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16805 ROAD 19%PLATTEVILLE, COLORADO 80651-9298*

August 26, 1981Fort St. VrainUnit No. 1P-81213

\ 4O el I r~!

Mr. James R. Miller, Chief f ( {Standardization & Special Sw SEPOs Odf am.2p.s,ka p ,-

Projects Branch

IdDivision of Licensing

kNuclear Regulatory CommissionyWashington, D. C. 20555 %.r

,

%Subject: NUREG 0737 J'

|

Ref: NRC Order Dated August 6, 1981

| Dear Mr. Miller:

| We are in receipt of the above refert ced order, but we are somewhat'

confused in the implications the order may have with specific refer-

j ence to page 4 wherin it is stated that:

"The licensee shall satisfy the specific requirementsdescribed in the Attachment to this Order, as appropri-ate to the licensee's facility, as early as practice-able but no later than 60 days after the effective dateof the Order.",

!

! As you are aware there has been considerable correspondence involv-ing the various items of n11-2 and the associated guidelines ofNUREG 0737 concerning the applicabildty of these requirements to

i Fort Saint Vrain. In some cases the requirements are clearly not; applicable to Fort Saint Vrain and other cases the applicability| did not provide a well defined path of action. We have evaluated,

| and responded accordingly, to the individual NUREG 0737 items, butwe have not, to date, received any NRC response relative to thevarious positions we have taken. In order to clarify the impli- 1

cation associated with the Order we believe it is necessary to; clarify the various items of the Attachment to the Order.

i

In this respect we have provided in the attachment to this letteran update of the various NUREG 0737 guidelines which delineatesthe present status of the items. In many cases, implementation hasbeen completed or will be completed within 60 days. In other cases

|

8109090233 810826 'p'

PDR ADOCK 05000267IP PDR g

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MR. JAMES R. MILLER, CHIEFAugust 26, 1981P-81213-Page 2

implementation has not and cannot be accomplished without further~

i resolution. These latter items primarily involve areas where ex--, ceptions have been taken, alternatives have been proposed, or ex-isting methods and/or procedures are, in our opinion, adequateto meet the intent of NUREG 0737 as these items are applicable,partially applicable, or unapplicable to Ft..St. Vrain.-

You will note from the attachment that we have responded to eachitem, and with few exceptions our responses were submitted withinthe schedules set forth by the requesting documents. We were re-cently informed that the entire review of our responses ae well asan overall evaluation of applicability of NUREG 0737.to gas cooledreactor technology has been contracted by the NRC to Oak RidgeNational Laboratory.

The key to the Order is the interpretation of the words "as appro-.priate to the licensee's facility" and the issue at han4 and theintent of our clarification is to provide further information withregard to that wording,and to point out that we obviously cannot

; implement some of the items which are subject to further actionl and/or resolution on the part of the NRC.

VVery truly yours,

h 1T WRA.<s ~{DonW.Warembour}gManagerNuclear Production

DWW/skd

Attachment

cc: George Kuzmycz_

Jim Miller

:

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ATTACHMENT P-81213

Clarification of Attachment

To NRC Order Dated August 6, 1981

Impl/ Docitem Title Applicability Specific Requirement Suba Due Dates PSC Status

1.A.1.1 STA ALL (a) Provide STA coverage by 1/1/81 Letter P-80438, dated Decembe r 20, 1980degreed individuals (or indicated that the STA training had been

equivalent), trained to completed.licensee's program.

(b) Submit description of 1/1/81 Letter P-80444, December 30, 1980 pro-current training program vided the description of the STA Training,and demonstrate compliance our program for continued training and our

with 10-30-79 letter. long tern program for retaining the STA's.

(c) Submit description of long 1/1/81term training program.

I.A.2.1 Reactor Operator ALL Submit description of and imple- 8/1/80 The revised operator training program was

Qualification ment Upgraded Training Program. submitted via P-81002, January 2,1981,and in presently in effect.

1.C.I Accident Procedures ALL (a) Submit reanalyses of inade- 1/1/81 Item I.C.1 vas specifically addressed inquate ecre cooling and p.o- our letter P-80438, dated December 20, lepose guidelines for emer-gency procedures, OR proposeschedule and justify delays.

(b) Submit reanalysis of 1/1/81 Based on several accident reanalyses that PSC'transients and accidents for had already completed in response to otheremergency procedures, OR pro- NRC inquiries, PSC has concluded that nopose schedule and justify further analyses or reanalyses are required.''

delays.

I.C.5 Feedback of ALL Implement procedures for feed- 1/1/81 Initial response - P-80438, December 20,Operating Experience back of operating experience (no 1980 indicated intent to comply. Program

documentation submittal is required). has been implemented and is presently ineffect.

l.c.6 Correct Performance ALL implement procedures to verify 1/1/81 Initial Response P-80438, December 20,1980or Operating Activities correct performance of operating follow-up response P-81075 February 27y

metivities (no documentation 1981 sets forth PSC position. To date nosubmit tal is required). response has been received.

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Attscheent P-81213;Page 2

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Impl/ Docj ;

i" Item Title Applicability Specific Requirement Sube Due Dates PSC Status

f< 4

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| 11.B.2 Shielding ALL (a) Have available design 1/1/81 Initial response and evaluations submittedu

details for vital area via P-79299 December 12, 1979 and P-79312.modifications. December 27, 1979. Further clarification

in P-90438, December 20, 1980 indicatesCDC-19 Cuide11nes can be met without fur-ther action.

I- (b) Submit technical 1/1/81deviations to staffpositions.

II.B.3 Post-Accident ALL Submit description of 1/1/81 Initial response P-79299, P-79312 andSampling deviations from staff P-80028. Follow-up response P-80438 in--

positions. .dicates compliance by January 1982.

-11.B.4 Training to ALL (a) Have available for 1/1/81 Initial response provided by F-80438 in-

Hitigate Core review a training dicates many of the guidelines of 4 '

Damage program for mitigating II. R. Denton's letter of March 28, 1980

core damage (no documen- are clearly not applicable to an HTCR.tation submittal required) The revised program was submitted via

P-81002, January 2,1981 and is now in(b) Implement training program 4/1/81 effect.

(no documentation submittalrequired).

II D.1 Performance ALL (a) Submit test. program (both 7/1/80 (PWRs) Response provided by P-80028 keys Ft. St.Testing nf BWR/PWR's). 10/1/80 (BWRs) Vrain program to F.PRI study. Implemen-RV/SRV's .

tation dependent on study result.(b) Submit qualification

program for PWR's blockvalve. 1/1/81 (PWRs)

.

11.E.1.2 Aux Feed PWRs (a) Submit final design and 1/1/81 Although not specifically designated as

Initiation documentation on safety being appilcable to Ft. St. Vrain our

and Flow grade flow indication initial evaluation was forwarded viaP-79299, December 12, 1979.

(b) Submit final design and 1/1/81 Further clarification provided by P-80438,documentation on safety indicates existing instrumentation meets

grade flow initiation. the requirements.

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f Attactueent P-81213*i

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Impt/ DocItem Title Applicability Specific Bequirement Suba Due Dates ' PSC Status

s

11.E.4.2 Containment ALL (a) Submit documentation 1/1/81 Initial response provided via P-79299'

1 solation justifying minimum contain- December 12, 1979 and P-80028. February'24ment pressure setpoint ' for 1980. . Partial acceptance received f ron NRCisolation of non-essential on March 31, 1980.

penetrations.

(b) Submit statement that purge 1/1/81' Follow-up provided in P-80438 tweember.20,valves not meeting CSS 6-4 1980 with the conclusioen that containment-(or interim position) are isolation is adequate and no further mod-

'

sealed and verification is ification is required.performed every 31 days.

11.F.1 Post-Accident ALL (a) For noble gas monitor 1/1/81 Initial response provided by F-79130,

Monitoring and lodine / particulate P-79249. P-79299, F-79312 and P-80028.sampling and analysis . ..Further clarification is provided bysubmit description and P-80438. .e-justification for devi-ations from staff re-quirements.

(b) Have available the final 1/1/81 PSC does have some additional portabledesign information for todine monitors on order with an expectednoble gas monitor and delivery of late October or early November.,iodine / particulate sampling 1981. In the interim PSC has established-and analysis. procedures for-fodine sampling that have

been reviewed by NRC 1 & E. a

C

11.F.2. Inst. for inadequate ALL Submit a report detailing the 1/1/81 ; Initial response provided via P-79299,

Core Cooling planned instrumentation system December 12, 1979. NRC 1et.er datedfor monitoring inadequate core March 31, 1980 indicates this requirementcooling. has been satisfied.

11.K.2.10 Antic. Trip on BW Submit final design for 1/1/81' Clearly not applicable to Fort St. Vrain.

LOW and TT anticipatory trip asdescribed in NUREC 0737.

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j - Attachment P-81213! Page 4

Impl/ Doc

Itg . Title Applicability Specific Requirement Suba Due Dates PSC Status-

II.K.2.13 Ther==1 Mechanical B&W Submit report on effects of 1/1/81 Not applicable to Fort St. Vrain.

Report Hi Pressure Injection onvessel integrity for SB LOCAwith no Aux Feedwater.

II.K.3.2 PORV/SV Failures PWR Submit report on SB LOCA and 1/1/81 NotappilcabletoFortSt'.VrAin'probability of fatture of PORV/SV/RV.

II.K.3.3 SRV/SV Failures ALI. Submit report (historical and 1/1/81 Not applicable to Fort St. Vrain.

& Challenges annually thereafter) of SRV/SVfailures and challenges.

II.K.3.7 PORY Opening R&W Submit report on the probability 1/1/81 'Not applicable t'o Fort St. Vrain.Probability of a PORV opening during an over-

pressurization transient.

-11.K.3.9 PID Controller Selected W Modify the Proportional Integral 12/1/80 Not appitcable to Fort St. Vrain.

Modification plants Derivative Controller (as recom-mended by W). Advise NRC whenmodif(cation-fg completed.

II.K.3.12 Anticipatory Trip W Submit confirmation of Antici- 1/1/81 Not appitcable to Fort St. Vrain.

on Turbine Trip patory Trip. If not currentlyimplemented, submit modificationdesign and schedule for imple-mentation.

II.K.3.13 Separation of HPCI/RCIC BWRs w/HPCI/RCIC Submit results of evaluation 1/1/81 Not applicable to Fort St. Vrain.Initiation Levels; Auto and proposed modification asRestart of RCIC appropriate.

II.K.3.16 Reduce Challenges to BWR Submit report on actions planned 4/1/81 Not applicable to Fort St. Vrain.

RV's to reduce RV challenges.

II.K.3.17 ECCS System Outages ALL Submit report on ECCS outages 1/1/81 Report was submitted via P-80441,and propone changes to reduce December 26, 19R0.

e outages.

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.. ,Attachment P-81213 ..

Page 5

Impl/ DocItem Title Applicability Specific Requirement Suba Due Dates PSC Status

11.K.3.18 ADS Logic BWR Submit report of feasibility 4/1/81 Not applicable to Fort St. Vrain.

Modifications of ADS system logic changesto eliminate need for manualactuation.

II.K.3.21 CSS /CPCI Restart BWR Submit report of evaluation, 1/1/81 Not applicable to Fort St. Vrain.

proposed modifications andanalysis to satisfy staffpositions.

II.K.3.22 RCIC Suction BWR w/RCIC Implement procedures and 1/1/81 Not applicable to Fort St. Vrain.

document. verification ofthis change.

11.1.3.27 Common Reference for BWR Implement change and submit 1/1/81 Not applicable to Fort St. Vrain.

110 Level Instruments documentation of changes.2

II.K.3.29 Isolation Condensor BWR w/ICs Submit evaluation of I.C. 4/1/81 Not applicable to Fort St. Vrain.

Performance performance.

II.K.3.30 SP LOCA Methods ALL Submit outline of program 11/15/80 Not applicable to Fort St. Vrain.for model.

II.K.3.44 Fuel Failure BWR Submit evaluation to verify 1/1/81 Not applicable to Fort St. Vraio..

no fuel failure..

II.K.3.45 Manual Depressur- BWR Submit evaluation on other 1/1/81 Not applicable to Fort St. Vrain.

Ization than ADS method fordepressuria. tion.

Il!.D.3.3 Improved Inplant ALL llave available means to 1/1/81 Initial response provided by P-79312 andIodine Monitoring accurately measure airborne P-80028. Interim procedures were estab-

,

radiotodine inplant during i 11shed. P-80438 indicated the new Radio-an accident. f chen Lab would be available by March 15,

1981. The Radio-chen Lab is now oper-ational. Additional instrumentation ison order with an espected delivery dateof October - November, 1981.

III.D.3.4 Control Room liabitability ALL (a) Submit control room 1/1/81 Response ' submitted via P-80438. December 12,habitability evaluation 1980 indicates existing condit e areinformation. adequate. No further action e =ntici-

O pated.

. (b) Submit modifications 1/1/81' <

.

.necessary to assure CR'3

habitability with a,

schedule for completion, i- I

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