ML20149M285

Application for Amend to License DPR-34,revising Tech Specs Re Plant Protective Sys Trip Setpoints & Operating Requirements

ML20149M285
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/08/1988
From:	PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20149M274	List: ML20149M273 ML20149M285 ML20149M290
References
TAC-47416, NUDOCS 8802250463
Download: ML20149M285 (7)

Text

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of the Facility Operating License) of 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 cf Facility Operating License, License No. DPR-34, is submitted for NRC review and approval.

Respectfully submitted, PUBLIC SERVICE COMPANY OF COLORAD0 By R. O. Williams, Jr. ,

Vice President, Nuclear Operations KELLY, STANSFIELD & 0'DONNELL Bryant O'Donnell James K. Tarpey Public Service Company Building Denver, Colorado 80202

Attorneys for Applicant p PDR

P-88025 Page 1 February 8, 1988 Attachment 1 TO P-88025 PSC RESPONSE TO THE DRAFT TECHNICAL EVALUATION REPORT CONCERNING PLANT PROTECTIVE SYSTEM SETPOINTS FOR FORT ST. VRAIN l

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P-58025 Page 2 Attachment 1 February 8, 1988  :

By Letter dated June 21, 1985 (P-85214), PSC submitted a Technical Specification Amendment request to the Plant Protective System (PPS) .

Trip Setpoints taking into account instrumentation uncertainties. i Several iterations have occurred in the review / comment /re-submittal t process. The latest PSC submittal, dated August 28, 1987, included a 4

License Amendment to address only those parameters currently in the existing Technical Specifications tend based on a revised methodology j per NRC Letter dated November 26, 1986 (G-86624)

By Letter dated November 25, 1987 (G-87422), the NRC provided a Draft Technical Evaluation Report (TER) on the August 28, 1987 submittel.

A meeting was held on December 3,1987, as a part of the Technical

Specification Upgrade Program meetings, to discuss the Draft TER.

l The following open Items, as sunnarized in Section 4.2 of the Draft t

TER, are listed below with PSC's response based on the resolutions reached in the December 3, 1987 meeting.

NRC Item 1: ,

1 o In Figure 3.3-2, add "value" to the word "allowable."

PSC Response:

In the preparation of the revised figure the word "value" was inadvertently left out. The word "value" has been incorporated in Figure 3.3-2 on page 3.3-3b of Attachment 2 to this letter.

NRC Item 2: r o In Table 3.3-1 Items 2.c), 2.d), and 2.e), express the Trip j Setpoint and Allowable Value in terms of either greater than or l less than as well as t: qual to the value specified and not in j

4 terms of a value with a plus or minus or just a single value.

PSC Response:

On December 8,1987 Mr. Ken Heitner of the NRC notified PSC that their Contract Reviewer had re-evaluated the August 28, 1987 submittal and found that the parameters expressed with plus and .

minus tolerances are acceptable as proposed. In addition, Mr. .!

, Heitner requested that the Basis for these parameters be revised ,

j to address the lower limit values. '

l l I The bases for parameters 2c, 2d, and 2e in Table 3.3-1 have been

revised to address the safety issues for the lower limit value  !

i requirement. These bases are found on pages 3.3-7 and 3.3-8 of l

Attachment 2 to this letter. '

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P-88025 Page 3 Attachment 1 l February 8, 1988 '

NRC Item 3:

) o On p. 3.3-5 under "general methodology" clarify the definition of  !

"Allowable Value," delete the words "the greater value of "

clarify the paragraph discussirg the margin between the Trip setpoint and the Analysis Value, and change "accuracy or drift" >;

to "accuracy and drift" 'or justify why ISA S67.04-1982  ;

methodology was not followed for these differences, j PSC Response: f

! . l Following indepth technical discussions during the December 3, ,'

1987 meeting, agreement was reached that a more conservative 1 2 approach was used by PSC than that outlined in the ISA 567.04-  !

. 1982 Standard. Recognizing that the methodology described in the [

Basis for LSSS 3.3 (and as referenced in the Basis for LCO 4.4.1) was confusing, agreement was reached to onIt the detailed writeup and merely reference that the ISA Standard S67.04-1982 was used.

This resolution has been incorporated into the Basis on page 3.3-4 of Attachment 2 to this letter. l NRC Item 4:

o For the Helium Circulator Penetration Interspace Pressure, make the rupture disc lower limit burst consistent between i Table 3.3-1, p. 3.3-2c, Item 2.d) pressure and the value in the basis on '

p. 3.3-9.  :

PSC Response:

The lower tolerance value of -2% of the norninal 825 psig rupture disc setting is 16.5 psig. This value has been rounded off to 17 psig. The lower limit for the rupture disc now bccomes 825 psig j minus 17 psig or 808 psig. This value has been incorporated into i the Basis on pages 3.3-8 and 4.4-12a of Attachment 2 to this (

letter.  !

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l NRC Item 5:

1 1 o For Steam Generator Penetration Interspace Pressure, make the

! rupture disc lower limit burst pressure consistent between Table

! 3.3-1, p. 3.3-2c, Item 2.e) and the value in the basis on p. 3.3-l 9.

PSC Response:

I i See PSC response to NRC Iten 4. This value has been incorporated j into the Basis on pages 3.3-8 and 4.4-11.

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P-88025 Page 4 Attachment 1 February 8, 1988 NRC Item 6:

o In Table 4.4-4, Part 2, Items 3a. and 3b., under the column headed "Permissible Bypass Conditions" change "above 30% rated power" back to "none". '

PSC Response,:

The "permissible bypass conditions" for Items 3a and 3b has been changed back to reflect "none" as shown in Attachment 2 of this letter. The basis on pages 4.4-10 and 4.4-13 has also been revised to add more clarification on the bypassing of some protective actions.

NRC Item 7:

o For the Circulator Speed-Low circulator trip, supply the programmed curve as a function of feedwater flow.

PSC Response:

Agreement at the December 3, 1987 meeting was reached that this ~

Item should be part of the longer term issues for future submittals. This subject will be included in the future submittal on the issue of Circulator Speed High Programed with Feedwater Flow.  ;

NRC Item 8: i i

o In Ta ble 4.4-2 (Part 1), Items 7a., 7b., and 7c., add the l footnote "p" designation under the column titled "Functional Unit".

l PSC Response:

Footnote (p) has been added to Items 7a, 7b, and 7c on Table 4.4-2(Part 1) as shown on page 4.4-4b of Attachment 2 to this letter.

NRC Item 9:

o Provide Trip Setpoints, Delay Times, and Allowable Values for Degraded Voltage Loss of Voltage Automatic Throw Over (ATO), and Loss of Voltage-D.G. Start, Load Shed and Load Sequence.

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'achment I r *uary 8, 1988 PSC Response:

Agreement was ree.ched at the December 3, 1987 meeting that additional NRC direction would be provided to PSC as to whether this issue should be addressed in a separate near term submittal or integrated into a future submittal addressing the PPS parameters not presently included in the existing Technical Specifications.

Section 4.3 of the Draft TER listed two recommended changes to the FSAR as a result of the review of the August 28, 1987 submittal.  !

PSC has reviewed the two following Items and has initiated FSAP Activity Assignments for updating the FSAR in Revision 6 to address these recommendations:

o In the FSAR make the "steam in PSC" consistent between the cases 3, 5, and 6 in Table 14.5-3 and Figures 14.5-3, 14.5 Sa, and 14.5-6, respectively, o In FSAR Section 7.1.2.4, for Low Superheat Header Temperature clarify that in order to get the trip, coincidence is required with High Differential Temperature Between Loop 1 and Loop 2 in TS Table 4.4-2, and consider deleting Item 7c. and making High Differential Temperature Between loop 1 and Loop 2 an explicit coincidence requirement in each of Items 7a. and 7b.

PSC reviewed the recommendation for clarifying the High Differential Temperature between loop 1 and Loop 2 coincident requirement with plant personnel and finds that their preference is to retain it as a separately specified Technical Specification parameter. The

, associated instrumentation for this parameter is a PpS input (as designed), is supported by a Setpoint Calculation Binder, and is addressed in the PPS Training for plant operating personnel.

Section 4.4 of the Draft TER provided a list of remaining PPS Issues for future submittals. These Issues are as follows:

o Provide analyses to account for instrumentation inaccuracy per ISA 567.04-1982 methodology for the circulator trip function Programed Feedwater Flow-Low. Also, justify any intended pemissible bypass condition such as "below 30% power."

o Resubmit the analyses to account for instrumentation inaccuracy per ISA S67.04-1982 methodology for the circulator trip function

, Fixed Feedwater Flow-Low. This resubmittal should resolve the NRC Staff's concerns with the superheater II high inlet temperature reached due to a hot gas streak penetrating the entire economizer-evaporator-superheater and should justify the permissible bypass condition for this trip function of "below 30%

power."

o Provide analyses to account for instrumentation inaccuracy per ISA 567.04-1982 methodology for the rod withdrawal prohibit Trip

P-88025 Page 6 Attachment 1 February 8, 1988 Setpoints and Allowable Values in Table 4.4-4(Part 1), Items 3a.

and 3b. as minimum, p. 4.4-7a.

o Provide analyses to account for instrumentation inaccuracy in the permissible Bypass Conditions for the PPS trip. The PPS Permissible Bypass Conditions themselves also need justified.

o Provide upgrade to STS standards for Setpoint and Allowable Values for:

(i) Wide Range Channel Rate of Change-High Scram, Primary Coolant Moisture High Level Monitor and Loop Monitor Loop shutdown and rod withdrawal prohibits for Startup Channel Rate of Change-High, Wide Range Channel Rate of Change-High ,

Linear Channel-High Power RWP (channels 3, 4 '

5, 6, 7, and 8) and Multiple Rod Pair Withdrawal.

(ii) Provide upgraded PPS surveillance and calibration requirements.

Agreement was reached at the December 3, 1987 meeting that the issues listed above still require further NRC/PSC discussions in '

order to develop a plan and submittal schedule for their resolution.

It should be noted that the Surveillance Requirements submitted in the June 21, 1985 amendment request still requires NRC staff review for approval.  ;

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