ML20247A223

Responds to Violations Noted in Insp Rept 50-267/89-07 on 890319-0430.Corrective Actions:Daily Repts Provided by Surveillance Technician Revised to Improve Readability & Eliminate Unnecessary Info

ML20247A223
Person / Time
Site:	Fort Saint Vrain
Issue date:	07/14/1989
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-89250, NUDOCS 8907210183
Download: ML20247A223 (7)

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p,o, gox gao Fort St. Vrain Denver co 80201-0840 .L i

Unit No. 1 P-89250 A. Clegg Crawford Vice President j Nuclear operations j U. 5. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

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I Docket No. 50-267  !

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SUBJECT:

NRC Inspection Report 89-07 i

REFERENCE:

(1) NRC Letter, Westerman to Williams, dated i June 8,1989(G-89201) i i

Gentlemen:

4 This lett er is in response to the Notice of Violation received-as a  ;

result of the inspection conducted by Messrs..R. E. Farrell and P. W.  :

Michaud during the period of March 19 through April 30, 1989 (Reference 1). By telecon on July 10, 1989, Mr. T. F. Westerman l granted an extension for this response to July 21, 1989. The I following response to the items contained in the Notice of Violation ,

is hereby submitted: j A. Failure to Comply with the Requirements of Technical  ;

Specifications  !

Two examples of the failure to comply with the requirements of Technical Specifications prior to changing plant conditions are es follows:

1 1' l 1. LC0 4.2.7.c and LC0 4.2.7.d specif that the prestressed concrete reactor vessel (PCRV) yshall not be pressurized -to more than 100 psia unless the  !

interspaces between the primary and secondary penetration closures are maintained at a pressure  !

greater than primary system pressure with purified helium gas.

Contrary to the above, the PCRV was pressurized to i greater than 100 psia from 10:18 P.M. on' March' 23, 1989, until 1:02 A.M. on March 2a. 1989, with the purified helium supply to the Region 27 interspace 1 isolated.

2. Surveillance Requirement-(SR) 5.6.1d requires that diesel engine exhaust temperature-- " shutdown" and l

"declutching functions" be tested monthly when the 8707210183 e9o714 PDR ADOCK 05000267 ggl  !

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standby diesel generators are required.

The diesel generators are required per LC0 4.6.1 when reactor power exceeds 2 percent.

Contrary to the above, reactor power was greater than 2 percent from 8:21 P.M. on March 27,, 1989, until 1:20 A.M. on March 29, 1989, with monthly TS Surveillance Requirement (SR) 5.6.1d not completed within the required interval.

This is a Severity Level IV violation. (Supplements)

(267/8907-01)

.1) The Reason For The Violation If Admitted:

The violation is admitted.

Example 1, noted in the Notice of Violation, was due to a procedural inadequacy. Two separate equipment clearances were issued against equipment associated with a single control rod drive penetration interspace. Both clearances l

required the isolation of the purified helium supply which is used to pressurize the penetration. One of the clea rances . was ret. ned prior to the Prestressed Concrete Reactor Vessel (PCRV) pressurizing to greater than 100 psia. The second clearance was not returned and PCRV pressure was increased with the interspace isolated.

. Instructions for checks to be performed by the Operations l Department personnel before increasing PCRV pressure are f included in the Overall Plant Operating Procedure (OPOP) I,

" General Plant Requirements". At the time of. the noted incident, OPOP I, Section B, "PCRV Pressurization to > 100 1 psia" instructions were limited to verifications .of the l

operation of valves which are manipulated from the' Control 1 Room. The procedure did not include any field verifications.

of manually operated valves or val /e lineups. The presence ,

and effect of outstanding clearances is routinely checked by  !

the Operations Department before the PCRV is pressurized.  ;

above 100 psia. However, the process was not formalized in '

OPOP I. The Operations Department did determine that there i were outstanding equipment clearances against the penetration. Operations requested that the Maintenance i Department return the clearances so that PCRV pressurization i could proceed. Maintenance returned one of the clearances. i The second clearance was not returned because it had never '

been accepted by workmen who had requested it.

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I Example' 2, noted in the Notice of Violation, was due to inadequats control of. rescheduled . Technical Specification Surveillance Procedures.

SR 5.6.1d-M, " Diesel Engine Exhaust Temperature Functional Test", was completed on February 8, 1989. The procedure was due to be performed again,Lin.accordance with '.ts normal scheduled period, by March- 8, 1989. At. the time the procedure came n/; the plant was shut down and the Limiting .

Condition for Operation' (LCO) associated with the Technical Specification surveillance requirement, " Prior To Reactor:

Operation Greater Than or Equal To 2%" was not applicable.

SR 5.6.1d-M was' placed on . a " Reschedule" status due to diesel ~ generator maintenance activities 'and plant conditions. Fort St. Vrain'.s administrative controls require that a " Reschedule" surveillance be performed before its associated LCO becomes effective.

The normal mechanism for issuing " Reschedule" surveillance tests is for the responsible department supervisor to contact the Surveillance Technician and' request issuance of the test so that it can be performed within the Technical Specification requirement. In this case, no request was made. The Surveillance Technician was not aware that reactor power was being increased and did not realize the test should have been issued.

2) The Corrective Steps Which Have Been Taken And The Results Achieved:

For Example 1, the second outstanding clearance was returned

~and the control rod drive penetration interspace. was immediately pressurized as. required. OPOP-I-was revised.to include additional checks which. murt be performed before increasing reactor. pressure above 100Lpsia. Additional checks include: verification.Lof' the status- of- PCRV:

penetration . primary and secondary closures, penetration.

interspace valve lineups, verification of penetration. safety j valves, penetration interspace drain valve linttups, Pla~nt ~' )

Protective System (PPS) switch lineups, Control , Rod Drive j (CRD) purge . valve- lineups, and' other verifications.- )

Extensive manual valve lineups are in the form of,~ checkoff. '

lists with independent verification by,a second individual. i Verifications are signed off by cognizant department  !

supervisors. l l For Example 2, reactor power was decreased to..less than 2%. ]

SR 5.6.1 " Reschedule" was successfully completed. The daily reports which the Surveillance Technician provides to the .l I

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P-89250 July 14, 1989 l

Control Room and Shift Supervisor have been revised to improve readability and eliminate unnecessary information.

The daily reports which show the status of " Reschedule" surveillance tests are provided to the morning " Plan of the Overall Plant Day" meeting Operating for review Procedure (OPOPby p)lant III, management.

"Startup Procedure", has been revised to include a Scheduling Department signoff. I The signoff indicates that all required surveillance tests have been performed before changes in plant operating modes are made.

l A communication link has been established between the Surveillance Technician and the Lead Scheduler to ensure that there is an awareness of changing plant conditions.

Station procedures governing the Surveillance _ Program have been reviewed to ensure that " Reschedule" surveillance are l adequately addressed. I Awareness of the issues associated with both examples noted in the Notice of Violation has been increased among management and performance level personnel ttrough the corrective actions taken.

3) The Corrective Steps Which Will Be Taken To Avoid Further ViB ations:

No further actions are planned for Example 1.

Station Procedures governing the Surveillance Program will be revised to incorporate the resu'lts of the review described above. Station Manager _ Administrative Procedures SMAP-1, " Technical Specifications . Surveillance Testing Program"; SMAP-2, "Non-Technical Specificaticu Surveillance Testing Program"; and SMAP-5, " Scheduling Program for Surveillance" wili be revised.

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4) The Date When Full Compliance Will Be Achieved:

Full compliance with regard to Example 1 was achieved on June 28, 1989, following the Plant Operations Review Committee review of the final change made to OPOP-I.

Full compliance with regard to Example 2 will be achieved by July 31, 1989, when the changes to SMAP-1, SVAP-2, and SMAP-5 are implemented.

B. Inadequate Control of Replaceiaent Parts for Safety-Related Equipment Criterion VIII of Appendix B to 10 CFR Part 50 and the licensee's quality assurance program require that measures be established for the identification of materials, parts, and components to prevent the use of incorrect or defective materials, parts, and components.

Contrary to the above, on April 12, 1989, an incorrect part number was specified and used to obtain a replacement part which was then installed in the "D" emergency diesel generator engine.

This is a Severity Level IV violation. (Supplement I) (267/8907-02)

(1) The Reason For The Violation If Admitted:

l The violation is admitted.

l The violation was due to a personnel error. Station Service l Request (SSR) 89501818 was issued to check the calibration of "D" Emergency Diesci Engine Water Temperature Switch.

Calibration efforts were not successful and it was determined that the switch should be replaced. The SSR was replanned by the Instrument and Controls (I&C) Supervisor to accompliLh the switch rr. placement. Replanning of SSR's by department supervisors is permitted by Administrative Procedure P-7, " Station Service Request Processing". While i selecting the safety related part number for the water 1 temperature switch, an I&C Technician erroneously selected  ;

the safety related part number for an oil temperature switch. The incorrect part number was located immediately adjacent to the correct part number in the Plant Safety  !

Related Parts Code List. The mistake was due to a.

transposition error made when moving across the line of the list. Contributing to the error, the incorrect part was physically similar to the correct part and it was made .by the same manufacturer. The occurrence of similar parts

P-89250 July.14/1989 being immediately adjacent'on the.. parts ~11st 'is isolated..-

The incorrect part was procured'and subsequently installed.

No -other similar incidents . involving - . installation- of incorrect safety related parts'due to transposition' errors while identifying parts 'when planning _ SSR's have .been identified.

(2) The Corrective Actions Which Have Been Taken And The~Results j Achieved:

The. correct temperature switch was obtained, calibratedf and' installed. The water and oil temperature _ switches on all four Emergency. Diesel Generator engines were verified to be correct.

A. rootcausedeterminationinvestigationwasinitiathdasa result of th~eincident. The investigation was-performed.-by personnel from the Systems Engineering Department. As a result of this- investigation,' a recommendation for corrective action was made. Investigation findings were I discussed with performance level I&C personnel. The I&C I staff agreed that SSR's which need to be replanned should be returned to the Planning Department as the preferred method.  !

The I&C staff feels that this-preferred process.is a good j practice, however, it is too restrictive in some situations to formalize as a requirement. There are situations encountered in the conduct of maintenance where it is.

appropriate .for the Supervisor to revise the work plan on SSR's. The incident involved in this= violation is an isolated case involving both personnel error and coincident adjacent similar parts on a parts list, and does not involve a programmatic problem.

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.i The results of the root cause determination investigation were presented to all I&C Technicians. .Results were presented by the Superintendent of I&C Maintenance in a training seminar format on April 27, 1989.- It was' recommended. that SSR's requiring' replanning be returned to Planning as the preferred. method. When replanning is performed by the Supervisor and parts are being. identified, appropriate caution was encouraged. ~ Independent verification-of parts. identification will be pe'rformed'whenever possible to minimize the probability of recurrence.

In addition, the Maintenance Quality Control group held a staff meeting in which it was stressed that the inspector _is responsible for verifying that replacement parts which are being installed are like-for-like parts.

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No cases of the specification and use of an incorrect part in safety related e,aipment have occured since the ,'

corrective actions outlined above were taken.

3) The Corrective Steps Which Will Be Taken to Avoid Further 1 Violations:

No further corrective steps are planned.

4) The Date When Full Compliance WilI be Achieved:

Full compliance was achieved on April 27, 1989, following d the seminar presentation described above.

If you have any questions, please contact Mr. M. H. Holmes at (303) 3 480-6960. i 1

Very truly yours,

'S Y f A..Clegg Crawford j Vice President a Nuclear Operations ACC:DLW/bhb

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cc: Regional Administrator, Region IV i Attn: Mr. T. F. Westerman, Chief l Projects Sect'on B l i

Mr. Robert Farrell l Senior Resident Inspector Fort St. Vrain Mr. Robert M. Quillen, Director  ;

Radiation Control Division i Colorado Department of Health Colorado Public Utilities Commission Attn: Ralph Teague, P. E. ,

1580 Logan Street, OL1 Denver, CO 80203

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