ML20205R125

Responds to NRC Re Violations Noted in Insp Rept 50-267/88-20.Corrective Actions:Fuse F7 Replaced,Circuit re-established,incident Reviewed W/Electricians Involved & Training Development Request Will Be Initiated

ML20205R125
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/04/1988
From:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
P-88395, NUDOCS 8811090452
Download: ML20205R125 (4)

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$Public Service ~

ch 16805 WCR 19 1/2, Platteville, Colorado 80651 November 4, 1988 Fort St. Vrain Unit No. 1 P-88395 i

i U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, ij.C.

20555 Docket No. 50-267

SUBJECT:

NRC Inspection Report 88-20

REFERENCE:

NRC letter, Callan to Williams, dated October 6, 1988 l

(G-88412)

Gentlemen:

This letter is in response to the Notice of Violation received as a result of the inspection cond ated by Messrs. R. E. Farrell and P. W.

Michaud during the period August 1 through September 10, 1988. The following response to the item contained in the Notice of Violation is hereby submitted:

Failure to Follow Procedures Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program require that activities affecting quality be prescribeo by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and be accomplished in acccrdance with these instr' actions, procedures or drawings.

The licensee's Procedures P-2, Issue 14, "Equipment Clearances and Operation Deviations," and SMAP-19, Issue 7,

"Processing 1

Equipment Clearance and Operation Deviations,"

provide requirements, respor.sibilities, and steps for issuing and 4

processing clearances. Sections 4.1 and 3.7 respectively of the above procedures provide instructior.s for the modification of clearances.

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P-88395 November 4, 1988 Contrary to the above, on September 7,

1988, while placing Clearance No. 24662, Fuse F7 on Panel N9212 was pulled.

This fuse was not listed on Clearance No. 24662 and no modification of the clearance was made to include Fuse F7.

This is a Severity Level IV violation. (Supplement I)(267/8820-01) g1) The Reason For The Violation If Admitted.

s The violation is admitted.

The workmen involved in this incident misunderstood the cleared equipment boundary of l

Clearance No. 24662.

The plant electrini drawings being used in the job underway were also misread.

l Clearance No. 24602 was used to de-energize the output circuits associated with plant 480 volt undervoltage relay protection for the purpose ofworkingChangeNotice(CN) 2748A. The output circuits consist of DC voltage signals which initiate trips, alarms and other plant protective actions. AC voltage input circuits for the plant 480 volt undervoltage relay protection system were not de-energized by Clearance No. 24662.

CN-2748A specified the installation of zipper tubing on selected cables in order to meet fire protection separation criteria.

Installation of zipper tubing required that affected cables, including cables for AC voltage input, be determinated.

Plant electricians determined that the cables to be worked were energized.

Electricians contacted the design engineer in charge of CN-2748A before erk was started. The electricians were informed that the output functions of the breakers involved in the circuit were de-energized, by Clearance No. 24662, to prevent unwanted actuation of plant protective features. The electricians felt that.ne AC voltage portions of the circuits could be de-energized, for personnel safety, within ths bounds of the clearance which had already been established.

Plant electrics 1 drawings were used to determine which fuses should be pulled to de-energize AC input circuits.

A drawing was misread and Fuse F7 was removed.

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r P-88395 November 4, 1988 Although Clearane.

No. 24662 was established primarily to protect plant equipment, it should have also provided for personnel safety.

Plant electricians should have modified the clearance to include removal of additional fuses.

Administrative controls established in Station Managers-Administrative Procedure (SMAP) 19, "Processing Equipment Clearance and Operations Deviations," would have provided for additional reviews and checks of the modified clearance.

Additional checks could have identified the incorrect selection of Fuse F7 in this case.

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

Fuse F7 was replaced and the circuit was re-established.

The iacident was reviewed with tne electricians involved In addition, the incident was reviewed with the entire staff of electricians at the plant. The importance of modifying procedures and the correct interpretation of plant drawings was stressed during a departmental meeting held for this purpose.

The electricians involved have indicated that in the future all clearance requirements will be met.

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

A Training Development Request. (TOR) will be initiated requesting that the Nuclear Training Department :11 enhance the ongoing training provided to tha plant electricians by including sessions on clearance requirements.

(4) The Date When Full Compliance Will Be Achieved:

Full compliance was achieved following replacemeit of Fuse F7 on September 7, 1988.

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P-88395 November 4, 1988 Should you have any further questions, please contact Mr. M. H. Holmes at (303) 480-6960.

Sincerely, t/$1/b1A.D.tDauAtt3 R. O. Williams, Jr.

Sr. Vice President, Nuclear Operations rcd:DLW/dje cc: Regional Administrator, Region IV ATTN: Mr. T. F. Vesterman, Chict Projects Section R Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain l