ML20137H939
| ML20137H939 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/05/1985 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20137H920 | List: |
| References | |
| P-85461, NUDOCS 8601220151 | |
| Download: ML20137H939 (5) | |
Text
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Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 December 5, 1985 Fort St. Vrain Unit No. 1 P-85461 Regional Administrator
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Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 DEC l 61985 Arlington, TX 76011 g
ATTENTION:
E. H. Johnson Docket No. 50-267
SUBJECT:
I & E Inspection Report 85-25
REFERENCE:
NRC Letter, Martin to Lee, dated 11/15/85, (G-55461)
Dear Mr. Johnson:
This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period September 3 through October 4, 1985. The following response to the items contained in the Notice of Violation is hereby submitted:
1.
Failure to Report 10CFR50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors" in paragraph (b) non-emergency events, (2) four-hour reports, require, in part, "... the licensee shall notify the NRC as soon as practical and in all cases within four hours of the occurrence of any of the following:
.. (ii) Any event or condition that results in manual or automatic actuation of any Engineered Safety Feature (ESF), including the Reactor Protection System (RPS)."
Contrary to the above, the licensee, at 1423 hours0.0165 days <br />0.395 hours <br />0.00235 weeks <br />5.414515e-4 months <br /> MDT on September 16, 1985, experienced an RPS actuation, specifically, a scram signal, and failed to report that event until 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> MDT on September 17, 1985.
SCSO Y
$ gooks 7 PDR
. This is a
repeat violation similar to violation 50-267/8517-01.
This is a Severity Level IV violation (Supplement I.D.) (50-267/8525-01).
A.
The corrective steps which have been taken and the results achieved.
This event was not reported until Septeinber 17, 1985, because of a misinterpretation of the reportability requirements of 10CFR50.72.
Operations Order #85-19 was issued clarifying the conservative approach being taken as to the reportability of all automatic and manual scrams that are not part of a pre planned or expected event.
Operations Order #85-19 Public Service Company will be receiving a Notice of Violation from the NRC concerning the failure to make a non-emergency notification.
This situation resulted from a decision based on a rationalization of the reporting requirement.
Specifically, one item in 10CFR50.72 (and verbatim in RERP-CR) requires a
four-hour non-emergency notification to the NRC for "any event or condition that results in manual or automatic actuation of an Engineered Safety Feature (ESF), including the Reactor Protection System (RPS).
However, actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor operation need not be reported."
In this particular situation, it was reasoned that since the reactor was shut down, the control rods were all fully inserted, and the CRD breakers were open, the fact that we received a scram (erroneously) while performing a surveillance test did not constitute an " actuation" of an Engineered Safety Feature.
The purpose of 10CFR50.72 is to keep the NRC abreast of
" occurrences" at nuclear power plants.
These
" occurrences" need not necessarily be items of
" consequence" or "significant" from our rerspective.
In the applicable section of 10CFR50.72, ti.e interest on the part of the NRC is that the Reactor Protective System, or portions of it, has taken some kind of action (automatically) or has been directed to take some action (manually) during a non pre planned event.
Non pre planned essentially means that it wasn't written down as part of a routine evolution, it wasn't
t,
. pre planned.
It does not mean, for example, that the reactor operator fully expected some minor difficulty while bringing a circulator up, so if he has to isolate it because he encounters problems he doesn't have to report it.
The conclusion in reviewing difficulties in making notifications is that Public Service Company is tying the " significance" of the event with the necessity of making a report.
This is an erroneous interpretation which invariably leads to second guessing, and Notices of Violation.
Consequently, until further directed, the Operations staff is to make notifications using the following guidance for this section of 10CFR50.72.
1.
Single channel trips are not reportable for any scram, loop shutdown, circulator trip, or RWP.
2.
Scrams, loop shutdowns, circulator trips or RWP's, that are explicitly expected as part of an evolution procedure / test are not reportable.
For example, during a
routine plant
- shutdown,
<perators manually insert a scram at about 2%
power. That is not reportable. A second example is during PPS surveillances when operators deliberately trip 2/3 scram channels and receive an automatic scram.
A final example is when operators reposition the scram switch or the Reactor Mode Switch (RMS) as required to perform a procedure test.
3.
Scrams Automatic other than as specified in 2. above, all automatic scrams are reportable, regardless of the plant condition.
Manual other than as specified in 2. above, all manual scrams are reportable, regardless of the plant condition.
4.
Loop Shutdowns Automatic other than as specified in 2. above, all automatic loop shutdowns are reportable, regardless of whether the loop was in service or not.
Manual other than as specified in 2. above or as
. routinely required to establish desired plant conditions, all manual loop shut downs are reportable.
5.
Circulator Trips The reportability of circulator trips is currently under review by the NRC.
Although it is PSC's position that single circulator trips are not reportable, we have made an agreement to report them until our position is concurred with by the NRC.
Automatic other than as specified in 2. above, all automatic circulator trips are reportable, regardless of whether or not the circulator was operating /self-turbining and regardless of whether the brake and seal were set.
Manual other than as specified in 2. above or as routinely done to shut down a circulator, all manual circulator trips are reportable.
This reporting requirement includes those situations in which operators are having difficulty with the circulators, so the operators decide to trip it.
6.
Rod Withdrawal Prohibits Automatic other than as specified in 2. above, or as routinely done during power changes, all automatic RWP's are reportable Manual other than as specified in 2. above, all manual RWP's are reportable.
All situations for all conditions cannot be addressed in a memo. Since we have had difficulty in this area, it is expected the Shift Supervisors immediately obtain a second opinion from the TA's, the Superintendent of Operations, or one of the department managers.
In addition, it is expected for Mr. Evans or Mr. Fuller to be notified promptly, day or night. Don't wait until the next morning.
The intent of the Operations Order is to make the Operations staff aware that Public Sevice Company is taking the position that anything that is even remotely
" unusual" is reportable.
If in doubt, report it.
r
. B.
Corrective steps which will be taken to avoid further violations:
No-further action is required.
C.
The date when full compliance will be achieved:
Compliance has been achieved.
~
Should you have any further questions, please contact Mr. Frank J.
Novachek, (303) 571 7436, ext. 201.
Sincerely, ll$j'/n J. WI'Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG:MED/so 4
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