IR 05000267/1986016

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/86-16

ML20211H912
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/20/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8702260322
Download: ML20211H912 (2)

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FEB 2 01987 In Reply Refer To:

Docket: 50-267/86-16 Public Service Company of Colorado ATTN: Robert O. Williams, J Vice President, Nuclear Operations P. O. Box 840 Denver, Colorado 80201-0840 Gentlemen:

Thank you for your Letter P-86493 dated August 5,1986, in response to our letter and Notice of Violation dated July 7,1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, Wnal Slaned By J. E. Gagflardo J. E. Gagliardo, Chief Reactor Projects Branch cc: l J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station i

16805 WCR 191

! Platteville, Colorado 80651 P. Tomlinson, Manager, Quality

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Assurance Division l (same address)

Colorado Radiation Control Program Director Colorado Public Utilities Commission bec: (see next pag

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h' PublicService~ reim se, Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651

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. August 5, 1986 Fort St. Vrain Unit No. 1 P-86493

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Director, Office of Inspection and Enforcement  ! AUG - 81986 U. S. Nuclear Regulatory Commission j l'

Washington, DC 20555 _

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Docket No. 50-267 SUBJECT: Response to Notice of Violation and Proposed Imposition of Civil Penalty REFERENCE: 1) NRC Letter, Martin to Walker, Dated 7/7/86 (G-86354)

2) NRC Letter, Gagliardo to Walker, Dated 5/23/86 (G-86277)

3) PSC Letter, Williams to Director, IE Dated 08/05/86

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(P-86492)

Gentlemen:

Attached is our response to the Notice of Violation and Proposed Imposition of Civil Penalty which resulted from NRC Inspection Report No. 50-267/86-1 The subject of this violation was the operation of the Fort St. Vrain Nuclear. Station at a power level in excess of 35". reactor powe Q QS[l

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P-86493 -2- August 5, 1986 Public Service Company of Colorado does not elect to request mitigation of the proposed civil penalty, in whole or in par A-check payable to the Treasurer of the United States in the amount of 575,000 has been remitted under separate cove Should you have any questions concerning this response, I will be pleased to discuss them with yo

Sincerely, f & -

R. O. Williams, J Vice President, Nuclear Operations R0W:CHF/kls cc: Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter ) .

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Public Service Company of Colorado ) ' Docket N Fort St. Vrain Unit No. 1 )

AFFIDAVIT

. . . . . . . being duly sworn, hereby deposes and says that he is Vice President of Nuclear Operations of Public Service Company of Colorado; that he is duly authorized to sign the file with the Nuclear Regulatory Commission the attached response to the Notice of Violation identified in NRC Inspection Report 86-16; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belie s s

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R. O. Williams, J Vice President of Nuclear Operations STATE OF [cd;<re /c )

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Subscribed and sgorn to before me, a Notary Public in and for r// / 183/('j/ssf_tyg'

on this 5d day of efu.Se u f , 1964

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RESPONSE TO NOTICE OF VIOLATION 50-267/8616-01 ATTACHMENT TO LETTER P-86493 Summary of Violation

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In the Commission's November 20, 1985 Memorandum and Order the maximum reactor power at Fort St. Vrain was limited to 35%. The Memorandum and Order also stated that the actual authorization of a 35% limit shall be made by the Director, Office of Nuclear Reactor Regulation. The Director, Office of Nuclear Reactor Regulation, issued the above authorizatioa by letter, dated February 7, 198 Contrary to the above, on May 6, 1986, between approximately 8:30 a.m. and 9:15 a.m., the Fort St. Vrain reactor was operated above the 35% restriction reaching a maximum power level of 42%.

This is a Severity Level III Violatio Statement of admission or denial of the alleged violation:

Public Service Company of Colorado admits that the Fort S Vrain reactor was operated at power levels above 35% for a l period of approximately forty-five (45) minutos on

- May 6, 1986. Further, Public Service Company of Colorado acknowledges that such operation was contrary to the Commission's Memorandum and Order of November 20, 198 Reason for the Violation:

Maintenance was to be performed to correct a minor oil leak on a l hydraulic operator. Due to an inadequate clearance, main steam l was bypassed to the reheat steam system, which ultimately resulted in reactor power exceeding 35%. Administrative controls were not effective in covering Management philosophy l with regard to the Commission's order or in providing guidance l to the Operations Staff to preclude exceeding the limitation.

l Corrective Steps that have been taken, and the results achieved:

Reactor power was reduucd to less than 30% and the Interlock Sequence Switch was plcced in the " Low Power" position. This action introduces a Rod Withdrawal Prohibit which automatically prevents control rod withdrawal if measured reactor power should exceed 30%. Operation in this manner continued until May 31, 1986, at which time the reactor was shut down for Environmental Qualification work.

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-2-Reactor Operators initially believed that the electro- -

hydraulic control (EHC) system was at fault at the beginning of the transient. Although investigation during and immediately following the power increase identified the bypassing of main steam as the cause of the event, the turbine generator was taken off-line and the EHC system was checked for deficiencies. No deficiencies which could have impacted the excursion were identifie A Special Instruction was written which specifically directed the Reactor Operators to scram the plant in the event that the reactor power should exceed 34% during subsequent operation until May 31, 198 Acknowledgement of the instruction was made by signature of all Reactor Operators on shif The importance of maintaining the plant within NRC-ordered operational limits was specifically discussed with the Superintendent of Operations and his staff. In particular, the meaning of an NRC Order was clarified, so that there could be no misunderstanding of its importanc The plant Transient Review Committee and Technical Advisor conducted reviews of the even From these reviews, recommended actions to prevent recurrence have been develope All Standard Clearances for Systems 13, 21, 22, 31, and 32 have been reviewed for their impact of plant operations in the event that the clearance boundary cannot be maintaine These systems were selected because of their potential impact on operations. Recommendations as a result of this review are currently being evaluate The corrective steps which will be taken to prevent recurrence:

Standard Clearance forms will be revised as a result of the recommendations of the above review. These revisions will be completed prior to restar Valve PV-22129-1 will be inspected and repaired as necessary. This valve was identified as the probable clearance boundary failure point. This work is currently scheduled and will be completed prior to restar '

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-3-Management philosophy with regards to NRC requirements and -

the resulting operator actions and responsibilities will be clarifie Specifically, this transient will be reviewed with Operations Staff, and supervisory authority will be redefine This has been partially completed; the remainder will be completed prior to restar The date when full compliance will be achieved:

Full compliance was achieved on May 6, 1986, when reactor power was reduced below 35%.

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