ML20246B698
| ML20246B698 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/14/1989 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-89307, NUDOCS 8908230437 | |
| Download: ML20246B698 (4) | |
Text
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i-f hPublic Service *
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P.O. Box 840 Denver CO 80201 0840
- A. Clegg Crawford August 14,.1989 vic, pro,;eent o
Fort-St. Vrain-Nuclear operations Unit No. 1 3-
'P-89307 U. S. Nuclear Regulatory Commission
'i.
ATTN:
Document Control-Desk 4
Washington, D. C.
20555 Docket No. 50-267
SUBJECT:
Response to Notice of Violation 8915-01
REFERENCE:
NRC Letter, Milhoan to
-Williams, dated July 14, 1989 (G-89234)
Gentlemen:
This letter.is in response to the Notice of Violation 8915-01 received as a result of the inspection conducted by Mr. P. W. Michaud during the period of June 23-27, 1989 (See Reference). The following response is hereby submitted:
Failure To Provide Adeauate Administrative Control Of Plant Changes That Affect Safety-Related Plant Procedures Technical Specification AC 7.4. requires that written procedures as recommended in Appendix A of Safety Guide 33, November 1972, shall be established, implemented and maintained for activities affecting plant operation.
Contrary to the above, on March 22, 1989, a change was made to the method of secondary heat balance calculation by the licensee's reactor support group without revising Procedure OPOP-IV, " Plant Operation Between 30?J and 100?; Power." This resulted in operation above the authorized maximum power level of 82 percent of full power, by up to 1.6 percent on ' June 22-23,
- 1989, for a period of approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
This.is a Severity Level IV violation.
(Supplement I) (267/8915-01) l 8908230437 890814
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PDR ADOCK 05000267 l
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e P-89307 August 14, 1989 (1) The Reason For The Violation If Admitted The violation is admitted.
There are-three different indications of reactor power available to the operators, as displayed on the data logger:
primary heat
- balance, secondary heat balance, and linear power channels.
The secondary heat balance uses more directly measured data (i.e.
1 feedwater flow, temperature, and pressure) than the primary heat balance, and is used as a more accurate indication of reactor power at higher power levels.
At approximately 55 percent reactor power, cold reheat steam (steam entering the reheater section of the steam generators) attemperation is initiated as required to balance. hot reheat (steam exiting the reheater section of the steam generators) and main steam temperatures due to the increased heat transfer' design of the reheater section.
This attemperation flow must be accounted for in the secondary heat bulance calculations to ensure an accurate calculated reactor power level.
Prior to March 22, 1989, this update to the secondary heat balance program was performed manually on data logger screen 2278 per procedure OPOP-IV or data logger screen 6049 per procedure SOAP-4,
" Plant Operations Shift Turnover." On March 22, the secondary heat balance update. function was deleted from screen 2278, disabled from screen 6049, and assigned to screen 2274 Prior to initiating the secondary heat balance program changes, it was recognized that operator training would be required, and a training seminar was conducted over a five week period ending March 15, 1989.
Training and procedure changes have commonly been initiated as a result of changes to the plant computer.
PSC procedure TSP-27, " Plant Computer Changes," identifies how to request and initiate a plant computer change, however, the need for associated changes to plant procedures is not addressed. Thus, the instructions to operators in OPOP-IV and 50AP-4 concerning secondary heat balance update requirements were overlooked.
(2) The Corrective Steps Which Have Been Taken And The Results Achieved The requirement for operators to manually update the secondary heat balance calculation when attemperation flow is initated was evaluated and determined to be unnecessary.
The plant computer can automatically detect initiation of attemperation flow based on positive flow indication.
The secondary heat balance calculation program has been modified to account for attemperation flow l
automatically.
OPOP-IV has been revised to instruct operators to confirm this automatic change to the calculation, and SOAP -4 has l
been corrected by deleting the secondary heat balance manual update procedure for screen 6049.
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1 P-89307 August 14, 1989 On June 28, 1989,. plant management directed that all computer changes will require' documentation of Operations Department procedure reviews and ' Operations ~.. Department. management approval. This direction was.
.made via Memo PPC-89-2045:and: was implemented to provide -interim control-until a detailed' procedure is prepared.
Fort St.
Vrain : operation 1s limited to 82 percent' reactor power by -
4 ithe NRC. 0perations' Order 87-10 was issuedL by PSC in 1987 to
~
. administratively restrict reactor power.to 81 percent.and; instructed-E operators lto observe.this power'. limitation. as indicated ~by the secondary' heat! balance and average linear power channel indication.
Operations Order 87-10 has been superseded by Operations Order _ 89-03 to administrative 1y ' control reactor. power below 80 percent by the h
most conservative indication of primary heat balance,Lsecondary heat
~
' balance, or linear power. channels.
(3) The Corrective- -Steps Which Will Be Taken To Avoid Further Violations A new procedure to ensure adequate control of-plant computer changes has been prepared and is in routing for review 'and approval._ This i:
procedure will require that. each computer change be evaluated for
-procedural. impact, and any required procedure changes must be completed "before 'the; computer changes are implemented. The new-procedure will be. implemented-by September 30, 1989.
Procedures primarily. affected by plant computer changes have been identified and reviewed to determine -if other discrepancies exist that may have the potential for affecting plant operation. No discrepancies were found which affect-operator action or-plant-ope rati on'.
- However, some incorrect-references were identified and will be corrected by August 31, 1989. A computer search of other i
plant. procedures will be conducted by' August 31, to identify any other procedures that may be affected by plant computer changes.
Due to the importance reactor power indication has in safe plant operation, further. evaluation:will be performed to identify if there are any other procedural or computer errors related to reactor power indication. This evaluation will be performed and any identified changes implemented by September 30, 1989.
(4)~ The Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 30, 1989, including the implementation. of the new procedure to control plant computer changes, corrections to procedure references found to be incorrect, and any necessary procedural changes resulting from the additional j
evaluations.
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P-89307 August 14, 1989 If. you have any questions, please contact Mr. M. H. Holmes at (303) 480-6960.
Sincerely,
+A@
A. Clegg Crawford Vice President, Nuclear Operations ACC/MJ:drg cc:
Regional Administrator, Region IV ATTN:
Mr. T. F. Westerman, Chief Projects Section B Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain Mr. Robert M. Quillen, Director Radiation Control Division Colorado Department of Health Colorado Public Utilities Commission ATTN:
Ralph Teque, P. E.
1580 Logan Street, OL1 Denver CO 80203
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