ML19332A533
| ML19332A533 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 09/08/1980 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| P-80302, NUDOCS 8009160344 | |
| Download: ML19332A533 (4) | |
Text
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PLATTEVILLE, COLOR ADO 80651 September 8, 1980 Fort St. - Vrain Unit No. 1 P-80302 Mr. Robert L..Tedesco Assistant Director for Licensing Division of Licensing U. S. Nuclear Regulatory Cormission Washington, D.C.
.20555 Docket No. 50-267
Subject:
Amendment No. 22 to Facility Operating License No. DPR-34
Dear Mr. Tedesco:
Amendment No. 22 to the Facility Opetating License was received at the ' plant site on August 28, 1980. Since the license amendment is effective as of the date of issuance,' and since the date of issuance was identified as August 19, 1980, ' the time diff erence between issuance and receipt obviously precludes prompt implementation of the amendment. Amendments issued in this fashion present considerable problems in that immediate implementatica of an anend-ment of this size is impossible.
Due to the nature and scope of the material contained, the number of new surveillance test procedures to be performed, distribution of copies of the a
amendment, and the time required to f amiliarize personnel with'the new LCO requirements, immediate implementation of Amendment No. 22 is not feasible.
Prompt imples.ntation of any amendment is further compounded by the fact that upon receipt of an amendment, the licensee staff perforgs a detailed review of all material included with the amendment to determine:
1.
Which proposed-revisions wera approved.
- 2.. If the proposed revisions were approved as submitted.
3.
Whether or not clerical errors exist.
)
4.
Whether or not all pages 'isted as being removed and added are contained in the attachment.
A 1
f001 5.
That plant procedure changes reflect current procedure issues.
S That plant' procedure. revisions or cancellations are properly approved and l O 6.
dispositioned.
8009160 Y
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Mr. Robert L. Tedesco September 8, 1980 Upon issuance of an _ approved surveillance test required by the anendment, the test must be performed to verify that it fulfills the functional requirements specified in the procedure.
Based on criteria 1, 2, 3, and 4 above, the following problem areas were identified with Amendment No. 22.
1.
a) The cover letter lists P-77221 dated November 1,1977, as part of the amendment.
The purposa of P-77221 was to provide the commission with further analysis performed relative to certain accident conditions described in the FS AR, using Technical Specifications LCO 4.1.3 and 4.1.7, to facilitate approval of reactor operation at 100% power. The Safety Evaluation Report (SER) supporting Amendment No. 22, Section 9.0, Accident Reanalysis, page 14, first paragraph achnowledges that fact.
A Technical Specification change was not requested in P-77221.
Although it is recognized that P-77221 is not included in Step 1. A of the summary sheet of the Commission's findings, the reason for inclusion of this material in the SER with Amendment No. 22 is not clear.
b) Material contained in an app? ' cation for amendment dated January 23, 1979 (P-79015), was approved in Amendment No. 22, but was not in-cluded in either the cover letter or the summary sheet of the Con-mission's findings.
2.
A revision to Specification SR 5.4.1 was approved, but was not aji sub-mitted to the Commission on March 23, 1976 (P-76075).
The Safety Evaluation Report (SER) supporting Amendment No. 22, Section 6.0 Reactor Protective Systen Surveillance, page 9, s tates that the NRC staff and the licensee agreed to add the statement which modified the requested Technical Specification change as submitted in P-7f 075 in order to satisfy J
the requirements of IEEE-279-1971.
Technical Specification AC 7.1.2e.3 and AC 7.1.3g. l(d) require review of proposed changes to the Technical Specifications by the Plant Operations Review Committee (PORC) and the Nuclear Facility Safety Committee (NFSC).
The change to SR 5.4.1 included with Amendment No. 22 was not prepared by, discussed with, or verbally agreed to by any members of the Fort St.
Vrain staff. There was no correspondence from the Commission to the Fort St. Vrain staff which indicated a need to submit a revision to the change requested in P-76075.
Therefore, the revision to Specification SR 5.4.1, approved with Amend-ment No. 22, bypassed the normal revieu path, and was neither reviewed nor approved by the PORC or the NFSC as required by Specifications AC 7.f.2 and AC 7.1.3.
Mr. Robert L. Tedesco September 8. 1980 Furthermore, since the Fort St. Vrain staff was not included in any dis-cussions which related to the change as issued, no analysis was made to determine if the method is physically or electronically feasible.
Arrangements to preclude a similar situation appear to be in order.
We believe this requires clarification by the Commission.
3.
Clerical errors, as such, were not imnediately evident.
However, incon-sistencies in type, spacing, and page numbering were. Handwri: ten changes appear on pages 5. 4-3. 5. 4-4, 4. 2. 4a and 5. 2-10c.
Since handwritten changes are not acceptable per FSV procedures and since the amendment -is distributed as approved and issued by the Commissica, thfi is not an acceptable situation.
4.
All pages listed on the ATTACHMENT sheet were not contained in the at-tachment. Page 5.2-22 was missing. However, a new page identified as 5.2-21(a) should correctly have been designated as 5.2-22.
In order to resolve the problem of immediate implementation with Amendment No. 22, Public Service Company of Colorado requests that the provisions of the Amendment, with the exception of SR 5.4.1, be made effective October 1, 1980. This would allow the plant staff sufficient time to '.ssue the new surveillance tests required and to become familiar with the extensive new LCO requirements.
We request that the amended SR 5.4.1, item 3c under " Method" of Table 5.4-1 and item Ic under " Method" of Table 5.4-4 not be made effective until a mutual understanding is reached between PSC and the Connission.
That vill require that the Commission provide us with an interpretation of the intent, content, and requirements described by Amendment No. 22; a review by PSC to determine if we can comply with the specified method; and, PORC and NFSC review as required by Technical Specifications AC 7.1.2 and AC 7.1.3.
Further, we request that any future amer.dments provide a reasonable time for g
receipt, review, and preparation for implementation prior to being-made ef-
- fective, e
To resolve the problems identified during the review of Amendment No. 22, Public Service Company of Colorado requests the following:
1.
a) Safety Evaluation Reports which are not part of an amendnent to the Facility Operating License be submitted under separate correspcadence.
b) All applications for amendment which are approved by the Commission be included in the summary sheet of the Conmission's findfhgs.
2.
Changes required to submittals be formally documented so that the pre-scribed review and approval process can be adhered to.
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3.
Structure and format be consistent.
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Mr. Robrirt L. Tedesco September 8,1980 We request your concurrence as soon as possible. If you have any grastions, please contact ne at (303) 571-7436.
Very truly yours, 1
,G~
JYM Don Warembourg "anager, Nuclear Production DW/cis G
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