ML20033E124

Provides Enhancement to 891122 Response to Violations Noted in Insp Rept 50-267/89-20.Corrective Action:Operations Shift Personnel Dispatched to Blow Down Svc Air & Instrument Air Lines in Turbine & Reactor Bldgs

ML20033E124
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/23/1990
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-90035, NUDOCS 9003090080
Download: ML20033E124 (5)

Text

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O Public Service' Pa%u.

P.O. Box 840 Denver CO 80201 0840 A. Clegg Crawford Vice President Nuc! ear operations February 23, 1990 Fort St. Vrain Unit No. 1 P-90035-U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D. C. 20555 s

Docket No. 50-267

SUBJECT:

NRC Inspection Report 89-20

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REFERENCE:

1) NRC Letter, Milhoan to Crawford dated 10/23/89 (G-89369)

2) PSC Letter, Crawford to V. S. NRC dated 11/22/89 (P-89461)

Dear Sirs:

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. W.

Michaud during the period September _1 through September 30, 1989 (Reference 1).

This enhanced response, as documented below, is being submitted at the request of Mr. P. W. Michaud, Resident Inspector, to replace the response submitted November 22, 1989 (Reference 2).

Failure to Follow Procedure i

The Fort St. Vrain Technical Specifications, Section 4.7.a, states, in part that " written procedures shall be established, implemented Procedure 50P-84-02, Issue 7, "Outside Auxiliary Boiler," states in Step 4.2.1.40.e) to " Slowly close V-84881."

Contrary to the above, on September 6, 1989, Valve V-84881 was not closed, which allowed steam to enter the service air system which then entered the "A" Instrument Air System.

This is a Severity Level IV violation.

(Supplement I) (267/8920-01) 0$$l $00hhfg7 IIhh)

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'Page-2 February 23,~1990 1.

The Reason For The Violation If Admitted:

The violation is admitted.

The root cause of_this event was insufficient attention to procedural details by Operations personnel.

The operator.. was.

performing Non-Technical Specification surveillance procedure SR-0P-43-M on the. outside-auxiliary boiler (OAB).

SR-0P-43-M checks the boiler protective-trip setpoints and was being performed in preparation for placing the OAB in service to perform intermittent firing _ tests on the inside auxiliary boiler (IAB).

The OAB was successfully-fired but it tripped from approximately 60% load. The IAB was at approximately 20% load and tripped at the same time.

After several unsuccessful attempts to restart the OAB, it was left shutdown until troubleshooting could be performed.and the IAB was returned to service.

When personnel shut down the OAB for troubleshooting, it was expected to be of short duration.

Therefore, V-84855 was left open, contrary' to the complete shutdown instructions in the procedure.

The valve lineup error was compounded by multiple-equipment malfunctions.

It was determined that steam from the IAB had been entering the service' air system (reference figure 1) via the open super heater isolation valve (V-84839) on the OAB,. which was supplying steam through the open steam atomizing valve (V-84855),

then through a failed check valve (V-84882), and finally through an open service air atomizing valve (V-84881).. Once the (150 psig) steam entered the service-air header (90 psig) it continued on to-the normal service air h uder users.

The largest user is the sewage pond. The temperature % this line was-increased by the steam sufficient to cause a failure of the PVC piping near the chemical building. Operations personnel also noted that the service air piping near the "A" instrument air dryer was very hot. The heat (reference figure 1). extended through FCV 8217 into "A" reactor and "A" turbine building instrument air headers laith the "A" turbine building header being the hottest.

FCV 8217-is normally closed and is opened only when abnormally low pressures are detected in the "A" instrument air header.

FCV 8217 and its bypass V-8229 were closed when checked which indicated leakage through one or both valves.

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2. 'The Corrective Steps Which Have been Taken and the Results Achieved:

The result of this steam and moisture in the "A" Instrument Air System. was observed by the control room operators as malfunctioning instruments on the helium circulator auxiliaries.

Manual control was taken on these instruments, and the "B" Helium' Circulator was shut down-in response to these instrument malfunctions.

Available operations shift personnel were dispatched to blow down service air and instrument air lines in the turbine and reactor buildings.

A plan was formulated to blow down the "A" Instrument Air Header and each instrument supplied by it from highest to lowest elevation.

This was performed over a 2-day period, with a number of instruments on levels 1 and 2 of the reactor building and in the outside boiler room found having water in the air line.

Each of these instruments was blown down, calibrated, and returned to service.

V-84882 was cut out of the line and replaced due to gross leakage.

FCV-8217 was disassembled and inspected. The valve was dirty and not seating correctly.

It was cleaned and tested for u

leak tightness.

V-8229 was disassembled and blue checked. which l

verified the proper seating of the disc with the seating surface.

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Personnel involved in this event were counseled to consider the significance of shutting equipment down temporarily for troubleshooting. Where appropriate, normal shutdown should always be followed.

A program for periodically blowing down the ' air lines was established as a precautionary measure. The latest blow down was completed on 1/22/90. No moisture was present in the system.

3.

The Corrective Steps Which Will Be Taken To Avoid Further Violations:

For the most part, the OAB will not be used during defueling and no further corrective actions for either specific OAB procedure enhancements or OAB operator training are warranted.

PSC will enhance our General Employee Training (GET) Program to include a module to emphasize the necessity for procedural compliance.

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-P-900355 Page 4-February 23, 1990 c'

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-The Date When Full Compliance'Will Be Achieved:-

Full compliance was achieved.per the actions noted in Item No. 2 above on October 10;;1989.

The -GET program section that addresses 5the ~FSV procedure system has'been-revised.

Since.the inspection, this portion of the lesson-plan has been givenLincreased emphasis by the. instructors.

Should 'you have: any: further questions, please contact Mr.'M. H.

~

Holmes at (303) 480-6960.

4.

Sincerely,-

i (A

A. Clegg Crawford

-Vice President Nuclear Operations.

ACC/MED/km cc:

Regional Administer, Region IV

-ATTN:

Mr.' T. F. Westerman, Chief Projects Section'B' l

Mr. Robert E. Farre111 i

Senior Resident Inspector Fort St. Vrain 4

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