ML20011A350
| ML20011A350 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 09/25/1981 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Seyffrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20011A344 | List: |
| References | |
| P-81235, NUDOCS 8110090344 | |
| Download: ML20011A350 (5) | |
Text
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.,f puhuc ser*e company
- Conende va 16805 Road 19 1/2, Platteville, Colorado 80651-9298 September 25, 1981 Fort St. Vrain Unit No. 1 P-81235 RM@M J\\V]M,M i.
F Mr. Karl V. 3eyf rit, Director W 281981 I
.h Region IV Office of inspection and Enforcement D
Nuclear Regulatory Commission 611 Ryan Plaza Drive Suite 1000 2
Arlington, Texas 76012
Subject:
I&E Inspection Reports 81-11, 81-12, and 81-13
-D
Dear,
Mr. Seyfrit:
As ycu are aware, Public Service Company of Colorado has recently reorganized its Nuclear Production Division, and has also made a number of mana'gement staf fing changes.
The division of responsibilities for responding to Nuclear Regulatory Commission letters, bulletins, notice of violations, etc. is clearly defined for each department within the division, but was not understood by some of the new managers and supervisors. As a result, a review of Public Service Company's commitments to the Nuclear Regulatory Commission revealed that notices of violations contained in I & E Inspection Reports 81-11, 81-12, and 81-13 had not been officially responded to and were, in fact, beyond the 25 day limit for response as required in the notices of violations.
Public Service Company immediately took steps to inform the new managers of their responsibilities to e
avoid any further response problems, but the fact remains that notices of violations contained in I & E Inspection Reports 81-11, 81-12, and 81-13 were not responded to in'a timely manner.
We are therefores by this letter, responding to all three inspection reports.
1.
I & E Inspection Report 81-11, dated June 24, 1981
=
i The System Abnormalties Books are now divided into three bcoks containing:
- 1) Temporary Change Reports,
- 2) Clearances, cnd
- 3) Operation Deviation Reports.
This will lessen the handling, reduce lost copies, and improve the procedural control.
In addition, by October 1, there will be a computer index list prepared of the deviations which will aid in ' insuring the accuracy of the~ book contents.' We will also add a system for hDRADOCK110090344 s11005 i
05000267 g
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i Mr. Karl V. Seyfrit September 25, 1981 logging the deviations as they are added or removed from the book, which will aid in keeping the system current.
2.
I & E Inspection Report 81-12, dated June 15, 1981 Administrative Procedure 13 has been deleted and replaced with level 1 procedure, P-4, which we feel is a much better procedure.
Many format changes have beer made which will enhance the correct completion of Surveillance Tests.
In addition to the above, we have formed a Surveillance Standardization Group for the purpose of rewriting and reviewing Surveillance Tests.
This group will review all tests and implement changes to make our Surveillance.'ests more concise and precise, which will provide for better indivi, dual performance.
The schedule for completion of this revier! isMqhgh1,1982.
regard to the eleven Surveillance Tests reported to contain a
test conductor errors, seven dealt with storage battery speci fic gravity readings.
These tests were reviewed and found not to contain errors, but were done in accordance with the manufacturers suggested method.
The other tests cited were reviewed and corrections made as necessary.
3.
I & E Inspection Report 81-13, dated July 23, 1981 y
Item 1 Item 1 of this report deals with a water chemistry value on C1 2 (total residual) which exceeded the 0.5 ppm Technical Specification limit.
The value recorded on February 3, 1981, was 0.7 ppm, which is in excess of the 0.5 ppm limit.
LCO NR 1.1 says if, the value exceeds the limit then "immediate corrective action should be initiated," and "if corrective action does not return the chemical constituent to acceptable concentration within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />," notify the Nuclear Regulatory Commission.
In this case, the value within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was O ppm as recorded on SR 2.2.w, and no notification to the Nuclear Regulatory Commisgion is required because we are within the limit.
This item "therefore, complies with the requirements of the non-radiological ' Technical Specifications and should not have "
been an item of noncompliance.
Item 2
~
Item 2 states that on February 24, 1981,,thetot$1 phosphate value recorded in SR 1.1.w exceeded 50% of the limit (14 ppm),
and a daily sampling frequency was not initiated per SR 1.1.w.
I A
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Mr. Karl V. Seyfrit September 25, 1981 An investigation into this matter has concluded that the required daily samples were not taken per the procedure.
The following steps have been taken to eliminate further occurrences in the future:
- 1) The mistake has been discussed with members of the Water Chemistry Department and increased awareness of the procedure has been realized and 2) A rewrite of SR 1.1.w will be completed by August 31, 1981, and a better explanation of action level II requirements will be included.
Item 4.A, Sr. 1.1.w used to be scheduled from Friday to Thursday. This was a problem because the Water Chemistry Departn:ent was obtaining samples on this interval but did not actually receive the test and start analysis until Monday.
To place this matter in proper perspective, it should be noted that the purpose of esteblishing the Shift Supervisor's signature for a release to test is to ensure the test can b:. safely conducted givea plant status and conditions.
We have established this requirement for all Surveillance Tests to maintain consistency and uniformity, but in this particular case, the Shift Supervisor's signature is more cf a formality rather than of control, as taking samples does not affect plant status or conditions.
In this respect, we would agree that failure to obtain the Shift Supervisor's signature represented _a failure to follow procedures from a literal viewpoint, but did not represent a violation of the intent of the procedural control.
It is still our intent to maintain uniformity; therefore, the test has now been rescheduled on a Monday through Sunday schedule so the samples will be obtained and the data analyzed on the same schedule. This allows the Shift Supervisor to give permi,sion to start the test en Monday when analysis actually begins.
The NR 1.3w scheduling problem as been resolved in a similar manner.
Item 3 There appears to be conflicting statements in SR 1.1.w, which "in Section d),
calls for a weekly calibration using standard solutions and in Section e),
a monthly calculation of conductivity versus total dissolved solids.
These are conflicting because the weekly cal ibration provides the information to calculate the conversion from e:ectrical conductivity to total dissolved solids.
- However, toe Water Chemistry Procedures will be revised to comply with the Technical Specifications by September 11, 1981.
Item 4.B (1)
In an ettempt to insure and eudit the check of all the recorders, a Surveillance Test will be written and be in place by ac r
3 Mr. Karl V. Seyfrit September 25, 1981 September 18, 1981.
This Surveillance Test will provide a sign-off for every shift to indicate that all recorders are in service and inking properly Item 4.B (2)
Discussions have been held with the individual involved in the sign-off of this procedure with regard to the significance of his position as a test conductor and his responsibilities. The Surveillance Test discussed in Item 4.B (1) will aid in -avoiding this type of problem in the future.
SR 5.4.9-w will be rewritten by September 18, 1981, to be consistent with the new surveillance standardization format and will require the test conductor to return the recorder to normal in a more appropriate part of the test.
?
Item 4.C An audit of all clearances was made on August 22 and August 23, and all the clearance forms are.not filled out in the proper manner.
All personnel involved in equipment clearances and operation deviations have been required to review the requirements for clearances 'a s set forth in Administrative Procedure P-2.
In addition, a random audit of clearance status will be taken to ensure compliance.
We will be in full compliance by September 18, 1981.
Attached is Reportable Occurrence 81-036 (Preliminary) referred to by the Resident Inspector in the notice of violation.
Public Service Company is currently investigating the possibility of installing an additional automatic isolation at the point where the liquid waste system connects to the circulating water blowdown line.
The intent would be to automatically isolate the liquid waste line upon loss of circulating water blown.
6 P
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.Mr. Karl'V. Seyfrit. 1 September 25, 1981'
'A. Design' Change Action Request,.has been submitted to'the Engineering-Department to?: analyze, 'and design as required, the. necessary modifications. Public Service -Company will complete.the analysis and
. redesign-any modifications-by March 1, 1982.
'Very truly yours, his&Vh $
Oscar R. Lee s
Vice President, Electrical 4
Noted By:
// g D. W. Warembourg ~
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a REPORT DATE:
May 27, 1981 REPORTABLE OCCURRENCE 81-036 Determined ISSUE O OCCURRENCE DATE:
May 14, 1981 Page 1 of 6 FORT ST. VRAIN NUCLEAR GENERATING STATION PUBLIC SERVICE COMPANY OF COLORADO 16805 WELD COUNTY ROAD 19 1/2 PLATTEVILLE, COLORADO 80551 REPORT NO. 50-267/81-036/01-T-0 Preliminary IDENTIFICATION OF OCCURRENCE:
On Thursday, May 14,1981, at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, it was determined that the concentration of tritium in an unrestricted area following liquid waste release number 460, which was made on May 12, 1981, exceeded the limit specified in LCO 4.8.2(a). At the time of the occurrence, the reactor plant was operating at 70% thermal power and approximately 230 MW electrical.
This event is reportable per Fort St. Vrain Technical Specification AC 7.5.2(a)2.
CONDITIONS PRIOR TO OCCURRENCE:
The conditions prior to occurrence or at the time of reportability determination have no bearing on this' report.
DESCRIPTION OF c
OCCURRENCE:
Upon analysis by plant personnel of samples taken during radioactive liquid waste release number 460, it was determined that the concentration of tritium in an unrestricted area exceeded the limit specified in LCO 4.8.2(a).
Refer to Figure 1.
Effluents from the Reactor Building sump ( OA )
and the liquid waste system ( (j)ll Ditch (
) are disch rged to a common line
( OC ) leadin to the Goosequi D
).
Circulating vater blowdown ( ([) g) is admitted for dilution purposes prior to the effluent reaching the C osequill Ditch.
Radiation monitors RIS-6212 and RIS-6213 (
1 and 2 ) in the common discharge 'line alarm at preset values on high activity in effluent discharged from either the Reactor Building sump or the liquid waste system and provide a signal
( Q3 ), close HV-6212 to rip the liquid waste transfer pumps
(
), and if the release is from the Reactor Building sumo, close HV-204-2 ( (j) ), thus terminating the release.
Circulating water blowdown (dilution) flow is monitored by flow switch FSL-4101 ( ([) ), whicn.at a preset value of low blowdown flow
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s REPORTABLE OCCURRENCE 81-036 ISSUE O Page 2 of 6 provides a signal *o close HV-6212 ( @ ) and trip the liquid w ste transfer pumps ( 3 ) and Reactor Building sump pumps ( 7 )
(L_J ).
In order jo avoid a holdup of radioactive liquid waste in a
the oil separator ( U8 ) in the discharge line common to the Rea tor Building sump and liquid waste system, normally open V-62247 ( 9 )
is closed and normally closed V-62248 ( @)
is opened prior to initiating a liquM waste release. These two valves are returned to their normal positions upon completion of a liquid waste release.
Liquid waste release number 460 was initiated at 1235 hour: on May 12, 1981, and terminated at 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> on May 12, 1981.
The recommended release rate was 9.0 gpm, with a recommended circulating water blowdown (dilution) rate of 2,000 gpm. A subsequent analysis indicated an average release rate of 9.2 gpm and an average circulating water blowdown (dilution) rate of 2496 gpm.
In order to track liquid waste concentrations in the unrestricted area during the course of liquid vaste release number 460, Health Physics Department personnel collected samples on an hourly basis throughout the release. Subsequent analyses indicated the following results:
Sample Date, Time Samole Number 3H Concentration, uCi/ml 5-12-81, 1300 RC 18349 3.55E-3*
5-12-81, 1400 RC 18370 2.36E-3 5-12-81, 1500 RC 18371 2.38E-3 l
- Result in excess of LCO 4.8.2(a) 3H limiting concentration in an unrestricted area (3.00E-3 uCi/ml).
It should be noted that the sample indicating a concentration of tritium exceeding the limit of LCO 4.8.2(a) was taken from the l
Goosequill Ditch, considered to be in an unrestricted area, although I
lo.cated on Public Service Company of Colorado property.
The Goosequill Ditch flows into a 25 acre farm pond, also on Company property. The overflow of this farm pond drains into the South Platte River.
The additional dilution provided by the pond ensures that the concentration if water entering the South Platte River is within the limits of LCO 4.S.2(a).
APPARENT CAUSE OF OCCURRENCE:
The design of the Fort St. Vrain liquid waste discharge system is inadequate to preclude prcblems of this nature from arising..
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l REPORTABLE OCCURRENCE 81-036 ISSUE 0 Page 3 of-6 ANALYSIS OF OCCURRENCE:
Radiochemical analysis of the liquid waste monitoring tank contents prior to liquid waste release number 460 indicated a tri tium concentration of 5.66E-1 pCi/ml.
Based on the recommended release rate and dilution, the calculated tritium concentration in the unrestricted area would be 2.55E-3 pCi/ml.
Based on the average release rate and dilution, the calculated tritium concentration in the unrestricted area would be 2.07E-3 uC1/ml.
The results of samples taken at 1400 and 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on May 12, 1981, during liquid waste release number 460 show good agreemert with the calcu!=ted concentrations. The result of the sample taken at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on May 12, 1981, was approximately one and one half times larger than the calculated concentrations.
O An analysis of the main cooling tower makeup and blowdown flow recorder (FR 4101) subsequent to the occurrence indicated tnat blowdown flow was interrupted at aporoximately 1255 hours0.0145 days <br />0.349 hours <br />0.00208 weeks <br />4.775275e-4 months <br /> on May 12, 1981, for approximately one to two minutes.
Similar analysis of the liquid waste blowdown flow recorder (FR 6215) confirmed that the automatic control system responded propqrly by tripping the liquid waste transfer pump and closing HV-6112. The transfer pump was manually restarted by Operations personnel approximately eight to ten minutes after tripping, and the release was completed without further incident.
~
Although the automatic control actions worked properly, the approximately 150 to 200 gallons of liquid waste downstream of HV-6212 continued to be released upon loss of circulating water blowdown (dilution). The lack of sufficient dilution flow during this release period resulted in a tritium concentration in an unrestricted area in excess of the limit of LCO 4.8.2(a).
CORRECTIVE
. ACTION:
1.
Operations personnel are investiga ting the cause of the circulating water blowdown (dilution) flow interruption.
2.
Plant Managemenk is investigat'ing'the possibility of installing another automatic valve at the location where the liquid waste discharge line meets the circulating water blowdowr line, designed to isolate the daad leg until conditions are acceptable for release to the unrestricted area.
Final resolution will be included in a' future supplemental report.
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REPORTABLE OCCURRENCE 81-036 ISSUE O Page 4.of 6
' FAILURE DATA /SIMILAR R;EPc1TED OCCURRENCES:
None
. PROGRAMMATIC IMPACT:
None CODE IMPACT:
None 6
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Circulating Water Blowdown up
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IIV-7204-2 V-62248
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ponents referenced in this report 8
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Reactor on the operation taking place.
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Blowdown Flow 4
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r REPORTABLE OCCURRENCE 81-036 ISSUE O Page 6 of 6 Preparr.d By:
'd [F. bid rsderick J. B#st '
Senior Plant Engineer 1
Reviewed By:
( _-
E. Gahm chnical Services Supervisor Reviewed By:
Mb F. M. Mathie //
Operati6ns Marfaget Approved By:
NtAfd-Don Warembourg Manager, Nuclear Produ ion i
U. S. NUCLEAR E EGULATORY COMMISSION NRC FORM.ISS p.77)
LICENSEE EVENT REPORT CONTROi. S LOCK: l l
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7 8 9 LICENSFE CODE 14 15 LICENSE NUMBER 25 26 LICENM TYPE 30 57 CAT 68 CON'T E
5$RCE I L hl 0 l 510 l 0 l 0 l 2 l 6 l 7 hl n I s 11 l9 l g l1 l@l015l*2l7l8Il lh i
8 60 61 DOCKET NUMBER 68 69 EVENT DATE 74 75 REPORT DATE 80 EVENT DESCRIPTION AND PROBABLE CONSEQUENCES h l o 12 I l On Thursday, May 14,1981, at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> it was determined that the concentration l
l of tritium in an unrestricted area following liquid waste release number 460, which l
l0 la l 1014; lwas made on May 12, 1981, exceeded the limit specified in LCO 4.8.2(a).
Reportable l
[ 5'TTl I per Fort St. Vrain Technical Specification AC 7.5.2(a)2.
No accompanying occurrence. l l 0 is l I Reportable occurrences R0 80-52, 80-67, and 81-013 deal with a related subject area.
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ODE S BC E COMPONENT CODE SUSCODE SU E
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7 8
9 to 11 12 13 18 19 20 SEQUENTIAL OCCURRENCE REPORT REVISION
_ EVENT YEAR REPORT NO.
CODE TYPE N O.
@ yu'ER,ROl21 Lag 8 l1 l l-l 10 13 16 i d
10 11 l
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22 23 24 26 27 28 29 30 31 32 KN AC ON O P NT ME HOURS SB l FOR 8.
SLP L MANUF CTURER lx l@lx l@
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40 41 42 43 44 47 CAUSE OESCRIPTION AND CORRECTIVE ACTIONS h IiIOIlThe design of the Fort St. Vrain liquid waste discharge system is inadequate to avoid I g l problems arising from a 150-200 gallon dead leg downstream of automatic valve HV 6212 I i,121 lwhich is released regardless of dilution flow adequacy.
Reliability of dilution flow l g l and possibility of relocating automatic valve closure capability upon inadequate
<l iii4i l dilution flow being investi nted.
Final resolution to be submitted in a supplemental l 7
8 9reDOrt.
80 SYA S
% POWER OTHER STATUS DIS O RY DISCOVERY DESCRIPTION l1 l5 l W@ l0 l 7 l0 lhl N/A l
(C__l@l Liquid waste tracking sampling l
ACTIVITY CO TENT RELEASED OF RELEASE AMOUNT OF ACTIVITY LOCATION OF R" LEASE 3H l
l Liquid waste discharge piping to river l
l i l 6 [ W @ lP l@l 4. 6E-1 Curies of PERSONNEL EXPOS ES NUMBER TYPE DESCRIPTION i, m 10 i 0 l 01@Lz_J@l N/A l
PERSONNE L INJURIES NUMBER DESCRIPTION is is i i O i O i 0 l@i N/A i
7 8 9 11 12 80 LOSS OF OR DAMAGE TO FACILITY TYPE DESCRIPTION y W@l N/A l
PUBLI TY NRC USE ONLY 45 e
ISSUED DESCRIPTION
[.2_L.] LN._jhl N/A l
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8 9 10 68 69 80 &
NAME OF PREPARER -
PHON E:
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