ML20055D159
| ML20055D159 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/22/1990 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-90178, NUDOCS 9007050058 | |
| Download: ML20055D159 (6) | |
Text
O7 Public Service' 2"J." Abo P.O. Box B40 Denver CO 80201 Os40 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 A. Clegg Crawford V6ce President Nuclear operations 5
sune 22, 1990 Fort St. Vrain Unit No. 1 P-90178 V. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Docket No. 50-267
SUBJECT:
Fort St.
Vrain Updated FSAR, Appendix B,
10CFR50.54 Submittal
Dear Sirs:
Enclosed is a proposed change to the Updated Final Safety Analysis Report, Appendix B.
Public Service Company of Colorado (PSC) has determined that certain aspects of the proposal involve a potential reduction in commitment in the FSV Quality Assurance (QA) Program description as contained in the FSAR.
Specifically, these aspects are the use of controls other than the Change Notice System to implement modifications, such as cutting and capping of piping, in order to obtain positive equipment isolation. The other aspects of the change are within the frame work of the FSV QA Program and are provided for descriptive information only.
PSC has evaluated this proposed change and has determined that equivalent quality assurance controls are provided to satisfy the criteria of 10CFR50 Appendix B.
The reason for change and basis for our conclusion are also included.
In accordance with 10CFR50.54(a)(3), PSC is withholding this change from Appendix B pending NRC approval.
If you have any questions regarding i.his submittal, please contact Mr. M. H. Holmes at (303) 480-6960.
Very truly yours, 4t & h A. C. Craw rd Vice President Nuclear Operations
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Page 2 June 22, 1990
' Enclosure cc:
Regional Administrator, Region IV ATTN: Mr. J. B. Baird Technical Assistant Division of Reactor Projects Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain
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1 ENCLOSURE t
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Proposed FSAR Change
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Appendix B t
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1 UPDATED F3AR 1
Revision 7 B.5-19 B.S.3.2.
Desien Control Resoonsibilit,y All PSCo design actions are performed. within, and are the responsibility of, the Nuclear Engineering Division, and are governed Nuclear Engineering Division procedures.
Subcontracted design by tasks are authorized by procurement documents, in which requirements are included for compliance by the subcontractor, that are compatible with Nuclear Engineering Division procedures.
Procurement document reviews by the Quality Assurance Division assures the inclusion of appropriate design control and other appropriate quality provisions.
B.5.3.3.
Design Control System Y
All design modifications designated for permanent change to FSV and to be performed by PSCO are authorized and controlled by use of a Change-Notice system.
This system assures that required reviews and approvals are obtained prior to and on completion of the design task.
The Change Notice system includes provisions,to ensure that the required research is performed to identify applicable
- codes, standards, or other requirements and assure their inclusion in th6 generated design documents; that required design interface coordination and verifications occur; and that the required reviews and approvals are obtained prior to release and distribution of the M
Change Notice.
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Temporary design modifications or configurations to FSV are authorized and controlled by the use of the Temporary Configuration Report (TCR) system.
This system assures that engineering, EQ, QA, environmental and safety evaluations are conducted and management approvals are obtained prior to implementing the TCR.
TCRs shall be installed for no-longer than 90 days without prior review and approval by the Manager, Nuclear Production and Station Manager and by the Manager, Nuclear Engineering Division and no longer than 180 1 days without prior review and approval by the Senior Vice President' of Nuclear Operations.
Those temporary modifications or configurations to be made permanent are processed through the Change Notice system.
l Replacement of a component or part with a technically equivalent I component or part is permitted without a Change Notice, provided a l Technical Equivalency Assessment (TEA) has been performed, documented I and approved. A TEA shall not be used to make a design modification 3
l which would require a 10CFR50.59 safety evaluation or alter the i function, design intent or qualification (seismic, environmental) of I the affected system, component or part.
B.S.3,4.
Design control Procedures Nuclear Engineering Division Procedures prescribe in detail the methods and control measures to be applied to control of design modifications.
The Procedures include measures which provide assurance that:
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Equipment not required...fordefuelingactivities,asdefinedinlFSV Administrative Procedures, may'be placed "Out of Service" (005) in.
Le accordance with FSV standard equipment clearance procedures; u
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-In order to place-th'eLequipment in a long term 005 configuration, an 1
ij, Engineering = Evaluation,(EE) L and 10CFR50.59. safety evaluation is 100
' performed to categorize the equipment " Removed From Operational hl Service".(RF05)..
If long term physical'. isolation methods are required Lto obtain positive. equipment isolation-(e.g. ; installation of s
blind' flanges, cutting and capping of lines, determinating electrical.
leads), the activities'are' evaluated.in the EE and accomplished using 6'
~a Controlled Work' Procedure (CWP) in accordance' with FSV m
Administrative.
Procedures..
Plant status 'resulting ifrom RFOS activities'will be reflected on special handling documents and the f(
Plant Component. Data Base..
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Page-Affected i
-B.5-19,(Section B'5.3.3)-
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DESCRIPTION:-= Ado:
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Equipment: not required for.defueling activities, as defined in FSV-p, '
Administrative' Procedures, may be placed "Out of Service" (005) in J
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accordance 'with FSV standard equipnent clearance procedures.
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f In order to placelthe equipment in a long term 005 configuration.an.
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Engineering: Evaluation (EE).and-10CFR50.59 safety evaluation is E
-performed to-. categorize the equipment " Removed From. Operational.
P Service"-(RF05).
If long term physical isolation methods -are
[f required to obtain positive. equipment isolation (e.g. installation of i
blind flanges, cutting and capping of lines, determinating electrical
. leads), the activities are evaluated in the EE and accomplished'using V
a Controlled Work Procedure (CWP) in accordance with FSV
.i Administrative Procedures.
Plant status resulting from RF05 I
activities will be. reflected on special handling documents and the p
Plant Component Data Base.
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REASON:.
i The' reason for this change is to provide for minor modifications,
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,. requirements of.the Change Notice System. These~ modifications may be j
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required to.obtain positive equipment isolation on systems not i
I required.for defueling activities.
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This change will' not ; result in a reduction of PSC's commitment to
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10CFR50. Appendix B or the previously accepted QA Program description;
- This ; change deviates from the Change Notice System in that, instead
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. of a complex Change Notice Package, an Engineering Evaluation (EE) is
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prepared to facilitate.the design analysis, document statusing and
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- independent-review of the -modification.
Each of these EE's
-l associated with placing.a_ system or equipment in RF05 status receives
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ta 10CFR50.59 safety evaluation, and Plant Operations Review Committeet p
=(PORC) review.
The modification is~ then.- implemented 'with a f
Controlled Work-Procedure- (CWP) in accordance with standard -FSV
' Administrative Procedures.
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