ML20086T118
| ML20086T118 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/24/1991 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | |
| Shared Package | |
| ML20086T117 | List: |
| References | |
| NUDOCS 9201060141 | |
| Download: ML20086T118 (43) | |
Text
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E i BEFORE THE1 UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of the Facility Operating Li;ense)
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of )
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PUBLIC SERVICE COMPANY OF COLORADO )
1 1
Application for Amendment to Appendix A of the -
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-the Facility Operating License, License No. OPR-34, is submitted for NRC review and approval, Respectfully s'ubmitted, 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' 2~
9'61O60141 911224-PDR- ADOCK0500g7_-
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4 In the Matter of the Facility Operating License) of )
Public Service Company of Colorado Fort St. ) Docket No. 50-267 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 of Amendment to the 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.
0' h4 X. Clegg trawford F /
Vice President, Nuclear Operations STATE OF b b l4 M )
)
COUNTY OF /2Xrttl(h b )
Subscribe and sworn to before me, a Notary Public on this d@/ day of St dunDLL ,199J.
kkO.Ll.i 0AlhJLU fot'ary Public My commission expires '2 ,1932
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t ATTACHMENT 1 TO P-91435 .
SUMMARY
OF PROPOSED CHANGES .i
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Tege 1 Summary of Pronosed Chang _e_s Specification Changem License Revised to allow the physical security plan, Condition 3 guard trainits and qualification, and safeguards contingency plans to he terminated after all nuclear fuel has been removed from the Protected Area.
Chapter 7, Replaced " Manager, Nuclear Production and All Station Manager" with "Defueling and Decommissioning Program Director and Station Manager".
Chapter 7, Replaced "Vice President, Nuclear Operations" All with "Vice President responsible for nuclear activities".
7.1.1.2.b.1 Revised requirements for shift crew composition to apply only until all nuclear fuel has been removed from the FSV Protected Area.
7.1.1.2.b.3 Revised the requirement that a licensed operator be present in the control room during all shutdown and refueling conditions, to apply only until all nuclear fuel has been removed from the Protected Area. Also, deleted reference to the Technical Advisor.
7.1.1.2.b.6 Revised:the requirement that an operator or l
technician qualified in radiation protection procedures be on sits e never fuel is on site, to only apply when r nuclear fuel is within the Protected Arch iad during physical activities involving radioactively contaminated systems or equipment.
7.1.1.2.b.7 Revised to state that a Fire-Brigade is not required after- all nuclear fuel has been removed from the Protected Area.
l l 7.1.1.2.b.10 Deleted reference to the _ Superintendent of Operations. Also, added statement that RO and SRO licensing requirements do_not apply after all nuclear fuel has been removed from the Protected Area.
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< . I Page 2 Summary-of Proposed Channes (Continued)
Specification Chances 7.1.1.2.b.12 Deleted reference to th? 1achnical Advisor.
Also, added statement #Ast control room command requirements do not apply after all nuclear fuel has been removed from the-Protected Area.
Table 7.1-1 Added note that licensed operators and a minimum shift crew composition are not required after all nuclear fuel has been removed from the Protected Area. Also, deleted reference to Tet:hnical Advisors.
7.1.1.3 Deleted requirements for Technical Advisors.
This deleted page 7.1-Ba, so pages 7.1-8b and 7.1-8c were re-numbered as 7.1-8a and 7.1-8b.
7.1.1.4 Revised plant staffing and qualification requirements to apply only-until all nuclear fuel- has been removed from the Protected Area.
7.1.1.5.a,b Replaced " Nuclear Training and Support Manager" with " Facility Support Manager".
Also, added condition that the training programs for the-staff and the Fire Brigade are only required until all nuclear-fuel has been removed from the Protected Area.
7.1.1.5.c Deleted Technical Advisor training requirements.
7.1.2 Revised P] ant Operations Review Committee membership titles to reflect FSV reorganization.
7.1.2.5.j Revised. Radiological Emergency Response Plan to Defueling Emergency-Response Plan.
7.1.3 Revised Nuclear Facility Safety Committee membership titles to reflect FSV reorganization.
.7.4.a Revised .the requirement to _have written procedures for " Refueling-- operations" to "Defueling activities".
7.5.1.c Deleted Monthly Operating Report requirements.
f e Page 3 SJimmary of Proposed Chances (Continued 1 Specification Chances 7.5.1.e Revised requirements for the Semi-annual Radioactive Effluent Release Report to cover plant activities during the previous six months, versus during the previous six. months "of operation".-
7.8 Added new controls for High Radiation Areas.
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ATTACHMENT 2 TO P-91435 PROPOSED CHANGES This Attachment includes only those pages with proposed cF"'ges.
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-Fort St. Vrain Technical Specifications License Information Enclosure (1) to AEC Letter dated 12/21/73 Amendment No.
Page 4 of 5 (2) Technical Specifications The Technical Specifications contained in Appendices A l and B, as revised through Amendment No. , are hereby incorporated in the license. The licensee shall maintain the facility in accordance with the Technical 5pecifications.
1 (3) Until all nuclear fuel has been removed from the-l Protected Area, the licensee shall fully implement and maintain in effect all' provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans-including amendments made pursuar,t of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the-authority of 10 CFR 50,P3 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Fort St. Vrain Security Plan, Fort St. Vrain Guard Training'and- Qualification -Plan, and Fort St.
Vrain Safeguards Contingency Plan. All plans are with revisions submitted through June 6, 1990 as supplemented l by letter dated September 14,'1990. After all nuclear i fuel has been removed from the Protected Area, these l plans may be terminated.
(4) Introduction of New Natural Gas Sources While spent fuel or radioactive graphite core components remain onsite, no new natural gas sources (i.e., sources other than those analyzed and found acceptable in the staff's Safety Evaluation in support of License Amendment No. 82) shall be introduced within 0.5 miles of the location wher:. spent fuel or radioactive graphite core components are' stored, for any_ purpose, unless the licensee. submits and the NRC has reviewed and approved an' analysis demonstrating _that such natural gas will not present an unacceptable hazard to_the spent fuel or to-the radioactive- graphite core components or -to the equipment or systems needed.to protect the spent fuel or-
-radioactive graphite core components.
In accordance with this restriction, the opening of the 6-inch isolation valve leading to. the 16-inch natural-gas pipeline south of the plant, for any purpose other than short-term maintenance and surveillance' activities with the 6-inch valve continuously manned by an operator who has been instructed to promptly close-the valve in the event- a pipeline rupture is-observed or suspected, shall be considered a new natural gas source requiring analysis.
Fort St. Vrain 01 Technical Specifications Amendment No.
Page 7.1-1 7.1 ORGANIZATION, REVIEW, AND AUDIT-ADMINISTRATIVE CONTROLS Applicability Applies to the lines of authority and responsibility for the operational safety of the facility, and the organization for periodic review and audit of facility operation.
Objectives To define the principal- lines 'of authority and responsibility-for providing continuing review, evaluation, and improvement of the plant operational safety.
SPECIFICATION AC 7.1.1 - -ORGANIZATION,-ADMINISTRATIVE CONTROLS
- 1. RESPONSIBILITY l a. The Defueling and Decommtssioning Program Director I and Station-Manager shall.be responsible'for overall ,
unit operation and shall delegate in writing the~
succession to this responsibility during his absence, b .- The Shift Supervisor-(or dur_ing his absence from the l
control room andL Shift Supervisor's ' office, a designated individual) shall be responsible for the=
control' __ room command- function. A--management l directive -to this effect, signed -by the Vice l Pre;ident responsible for nuclear activities shall be reissued to all station personnel on an annual basis.
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Fort St. Vrain #1 Technical Specifications Amendment No.
Page 7.1-2
- 2. ORGANIZATION
- a. Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.
(1) Lines of authority. responsibility, and communication shall be established and defined for the highest management levels through intermediate levels, including all operating organization positions. These relationships shall'be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These- requirements - shall: be documented in the FSAR.
-l- (2) The Defueling and Decommissioning Program l Director and Station Manager shall be responsible - for overall unit safe operation and shall have control over those onsite activities l- necessary for. safe operation and maintenance of I
l the plant.
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- Fort St.-Vrain #1-Technical Specifications
-Amendment No.
Page 7.1-3 l (3) The Vice President responsible for nuclear
[ activities shall have corporate responsibility-for overall plant nuclear safety and'shall take .
any measures needed to ensure acceptable performance of the staff _ in -operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
(4) The individuals who train the operating: staff and those who carry out health- physics and: ;
1 quality assurance fonctions may repJrt to the '
appropriate onsite manager; however, they shall-have sufficient organizational freedom to' ensure their independence from operating pressures.
bc Unit Staff l (1) Until all nuclear. fuel has been removed from the l Protected Area (as shown on Figure 6.3-2), each on-duty shift shall be composed of at least the minimum shift crew composition shown_ in Table 7.1-1.
-(2) A -licensed operator must be.in the control-room-at all times.when fuel is- in'the reactor.
I (3) During shutdown and defueling' conditions, until:
l all nuclear fuel -has been removed from the:
1 Protected Area, an individual with a valid RO
-(or SRO) license shall be present :in the control
.] room.
Fort St Vrain 01 Technical Specifications Amendment No.
Page'7.1-4 (4) During the performance of reactor startup, reactor shutdown, and recovery from reactor tri t , two licensed operators must be in the control room, (5) All core alterations shall be observed and ,
directly supervised by either a licensed Ser.i or Reactor Operator or Senior Reactor Operator Limited to Fuel Handling. who has no other concurrent responsibilities during this operation.
(6) An operator or technician qualified in radiation protection procedures shall be present at the I facility at all times that there is nuclear fuel I within the Protected Area, and during any i physical ,ctivities involving radiologically l contaminated-systems or 9quipment.
(7)-Fire Brigade staffing requirements .have been:
incorporated into the Fire- Protection Program l Plan, A Fire Brigade is not required after all I nuclear fuel has been removed from the Protected l Area,
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Fort St. Vrain 01
.Techaical Specifications.
' Amendment No.
Page 7.1 (d) Except during extended shutdown periods, the use of overtime should be. considered _ on an individual basis and not for the entire staff on shift.
(9) If unusual circumstances arise requiring deviation from the above guidelines, such I deviation shall be authorized by the Defueling
, I and Decommissioning Program Director and Station Manager, his designee, or higher levels' of management, and with documentation of the basis for granting the deviation. Controls shall be established such that excessive individual overtime hours have not been assigned, The paramount consideration in overtime assignment shall be that significant reductions in the-effectiveness of operating personnel- would be highly unlikely, Routine- deviation from the above guidelines is not authorized.
Authorized- deviations .to the working hour f .
. guidelines shall be documented and available for.
review by the Nuclear Regulatory Commission.
l (10) The Shift Supervisors, and the Operations
-l- Manager shall hold:a Senior Reactor Operator's.
license. --The' Reactor-. Operators shall hold a
[ Reactor Operator's license, These - are not I requirements after all nuclear fuel has been l removed from the Protected Area,
Fort St. Vrain 01
. Technical Specifications Amendment No.
Page 7.1-7 (11) Except for the Shift Supervisor, the Shift Crew Composition may be one less thah the minimum requirements of Table 7.1-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the Shift Crew Composition to within the minimum requirements of Table 7.1-1. This provision does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crewman being late or absent.
This provision also does not exclude the requirement for a,i SRO licensed individual to be in the control room at all times other than the shutdown conditions specified in Table 7.1-1.
(12) During any absence of the Shift Supervisor from
. the control room or Shift Supervisor's office while the unit is in Hot, Cold, or Refueling Shutdown, an individual with a valid SRO license or R0 license shall be designated to assume the control room command' function. During any absence of the Shift Supervisor from the control room or Shift Supervisor's office during all l other conditions, an individual.with a valid SRO license shall be designated to' assume the l control room command -function. These are not' l requ irements after all nuclear fuel has been l removed from.the Protected Area.
Fort St. Vrain 01 Technical Specifications Amendment No.
Page 7.1-8 TABLE 7.1-)
MINIMUM SHIFT CREW COMPOSITION (c) l l Number of Individuals Required to Fill Position i i l l .I -
l l During Hot, Cold, or l l l Position l Refueling Shutdown (a) l All Other-Conditions l-1 I l 1 ,
I l l l l SS (SRO) i 1 l 1 l l l I l l SRO l Not Required i 1 l I l I . l.
I R0 1 1 1 2 (b) l l 1 I I I E0 l 1 1 1 1 1 1 I l l AT l Not Required i 1 l 1 I I I I SS - Shift Supervisor with a Senior Reactor Operator's License SRO - Individual with a Senior Reactor Operator's License R0 - Individual with a Reactor Operator's License EO - Equipment Operator '
AT - Auxiliary Tender NOTES
- a. Per Technical Specification definitions .Section 2.0, .
- b. One of_ the two Reactor Operators may -be -an Equipment Operator with a valid R0 license provided that th: ' staffing requirement for Equipment Operators is being met by another individual-qualified as an Equipment Operator.
I c. Licensed operators and a minimum shift crew composition.&re l not required after all nuclear-fuel has .been- removed from I the Protected Area.
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Fort St. Vrain #1 i Technical Specifications Amendment No.
l Page 7.1-8a
- 3. TECHNICAL ADVISORS l These requirements have been deleted in their entirety.
- 4. UNIT STAFF QUALIFICATIONS l a, Until all nuclear fuel has ? ,en removed from the l Protected Area, the staf fing of the plant shall be in accordance with American National Standards Institute (ANSI) N18.1-1971, " Selection and Training of Personnel for Nuclear Power. Plants".
I b. Until all nuclear fuel- has been removed from the l Protected Area, each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18,1-1971 for the comparable re.ition, except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September, 1975.
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Fort St. Vrain #1 Technical Specifications Amendment No.
l Page 7.1-8b
- 5. TRAINING l a. Until all nuclear fuel has been removed from the l Protected Area, a retraining and replacement training program for the cacility staff shall be maintained under l the direction of the Facility Support Manager, and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR 55. ,
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has been removed from the l b. Until ali nuclear fuel l Protected Area, a training program for th'e Fire Brigade j shall be maintained under the direction of the Facility Support Manager, and shall meet. or exceed the requirements of Section 27 of the NFPA Code-1975, except for Fire Brigade training / drill sessions which shall be held at least once per calendar quarter.
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Foet St. Vrain #1 Technical Specifications Amendment No.
Page 7.1-9 Specification AC 7.1.2 - Plant O_perations Review Committee (PORC), Administrative Controls The organization, responsibilities, and authority of the PORC shall be as follows:
- 1. Membership The Plant Operations Review Committee shall be composed of the following:
l Chairman: .Defueling and Decommissioning Program I Director and Station Manager l Deputy Program Director-l Facility Support Manager l Radiation Protection Manager Operations Manager l Defueling/ Maintenance Manager Systems Engineering Manager l l Decommissioning Engineering Manager.
- 2. Alternates An alternate chairman and' alternate -members . if required, shall be appo!.1ted in writing by- the PORC Chairman to -serve .in_ the absence of a chairman or a-member; however, no more than two alternate members shall participate as voting members in PORC activities at any-one-time.
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Fort.St. Vrain 01 .
Technical Specificotions
- Amendment No.
Page 7.1-10 ,
- 3. Meeting Frequency The PORC shall meet at least once per calendar month and as convened by the Chairman or his designated alternate.
- 4. Quorum A quorum shall consist of the Chairman or alternate Chairman, and four members including alternates.
- 5. Responsibilities The p0RC shall be responsible for:
- a. Review of all procedures required by Technical Specification 7,4(a), (b), (c), (d) and changes thereto, and any other proposed procedure or changes to approved procedures as determined by the-l Defueling and Decommissioning Program Director and-l Station Manager to affect nuclear-safety; 1
- b. Review of all proposed tests' and experiments that- ,
affect nuclear safety,
- c. Review of all proposed changes to the_ Technical Specifications,
- d. Review ot- all proposed changes or modifications.to' .
plant . systems or equipment that_ affect nuclear e
safety.
Fort St. Vrain #1 Technical Specifications Amendment No.
Page 7.1-11
- e. Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering the evaluation and recommendations to prevent recurrence to the l Defueling and Decommissioning Program Director and Station Manager and to the Chairman of the Nuclear Facility Safety Committee.
- f. Review of all Reportable Events.
- g. Review of facility operations to detect potential nuclear safety hazards, h, Performance of special reviews, investigations, and reports thereon as requested by the Chairman of the Nuclear Facility Safety Committee.
- i. Review of -the Plant Security-Plan and implementing procedures.
l-l j. Review of the plant Defueling Emergency Response l Plan and implementing procedures,
- k. Review of the Fire Protection Program Plan and L
implementing. procedures.
Fort._St Vrain #1 Technical Specifications Amendment No.
Page 7.1-11a 6, Authority The PORC shall:
I a. Function to advise the Defueling and Decommissioning l Program Director and Station Manager on all matters that affect nuclear safety, I b. Recommend to the Defueling and Decommissioning l Program Director and Station Manager in writing, approval or disapproval of items considered under 5.a through 5.d, abcve,
- c. Render determinations -in writing with regard to whether or not each item considered under 5.a through 5,e above constitutes an unreviewed safety question,
- d. Provide immcdiate written notification to. the l Defueling and Decommissioning Program--Director -and Station Manager, and. the Chairman of NFSC.'of.
I disagreement between-the PORC and-the Defueling and l Decommissioning Program Director 'and Station l Manager; however,.the Defueling and Decommissioning l Program Director and Station Manager shall have responsibility for resolution of such -disagreements pursuant to 6.a above.
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Fort St. Vrcin #1 Technical Specifications Amendment No.
Page 7.1-12
- 7. Records The PORC shall maintain written minutes of each meeting l and copies shall be provided- to the Defueling and l Decommissioning Program Director and Station Manager, and Chairman of the Fort St. Vrain Nuclear Facility Safety Committee.
Specification AC 7.1.3 - Nuclear Facility Safety Committee (NFSC), Administrative Controls I
The oroani7 tion, responsibilities, 0nd authority of the _
NFSC shall be as follows:
- 1. Function The Nuclear Facility Safety Committee shall collectively have the competence required to review problems in the following areas:
a . Nuclear Power Plant Operations
- b. Nuclear Engineering
- c. Chemistry and Radiochemistry
- d. Metallurgy p
Fort St. Vrain 01
., , Technical Specifications Amendment No.
Page 7.1-13 e, Instrumentation and Control
- f. Radiological Safety
- g. Mechanical and Electrical Engineering h, Quality Assurance Practices
- 1. Other appropriate fields associated with the unique characteristics of the nuclear power plant.
- 2. Membership The NFSC shall be composed of the following:
Chairman (As appointed - See Step 4) l Defueling and Decommissioning Program Director and Station 1 Manager l Deputy Program Director l Nuclear Licecsing Manager 1 Systems Engineering Manager l Decommissioning Engineering Manager l Quality Assurance Manager l Radiation Protection Manager
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Safety _and Security Director Consultants, as- required, shall be appointed in writing by l the Vice President _ responsible for nuclear activities.
3.-Alternates Alternate members, if required, shall be appointed in writing by:
l_ the Vice President responsible for nuclear activities; however, no more' than 'two alternate members shall participate as voting-members in NFSC activities-at any one time.
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Fort St. Vrain #1 Technical Specifications Amendment No.
Page 7.1-14
- 4. Chairman The Chairman and Alternate Chairman of the NFSC shall be l appointed in writing by the Vice Presiden+ responsible l for nuclear activities and shall serve as members of the NFSC.
- 5. Consultants Consultants shall be utilized as determined by the Chairman, NFSC, to provide expert advice to the NFSC.
6, Meeting Frequency The NFSC shall meet at least once per calendar quarter during the initial year of facility operation following fuel loading and at least once per six months thereafter.
- 7. Quorum A quorum of the NFSC shall consist of the Chairman or:
nis designated alternate and a majority of the NFSC members incibding alternates. No more than a minority of the quorum shall have line responsibilities for operation of-the facility.
- 8. Responsibilities
- a. The Nuclear Facility Safety Committee shall review:
(1) The safety evaluations for safety significant changes to procedares, equipment, or systems
Fort St. Vrain #1 Technical Specifications Amendment No.
Page 7.1-18 I
personnel or an outside fire protection firm; (b) a biennial audit of the fire protection program and implementing procedures; (c) a triennial fire protection and loss prevention inspection and audit utilizing an outside qualified fire consultant.
(9) The Offsite Dose Calculation' Manual and Process Control Program and implementing-procedures at least once per 24 months.
(10) The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months.
(11) The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21 Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975, at least once per 12 months.
- 9. Authority l The NFSC shall report to and advise the Vice President l responsible for nuclear activities on those areas of responsibility specified in 0.a, 8.b and 8.c above.
- 10. Records Records of NFSC activities shall be prepared, approved, and distributed as indicated below;
- a. Minutes of each NFSC meating shall be prepared and l forwarded to the Vice President responsible for l nuclear activities within 30 days following each meeting, i
Fort St. Vrain
Technical Specifications Amendment No.
Page 7.1-19 I b. After preliminary- approval by the Vice President l responsible for nuclear activities, the minutes shall be distributed to all NFSC members, and approved at the next NFSC neeting.
- c. Reports of- reviews encompassed by Section 8.a.
l above shall be- forwarded to the Vice President l responsible for nuclear activities, within 30 days following completion of the review.
- d. Audit reports encompassed by Section 8.c, above j shall'be forwarded to the Vice Presioent responsible l for nuclear activities, r.d to the_ management-positions responsible for the areas audited- within 30 days after completion of the audit.
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h Fort St. Vrain 01 Technical Specifications Amendment No, t Page 7.2-1 1
7.2 SAFETY LIMITS, ADMINi3TRATIVE CONTROLS Applicability Appli>-, to the administrative procedures to be followed in the event that a safety limit is exceeded.
Objectives j l
To define the administrative procedures which will be fo'. lowed in the event that a safety limit is exceeded.
i specification AC 7.2 - Acticn to be_Taken if a Safety Limit is__~Eg eeded,-Administratfve Controls It a safety limit is exceeded, as defined in Specification SL 3.1 and 3.2, the fol'iowing action shall be taken:
a, lhe reactor will be shut down immediately and reactor operations shall not -be resumed until approval is received from the NRC.
- b. The safety limit violation shall be reported to the l Commission, the. Defueling and Decommissioning '
l Program Director -and Station Manager, and to the r Chairman, NFSC immediately,
- c. A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the PORC, This report shall ' describe (1) applicable circumstances preceding the violation. - (2) effects of the violation upon facility components, systems or 2 structures, and (3', corrective action taken to
- prevent recurrence.
- 1. The Safety Limit Violation Report shall be submitted
! to the Commission, the Chairman, NFSC and. the l Defueling and Decommissioning Program Director and Station Manager within ten days of the violation.
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fort St. Vrain #1 Technical Specifications Amendment No.
Page 7.4-1 7.4 PROCEDURES - ADMINISTRATIVE CONTR01.5 Applicability Applies to administrative procedures which wi ;cvern plant operations.
Obiective l
To ensure that written procedures will be maintained to define requirements for plant operation.
Specification AC 7.4 - Procedures._ Administrative _ Controls
- a. Written procedures shall L.e established, )
implementco and maintained covering the activities i
referenced below;
- 1. The applicable procedures recommended in Appendix A of Safet> Guide 33, November,1972.
l 2. Defueling activities.
- 3. Surveillance and test activities of safety-related equipment. !
- 4. Security Plan implementation.
- 5. Emergency Plan implementation. i r
- 6. Process . Control Program (PCP) impicmentation.--
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Fort St. Vrain #1 Technical Specificottons Amendment No.
Page 7.5-3 and surveillance, in-service inspection, l routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty functions may be estimates based on pocket. dosimeter, TLD, or film badge measurements. $ mall exposures totaling less than 20% of the individual total dose need not be accounted for, in the aggregate, at least 80% of the whole body dose recoived from external sources shall be assigned t specific major work functions.
I c. Month 1.y Operating _ Report l The requirement for -this report _ ha s_ been_
i l deleted.
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Fort St. Vraiu #1 Technical Specifiestions Amendment No.
Page 7.5-4 l
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- o. Annual Radiological Environmental, Monitoring Report A report on the Radiological Environmental t
Monitoring Program for the previous calendar year shall be submitted- to the Nuclear Regulatory Commission in accordance with 10 CFR 50.4 as a separate document by May 1 of each year.
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Fort St. Vrcin 01 Technical Specifications Amendment No, Page 7.5-7 prepared and submitted to the Nuclehr Regulatory Commission in the Annual Radiological Environmental Monitoring Report.
- e. Semi-annual Radioactive Effluent Release Report -
Routine Radioactive Effluent Release Reports l covering the activities of the unit during the l previous six months shall be submitted within 60 days after January 1 and July 1 of each year. ,
The Radioactive Effluent Release Reports shall include a summary of the quantities of radioactive liquid and gaseous offluents and
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solid waste released from the unit as outlined in Regulatory Guide 1,21, " Measuring, Evaluating, and Reporting Radioactivity in bolid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from-Light-Water-Cooled Nuclear Power Plants,"
Revision-1. June, 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.
An annual summary of - hourly; meteorological-data collected over the previous year shall be maintained for five years by the licensee.
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Fort St. Vrain #1 Technical Specifications Amendment No. i Page 7.8-1 1
l 7.8 HIGH RADIA110N AREA l 7.8.1 Pursuant to 10 CFR 20, in lieu of the " control j device" or " alarm signal", each high radiation I area, as defined in 10 CFR Part 20, shall be l barricaded and conspicuously posted as a high l radiation area and entrance thereto shall be l controlled by requiring issuance of a Radiation l Work Permit (RWP). Individuals qualified in l radiation protection procedures (e.g.. Health l Physics personnel) or personnel continuously l escorted by such individt.als may be exempt from the 4
l RWP issuance requirement during the performance of l their astigned duties in high radiation areas with .i l exposure rates equal to or less than 1000 mR/h, l l provided they are otherwise following plant l l radiation protection procedures for entry into such l high radiation areas. Any individual or group of l individuals permitted to enter such areas shall be ,
provided with or accompanied by one or more of the following:
l a. A radiation monitoring device which l continuously indicates the radiation dose rate l in the area, or l b. A ' radiation monitoring device which l continuously integrates the radiation dose I rate in the area and alarms when a preset l integrated dose is received. Entry into such l areas with this monitoring device may be made l after the dose rate level in the' area has been l established and. personnel have been made-l knowledgeable of them, or l c. A health physics qualified irdividual (i.e.,
l qualified in radiation protection procedures)
I with a radiation dose rate monitoring device l who is responsible for providing positive l control over the activities within the area l and shall perform periodic radiation.
l 9rveillance at the frequency specified by the l . facility Health Physics staff in the RWP.
i l
d Fort St. Vrain 01 Technical Specifications Amendment No.
Page 7.8-2 i
l 7.8.2 In addition to the requirements of 7.8.1, areas t
I accessible to personnel with radiation levels l greater than 1000 mR/h at 45 cm (18 in.) from the I radiation source or from any surface which the l radiation penetrates shall be provided with locked l enclosures to prevent unauthorized entry, and the I
l s l keys shall be maintained under the administrative I control of the Shift Supervisor on duty and/or I health physics supervision. Enclosures shall !
l remain locked except during periods of access by l personnel under an approved RWP which shall specify ,
l the dose rate levels in the immediate work area an;i ?
l the maximum allowable stay time for individuals in '
I that area. In lieu of the stay time specification l of the RWP, direct or remote (such as use of closed I circuit TV cameras) continuous surveillance may be l made by personnel qualified in radiation protection .
I procedures to provide positive exposure control !
I over the activities within the area.
l For individual areas accessible to personnel with l radiation-levels of greater than 1000 mR/h that are located within large areas, where no enclosure exists for purposes of locking, and no enclosure .
can be reasonably constructed around the individual areas, then that area shall be- barricaded, ,
conspicuously posted and a flashing light shall be l activated as a warning device whenever the dose l rate in the area exceeds or will shortly exceed l 1000 mR/h.-
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NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS-
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Attachment 3 to P-91435 Pago 1 HO SIGiiITIC/.HT HAZARDS CollSIDERhTIOli AllALYSIS This request to amend the FSV Facility Operating Licenso and the Administrativo Controls Section of the Technical Specifications involvos soveral administrativo changos, all of which are associated with program revisions and organizational changos
.ppropriato for a ;wrmanently shutdown plant. Each chango will bo described and just. riod individually. Thoso descriptions will than be followed by a No Significant Hazards Consideration Analysis in accordance with the critoria contained in 10 CFR 50.92.
- 1. MADagpmunt Titio Chancqa PSC has undertaken a re-organization within Nuclear Operations to allow a bottor transition to tho decommissioning organization. This re-organization climinatos -cortain positions and creates othors, with the result that many of the positions identified within the Technical Specifications must be revised.
All references to the Vice President, Huclear Operations have boon replaced with the Vice President responsible for nuclear activities. This designatos the executivo levol position with responsibility for all activities associated with Fort St.
Vrain.
All references to the Mt egor, Nuclear Production and Station Manager have been replaced with the Dofueling and' Decommissioning Program Director and Station Managor.
Plant operations Review Committoo (PORC) membership has boon revised to include the-following:
Defueling and Decommissioning Program Director and Station Manager (formerly' Manager, Nuclear Production and Station Manager)
Deputy Program Director (now position)
Facility Support Manager (formerly Nuclear Training and Support Manager)
Radiation Protection Manager (formerly Superintendent of Chemistry and Radiation Protection)
Operations Manager ,
Defueling/Maintenanco Manager (new position)
Systems Engineering Manager Decommissioning Engineering Manager (now position)
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Attachmont 3 r
- to P-91435 Page 2 lioclear racillcy Safety Committoo (NPSC) membership han boon revised to include the followingt Chairman Dofueling and Decommissioning Program Director and Station Manager (formerly Manager, Nuclear Production and Station Managor)
Deputy Program Director (now position)
Nuc30ar Licensing Manager (formorly Manager, Nuclear Licensing and Resource Management)
Systems Engineering Manager (formerly Manager, Nuclear Engincoring Division)
Decommissioning Engineering Manager (now position)
Quality Assuranco Manager (formerly Manager, Quality Assuranco Division)
Radiation Protection Manager (formerly Nuclear Training and Support Managar) "
Safoty and Security Director consultants, so required Justification The ro-organization described abovo is illustrated on the attached organization chart, provided for information. This organization will improve internal commur.ications by reducing overall management positions and clininating at least one level of management. Also, this organization focuses on the office of the Program Director which will facilitato the transition into the Early Dismantlement decommisujoning organization upon the completion of defueling. For those reasons,-PSC has announced that this organization will ho implemented in January 1992.
This organization retains sufficient expertise and diversification within both the PORC and NFSC, consistent with that contained in the present committoos, and with the guidanco provided in the Standard - Technical Specifications (e.g., Westinghouse STS, NUREG-0452, Rwvision 5). The functions and charters of these safety committoos have not boon changed.
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Attachment 3 to P-91435 Page 4
- 2. Ecsgrity Proaram Deletion After Fuel Removal Licenso condition 3 was revised to allow the termination of the physical security plan, guard training and qualification, -
and safeguards contingency plans after all nuclear fuel has boon removed from the FSV Protected Area. ,
F Justification! After all nuclear fuel has been removed from the FSV Protected Area, PSC will implement an Access control plan, consistent with Section 8 of the Proposed Decommissioning Plan. At that time,- FSV will not be a-utilization facility as defined in 10 CFR 50.2, we will not conduct activities licensed pursuant to 10 CFR 70, and formula quantities of strategic special nuclear material or special 1 . clear material will no longer be within the FSV Protucted Area. Thorofore, a physical security plan, guard training and qualification, and safeguard contingency plans in accordance with 10 CFR 73 will not be required.
- 3. Egigtion of Licensed Operators Af ter Fuel Immoval All requ!.rements for licensed operators (e.g., RO, SRO, SSLO) were revised to allow the deletion of those positions once all nuclear fuel has been removed from the FSV Protected Area, Jystification: Onca all nuclear fuel has been removed from the FSV Protected Area, then Fort St. Vrain will no longer be considered a nuclear reactor or a utilization facility as defined in 10 CFR 50.2. Therefore, the operator licensing requirements in 10 CFR 55 are not applicable and licensed operators are not required. This is consistent with j the organizational requirements contained in the proposed FSV Decommissioning Technical Specifications (PSC Letter, Crawford to Weiss, dated August 30, 1991, P-91278).
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Attachment 3 to P-91435 Page 5
- 4. Deletion of Technical Advisors All references to Technical Advisors were delnted.
Justificationt Deletion of the Technical Advisor position can be accomplished at the present time, based on the permanent shutdown condition of the plant. This is consistent with the equivalent Shift Technical Advisor (STA) requirements in the Westir.ghouse Standard Technical Specifications (HUREG-0452, Revision 5). STS Table 6.2-1, Minimum Shif t Crow composition, does not require that the STA position be manned during cold shutdown and refueling modes. The permanently shutdown condition of Fort St. Vrain allows sufficient time for any plant concerns to be resolved by available staff, including operations, System, Engineering, and Management personnel.
- 5. Deletion of the Fire Brictade Af ter Fuel Removal All requirements for a Fire Brigade were revised to allow deletion of the Fire Brigade after all nuclear fuel has been removed from the FSV Protected Area. ;
Justification: once all nuclear fuel has been removed .
from the FSV Protected Area, Fort St. Vrain will essentially I have the same fire hazards- that will exist during decommissioning. PSC has developed a Decommissioning Fire Protection Plan (D/FPP) appropriate for the hazards during decommissioning, and this plan does not include requirements for a firo brigade. The 10 CFR 50.59 safety evaluation for the D/FPP states that a fire brigade is not required after all nuclear fuel has been removed from the plant based on the reduced consequences of a fire, and considering the availability of local offsite fire department assistance. A copy of the 10 CFR 50.59 safety evaluation for the D/FPP is being provided for NRC information under separate cover (PSC Letter, Crawford to Weiss, dated December 2 0, 1991, P-914 3 4 ) .
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Attachment 3 to P-91435 Page 6
- 6. Redefinition of Reauirements for Radiation Protection Personnel The requiremont that an operator or technician qualiflod in radiation protection procedures be present at the facility whenever fuel is on site was revised to apply whenever nuclear fuel is within the FSV Protected Area and during physical activition involving radioactively contaminated systems or equipment.
Justification The FSV ISFSI is located on PSC property and therefore could bo considered "on sito". However, the ISFSI design does not require that radiation protection personnel be on site while fuel is being stored in the ISFSI.
After all nuclear fuel has been removed from the Protected Area, radiation protection personnel will bo requirad an cito during physical activities involving radioactively contaminated systems or equipment, to ensure adequato worker protection.
- 7. Personnel Oualification The requirements that plant staffing and qualifications shall meet ANSI N18.1 were revised to apply only until all nuclear fuel has been removed from the Protected Area.
Justification: ANSI N18.1' provides requirements for selection and training of personnel for nuclear power plants.
After all nuclear fuel has been removed from the Protected Area, Fort St. Vrain will not be considered a nuclear reactor as defined in 10 CFR 50.2, and the requirements for nuclear power plants will not be applicabic.
- 8. Recuirement for Defuelina Procedures Section 7.4 was revised to require written procedures for "Defueling activities" in lieu of " Refueling operations".
Justification This revision formalizes - PSC's current-practices for applying the previous requirements for
" Refueling" administrative controls to "Defueling" activities.
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Attachment 3 to P-91435 Page 7
- 9. Reletion of _ Monthly ODeratinct Report The requirements to submit a Monthly Operating Report were deleted.
4 Justification: FSV AC 7.5.1.c requires that the Monthly Operating Report includet (1) a narrative summary of operating experience including major safety-related maintenance, (2) a report of any single release of radioactivity or radiation exposure which accounts for more than 10% of the allowable annual values, (3) a report of indications of failed fuel, and (4) monthly statistical information contained in Regulatory-Guide 1.16.
Relative to Item (1), the FSV Possession only License precludes any further operation of the plant. Therefore, r there wil? be no additional operating experience to report.
Also, the amount of major safety.related maintenance has boon and is expected to be small, would not be of generic interest, and is not significant enough to support a monthly report.
Regarding Item (2), radioactivity releases that exceed specified limits trust be reported within 30 days in accordance with Administrative Control 7.5.3, and reports of overexposures are required by 10 CFR 20.405.
Regarding Item (3), there is no mc7hanism to create additional' failed fuel, as long as LCO 4.2.15 PCRV liner cooling requirements are mot. Any LCO 4.2.15 violations would be reportable via an LER.
Regarding Item (4), the Possession Only License precludes any further operation, so there will be no further power level, availability, or generation statistics to report, as required by Regulatory Guide 1.16.
Most of the Monthly Operating Report information is not applicable for a permanently shutdown plant, and the information that would be applicable is available from other sources. Therefore, the continued submittal of a FSV Monthly Operating Report is not meaningful and this task may be deleted.
l Attachment 3 l to P-91435 Pago 8 10, Revision of Semi-annuni RadigActive Effluent Release Report 1 :
l The requiremont for the Semi-annual Radioactivo Effluent Roloano Roport to cover the previous six months of operation was revised to cover the previous six months.
Justificationi. Further opqration of Fort St. Vrain has boon precluded by the Possession only Liconne. Therefore, it is appropriate that the Semi-annual Radioactivo Effluent Roloaso Report cover the previous six month period.
- 11. Mdition of Illgh RadiatiQ.D_AE9A. Controls, Now Section 7.8 was added to provido requirements for conducting activitios in a high radiation area under Radioactivo Work Permit controls.
JustificationL These requirements are consistent with the Westinghouse Standard Technical Specifications (NUREG-0452, Revision 5), and with Appendix D of Draf t Regulatory Guido DG-8006, " Control of Access to liigh and Very liigh Radiation Areas in Nuclear Power Plants", which is being developed consistent with the now 10 CPR 20 requirements.
The proposed Section 7.8 differs from the Standard Technical Specification (STS) wording in that specifits 10 CFR 20 paragraph references have been dolcted.- Also, the specific critoria that define a high radiation area have been doloted, so_that a high radiation area is "as defined in 10 CFR Part 20". The paragraph numbers and the high radiation area critoria differ betwoon the current 10 CFR 20 and the now 10 CFR 20. PSC currently anticipates that defueling will be completed before the implementation date of the new 10 CFR 20 requirements, and that the Decommissioning Technical Specifications will then supersedo the existing Technical
. Specifications. However, the proposed Section 7.8 wording l will allow use of either the current 10 CFR 20 or the new 10 CFR 20 requirements.
An additional change from the STO wording is that the last
- sentonce in Section 7.8.2 states that a flashing light will bo i activated as a warning device "whenever the doso rato in the i
area exceeds cr till shortly exceed 1000 mR/h. " The phrase in quotes is included in DG-8006, but it is not a part of _ the STS
-wording; PSC included this phrase as a clarification of the requirements for a warning device around a very high radiation area.
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Attachment 3 to P-91435 Page 9 ,
llo Sionificant Harards Consideration Analysis In tacordance with the standards in 10 CFR 50.92, and based on the justification provided above, the proposed amendment to the FSV Facility Operating License and Technical Specifications involvos no significant hazards consideration, since it would nott
- 1. Involve a significant increase in the probability or consequences of an accident previously ovaluated.
This amendment generally maintains the current lovel of administrativo controls until all nuclear fuel has beois removed from the FSV Protected ' Area. The climination of Technical Advisors and the establishment of now high radiation area controls is consistent with controls provided in the Standard Technical specifications in uso at other nuclear facilities. Based on the justifications provided abovo in the discussion of individual proposed changes, the program reductions allowed after fuel has boon removed from the Protected Area and tb- Other proposed changes do not increase the probability or the consequences of any provlously evaluated accidents.
- 2. Create the possibility of a new or different kind of pccident from any accident previously evaluated.
The proposed revisions to the Administrative Controls do not create any new or abnormal modes of equipment operation and do
- not create the possibility of any new accidento
- 3. Involve a significant reduction in a margin of safety.
As long as nuclear fuel is located within-the FSV Protected Area, the samo level of administrative review will be retained as is currently in offect and personnel qualifications will bo i
maintained. After nuclear fuel has been removed, the lovel of administrative controls provides an appropriate administrative l margin of safety. No operational margins of safety are affected by this proposed amendment.
I conclusion:
Based on the above, it is concluded that performance of defueling or other shutdown activities at Fort St. Vrain, in accordance with the proposed changes to the Adminir.trative controls, will involve no significant hazards consideration.
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