ML20149E148

Forwards Comments on Revised Safety Evaluation Re Proposed Safe Shutdown Sys & Exemption Requests Concerning 10CFR50, App R

ML20149E148
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/03/1988
From:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
To:	Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
Shared Package
ML20149E150	List: ML20149E148 ML20149E162
References
P-88046, TAC-54373, NUDOCS 8802100346
Download: ML20149E148 (4)

Text

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2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 R.O. WILLIAMS, JR.

UELE DONS February 3, 1988 Fort St. Vrain Unit No. 1 P-88046 U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, D.C. 20555 Attention: Mr. Jose A. Calvo Director, Project Directorate IV Docket No. 50-267

SUBJECT:

PSC COMMENTS ON REVISED NRC FIRE PROTECTION SAFETY EVALUATION

REFERENCES:

1) NRC letter, Heitner to Williams, dated December 18, 1987 (G-87454)

2) PSC letter, Williams to Berkow, dated January 16, 1987 (P-87013)

3) PSC letter, Walker to Berkow, dated December 20, 1985 (P-85488)

4) PSC letter, Williams to Calvo, dated December 15, 1987 (P-87422)

Dear Fr. Calvo:

PSC has reviewed the NRC's revised Fort St. Vrain Fire Protection Safety Evaluation in Reference 1. PSC's comments are mostly editorial suggestions and are 'noted in the' attached marked up draft Safety Evaluation. Most of these markups are self explanatory. A few merit a brief exolanation, as described below:

b 8802100346 080203 NOD PDR ADOCK 05000267 p F PDR

i i P-88046 February 3,1988 Section 1.0 PSC considers that the NRC's previously issued Safety Evaluations on fire protection for the Three Room Control Complex should be referenced as part of the FSV fire protection regulatory guidance to complete the itemization of applicable NRC regulatory guidance to FSV on fire protection. Accordingly, these have been noted in the FSV Fire Protection Program Plan Section 1.2 and should be specified by the NRC in Section 1.0 of the SER as well.

Section 1.2 PSC considers that the schedular exemption from 10 CFR 50.48 requested in FSV's Appendix R Evaluation should be addressed and granted in this Safety Evaluation since it has not been officially approved yet. This involves adding a Section 2.13 to the SER on this subject.

Section 2.1 PSC notes that the NRC has chosen to use the term "post fire shutdown system" to denote the "FSV Fire Protection Shutdown /Cooldown" model, which is different from the FSV "safe shutdown" systems occasionally used in the draft Safety Evaluation. PSC has utilized the "post fire shutdown system" language where it may not have been included throughout the safety evaluation.

Section 2.1.2.1 The following sentence was added to the safety evaluation based on PSC's comments of January, 1987 in Reference 2:

"The post fire shutdown procedure includes an instruction that I should nuclear instrumentation be unavailable, operators are to I activate the use of the Reserve Shutdown System, in shutting down following a fire event."

This PSC coment was an explanatory enhancement, based on PSC's inclusion of such an instruction in FSV procedure SSCHDPC, "Safe i Shutdown and Cooling with Highly Degraded Plant Conditions", as noted '

in Reference 3. The PSC Response to NRC Question 14 in Reference 3 justified that source range flux monitoring was unnecessary following a fire at FSV, since like a BWR there could be no fire-induced boron dilution. As an additional safeguard PSC sta^.ed, i

"If following a fire the neutron monitoring instrumentation is lost or indication appears to be erroneous, the Reserve Shutdown Procedure will be activated.

This requirement was in addition to the FSV Interim Technical Specification LCOs 3.1.4 and 3.1.6., which require full insertion of sufficient control rods to achieve the specified shutdown margin, as verified by operable rod position indication, or the actuation of sufficient reserve shutdown material to achieve the specified ,

shutdown margin, when the reactor is snutdown, i

P-88046 February 3, 1988 When FSV procedure SSCHDPC, "Safe Shutdown and Cooling with Highly Degraded Plant Conditions", was superceded by procedure SSC-03, "Recovering From a NonCongested Cable Area Fire Resulting in an Interruption of Forced Circulation" and the commitments in Reference i 3 were superceded by the FSV Fire Protection Program Plan submitted r to the NRC.in Reference 4, this requirement was deleted in an effort  !

to standardize operator actions in accident events. The applicable Technical Specifications and operator training on them are sufficient

- to. ensure the ' timely actuation of tiie Reserve Shutdown System, if necessary, following a fire event. Therefore the additional neutron monitoring instrumentation induced actuation of the Reserve Shutdown i

System is not necessary, and should be deleted.

Section 2.1.2.2  !

PSC suggests adding the conclusion from PSC's most recent analysis .

concerning the effects of no liner cooling system operation on the  :

PCRV during functioning of the FSV Fire Protection Shutdown /Cooldown model, as an enhancement to the safety evaluation.

Section 2.1.2.3 PSC noted a suggested revision of the flow path description of the FSV Fire Protection Shutdown /Cooldown Train A to more accurately reflect the model in this section. PSC suggests revising Reference 16 in the draft SER to reflect PSC's most recent analysis instead of -

the superceded analysis referenced.

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P-88046 February 3,;1983 l Section 2.1.3.1  ;

i PSC has included suggested wording concerning _the verification of the l FSV fire protectirn equipment operability requirements, which were  !

recently submitted to the NRC in Reference 4. i If you have any questions enncerning these coments, please coatact  :

Mr.'M. H. Holmes at (303) 480-6960.

Very truly youk ,

i R. O. Williams, Jr.

Vice President, Nuclear Operations cc: Regional Administrator, Region IV ,

ATT: Mr. T. F. Westerman, Chief  ;

Project Section B l Mr. Kenneth Heitner t Project Manager, NRR Mr. Dennis Kubicki Fire Protection Engineer Plant System Branch, NRR Mr. R. E. Farrell '

Senior Resident Inspector '

Fort St. Vrain R0W/ RAS:bre ,

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1. o> EHITED STATES

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

Vice President, Nuclear Operations Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201-0840

SUBJECT:

REVISED FIRE PROTECTION SAFETY EVALUATION FOR CONiENT (TAC NO. 54373)

We have reytewed your comments on our earlier draft fire protection safety evaluation (SE) dated November 18, 1986. Your comments were submitted by letter dated January 16, 1987 (P-87013). Additionally, we have updated the SE to reflect certain changes you have proposed to your 7.ost fire safe shutdown model, as described in your letter dated May 15, 1987 (P-87167). Our revised SE is enclosed for yoer comments, As noted in the SE, a number of items are left open for verification through inspection. The inspection of thr.se items will be scheduled separately, but you are responsible for maintaining these items in an acceptable condition.

We have also held a number of discussions with your staff concerning the listing of fire protection modifications yet to be completed. The most recent update of this list is your submittal dated April 29, 1987 (P-87160). We find it acceptable for you to modify this list and inform the Commission at regular intervals of your changes. However, the overall goal of completing all fire protection modifications by startup following the fourth refueling should not be compromised.

We request you provide your final comments within 60 days of the date of this l letter. The information requested in this letter affects fewer than 10 I respondents; therefore, OMB clearance is not required under P.L.96-511. l Sincerely, n x Kenneth L. Heitner, Project Manager Project Directorate - IV Division of Reactor Projects - III, l IV, V and Special Projects  !

Office of Nuclear Reactor Regulation l

Enclosure:

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As stated -

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cc w/ enclosure: - I ~ i See next page ( ,j ^

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Mr. R. O. Williams, Jr.

Public Service Company of Colorado Fort St. Vrain cc:

Mr. D. W. Warembourg, Manager Albert J. Hazle, Director Nuclear Engineering Division Radiation Control Division Public Service Company Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201-0840 Mr. David Alberstein, 14/159A Mr. R. O. Williams, Jr., Acting Manager GA Technologies, Inc. Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. P. F. Tomlinson, Manager Public Service Company of Colorado Quality Assurance Division P. O. Box 840 Public Service Company of Colorado Denver, Colorado 80201-0840 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Senior Resident Inspector U.S. Nuclear Regulatory Commission Mr. R. F. Walker P. O. Box 640 Public Servica Company of Colorado Platteville, Colorado 80651 Post Office Box 840 Denver, Colorado 80201-0840 Kelley, Stansfield & 0'Donnell Public Service Company Building Commitment Control Program Room 900 Coordinator 550 15th Street Public Service Company of Colorado Denver, Colorado 80202 2420 W. 26th Ave. Suite 100-0 Denver, Colorado 80211 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Chairman, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency  :

1 Denver Place 999 18th Street, Suite 1300 Denver, Colorado 80202-2413 l

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