IR 05000267/1988029

Ack Receipt of 890224 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/88-29. Implementation of Corrective Actions Will Be Reviewed During Future Insp

ML20236C032
Person / Time
Site:	Fort Saint Vrain
Issue date:	03/14/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8903210443
Download: ML20236C032 (2)

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In Reply Refer To: E $$E  !

b Docket: 50-267/88-29

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Public Service Company.of Colorado ATTN: Robert 0. Williams, Jr., Senior Vice President, Nuclear Operations P 0. Box 840-.  ;

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Denver, Colorado 80201-0840 i Gentlemen:

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Thank you for your letter of February 24, 1989., in response to our letter 1 and Notice of Violation dated January 27, 1989. We have reviewed your reply and-find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that. full compliance has been achieved and will be maintaine

Sincerely, I

Ottina/ &ned By:

A. B. BEACH - l L..J. Calla ~n, Director'

Division of Reactor Projects

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Fort St. Vrain Nuclear Station ATTN: C. Fuller, Manager, Nuclear" .

Production Division 'I i

16805 WCR 19) ..

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Platteville, Colorado 80651 Fort St. Vrain Nuclear Station ATTN: P. Tomlinson, fianager Quality Assurance Division 16805 WCR 196 Platteville, Colorado 80651

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h Public Service ~ PA N 16805 WCR 19 1/2, Platteville, Colorado 80651 February 24, 1989 Fort St. Vrain Unit No. 1 P-89067 . e, .

k$hk U. S. Nuclear Regulatory Commission  ? ' ,' ,,

ATTN: Document Control Desk i (

Washington, D.C. 20555 h, :

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Docket No. 50-267 -

SUBJECT: NRC Inspection Report 88-29 REFERENCE: NRC letter Callan to Williams dated-January 27, 1989 (G-89030)

Gentlemen:

This letter is in response to the Notice of Violation received as a result of the inspection conducted by Messrs. R. E. Farrell, P. W. Michaud, and K. L. Heitner during the period November 27 through December 31, 198 The following response to the item contained in the Notice of Violation is hereby submitted:

Failure to Follow Procedure Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program require activities affecting q'ality be accomplished in accordance with documented instructions, procedures, or drawing The licensee's procedure SMAP-19, l " Processing Equipment Clearances and Operation Deviations," Issue 7, Section 3.7.1, describes conditions for modification of a clearance, including requirements for notification of and authorization by the clearance holder, entry of changes, and approval by the shift supervisor, h2 2 ?f 05 ? - fl k W as\ '

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P-8906 February 24, 1989 ,

Contrary to the above, on December 12, 1988, a clearance was improperly modified in that a tag was found on Valve V-11329 (Region 29 Hopper Isolation Valve), while the location listed on the tag was " Region 29 Bottle Valve." In addition, the clearance tag contained voided Clearance No. 2768 This is a Severity Level IV violatio (Supplements)(267/8829-01)

(1) The Reason For The Violation, If Admitted:

The violation is ao'mitted. The violation is due to a failure to follow the proper procedure on the part of two individual .

t Corrective maintenance work activities were scheduled to be '

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performed on equipment associated with Reserve Shutdown (RSD)

Region 3 Clearance number 27677 was implemented to clear out ;

the system for this wor Craftsmen assigned to the job determined that the high pressure helium bottle located adjacent i to the work in progress (Region 29 bottle) should be removed to improve access to the work area. Removal of the high pressure bottle required that the bottle valve be cleared in the closed >

position on RSD Region 29. A clearance was then requested from the Operations Department to permit removal of the RSD Region 29 l high pressure bottl '

A new clearance was initiated by Operations personnel in  ;

accordance with Station Manager's Administrative Procedur SMAP-19,- " Processing Equipment Operation {

Clearances and 1 Deviations." The requested clearance point, RSD Region 29 bottle i valve, is a component of a standard clearance which is routinely used for maintenance on RSD Region 2 A new clearance, number 27686, was issued with a new field clearance tag. At this point Operations personnel determined that the generation of a  ;

whole new clearance was not necessary due to the fact that the clearance was requested in support of a single work activit Clearance number 27686 was therefore, cancelled and the RSD Region 29 bottle valve clearance point was added to the paperwork for clearance number 27677. However, Operations personnel used the field clearance tag, which had been generated for clearance number 27686, rather than preparing a new ta Equipment Operators closed the high pressure bottle valve, hung the field clearance 27686 tag, and notified the craftsmen that the equipment was cleared ou _ _ - _ - __ - -- . - _ - _

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February 24,'1989 i

Craftsmen were then dispatched to the work area to' remove.the high pressure bottle on RSD Region 2 The bottle was i disconnected and removed. Removal of the bottle introduced the l problem that the field clearance tag was attached- to' the high {

pressure bottle valv Station practices require that unused '

-high pressure bottles be secured, top and bottom, and have--a bottle cap installe To accomplish this requirement the clearance tag would have to be covered up by the bottle cap and ,

the bottle itself would have to be relocated, away from the work l area, in a bottle rack. The craftsman was concerned that. the i'

clearance tag would be concealed and potentially mis'placed if another high pressure bottle were used when .the system was returned to servic .The field clearance tag was therefore .!

removed from the bottle by the craftsman and placed on . equipment '

in the immediate area of the work in progres (2)The Corrective Steps Which Have Been Taken And The Results l Achieved: ,

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s The field clearance tag was revised to include the correct clearance number and the tag was properly rehun ] ,

The Superintendent of Operations discussed the event with involved Operations personne Operators were instructed..to prepare new field clearance tags or correct existing tags if

, clearances are combined in the futur The plant Maintenance Manager reinstructed the craftsman in the proper actions to be taken when dealing with field clearance tags and removable equipment. The craftsman was verbally reprimanded in accordance with Station progressive discipline policie The plant Maintenance Manager conducted a follow-up meeting on ,

February 9, 1989 with the craftsman. The craftsman indicated a t correct understanding of requirements for clearances at the follow-up meetin No similar events have occurred since the incident noted in the Notice of Violatio (3)The Corrective Steps Which Will Be Taken To Avoid Further Violations:

PSC has determined that this incident was an isolated case unique to the work that was in progress. No additional corrective steps are planne 1 mm m.__m _--__ u____

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. ! P-89067 -4-- , February 24, 1989 R t

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.(4) The Date'When.F'ull Compliance Will Be Achieved-

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Full i compliance' 'was achieved effective with the noted follow-upi

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I meeting ; held.on February 9,198 'k Should- you- :have . any further questions,. please contact' l

. Mr,. M.~ H. '.Holmesfat (303) 480-696 J '

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Sincerely, i

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, R. O. Williams, J Senior Vice President,. .1 Nuclear Operations 4

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cc: . Regional Administrator, Region IV .i ATTN: Mr. T. F. Westerman, Chief M Projects Section B ..

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Mr. Robert-Farrell  ;

Senior Resident Inspector 1 Fort ~St. Vrai !,

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