ML20071Q555

Responds to NRC Re Violations Noted in IE Insp Rept 50-267/82-24.Corrective Actions:Std Clearance Form for Control Rod Drives Revised to Allow Positioning of Breaker During Removal or Installation

ML20071Q555
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/06/1982
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-82542, NUDOCS 8212290367
Download: ML20071Q555 (3)

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PUBLIC SERVICE COMPANY OF COLORADO P. O. BOX 840 . DENVER. COLORADO 80200 OSCAR R. LEE OOCember 6, 1982 vic e . = " * "'

Fort St. Vrain Unit No. 1 P-82542 A

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Mr. John T. Collins, Regianni Administrator U. S. Nuclear Regulatory Ca mission 611 Ryan Plaza Dr., Suite 'O Arlington, TX 76011

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I&E nspection Report 82-24 REFER : % :. NRC Letter dated, November 17, 1982

Dear Mr. Collins:

This letter is in response t. u.e cic^ ef Vic'atien received as a result of inspections conducio:. at Fort St. Vraia e.. ring the period October 1-31, 1982. The following respensa to tre ite s <sntained in the Notice of Violation is hereby submittec-

1. Technical Specification 7.4.a, " Procedures, Administrative Control s," states, in part, that, "

. . . written procedures shall be established, implemented, and maintained . . . ."

Standard Clearance Point Form 4039, Attachment P-2c to Administrative Procedure P-2, dated October 8, 1982, required the main power creaker for Region 27 :ontrol rod drive to be in the "0FF" position, Valve V-11277 to be closed and tagged, and Valve V-11127 to be tagged.

Contrary to the above, on October 12, 1982, while Standard Clearance Point Form 4039 was still in effect, the NRC inspector determined that the main power breaker for Region 27 control rod drive was in the "0N" position. On October 13, 1982, the NRC inspector determined that Valve V-11277 was open and not tagged, and Valve V-11127 was not tagged.

This is a Severity Level V Violation. (Supplement I.E)

(50-267/8224-01)

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4 (1) The corrective steps which have been taken and the results achieved:

The individual involved was verbally reprimanded for violation APM P-2, and the Manual of Safe Practices concerning equipment clearances.

(2) Corrective steps which will be taken to avoid further violations:

The Standard Clearance Form for Control Rod Drives was revised to allow positioning of the breaker during removal or installation as required by Procedures MP 12-1 and MP 12-6.

(3) The date when full compliance will be achieved:

December 3, 1982.

2. Technical Specification 7.4.a, " Procedures, Administative Controls," states, in part, that, ". . . written procedures shall be established, implemented, and maintained . . . ."

Administative Procedure P-4, " Surveillance Testing Program,"

Issue 3, dated October 26, 1981, states in part, "4.1.4 The person (s) assigned to conduct the Surveillance Test (Test Conductor (s)) are responsible for: ...

"f) Performing the test, in a functionally sequential order, and filling in the appropriate blanks provided upon step completion."

"4.2.4 Test Sections and Their Significance" "e) . . . In addition each page of the procedure Section 5.0 shall be signed and dated by s Test Conductor. . . at the bottom of eac1 page.

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A Test Conductor's initiils or signature is verification that:

1) Each step so marked has been completed satisfactorily.

2) The page signed has been completed with all required data entered."

Contrary to the above, on October 22, 1982, the NRC inspector determined that Surveillance SR 5.3.6-M did not have its appropriate blanks filled in upon step completion, and the bottom of each page had not been signed / dated.

This is a Severity Level V Violation. (Supplement I.E.)

(50-267/8224-02)

(1) The corrective steps which have been taken and the results achieved:

Personnel involved with the test were advised as to the proper method of performing the test per P-4.

(2) Corrective steps which will be taken to avoid further violations:

A memo was sent out to all operations personnel informing them of the proper method of signing off surveillance tests when a duplicate copy is utilized for additional personnel involved in the testing process.

(3) The date when full compliance will be achieved: ,

December 10, 1982.

Should you have any further questions, please contact Mr. Edwin D. Hill, (303) 571-7436, ext. 201.

Very truly yours, OSCA . LEE B','

.?VA&v Oscar R. Lee ORL/skr i

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