ML20063E619

Responds to NRC Re Violations Noted in IE Insp Rept 50-267/82-08.Corrective Actions:Established Control Point for Controlled Area,Posted Approved Procedures & Revised Surveillance Test of Gas Waste Release

ML20063E619
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/26/1982
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20063E596	List: ML20063E619
References
P-82162, NUDOCS 8207130474
Download: ML20063E619 (6)

Text

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h PUBLIC SERVICE COMPANY OF COLORADO P. O. BOX 840 DENVER, COLORADO 80200 OSCAR R. LEE May 26, 1982 v.c c . es' ""'

Fort St. Vrain Unit No. 1 P-82162 Mr. John T. Collins, Regional Administrator @

U. S. Nuclear Regulatory Commission g' d N 1"1 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76012

SUBJECT:

Ins eport 82-08 Docket 50-267

Dear Mr. Collins:

This letter is in response to the Notice of Violation received as a result of an inspection conducted at Fort St. Vrain during the period of March 1-31, 1982.

~

The specific items found in violation and the responses are as follows:

A. Posting, Controls, and Surveys Technical Specification 7.4.a, " Procedures, Administrative Controls" states in part that, " . . written procedures shall be established, implemented, and maintained. . . ."

Health Physics Procedure HPP-9, " Establishing and Posting Controlled Areas," Issue 3, dated February 25, 1981, states in part:

"2.5 Controlled areas shall be clearly marked in accordance with the procedurt. and adequately surveyed to insure that the boundaries established completely define the controlled area and that no loose surface contamination, airborne activity, excessive radiation streaming, etc.

exists immediately outside the local boundary. ..

"5.3 Contaminated Area 5.3.1 Establish a perimeter with a convenient point of access.

5.3.2 At the point of access, tape to the floor a piece of absorbent paper to be used as a control point.

8207130474 820629 gDRADOCK 05000267 PDR

5.3.3 If radiation levels are low enough to obtain a valid response, a Frisker will also be located at the Control Point.

5.3.4 For abnormal conditions such as a radioactive liquid spill, the magenta and yellow barrier rope or tape will serve as an appropriate radiation caution. For longer lasting conditions, conspicuously post signs on the rope which bear the radiati_on caution symbol and the words:

CAUTION: CONTAMINATED AREA 5.3.5 On the signs indicate the maximum contamination levels, time, date, initials, and requirements for entry."

Contrary to the above, the NRC inspector determined that the controlled area established March 4, 1982 on level 5 of the Reactor Building at the area around the B-5 PCRV penetration was no't adequately surveyed, a control point was not established as required, and the posting of the area was not in accordance with approved procedures.

This is a Severity Level IV Violation. (Supplement IV.0.1.)

(1) The corrective steps which will be taken and the results achieved:

The affected area was surveyed, a control point was established, and posting per approved procedures was accomplished.

(2) The corrective steps which will be taken to avoid further violations:

Health Physics Procedure HPP-9 was reviewed and subsequently extensively revised in Issue 4, dated March 31, 1982. All areas in the plant have been posted accordingly.

Health Physics personnel have received training on the revised requirements of HPP-9 L

(3) The date when full compliance will be achieved:

March 31, 1982.

B. Technical Specification LCO 4.8.1, " Radioactive Gaseous Effluent, Limiting Conditions for Oper& tion," states in part that:

"a) The release of gaseous and airborne particulate effluents shall be made on an isotopic basis. . . . "

Technical Specification 7.4.a, " Procedures, Administrative Controls," states in part that, ". . . written procedures shall be established, implemented, and maintained. . . ."

Administrative Procedure P-4, " Surveillance Testing," Issue 3, dated October 26, 1981, states in part:

"e) Section 5.0 requires an entry by a Test Conductor in each step performed in the body of the procedure. . .In addition, each page of the procedure Section 5.0 shall be signed and dated by a Test Conductor . . .

"A Test Conductor's initials or signature is verifictaion that:

1) Each step so marked has been completed satisfactorily.

2) The page signed has been completed with all required data entered."

Surveillance Test SR 5.8.labc-M for Radioactive Gaseous Release number 592 from 'A' Receiver T-6303, Section 5.0 states in part:

"39. Valve lineups complete and attached for release per:

attached sheet from SOP-63. . . "

-Contrary to the above, the licensee-determined on March 6, 1982, that even though the surveillance Sr 5.8.labc-M had been signed off veri fying proper valve lineup prior to the radioactive gaseous release, a valve was.found improperly positioned which .

caused an overpressurization of the. vacuum tank T-6301. This '

resulted in.the rupture of the tanks rupture disk and the excessive gas . pressure relieving through the associated safety valve followed-by a subsequent inadvertent release; including gaseous and airborne particulate effluents for which an isotopic analysis had not been made.

This is a Severity Level IV Violation. (Supplement I.E.)

(1) The corrective action taken and the.results achieved: ,

l The gas. waste release was immediately terminated upon noticing high pressure in the gas waste vacuum tank. The error in the valve line up was then identified and corrected. The valve line-up problem and the resultant area pressurization of the gas waste vacuum tank was the reason the rupture disk being rupture. ,

(2) The corrective steps which have been taken to avoid further violations:

Surveillance Test SR 5.8.labc-M has been rewritten to include an independent verification of the proper -valve line up prior to and after each gas waste release. This independent check by another operator should provide an additional step in the procedure to avoid this-type of occurrence in the future.

(3)- The.date when full compliance will be achieved:

Full compliance was achieved on March 30, 1982 when the new Surveillance procedure- which included independent valve line-up verification was issued.  ;

C. Technical Specification 7.4.a, " Procedures, Administrative Controls," states, in part, that, ". . . written procedures shall be established, implemented, and maintained . . . ."

Administrative Procedure P-1, " Plant Operations," Issue 5, dated l February 19, 1982, states, in part: '

! i i "4.5.2 Personnel responsible for obtaining data are required to assure that: . . .

I I_- _

s. . ,

. l;;~ ~

"2) A verificatio'n check is performed at least once -

each . shift to assure pens are Jn_ king and _ _ _

recorders reading properly." , -

Contrary to the above, on March 12, 1982, at 6:30 a.m. MST, the NRC inspector . determined that recorder RR 93256, " Effluent Activity Monitors," had -not been reading properly since approximately 6:45 pm. MST,. March 11, 1982.

This is a Severity Level V Violation. (Supplement I.E.)

(1) The corrective steps which have been taken and the results achieved:

Maintenance was pecformed on the recorder and it was operating properly on March 12th.

(2) The corrective steps which will be taken toravoid further violations:

The weekly surveillance' procedure SR-0P-18-w will be revised to include a sign-of f for every shift rather than ,

the present requirement of once a day? The in:reased attention to the equipment as evidenced- by the sign-off every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should help alleviate this type of-problem in the future.

(3) The date when full compliance will be achieved:

The revision to SR-0P-18w will be issued by June 28, 1982 '~

and we will be in full compliance.

Should you have any further questions, please contact Mr. Edwin D.

Hill, (303) 571-7436, ext. 201.

Very truly yours,

?

hdMVh Oscar R. Lee ORL/skd s

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 )

,/

AFFIDAVIT

. . . . 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 82-08; 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.

G/2ht

0. R. Lee Vice President of Electrical Production STATE OF (7(/ O )

COUNTY OF h8 )

Subscribed and s rn to before me, a Notary Public in and for-/hp Shit dbfGrddC) on this '2 /o day of H7 rut , 1982. O G

kb ALu f b/5>71A/O Nqfary Public4' My commission expires // - k ,196 5