation of the startup channel low count rate rod withdrawal prohibit not being required.
Action statements are added to address the situations with one and two startup channels inoperable.
Associated surveillance requirements of SR 5.7.5 are referenced in accordance with the TSUP format requirements. This is different from present LCO 4.7.1 and very similar to TSUP LCO 3.9.2.
The Basis for LCO 4.7.5 is very similar to TSUP LCO 3.9.2 except for the addition of a discussion concerning the possible condition of withdrawing all control rod pairs without the reactor going critical.
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Attachment 1 P-89344 Page 6 of 7 LCO 4.7.6 This is a new LCO addressing the maintenance of two-way communications between the operations Control Room and the FHM control room. It maintains the TSUP analyses and format intact.
Includes an applicability statement and an associated surveillance requirement reference.
The Basis is identical to TSUP LCO 3.9.6.
5.7 Revise the entire section 5.7 to include six surveillance in the format similar to the TSUP. The
, SR numbers have been maintained consistent with current SR numbers to minimize retraining and to minimize renumbering of references and asscciated procedures.
SR 5.7.1 This surveillance is designed to ensure the operability of the Fuel Handling Machine safety systems. .These surveillance are new to the current Technical .
Specifications and have been modified from the TSUP SR 4.9.3 to accommodate the different location of the LCO and to revise the frequencies in item c. from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 14 days to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and 31 days for crane inspections.
SR 5.7.2 Changed title of Surveillance from " Fuel Storage '
Facility" to " Fuel Storage Wells".
This Specification is substantially enhanced to incorporate the TSUP and FSAR Section 14.6.3.2 analyses and is consistent with the current Technical Specification. The SR 5.7.2 is very similar to TSUP SR I
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Included an associated LCO statement.
Replaced "ence per REFUELING CYCLE" in item c) of the TSUP with "once per 18 months". ;
The Basis descrites the significance of each of the required temperature and pressure conditions and is very similar to the Basis of TSUP SR 4.9.4.
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Attachment 1 P-89344 j Page 7 of 7 SR 5.7.3 Add a new SR 5.7.3 with e. requirement to determine that the reactor temperature and pressure conditions satisfy LCO 4.7.1 every- 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to verify the SHUTDOWN MARGIN ir. accordance with SR 4.1.4. This is a new requirement for the~ existing surveillance and identical to TSUP SR 4.9.1.
SR 5.7.4 This is a new surveillance added to provide requirements not included in the current Technical l Specifications for the Spent Fuel Shipping Cask. .
SR 5.7.4 and the Basis are identical to TSUP SR 4.9.5.
An associated LCD statement is included.
SR 5.7.5 This specification adds new survaillances for the startup channel monitoring of neutron flux during a refueling period. The surveillance are very similar to those contained in current SR 5.4.1 and very similar to TSUP SR 4.9.2.
The Basis describes that these surveillance are in ,
addition to the calibration requirements of SR F.4.1. 1 Also included is a discussion of the condition where the startup channel rod withdrawal prohibit can be bypassed.
SR 5.7.6 This- is a new SR added to provide surveillance requirements for the new Communications During Core Alterations LCO (LCO 4.7.6). It incorporates the TSUP analysis intact.
Includes an associated LCO statement.
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