IR 05000267/1989007

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/89-07

ML20248A290
Person / Time
Site:	Fort Saint Vrain
Issue date:	07/28/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8908080235
Download: ML20248A290 (2)

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JLL 2 8 1989

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In Reply Refer T9:

Docket: 50-267/89-07 Public Service Company of Colorado ATTH: Robert 0. Williams, Jr., Senior Vice President, Nuclear Operations P.O..Bor. 840 Denver, Colorado 80201-0840 Gentlemen:

Thank you fcr your letter of July 14, 1989, in response to our letter and Hotice of Violation dated June 8, 1989. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation., We will review the imp 1mntation of yc>dr corre;tive actions during a future inspection to detennine that full compliance has been achieved and will be maintaine

Sincerely,

, Original Signed By:

890eoeon2509j7S567j Jamos L Milhoan ABOM 0 o PNV

$DR James L. Milhoan, Director Division of Reactor Projects cc:

Fort St. Vrain Nuclear Station ATTN: C. Fuller, Manager, Nuclear  :

Production Division '

16805 WCR 191 i Platteville, Colorada 80651

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Fort St. Vrain Nuclear Station  ;

ATTN: P. Tomlinson, Manager .

Quality Assurance Division 16805 MCR i9i Platteville, Colorado 80651 Colorado Public Utilittes Commission j ATTN: Ralph Teague, '

1580 Logan Street OL1 Denver, Colorado 80203 Colorado Radiation Control Program Director bec to DMB (IE01) w/ copy of licensee lt "

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Public Service Company of Colorado -2-  ;

bec distrib by RIV w/ copy of licensee ltr:

RRI R. D. Martin, RA l Project Engineer (DRP/B) i Sect 1on Chief (DRP/B)

RPB-DRSS Lisa Shea, RM/ALF j

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MIS System RSTS Operator K. Heitner, NRR Project Manager (MS: 13-3-18) RIV File DRS DRP

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Pu.blic Service-huly,14,1989 P.O. sox 840 -

Denver co 80201; 0840 Fort St. Vrain

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Unit No. 1 A. Clegg Crawford .!

P-89250 Vice Presiderrt ,

Nucle::r operations . ~!

.. j U. S. Nuclear Regulatory Commission ,

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j ATTN: Document Control Desk

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Washington 0.C. 20555

j Docket No. 50-267

SUBJECT: NRC Inspection Report 89-07 j (1) NRC Letter, Westerman j REFERENCE:

to Williams, dated l June 8, 1989 (Ge89201)  !

j Gentleinen:

This letter is. in response to the Notice of Violation received as a  !

result of the inspection conducted by Messrs. R. E. Farrell and P. l Michaud during the . period .of . March 19 through April 30, 1989 j (Reference 1). By telecon on July 10, 1989, Mr. T. F. Westerman j The

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granted an extension for this response to July 21, 196 ,

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foliciwing response to the items contained in the Notice of Violatio l is nereby submitted: Failure to Comply with the Requirements of Technical  !

Specifications  ;

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Two examples of the failure to comply with the requiremer.ts  !

of Technical Specifications prior to changing plant conditions are as follows: { LC d.2.7.c and LCO 4.2.7.d specify that .the i prestressed concrete reactor vessel (PCRV) shall not be pressurized to more than 100 psia unless the ,

interspacus between the primary- and secondary penetration clcsures are maintained at a pressure l greater than primary system oressure with purified  ;

helium ga Contrary to the above, the PCRV was pressurized to greater than 100 psia from 10:10 P.M. ou Harch 23, 1989, until 1:02 on March 24, 1989 3with the purified helium supply to the Region 27 interspace isolate . Surveillance Requirement (SR) 5.6.1d requires that diesel engine exhaust temperature "shutdcwn" ard

"declutching f unctions" be tested monthly when the

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s,tandby diesel generators are require j

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The diesel generators are required per LCO 4.6.1 when reactor. power exceeds 2 percen '

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Contrary to the above, reactor power was greater than 2 percent from 8:21 P.M. en March'27, 1989, until .'1:20 . on . March 29, 1989, with monthly TS Surveillance .lD Requirement (SR). E.6.1d not completed wi. thin the required interva ,

This .is a Severity Level IV violation, (Supplement'I) 1 (267/8907-01) {

.. 1 1) The Reason For The Violation If Admitted:

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The violation is admitte ']

i Example 1, noted in the Notice of Violation, was due to a l procedural inadequacy. Two , separate equipment clea.ances i were issued against equipment associated with a single .j control rod drive penetration interspace. Both clearances i required the isolation of the purified helium supply which j is used to pressurize the penetratio One p the clearances was returne prior to the Prestressed Concrete Reactor Vessel (PCRV) pressurizing to greater than 100 psi The second clearance was not returned and PCRV  ;

pressure was increased with the interspace isolate 'i t

Instructions for checks to be performed by the Operations _j

Department personnel before increasing PCRV pressure are l included in the Overall Plant Operating Procedure (OPOP) I,

" General Plant Requirements". At the time ofl thel.noted- -l

incident, OPOP 1, Sectior. B, "PCRV Pressurization to -> 100 - 1 psia" instructions were limited to verifications of? the' i operation of valves which are manipulated from!the Control 1 Room. The procedure did not include any field. verifications {

of manually operated valves or velve-lineups. The presence j and effect of outstanding clharantes is routinely checked b I the Operations Department before the PCRV is pressurized '

above 100 psia. Howper, th'e process was not formalized in CPOP I. The 0perations Departnent did' determine that there t~ere outstanding equipment ' clearances against the penetratio Operations requested. that the Maintenance Departn:ent return the clearances so that PCRV pressurizatio :!

could proceed. Maintenance returned one of the clearance !

The second clearance was not returned because. it- had 'never .i been accepted by workmen who had requested i !

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Example 2, noted in the Notice of Violation, was due to i.nadequate control of. rescheduled' Technical Specification Surveillance Procedure l SR 5.6.1d-M, " Diesel Engine Exhaust Temperature Functional i Test"n was completed on February 8, 1989. The procedure was ,

due to be performed again, in accordance with its normal '

scheduled period, by March ~ 8, 1989. At the time the procedure came due, the plant was shut down and the Limiting ;

Condition for Operation (LCO) associated with the Technical Specification survei llar.ce requirement, " Prior To Reactor Operation Greater Than or. Equal To '2%" was not applicabl SR 5. 6.1 d 41 was placed cn a " Reschedule" status due to diesel generator maintenance activities and plant condition Fort St. Vrain's administrative controls require that a " Reschedule" surveillance be performec' before its associated LCO becomes effectiv The normal mechanism for issuing " Reschedule" surveillance tests is for the reg W ible department supervisor to contact tLe Surveill. > D -wician and request issuance of the test so that it 1 N Jer irmed within the Technical Specification requi e <

this case, no request was mad The Surveil' e V cian was not aware that reactor power was n: *1 9 sed and did not realize the test should have beer, m- j 2) The Corrective Steps _Which Have Been Taken And The Pesults Achieved:

For Example 1, the second outstanding clearance was returned and the control rod drive penetration interspace wils irrediately pressurized as recuirec. OPOP-1 was revised tc include accitional checks which must be performed before inc rea si r.c reactor pressure ebose 100 psia. Addi tiotial cl et ts include: veriticction o# the status of FCPV penetraticr prir a r) inc secordery closures, penetration interspcce valve lineups, verification of penetration safety valve penetration interspace drain valve lineups, Plant Frotectise Syster (FFS) switch lineurs. Control Roc Crive (CED) purge valve lineups, and other verification Extensive manual valve liteups are in the form of checkoff lists with irdeper der,t verification by a secora incivioua 'le ri fi ca t i t n s are signed off by cernizant cepartment supervisor For Example 2, reactor power was decreased to less than 2%.

SR 5.6.1." Reschedule" was successfully completed. The caily reports dich the Surveillance Technician provides te the l

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July-14, 1989, 'i q

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Contrp1 Room and Shift. Supervisor havebeen revised to-

improve readability 'and eliminate unnecessary information.' E The daily reports which shoe- the status of- " Reschedule" -

surveillance ' tests are provided to the morning "Planraf the j Day"'hieeting!for review by plant management. Overall- Plant- '

Operating Procedure (OPOP)=III, "Startup Procedure", has ' j" been revised:to include .a' Scheduling Department- signoff.-

l The ~ signoff indicates that all required surveillance tests .

t have been performed before changes in plant operating mode ,

g are mad q A ccn.munication . link' has been established .between the j

Surveillance Tcchnician and the' Lead Scheduler to ensure that there,.is an awareness of changing plant conditio_n i Station procedures gov _erning' the Surveillance Program hav been reviewed to ensure that " Reschedule" surveillance are adequately addresse Awareness of the issues associated with bcth examples noted in the Notice of Violation has been- increased an:eng a n'anagement and . performance level personnel through the corrective'acticns'tske ) The Corrective Steos -Which Will

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Be Taken To Avoid ,l Further Violations:

No further actions are planned for Example .

Station Procedures governing the Surveillance Program will '!

be revised to incorporate the results of th revie described above. Station Manager Administrative Procedures SMAP-1, " Technical Specification.s- Surveillance Testing-Program"; . SMAP-2, "Non-Technical Specification Surveillance - I Testir.g Frogran"; and SMAP-5, "Schedul.ing ' Program' for :I furveillances" will be revise )

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P-89250 ,

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The Da.te When Full-Compliar.ce Will Be Achieved 1

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Full ' compliance with regard to'ENample ! was achieved cn

' June 28, 1989, following the' Plant Operations Review

' Committee review of the final . change made to OPOP- Full compliance with regard to Example 2.will be achieved by '

July 31, 1989, when the changes'to SMAP-'l, SMAP-2, and SMAP- lI

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5 are implemente Inadequate Control of' Replacement Parts for -Safety-Related F.quipment Criterion VIII of Appendix.0 to 10'CFR Part 50 and'the license'e's-quality assurance program require that measures be established for~ the identification of materials, parts .and components to prevent the use of incorrect or defective materials, parts, and composant .

Contrary to the above, on April'- 12. 1989',. an. incorrect part .

number was specified and uced to obtain a replacement part which was then installed in the "D" emergency dieser generator engin This is a Severity Level IV violatio (SupplementIF(267/8907-02)

(1) The Reason For The Violation If Admitted:

The violation is admitte The violation was due to a oersomnel trror. Stetton Service i Request (SSR) 89501818 was issued to check lthe calibration

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.of "0" Emeroency Diesel Engine Water Temperature Switc Calibration offorts were not successful and . it - was cetermined that the switch should be replacco. The SSP was replanned by the in.strument and Controls-(18C) Supervispr-to accomplish the switch replacement. -Replanning of SSR's bf cepartrcent supervisors is permitted by Administr ativ e Procedure P-7, " Station Service Recuest Processing"~. While ,

selecting the safety related part number 'for= ths water ~

temperature switch, an I&C Technician erroneously selected-  ?

the safety related part number for an oil temperature switc The incorrect pert number was located; immediately i adjacent to the correct part rumber in the Plout . Safety- -i Pelateo Parts Code Lis The mistake wac due to 'a i transposition error made when moving across the line ofL the' .

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lis Contributing to the error, the inct>rrect part.was j physically similar tc the correct part and it was made b i the same manufacture The occurrence of similar parts l

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being ,immediately. adjacent on the parts ~ list is isolate T.he incorrect part.was procured and subsequently installed, i No other similar incidents involving installation of

. incorrect safety related parts due to transposition' errors while identifying parts when planning SSR's have been identifie (2) The Corrective Actions Which Have Been Taken Ar.d The Results Achieved:

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The' correct temperature switch was obtained, calibrated,-and installed. The water and oil temperature switches on .all ,

four Emergency Diesel Generator engines were verified to be correc A root cause determination investigation was initiated as a

. result of the incident. The investigation was p * formed by

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personnel from the Systems Engineering Department. .As a result of this investigation, a recommendation for corrective action was mad Investigation findings wer discussed with' performance level I&C personne The 1&C staff agreed that SSR's which need to be replanned should be returned to the Planning Department as the preferred metho The I&C staff feels that this preferred precess is a good practica, however, it is too restrictive in some situations to formalize as a requirement. .There are situations encountered in the conduct of maintenance where it is appropriate for the Supervisor to revise the work plan on-SSR's. The incident involved in this violation is an '

isolated case involving both personnel error and coincident adjacent similar pat ts on a parts list, and does not involve a programmatic proble The results of the root cause determination investigation were presenteo to all 1&C Technician Results were presented by the Superintendent of If,C Maintenance in a t rair.ing seminar format on April 27, 198 It was recomrrended that SSR's requiring replanning be returned to Planning as the preferred method. When replanning is perforn ed by the Supervisor and parts are being.ioentified, j appropriate caution was encouraged. Independent verification i of ' parts identification w'll be perforr,)ed whenever possible i to minimize the probability of recurrenc In addition, the Maintenance Quality Control group held a staff meeting in which it was' stressed that the inspector is responsible for verifying that replacement parts which are being installed are like-for-like part j

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No. qases of the specification'and use of an incorrect part in safety related equipment have occured- -since the corrective actions outlined above were take )- The' Cor_rective- Steps Which Will Be Taken to Avoid Further Violations:

No further corrective steps are p'.anne ) The Date When Full Compliance Will be Achieved:

Full compliance was -achieved on April 27, 1989, followin the seminar presentation described abov If you have any questions, please contact Mr. M. H. Holmes at (303)

480-696 Very truly yours,

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6&l A. Clegg Crawford

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Vice President Nuclear Operations ACC:DLW/bhb cc: Regional Administrator, Region IV Attn: Mr. T. F. Westerman, Chief Projects Section B Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain Mr. Robert M. Quillen, Director Radiation Control Division Colorado Department of Health Colorado Public Utilities Commission Attn: Ralph Teague, P..E.

i 1580 Logan Street, OL1 Denver, CO 80203

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