ML20055G860

Responds to NRC Re Violations Noted in Insp Rept 50-267/90-07.Corrective Actions:Site Mgt Recognized Applicability of 10CFR50.72(b)(2)(vi) Re Previous Day Notification & Immediately Notified NRC

ML20055G860
Person / Time
Site:	Fort Saint Vrain
Issue date:	07/20/1990
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-90234, NUDOCS 9007240244
Download: ML20055G860 (4)

Text

n .-

i O rubiic service'  := := -

P.O. Box 840 4

- Denver CO; 80201 0840 A. Clegg Crawford i Vice President

• Nuclear Operations July; 20,c 1990 -i Fort St. Vrain Unit No. l- 1 P-90234-  !

t DU. S. Nuclear Regulatory Commission ATTN: ~ Document Control Desk 2 '

Washington, D.C.- 20555 Docket No. 50-267 '(

SUBJECT:

NRC INSPECTION REPORT 90-07 l_ RF.FERENCE: NRC Letter, Collins to Crawford, 1:

dated June 22,1990(G-90145) 1

Dear Sirs:

L . .

During .the NRC inspection conducted by Mr. R. E. Farrell during the '

period of. March 30, 1990, through May 31, 1990, a violation 'of NRC requirements was identified. The-' violation involved a failure'to make a required four (4) hour' nonemergency report within the:

allowable' time, as described in the referenced: letter. ,

6 The referenced transmittal letter also expressed concerns with regard to an' apparent decline in sufficient planning and . implementation of l management controls. As you ' recall, in our meeting of April 16, l 1990 Ewe discussed precautionary actions that had'.been taken : to minimize , the potential- for a decline in performance resulting from

.; the permanent shutdown of. Fort St. Vrain. 'We ,are continuing to L '

assess our management actions concerning this very important subject .t' and will provide a written response to you with our conclusions no later than July.31, 1990. ,

y .In accordance with 10CFR2.201, Public Service Company of Colorado .

'hereby submits the following response to your Notice of Violation.  ;

Failure to Make a Required 4-Hour Nonemergency Report Within the Allowable Time

- .c 10CFR50,72(b)(2)(vi) and the licensee's Procedure EP Class,-Issue 7,.

• " Event and Emergency Classification Overview," paragraph C14.12,

', require that the licenses ~ notify the NRC as soon as practical and, in

, all cases, within four'(4) hours of .any event for which notification to other government agencies has been or will be made.

4 [.OONOb $7 y [ O]

a , ,,

n is ,

-}

gyN o - P-90234-Page 3 July 20, 1990-

' 2., The Corrective Steps Which Have Been Taken and The Results-Achieved During followup discussions with Corporate offices on the morning of April-20, 1990, site management became aware of -the-

. notifications' that had been made the previous afternoon. Site management recognized the applicability of 10CFR50.72(b)(2)(vi),

and_immediately notified the NRC.

No additional instances of failure to make notification to the U'

NRC-when a report is made to another government agency have occurred since the incident on April 19, 1990.

3, The Corrective Steps Which Will Be Taken To Avoid Further Violations The need to coordinate reporting-activities with the NRC when making notifications to other government agencies was - discussed and clarified with the Corporate Environmental Services Department, including the management responsible for such' reporting.

s Station administrative controls and procedures which address

. situations which may require reporting to government agencies other ,than the NRC have been reviewed.. Station procedures

-contain-adequate-instruction for site personnel. ' Improvements made in. the area of communications between the FSV site and the.

Corporate Environmental Services Department should preclude violations of this sort in the future.

I

.ij

(!

[

r y ,,n .l , 4

,,)P

< _q j *-

P-90234

-Page 2 July 20, 1990 Contrary to the above on April 19, 1990, commencing at 4:00 pm (MDT),

a> the licensee made notifications regarding water. chemistry to the National Response Center, EPA Region VIII, Colorado Department of Health, Hazardous Material and Waste Management Division, and Welv County Local Emergency Planning Committee. The licensee did not make-the required notification to the NRC until 11:26 am;(MDT) on April 20,.1990.

This is a Severity Level IV violation. (Supplement I.D.) (267/9007-01)

1. The Reason For The Violation If Admitted The violation is admitted.

The violation occurred .due to a lack of communication between site personnel and the Corporate department which is responsible for. formal communication with other government agencies concerned with the initiating event.

-Personnel in the Fort St. Vrain Water -Chemistry Department monitored the unanticipated release of hydrazine from plant.

process streams. Water Chemistry Technicians were farriliar with tne limits' associated with the facility Discharge Permit. This permit does. not define hydrazine discharge limits. As site

' personnel became aware that the plant hydrazine discharge may be in violation of ~ other Federal regulatory limits, the Corporate Environmental Services Department was contacted. Contact =with the Environmental Services Department was made so.that Corporate resources and expertise could be utilized to' address and resolve

.the problem. Co6siderable discussion of the problem took place on April 19, 1990, and possible corrective actions were discussed. Plant personnel understood that further communication on the issue would occur with the site or Ap-il 20, 1990, so that an integrated corrective action picn could be developed. Late in-the-day of April 19, 1990, the Corporate officer, concluded that a violation of environmental regulations had cccurred, and notifications were initiated to the National Response Center, EPA Region VIII, Colorado Department of tiealth, Hazardous Material and Waste ~ Management Division, and the Weld County Local Emergency Planning Committee. Corporate Environmental Services Department personnel were unaware of the parallel reporting requirements found in 10CFR50.72(b)(2)(vi)<

i k'

%g .s;,;S/

"l'\ ':

P-90234 e :Page.4 July 20, 1990

4. The Date When Full Compliance Will Be Achieved Full compliance was achieved on April 20, 1990, when formal, notification,of the hydrazine release was made to the NRC.

<; If you 'have any questions. or comments concerning this response,

-please contact Mr. M. H.' Holmes at-(303) 480-6960.

Sincerely,-

$- Yy b A. Clegg Crawford-Vice President, -

Nuclear Operations.

Fort St. Vrain Nuclear Generating Station

ACC:DLW/bh cc: Region Administrator, Region IV Attn: Mr.'J. B. Baird

- ' Technical Assistant Division of Reactor Projects Mr. Robert Farrell

. Senior Resident. Inspector Fort St. Vrain 1

f

.d 1

5 a _

. .q,..