ML20041G468
| ML20041G468 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/20/1982 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20041G467 | List: |
| References | |
| P-82022, NUDOCS 8203220345 | |
| Download: ML20041G468 (6) | |
Text
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PUBLIC SERVICE COMPANY OF COLORADO P.
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BOX 840 DENVER, COLORADO 802OI OSCAR R. LEE M
V8CE PRESIDE DdT D'
3"""ary 20, us2 Ju 251982 Fort St. Vrain li i
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Unit No. 1
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P-82022 Mr. John T. Collins, Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76011
SUBJECT:
I & E Inspection Report 81-26 l
REFERENCE:
NRC Letter dated December 22, 1981 (G-82004)
Dear Mr. Collins:
4 This letter is in response to the Notice of Violation raceived as a result of inspections conducted at Ft. St. Vrain during the period November 1, 1981 to November 30, 1981.
The follcwing response to the items contained in the Notice of Violation is hereby submitted:
1.
Technical Specific.ition LCO 4.6.ld) states in part that:
"The reactor shall not be operated at power unless the following conditions are satisfied:
i "d) Both the diesel-generator sets are operable, including the following:
"4.
325 gallons of fuel in each day tank. One diesel generator set may be inoperable for up to 7 days (total for both) during any month provided the operability of the other diesel-generator set is demonstrated immediately as in a) above and all essential buses are operable.
Contrary to the above, on October 20, 1981, and on October 21, 1981, l
Emergency Diesel Generator sets lA and 1B, respectively, were removed from service for maintenance without demonstrating the operability of the alternate diesel-generator set immediately prior to their removal l.
fror service.
This is a Severity Level III Violation (Supplement IV.E.2) h l
l 8203220345 820316 I
PDR ADOCK 05000267
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January 20, 1982 P-82022 (1) The corrective steps which have been taken and the results achieved:
Both diesel generator sets were run on October 21, 1981 to verify operability.
Both units tested satisfactorily.
(2) Corrective steps which will be taken to avoid further violations:
An examination was made of the possible mechanisms to provide a more positive control in assuring compliance with LCO 4.6.1.
The clearance procedure was identified as the most practical means of improving this control as clearances arc routinely issued for maintenance work on the diesel generator sets.
The standard clearance forms for the diesel generator engines will be modified to include a conspicuous statement concerning LCO 4.6.1 requirements with respect to test requirements preceding and following removal of the units from service.
The special require-ments of this clearance should then be obvious to the operators who administer the clearances.
(3) The date when full compliance will be achieved:
Full compliance regarding the preparation of the modified clearances will be completed prior to February 15, 1982.
2.
" Procedures, Administrative Controls,"
states in part that, ".
. written procedures shall be established, implemented, and maintained.
Administrative Procedure F-1, " Plant Operations," Issue 4, dated August 3, 1981, Section 4.6.2 states in part as follows:
"EACH ASSIGNED
Also records in the proper RWP blocks:
a) Film badge number b)
Dosimeter number c)
Initial reading of dosimeter d) Time in.
Contrary to the above, on November 16, 1981, a Health Physics Technician had failed to log into the radiation work permit (RWP) control area and was not wearing a pocket dosimeter as required by the RWP.
This is a Severity Level V Violation.
(Supplement IV.E.2)
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January 20, 1982 P-82022 (1) Corrective steps which have been taken and the results achieved:
The individual involved was reminded about the proper use of RWP's and the responsibilities associated with RWP use.
No recurrences have been noted.
(2) Corrective steps which will be taken to avoid further violations:
All Health Physics Technicians have been retrained in the procedures and responsibilities associated with RWP use.
(3) Date when full compliance will be achieved:
November 16, 1981.
3.
Technical Specification 7.4.a, " Procedures, Administrative Controls,"
states in part that, ".
. written procedures shall be established, implemented, and maintained..
A.
Administrative Procedure P-2, " Equipment Clearances and Operations Deviations," Issue 4, dated June 12, 1981, Section 4.1 states in part as follows:
" SHIFT SUPERVISOR 13.
Directs the Reactor Operator to restore the equipment to normal conditions.
" REACTOR OPERATOR 14.
Directs the Operations required to place the equipment in-service.
16.
When completed, signs the form indicating the equipment is restored to normal conditions.
Contrary to the above, on November 3, 1981, the PCRV Auxiliary Piping System equipment clearance for a modification performed on the helium penetration interspace for B-2-3 steam generator module was returned and the system returned to normal operation without meeting the system's seismic requirements necessary to classify the system as operational.
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f January 20, 1982 P-82022 I
(1)
The corrective steps which have been taken and the results achieved:
I i
Part A of this Notice of Violation is directly a result of j
Part B.
The Operations staff performed their duties in accordance with P-2.
The problem was created by an improper QC sign off which is addressed in Part B.
(2)
Corrective steps which will be taken to avoid further violations:
As is noted in 3.A.1), above, the failure to follow procedures was the result of an improper QC signof f as is addressed in Part B.
There was not a violation of procedures with respect i
to P-2 as the Operations staff acted in accordance with the procedure.
(3)
The date when full compliance will be achieved:
As stated in 3.B.3, full compliance was achieved on
]
November 3, 1981.
B.
Controlled Work Permit 82-252 assigned to Change Notice 1427A, 1
dated October 28, 1981, contained a step which stated, " Install j
pipe supports per CN-1427A, SK-3, SK-4, SK-5".
This step has been 1
classified as a Witness Point (WP) by the QA/QC department. The WP requires a Quality Control Technician to perform an inspection to verify that the work was performed correctly.
Contrary to the above, on November 2,1981, a Quality Control Technican has initialed and dated the verification for the correct installation of a pipe support shown in Sketch 5 (SK-5) which had not been installed as indicated.
1 (1) The corrective steps which have been taken and the results achieved:
4 Compliance regarding the above violation was achieved on November 3, 1981 at approximately 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> by installing and inspecting the_ pipe support as shown in SK-5.
(2)
Corrective steps which will be taken to avoid further violations:
The occurrence of the violation was caused by personnel error. As a consequence, the importance and necessity 2
of following procedures was reviewed and emphasized with the entire QA/QC Inspection staff on November 3, 1981.
This verbal re-emphasis was followed by an intra-department memo and should preclude repetition.
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January 20, 1982 P-82022 (3)
The date when full compliance will be achieved:
Full compliance specifically regarding the above violation was achieved on November 3,1981 at approximately 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />, with the installation and inspection of the pipe support shown in SK-5.
Should you have any further questions, please contact Mr. Edwin D.11111, (303-571-7436, Ext. 218)
Very truly yours, (MC C
scar R. Lee Vice President ORL/skd
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter
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Public Service Company of Colorado
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Docket No. 50-267 Fort St. Vrain Unit No. 1
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. being duly sworn, hereby deposes and says that he is Vice President of Electrical Production of Public Service Company of Colorado; that he is duly authorized to sign the file with the Nuclear Regulatory Commission the attached response to the Notice of Violation identified in NRC Inspection Report 81-26; that he is familiar with the contet thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
(U O. R. Lee Vice President of Electrical Production
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STATE OF
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COUNTY OF Subscribed and sworn to before me, a Notary Public in and for f f b k o o!OrMo on this 20 td day of 7&Awu
, 1982.
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fotary Pubifc My commission expires M y( M & N, 19[3 l
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