IR 05000267/1987007

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/87-07

ML20214Q440
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/01/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8706050030
Download: ML20214Q440 (2)

Text

JUN I 1987 1

.

..

In Reply Refer To:

Docket: 50-267/87-07 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 of May 7,1987, in response to our letter and Notice of Violation dated April 7, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review

j the implementation of your corrective actions during a future inspection to determine that full compliance has been schieved and will be maintaine

Sincerely, ORIGINAL SIGNED BY:

J. E. Gagliardo, Chief Reactor Projects Branch cc:

Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 1913 Platteville, Colorado 80651 P. Tomlinson, Manager, Quality Assurance Division (same address)

Colorado Radiation Control Program Director Colorado Public Utilities Commission bcc: (see next page)

f l

/

RIV:FRPS C:FRPS C:RPSB C:llP /4 C:RP8 REBaer/jt BMurray LAYande 1 JP,atd an JEGagi fdo'

4/e,/87

-'

5/A/87 0 4 ,/>7 4 ay

/gg/87 3 B706050030 870601 PDR G

ADOCK 05000267 PDR f@\

.

. .

Public Service Company of Colorado -2-bec to DMB (IE06)

bec distrib. by RIV:

RPB DRSP Resident Inspector R. D. Martin, RA D. Weiss, RM/ALF Section Chief (RPB/A)

RSB Section Chief (RSB/ES)

RPSB MIS System RSTS Operator RIV File l Inspector

! Section Chief L. A. Yandell R. L. Bangart R. E. Hall Project Inspector, RPB i

i l

_ - - - - - _ _ - - _ ---- - _- _ -- - _ - _ _ _- _ -_ -- _- - - - - - - - . - - - - - - - - -_- -

.

.

• O .

. . .

%"!L...

h Public Service ~ .

'

s@ M($hIb s !!

NV l 5861 May 7, 1987 ._ y Fort St. Vrain Unit No. 1 P-87163 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Docket No. 50-267 SUBJECT: I&E Inspection

.

Report 87-07'

REFERENCES: 1) NRC Letter, Gagliardo to Williams, dated 4/7/87 (G-87115)

2) PSC Letter, Williams to Gagliardo, dated 3/17/87 (P-87112)

Gentlemen: ,

This letter is in response to the Notice of Violation received,as a result of inspections conducted at Fort St. Vrain during the period March 2-6, 1987 (Reference 1). The following response to the item contained in the Notice of Violation is hereby submitted:

During an NRC inspection conducted on March 2-6, 1987, a violation of NRC requirements was identified. The violation involved the failure to sample and analyze liquid effluent prior to release. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below: )

Radioactive Liouid Effluent Release Technical Specification 8.1.2.b.1 requires that before' the release of radioactive liquid effluent, two representative samples of liquid effluent from the radioactive liquid waste system shall be analyzed for gross alpha activity, gross beta i activity, principal gamma emitters, I-131, tritium, dissolved and !

-

entrained gases, and other radioisotopes of concer d bk Mf _U (/ WV

..

,

. . ,

.

.

P-87163 -2- May 7, 1987 Contrary to the above, on February 7-8, 1987, approximately 2500 gallons of radioactive liquid effluent was released without two representative samples being obtained and analyzed before the releas This is a Severity Level IV violation. (SupplementI)(267/8707-01)

(1) The reason for the violation if admitted:

The release of radioactive liquid effluent without prior analysis of representative samples occurred due to a personnel misunderstanding that resulted from a procedural deficiency and a communication error. The individuals involved believed that the liquid released on February 7-8, 1987, had been previously sampled and analyze On February 5,1987, in preparation for a release of liquid ;

effluent from the FSV monitor tank, the Health Physics Supervisor initiated an investigation to determine if the contents had been

. sampled as required. This investigation determined that the tank had been sampled on February 1,1987, and the contents were designated as release #1034 The Operations personnel contacted ;

at that time had no recollection of performing release #1034 and documentation of the release was not found. The Health Physics Supervisor then concluded that the tank contents were release

1. 103 Duplicate documentation was prepared, based on the February 1, 1987 sampling, and the release was mad .

In reality, release #1034 had been made on February 3, 1987. 'The l documentation was apparently in route to the affected departments at the time of the Health Physics investigation. When the release documentation was reviewed the error was recognized and pSC reported the event to the NR ,

. '

,

The procedural deficiency and communication error that resulted I in this unanalyzed release are described as follows:

procedural Deficiency The process for performing liquid waste releases is not controlled from initiation to completion through the Technical Specification surveillance procedure, to the extent that all affected departments are not kept equally

,

aware of the status of a releas ! .

-'~-~-}

.

m ,

.

. '.

-

.  ;

,

l P-87163 -3- May 7, 1987 The initiation of a liquid waste release begins with a verbal request from Operations to Health Physics indicating a need to . perform a release and requesting that the monitoring tank be sampled. . Health Physics obtains two samples from the recirculated monitoring tank and delivers i them to Radiochemistry for analysi Radiochemistry analyzes the- samples and initiates a Radioactive Liquid l Waste Release Form along with the release number and release calculation The release form is then sent to Health Physics for their review of. the calculation Upon completion of the review, the release form is then delivered to Operations at which time the actual release is performed in accordance with the surveillance procedure ESR 8.1.2 bed- Hence, the surveillance procedure for liquid waste releases is initiated when Operations receives the Radioactive Liquid Release Form from Health < Physic Operations performs the release and completes the surveillance procedure. Upon completion of.the release, the surveillance procedure, ESR 8.1.2 bed-M, is sent to Scheduling and the release form is sent to Health Physics for revie Once Health Physics reviews the release form, it is forwarded to Radiochemistr Radiochemistry and Health Physics are not required to sign off -on the surveillance procedure, acknowledging initiation and completion of a releas . \

Communication Error

1 The Health Physics Supervisor instructed his technicians to investigate the possibility of liquid effluent release #1034 ever being made. He assumed that they would check station logs. The technicians, however, only checked verbally with Operations personnel to see if the release was ever mad Nobody in Operations had any recollections of the release being made, so it was reported to the Health Physics Supervisor that the release was never performed when in actuality, it had been. There was sufficient documentation in the station logs to determine that the release had been performe > , 1

,

' e

,

'\

t e

% -

, _ _ _ _.- - - - - - - - _ - - - - ..

.. . .

-

.. .

.

.~

. .

,

• *. .

.'

P-87163 -4- May 7, 1987 (2)The corrective steps which have been taken and the results achieved: .

New policies have been placed in effect that prohibit duplicating Radioactive Liquid Release Forms and Radioactive Gas Waste Release Fo rm These policies also prohibit making a release before the completed release form from the previous release has been received by Radiochemistry. If a liquid effluent release

'

form is lost, the monitoring tank will be recirculated and two samples retaken and reanalyzed with a new form being issued from this data. If a gas waste release form is lost, another grab sample and tritium sample will be taken and reanalyzed with a new form being issued. In this way, no unanalyzed liquid effluent release or gas waste release will be mad (3) Corrective steps which will be taken to avoid further violations:

.

The liquid waste release surveillance procedure will be revised to more clearly define and control the different responsibilities involved in the release process. This will eliminate the possibility for a communication error because all affected i departments will be made aware of the sta+.us of the release and will follow it more closely in its progression from initiation to completio Procedures dealing with radioactive gas waste releases ,and reactor building sump releases will also be reviewed, with this consideration in mind, and revised as neede ,

' ~

(4) The date when full compliance will be achieved:

June 30, 1987 .

This event was reported to the NRC in Licensee Event Report 87-004

. (Reference 2).

(

(

'

\ #

t

. .

. ,

,

,

8 O s a

.

P-87163 -5- May 7, 1987 Should you have any further questions, please contact Mr. M. H. Holmes, (303) 480-696

Sincerely,

,

R. O. Williama, J Vice President, Nuclear Operations

'

Fort St. Vrain Nuclear Generating Station R0W:FJB/skd '

cc: Regional Administrator, Region IV Attn: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain

-

Ocensing Review By: _ _ _ _

.

~% Date.' T'*?'9 ' W] ~

'

l':f

.

\

.

l['

s

.

T l

,

E

o *. .

Document Name:

PSC-38 Requester's ID:

OP29 Autho 's Name:

Baer/jt Document Comments:

Thank you for response to NOV 87-07

.