ML20054M458

Responds to NRC Re Violations Noted in IE Insp Rept 50-267/82-06.Corrective Actions:Tech Spec 5.5.3 Will Be re-evaluated to Read More Clearly

ML20054M458
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/16/1982
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20054M455	List: IR 05000267/1982006 ML20054M456 ML20054M458
References
P-82196, NUDOCS 8207130259
Download: ML20054M458 (4)

Text

a pulfe Service Company *f CeHende

• - 16805 WCR 19 1/2, Platteville, Colorado 80651 rb - h fM [] W/[Ni$,

_=I '

June 16, 1982

> j l J N 2 llggg Fort St. Vrain Unit #1 l

" l--

_ jw/ P-82196 Mr. John T. Collins, Regional Administrator U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76012

SUBJECT:

Inspection Report 82-06 Docket 50-267

REFERENCE:

P-82147

Dear Mr. Collins:

Pursuant to cur telephone conversation with members of your staff, we have re-evaluated our response provided by- the above referenced letter. We are submitting a revised response as follows:

A. Timely Conduct of Surveillance Tests Upon re-evaluating your findings and the Technical Specification based on conversation with members of-your staff, we feel that the Technical Specification is poorly worded, but we agree that in the most literal sense the SR 5.5.3 requires -that the charcoal filters be laboratory tested after painting and fires and that chemical releases must be evaluated on a case by case basis.

The problem with the Technical Specification is that it places no quantitative means of evaluating test requirements, and if interpreted literally could require a test of the charcoal for touch up painting and small quantities of smoke in the reactor building. We believe- this type of interpretation is much too restrictive, and certainly cannot be justified in terms of cost or overall effect on the charcoal filters. At the same time, however, it is difficult to place quantitative values on painting or fires. It is obvious, for example, that the fire in question had no adverse effects on the charcoal filters as indicated by the laboratory test of December'17, 1981.

8207130259 820707 ,

PDR ADOCK 05000267 G PDR

(

-g-We will attempt to re-evaluate the Technical Specification, and if possible, we will submit a revised SR 5.5.3. In the interim, or if it is not possible to clarify SR 5.5.3 we will comply with the Technical Specification by requiring a formal evaluation and laboratory tests of the charcoal following a fire or chemical spill in the Reactor Building if necessary. Painting in the-Reactor Building is controlled by other mechanisms.

To ensure timely reporting and evaluation of fires or chemical spills an Operations Order has been issued requiring a " Report of Fires or Chemical Spills" in the Reactor Building. This report will be utilized to initiate action under the Technical Specifications, and should serve to avoid future violations of SR 5.5.3.

B. Vie.of Correct Procedure Revision Your staff indicated that our response for this item did not indicate the mechanism by which we would institute corrective action. Please be informed that written instructions have been issued to the Surveillance Clerk to reflect the .new procedure.

An official procedural change request has been initiated to change our surveillance test procedure. This procedural change will be processed as soon as possible.

Very truly yours,

.ch [ futtdw&

Don W. Warembourg #

Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/ske Attachment

NUMBER d82-12

. REPORT OF FIRE OR CHEMICAL SPXLLS The following report is to be initiated by the Shift Supervisor or his designated alternate and forwarded to the Radiation Protection Department following any fire or chemical spill in the reactor building.

Date of Event Approximate Time of Event Name or Department Reporting Event Brief Description of Event Location .

Duration If Chemical Spill Identify Chemicals & Quantity Description of Event (Include Action Take & Consequences)

(

Signed Date RADIATION PROTECTION DEPARTMENT:

Date Report Received Evaluated By Initiated Charcoal Filter Yes No Tests Under SR 5.5.3 Evaluation:

e Test Results and any further action that may be required are to be reported to the Plant Manager or Superintendent, Operations.

Signed Date

NUMBER #82-12

1. C

, DATE

~

SYSTEM Administrative i

OPERATIONS ORDER ATTENTION:

I XXXX l l XXXX l l XXXX l l XXXX l l__ l l l l l l l SS R0 EO AT Note: '

Initial when order is read e

In order to demonstrate compliance with Technical Specification SR 5.5.3 it is necessary to evaluate the reactor building charcoal filters following painting, fires or chemical releases to the reactor ouilding. To comply with this Tech Spac it is necessary to initiate action by some vehicle which will establish the evaluation process.

Effective with the date of this Operations Order the Shift Supervison or his designated alternate is responsible to initiate the attached

" Report of Fire or Chemical Spills".

Painting is controlled by various other vehicles such as PTR's, CN's, etc. The Shift Supervisor, however, shall be cognizant of pain ng activities within the reactor building, and no painting shall b without the express approval of the Plant Manager or his des a't alternate.

/

Superintendbnt, Operations (or) Station Manager i