ML19332D432

Responds to NRC 891023 Ltr Re Violations Noted in Insp Rept 50-267/89-20.Corrective Action:Personnel Instructed to Consider Potential Adverse Impacts of Shutting Equipment Down Temporarily for Troubleshooting

ML19332D432
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/22/1989
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-89461, NUDOCS 8912010192
Download: ML19332D432 (3)

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Public Service'  ::",'l:.41.

P.O. Box 840 November 22, 1989 Denver co 80201 0840  !

Fort St. Vrain Unit No. 1 A. Clegg Crawford

• P-89461 vice Pre.ioent Nuclear operatiota L

U. S. Nuclear Regulatory Commission e ATTN: Document Control-Desk Washington, D.C. 20555 Docket No. 50-267 l

SUBJECT:

..nC Inspection Report 89-20

REFERENCE:

NRC Letter, Milhoan to Crawford l dated October 23,1989(G-89369)

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Gentlemen:

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This letter 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 September 1 through September 30, 1989 1 (Reference 1). The following responses to the items contained in the r Notice of Violation are hereby submitted, j Failure to Follow Procedure The Fort St. Vrain Technical S; ecifications Section 4.7.a. states, in part, thet " written pincedures shall be established, implemented .

Procedure SOP-84-02. Issue 7. "Outside Auxiliary Boiler " states in Step 4.2.1.40.e) to " Slowly close V-84881."

Contrary to the above, on September 6, 1989. Valve V-84881 was not closed, which allowed steam to enter the service air system which then entered the "A" Instrument Air System.

This is a Severity Level IV violation. (Supplement I) (267/8920-01)

1. Tl.; Reason For The Violation If Admitted:

The violation is admitted. The root cause of this event was insufficient attention to procedural details by Operations personnel. The operator was performing surveillance procedure SR-0P-43-M on the outside auxiliary boiler (OAB). SR-OP-43-M checks the boiler protective trip setpoints and was being performed in preparation for placing the OAB in service to perform intermittent firing tests on the inside auxiliary boiler (IAB). The OAB was successfully fired but it tripped from approximately 60% load,

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e P-89461 November 22, 1989 L ,

The IAB was at approximately 20% load and tripped at the same I time. After several unsuccessful ettempts to restart the OAB, it was left shutdown until troubleshooting could be performed and the IAB was returned to service. Therefore, when personnel shut down the boiler for troubleshooting, a valve was inadvertently left open, contrary to the procedure's instructions. This resulted in steam entering the Service Air System.

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

Personnel involved in this event have been instructed to consider the potential adverse impacts of shutting equipment down temporarily for troubleshooting. Personnel were instructed that normal shutdown procedures should be utilized and followed whenever possible. Furthermore, the entire Operations Department has been reminded of the necessity 1or mandatory procedural

! compliance. As part of PSC's Performance Indicator Program, failure-to-follow procedure events are tracked, and have shown a decreasing trend since inid-1988.

3. The Corrective Steps Which Will Be Taken To Avoid Further Violations:

For the most part, the OAB will not be used during defueling and no further corrective actions for either specific OAB procedure enhancements or 0AB operator training are warranted. PSC will enhance our General Employee Training (GET) Program to include a module to emphasize the necessity for procedural compliance.

4. The Date When Full Compliance Will Be Achieved:

Full compliance was achieved per the actions noted in item No. 2 above on October 10, 1989. The implementation of the GET Program training module on procedural compliance will be completed by February 1, 1990.

Should you have any further questions, please contact Mr. M. H.

Holmes at (303) 480-6960.

Sincerely, A.

A. Clegg Crawford Vice President Nuclear Operations ACC/MED/km i

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