ML20032C637
| ML20032C637 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/22/1981 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20032C628 | List: |
| References | |
| P-81259, NUDOCS 8111100676 | |
| Download: ML20032C637 (13) | |
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PUBLIC SERVICE COMPANY OF COLORADO
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SOX 840. D E N V E R, - C O L O R A D O 80209 OSCAR R. LEE l
VtCE PREStDEN T l
October 22, 1981 Fort St. Vrain
(
Unit No. 3 P-81259 Mr. Karl Seyfrit, Director U. S. Nucleas R6gulatory Commission Region IV I
611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76011
SUBJECT:
I & E Inspection Reports 81-11, 81-12, and 81-13
REFERENCES:
1.
PSC Letter dated October 25, 1981 (P-81235) i 2.
NRC Letter dated October 5, 1981 (G-81176)
Dear Mr. Seyfrit:
In a letter dated September 25, 1981, (Reference 1), Public Service Company responded to the Notices of Violation as a result of the I & E Inspections 81-11, 81-12, and 81-13.
In a meeting subsequent to the submittal of our response with the NRC Resident Inspectors, we were informed that the responses to these Notices of Violations were in-adequate in some areas and that the letter was not submit *.ed under oath or affirmaton. The following is a revised response to the Notices of Violation as a result of I & E Inspections 81-11, 81-12, and 81-13:
A.
I & E Inspection Report 81-11, dated June 24, 1981 1.
Technical Specification LCO 4.8.2(a) states that "the max-imum instantaneous release rate of radioactive liquid effluents from the site shall be such that the concentration of radionuclides in the cooling tower blowdown water discharge does not exceed the values in Table II, Column 2, 10CFR 20, Appendix B, for unrestricted areas."
8111100676 811102 PDR ADOCK 05000267 G
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2 October 22, 1981 P-81259 Contrary to the above, on May 14, 1981, at 1:00 p.m., it was determined by the licensee that the concentration of tritium in the cooling tower blowdown water discharge which was made on May 12, 1981, was 3.55E-3pci/cc, exceeding the limiting concentration for tritium (3.00E-3pci/cc).
This is a Severity Level IV Violation.
(1) The corrective steps which have been taken and the results achieved:
Violation of LCO 4.8.2(a) occurred at 1300 hrs. on May 12, 1981.
Compliance was achieved at 1400 hrs.
on May 12, 1981 when verification of tritium con-centrations by sampling and sample analysis was completed.
(2) Corrective steps which will be taken to avoid further violations:
The design of the Ft. St. Vrain liquid waste discharge l
system is inadequate to preclude problems described above from recurring.
Plant management is presently investigating the possibility of installing another automatic valve at the location where the liquid waste discharge line meets the circulating water blowdown line designed to isolate the dead leg until conditions are acceptable for release to the unrestricted area.
(3) The date when full compliance will be achieved:
Full compliance specifically regarding the above violation was achieved at 1400 hrs. on May 12, 1981.
Completion of the re-design to avoid further violations is scheduled for completion March 1, 1982.
2.
Technical Specification 7.4.a, Procedures Administrative controls, states in part that " Written procedures shall be established, implemented, and maintained.
Procedure P-2, " Equipment Clearances and Operation Deviations,"
paragraph 4.2.13 instructing the reactor operator, states:
"Femoves Operation Deviation Sheet from the ' Systems Abnor-
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malities Book' and initials the form to indicate the system is in its normal condition," and paragraph 4.2.14 states " verifies all subtags listed on the deviation form have been returned."
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I October 22, 1981 P-81259 Operations Order 81-01 states in part that "the responsible operator will initial the deviation form as indicated when the equipment is normal. Reactor operator will check account-ability of subtags on the deviation form and transfer all paper and tags to shift supervisor."
Contrary to the above, on May 19, 1981, it was determined by the NRC inspector that two deviation forms which had been initialed as " equipment normal," were still in the Systems Abnormalities Book although the system status tags were still in place on the specified equipment. The system status tags were numbers 2196 and 2249.
This is a Severity Level IV violation.
(1) The corrective steps which have been taken and the results achieved:
Compliance regarding the above violation was achieved on May 19, 1981 immediately after the problem was brought to operations personnel's attention.
(2) Corrective steps which will be taken to avoid furth2r violations:
The System Abnormalities Book was divided into three books containiug:
(1) Temporary Change Reports, (2) Clearances, and (3) Operation Deviation Reports. This division of the System Abnormalities Book will lessen the handling which will reduce the possibility of lost copies and improve pro-cedural control.
In addition, as of October 1, 1981, there is a computer index list prepared of the contents of each book to be used for internal auditing purposes which will aid in insuring the accuracy of the books contents.
(3) The date when full compliance will be achieved:
October 1, 1981.
B.
I & E Inspection Report 81-12, dated June 15, 1981 1.
Failure to Follow Procedure in the Review of Surveillance Test Results Technical Specifications, paragraph 7.4.a states in part, " Written procedures shall be established, implemented and maintained cover-ing.
. surveillance test activities of safety-related equipment."
October 22, 1981 P-81259 Procedure ADM-13 (Rev. 19, January 10, 1980), " Technical Specification - Surveillance," states. in paragraph 3.1.3(d),
"Section 6.0, Step 6.13 requires the signature of a represen-tative of the department responsible for the test other than the Test Conductor.- His signature signifies that he has re-viewed the Tests Sheets, verified conformance with documented instructions and procedures, and concurs with the conclusions of the Test Conductor. Step 7.1 requires the signature of the supervisor of the department (or his designee) responsible for the performance of the. test.
His signature signifies that he has evaluated test.results, noted retest requirements, and approves the test as performed and recorded.
Contrary to the above:
For eleven surveillance tests conducted between March 31 and May 3, 1981, departmental representatives and departmental supervisors had signed the test records, even though these records contained data omissions, data outside prescribed acceptance criteria, and incorrect results calculated from raw test data. On none of these test documents were comments or retest requirements recorded to indicate that the reviewers had noted these errors as a result of the reviews required by ADM-13 above.
This is a Severity Level IV Violation.
(1) The corrective steps which have been taken and the results achieved:
Compliance was achieved on or before June 30, 1981 by correcting the errors in the four Surveillance Tests found to contain errors.
Seven Surveillance Tests reported to contain test conductor errors dealt with storage battery specific gravity readings which were found not to be in error but performed in accordance with the manufacturers suggested method.
(2) Corrective actions which will be taken to avoid further violations:
Administrative Procedure 13 has been deleted and replaced I
with level 1 procedure, P-4, which we feel is a much better procedure. Many format changes have been made which will enhance the correct completion of Surveillance Tests.
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October 22, 1981 P-81259 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 Tests more concise ano precise, which will provide for better individual performance. The schedule for com-pletion of this review is March 1, 1982.
(3) The date when full compliance will be achieved:
Full compliance specifically regarding the above violation was achieved on or before June 20, 1981. Completion ard-issuance of P-4 to replace ADM-13 occurred on August 20, 1981 Completion of the Surveillanco Standardization Group's task is scheduled for March 1, 1982.
C.
I & E Inspection Report 81-13, dated July 23, 1981 1.
Technical Specification LCO NR 1.1 states in part that ".
.-The concentration of the specified chemical constituents in the station non-radioactive liquid effluents at the diversion box to the Goose-quill Ditch shall not exceed the following:
Constituent Maximum Concentration or Value C1 2 (Total Residual) 0.5 ppm.
Technica.1 Specification LCO 7.5 states in part that ".
. The reportable occurrences discussed below shall be the subject of written reports to the Director of the appropriate NRC Regional Office within thirty days of occurrence of the event Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plaret shutdown required
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by a limiting condition for operation.
f Contrary to the ab'ove, on June 25, 1981, at 8:30 a.m. it was determined by the NRC inspector during a review of the weekly surveillances NR 1.1-W, " Chemical Concentrations," that the concentration for the residual chlorine sample taken on February 3, 1981 was 0.7 ppm, exceeding the limit for chlorine (0.5 ppm) and was not reported to the NRC.
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This is a Severity Level VI Violation.
(1) The corrective steps which have been taken and the results achieved:
LCO NR 1.1 was not violated thus compliance was continuous.
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October 22, 1981 P-81259 (2) Corrective steps which will be taken to avoid further violations:
Not applicable.
(3) The date when full compliance will be achieved:
This report deals with a water chemistry value on C1 (totalresidual)whichexceededthe0.5ppmTechnica$
Specification limit.
The value recorded on February 3, 1981, was 0.7 ppm, which is iw 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 Commission 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.
2.
Technical Specification SR NR 1.l(b) states in part that ".
If the analysis for constituent concentrations in the non-radioactive effluent discharge indicates greater than 50% of the limit stated in LCO NR 1.1 for any constituent, the sampling and analysis for that constituent shall be at the frequency of Action Level II of Table NR-1 until such time as the analysis for the constituent decreases or reaches a new equilibrium value (as defined by four consecutive daily analyses whose results are within i 10%) at which time weekly sampling may be resumed.
Contrary to the above, on June 25, 1981 at 9:00 a.m. it was determined by the NRC inspector during a review of the weekly surveillances NR 1.1-W, " Chemical Concentration," that the concentration for the total phosphate sample taken on February 24, 1981 of 7.814 ppm, exceeded the 50% limit (7 ppm), and the re-quired daily samples were not taken.
This is a Severity Level VI Violation.
(1) The corrective steps which have been taken and the results achieved:
Corrective steps to take daily samples for the Surveillance Test procedure SR-NR 1.1 for February cannot be taken such as to backfit the test.
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October 22, 1381 P-81259 (2) Corrective steps which will be taken to avoid further violations:
Compliance can be achieved for future occurrences by the following measures which have been completed on or before August 31, 1981; (1) The error has been dis-cussed with members of the Water Chemistry Department to improve their awareness of the required procedure, (2) A rewrite of SR-NR 1.1 which included a better explanation of action level II" requirements was completed.
(3) The date when full compliance will be achieved:
Compliance was achieved on August 31, 1981 3.
Technical Specification SR NR 1.l(d) states in part that
. The conductivity and pH meters shall be calibrated using standard solutions weekly.
Contrary to the above, on June 25, 1981, at 2:00 p.m. it was determined by the NRC inspector that Water Chemistry Procedure (WCP-8,5.3) requires a check of the conductivity cell monthly against a known standard for the calculation of the cell constaat. No weekly calibration using standard solutions is being performed by the licensee.
This is a Severity Level VI Violation.
(1) The corrective steps which have been taken and the results achieved:
Compliance was achieved July 30, 1981.
(2) Carrective steps which will be taken to avoid further violations:
There appears to be conflicting statements in SR NR 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 calibration provides the information to calculate the conversion from electrical conductivity to total dissolved solids. However, the Water Chemistry Procedures will be reviaed such that both Section (d) and Section (e) will be performed on a fre-quency of weekly.
October 22, 1981 P-81259 (3) The date when full compliance will be achieved':
Full compliance was achieved July 30, 1981. Completion of Water Chemistry Procedures occurred September 11, 1981.
4.
Technical Specification 7.4.a. " Procedures, Administrative Controls," states in part that ".
written procedures shall be established, implemented, and maintained.
4A.
Procedure ADM-13 (Rev. 19, January 10, 1980), " Technical Specification Surveillance," paragraph 3.1.3.a) states in part that ".
Section 4.0 requires the signature of the Department Supervisor and the Shif t Supers isor on duty for permission to initiate the test Contrary to the above,17 of the 20 weekly surveillances, NR 1.1-W, " Chemical Concentrations," reviewed by the NRC inspector had been started on a Friday, but the Shift Supervisor signatures to initiate the surveillances were dated for the following Monday.
Three of the 20 had Shif t Supervisor signatures dated for the following Tuesday. All of the monthly surveillances, NR 1.3-M,
" Turbine Building Sump," reviewed by the NRC inspector had been started at the beginning of the month, but the Shift Supervisor signatures to initiate the surveillances were dated at the end of that month.
This is a Severity Level VI Violation.
(1) The corrective steps which have been taken and the results achieved:
Compliance was achieved on July 20, 1981 by changing the day of the issuance of the tests.
(2) Corrective steps which will be taken to avoid further violations:
SR 1.1.w used to be scheduled from Friday to Thursday.
This was a problem because the Water Chemistry Depart-ment was obtaining samples of 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 establishing the Shift Supervisor's signature for a release to test is to ensure the test can be safely conducted given plant status and conditions. We have established this requirement for all Surveillance Tests to maintain
October 22, 1981 P-81259 consistency and uniformity, but in this particular case, the Shift Supervisor's signature is more of 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 pro-cedural control.
It is still our intent to maintain uniformity; there-fore, the test has now been rescheduled on a Monday through Gunday schedule so the samples will be ob-tained and the data analyzed on the same schedule.
This allows the Shif t Supervisor to give permission to start the test on Monday when analysis actually begins. The SR NR 1.3M scheduling problem has been resolved in a similar manner.
(3) The date when full compliance will be achieved:
Compliance was achieved on July 20, 1981.
4B.
(1) Administrative Procedure P-1 (Issue 2, August 4, 1980),
" Plant Operations," paragraph 4.5.2(e) states in part that ".
. A verification check is performed at least I
once each shif t to assure pens are inking and recorders reading properly.
Contrary to the above, on June 25, 1981, at 6:30 a.m. the NRC inspector determined that the printer for RR 93256,
" Effluent Activity Monitor, "was not reading properly in that the printer had been secured since June 24, 1981, at 10:30 a.m.
(2) Procedure ADM-13 (Rev. 19, January 10, 1980), " Technical Specification Surveillance," paragraph 3.1.3 (b) states in part that ".
. Section 5.0 requires an entry by the test conductor in each space provided in the body of the procedure.
In addition each page of the procedure section 5.0 shall be initialed or signed and dated by the test conductor.
His initials or signatures are verification that:
The step marked has been completed satisfactorily.
The page initialed has been completed with all required data entered.
October 22, 1981 P-81259 Surveillance SR 5.4.9-W, " Area Monitor Functional Test,"
states in part ".
. 5.1.9 verify all alarms are reset and all indications are normal..."
Contrary to the above, on June 29, 1981, at 6:30 a.m. the NRC inspector noted that recorder RR 93254 " Area Monitor" had not been indicating as required since the completion of SR 5.4.9-W which had been signed off as complete by the Test Conductor at 3:30 a.m. June 29, 1981.
This is a Severity Level V Violation.
4B. (1)
(1) The corrective steps which have been taken and the results achieved:
Compliance was achieved immediately after notification of the problem by the NRC inspector on June 25, 1981 at 6:30 a.m.
(2)
Corrective steps which will be taken to avoid further violations:
In an attempt to insure and audit the check of all the recorders, a Surveillance Test will be written. This Surveillance Test will provide a sign-off for every shif t to indicate that all the recorders are in service and inking properly.
(3) The date when full compliance will be achieved:
Compliance was achieved June 25, 1981 specific to the violation.
The Surveillance Test will be completed by September 18, 1981.
- 43. (2)
(1)
The corrective steps which have been taken and the results achieved:
Compliance was achieved on June 29, 1981 immediately after notification by the NRC inspector of the problem.
(2) Corrc.-tive steps which will be tsken to avoid further violations:
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, 1931 to be consistent with the new surveillance standardization format and will require the test con-ductor to return the recorder to normal in a more appro-priate part of the test.
d October 22, 1981 P-P1259 (3) The date when full compliance will be achieved:
Full compliance was achieved on June 29, 1981.
4C.
Procedure P-2, " Equipment Clearances and Operation Deviat' ions,"
Issue 4 dated June 12, 1981, Section 4.1, " Equipment Clearance Procedure" states in part that "
REACTOR OPERATOR OR HIS DELEGATE 5.
Ilangs the white and hard copies of the clearance card at the main clearance point.
Ilangs all auxiliary tags and checks off on the Standard Clearance Points form.
Contrary to the above on June 18, 1981, at 7:00 a.m., the NRC inspector noted nine Standard Clearance Points forms with auxiliary tags that had not been checked off as required.
This is a Severity Level VI Violation.
(1) The corrective steps which have been taken and the results achieved:
Compliance was achieved on June 18, 1981 immediately upon notification by the NRC inspector of the problem. All clearances were audited at this time.
(2) Corrective steps which will be taken to avoid further violations:
An additional audit of all clearances was made on August 22, and August 23, revealing that all the clearance forms were 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 as set forth in Administrative Procedure P-2.
In addition, a random audit of clearance status will be taken to ensure compliance.
(3) The date when full compliance will be achieved:
Full compliance was achieved on June 18, 1981.
October 22, 1981 P-81259 5.
Technical Specification 7.4, " Procedures, Administrative Controls," paragraph d, requires that " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure."
Health Physics Procedure HPP-9 (Issue 3, February 25, 1981)
" Establishing and Posting Controlled Areas," states in part that "
. Controlled areas shall be clearly marked in accordance with the procedure.
Contrary to the above on June 29, 1981 at 1:30 p.m. the NRC inspector noted that the north stairwell access to the refueling floor was not clearly marked in that the Radiation barrier was not in place.
This is a Severity Level V Violation.
(1) Corrective steps which have been taken and the results achieved:
As noted in IE Inspection Report 50-267/81-13, the barrier was replaced immediately upon notification by the NRC Resident Inspector, on June 29, 1981. Additionally, appro-priate marking devices were provided independent of the barrier. Compliance with Health Physics Procedure HPP-9 was thus achieved.
(2) Corrective steps which will be taken to avoid further violations:
Appropriate marking devices will be provided independent of barriers extant and controlled areas.
(3) The date when full compliance will be achieved:
June 29, 1981.
Should you have any further questions, please contact Mr. Ed Hill (303 - 571 - 7436, Ext. 218)
Very Truly Yours, 6
- 0. R. Lee Vice President ORL/skd f
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter
)
)
Public Service Company of Colorado
)
Docket No.
50-267 Fort St. Vrain Unit No. 1
)
.... being duly sworn, hereby deposes and says that he is Vice President of Electrical vroduction of Public Service Company of Colorado; that he is dely authorized to sign the file with the Nuclear Regulatory Commission the attached response to the Notice of Violation identified in NRC Inspection Report 81-18; 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 belief.
Ib
- 0. R. Lee Vice President of Electrical Production STATE OF 3lOrdtO
)
) ss COUNTY OF WP-l0
)
Subscribed and s8rn to before me, a Notary Public in and for benVer. O.
on this 22 day of Ot4o ber,1981.
Lf)77nd)L.)
.L/ m No#ary Public v My commission expires
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