ML20054M456
| ML20054M456 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/14/1982 |
| From: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20054M455 | List: |
| References | |
| P-82147, NUDOCS 8207130256 | |
| Download: ML20054M456 (5) | |
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l PUBLIC SERVICE COMPANY OF COLORADO DENVER, COLOMADO 8020f P.
O. sox neo oscAn n. u:t:
May 14, 1982 v.c.... m..o Fort St. Vrain Unit tio. 1 J -32147
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,s' Mr. John T. Collins, Regional Administrator
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My 2 l 1982 U. 5. Iluclear Regulatory Commission
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611 Ryan Plaza Dr., Suite 1000
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Arlington, TX 76012
SUBJECT:
Inspection Report 82-06 Docket 50-267
Dear Mr. Collins:
This letter is in response to the tiotice of Violation received as a result of inspections conducted at Fort St. Vrain during the periods of March 8 through March 26, 1982.
The specific items found in violation and the responses are as follows:
A.
Timely Conduct of Surveillance The Fort St. Vrain Generating Station Technical Specifications required (sic), in paragraph 5.5.3, "The exhaust filters in the reactor building ventilation system shall be tested as follows...
samples from the charcoal filters shall be laboratory tested... following painting, fire...."
Contrary to the above, there was no laboratory test.o9 ducted on the charcoal filters after a
fire which occurred August 26, 1981.
This is a Severity Level IV violation.
(Supplement I.D.)
(8206-01)
(1)
The corrective steps which will be taken and the results achieved:
Technical Specification Surveillance Requirement SR 5.5.3 states that:
"a) Samples from the charcoal filters shall be laboratory tested after each 4400 hours0.0509 days <br />1.222 hours <br />0.00728 weeks <br />0.00167 months <br /> of operation of the unit, or following painting,
- fire, or chemical
- release in any ventilation zone communicating with the unit.
gff 0
I
s E.
Defined as any material which could resonably be expected to interfere with the charcoal to absorb (sic) methyl iodide."
It is our position that the above caveat applies to all three types of releases mentioned in the surveillance requirement.
In our investigation as to whether the capability of the charcoal to adsorb methyl iodide could reasonably have been interfered with as a result of the August 26, 1981 fire, the following instrumentation was consulted:
Pressure Differential Indicators (PDI) 7323-2, 7323-3, 7358-2, 7358-3, 7359-2, and 7359-3.
These instruments measure the pressure differential across the reactor building exhaust HEPA filters and charcoal adsorbers.
These instruments are evaluated on a weekly basis as part of the perforr..ance of Surveillance Test SR 5.5.3e-W.
The Pressure Differential Indicators were examined immediately after the August 26, 1981 fire, and daily thereafter.
The results were evaluated against the results obtained during the performance of Surveillance Test SR 5.5.3e-W, Week 34, August 24, 1981. Although no records were kept of the daily evaluations, the'results of the performance of the Surveillance. Test SR 5.5.3e-W, Week 35, August 31, 1981, are documented and indicate no-change in the pressure differential across the charcoal adsorbers.
The lack of an increase in pressure differential.across the charcoal adsorbers following the August 26, 1981 fire indicates that the ability of the charcoal to adsorb methyl iodide was 'not interfered with.
As Mr. Jaudon properly
- noted, the results of laborato ry testing conducted on the charcoal on December 17, 1981, confirmed-the integrity of the charcoal.
It is our position that our investigation and evaluation were prompt and thorough, that laboratory testing of the charcoal following the August 26, 1981 fire was not justified, and that no time were we in violation of surveillance requirement SR 5.5.3.
. (2)
Corrective steps which will be-taken to avoid further violations:
Future releases shall be evaluated on a case-by-case basis, utilizing the methodology illustrated above.
(3)
The date when full compliance will be achieved:
We have remained in compliance throughout the time period in question.
B.
Use of Correct Procedure Revision 10C FR,- Appendix 8,
Criterion V states, " Activities affecting-quality shall be prescribed -
by documented instructions, procedures
. and shall be accomplished in accordance with these instructions, procedures...." Licensee Procedure P-4, Issue 3' (10/26/81), " Surveillance Testing Program," states, in paragraph 4.1.4, "The person (s) assigned to conduct the.
Surveillance Test (Test Conductor (s)) are responsible for: a) obtaining a copy of the latest revision of the Test -Procedure for the Surveillance Test assigned 'from his Department Supervisor."
Contra ry to the
- above, in six instances,
_between j
November 3, 1981, and December 31, 1981, calibrations of instruments, which are Surveillance Tests, were conducted using l-out-of-date procedure revisions.
This is a Severity Level V violation.
(Supplement I.E.)
i (8206-02)-
l (1)
LThe corrective steps which will be taken and the results achieved:
- ~
Immediately upon learning of the violation all involved l
personnel were made aware of the problem, Procedure P-4 was re-emphasized.
l
, (2)
Corrective steps which 'will be taken to avoid further violations:
The Scheduling Department has the responsibility to control the issuance of new procedure revisions.
When 'a' new revision.is issued to the Scheduling Department, Scheduling will determine if that test is "out" for completion.
If test is not "out", then the new revision will be placed in file for future use and all out of date copies will be destroyed.
If the test is "out", the scheduler will locate'the surveillance test and determine if the test has been signed by the Shift Supervisor authorizing the start of the test.
If the test that is "out" has been authorized for start then, that test will be considered valid and allowed to continue.
If the test has not been authorized to start by the Shift Supervisor, then that out of date test will be removed and destroyed.
The revised test will then replace the out of date test.
(3)
The date when full compliance will be achieved.
Compliance specifically addressing the violations was-achieved on April 1,1982. Compliance regarding actions, as listed, to avoid further violation will be achieved by j
June 1, 1982.
Should you have any further questions, please contact Mr. Ed Hill, (303) 571-7436, ext. 201).
Very truly yorus, Oscar R. Lee ORL/skd i
r 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 82-06; 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.
l
- 0. R. Lee Vice President of Electrical Production STATE OF
[ofOrRCO
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) ss COUNTY OF Nek
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Subscribed and s[rn to before me, a Notary Public in and foribe_ $dc c((ol on this J r/
day of Hau.-
, 1982.
bYhill.
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tptaryPublir My commission expires
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