ML20070A873

Provides Position Re Continued Application of QA to Components Which Have Been Permanently Removed from Operational Svc,Per

ML20070A873
Person / Time
Site:	Fort Saint Vrain
Issue date:	01/21/1991
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-91009, NUDOCS 9101290088
Download: ML20070A873 (2)

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Denner CO fo20b 0040 January 21, 1991 Fort St. Vrain Unit No. 1 A. Clogg Crawford P-91009 U " ff i,n, U. S. Nuclear Regulatory Cortnission Document CLrtrol Desk 4

Washington, D. C.

20555 Docket No. 50-267 SUDJIrrt Application of Quality Assuranco Requirements to corponents Permanently Removed Frcrn Operational Service RFJ7EENCE PSC Irtter, Crawford to Weiss, dated August 16, 1989 (P-89287)

Gentlement The purpoco of this letter is to provide Public Service Carpany of Colorado's (PSC's) position regarding the continued application of Quality Assurance to cmponents which have bocn permanently removed frm operational service.

As you are aware, Fort St. Vrain (PSV) is permanently shutdcwn and is in the proccas of a lengthy defueling.

As irdic tod by the Defueling Safety Analysis Report (the referenco letter), systems and equipment relied on to prevent or mitigate postulated accidents durirg the defueling period are significantly reduced from thoco naw=ry for nuclear safety when the reactor was operating.

Defueling Administrative Prc.codures have bocn developed to control downgrading of selected systems frm an cperable status to a Removed from Operational Service (RFOS) status.

These procodures assure that no systems or equipnent which may nood to be relied on to prevent or mitigate the consequences cf accidents postulated to occur during defuelirg are removed frm service.

Before a system or equipnent item can bo placed in a RTOS status, the Defueling Administrative Procedures require pMparation of an Erginocring Evaluation, a 10 CFR 50.59 Safety Evaluation and review and approval by the Plant Operations Review committec.

This ensures that systems and equipment whose continued operability is required by-PSV 1bchnical Specifications ard Defueling Administrative Proceduros will be capable of effcctively performing their safety functions in the event of postulated defueling i

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i P-91009 Page 2 January 21, 1991 PSC considers that quality assurarce activities are no lorger i

required for systems which are historically safety-related but would rot be called upon to perform any safety functions during the defueling period, ard whicts have been remved frca operational service.

Since their safety-related functions are rot required durirg defueling, PSC considers that the 10 CPR 50 Appendix B requirements are no lorger applicable to these items.

At present, PSC has been applying quality assurance to th> RFOS systems ard equignent, but has concluded that application of quality assurance measures on RFOS systems and eq.11;nent is no longer required nor beneficial.

It is PSC's intention to cease quality assurance measures on RFOS systems ard equipennt on February 25, 1991.

Should you have any questions concernirg this matter, please contact Mr. M. H. Holmes at (303) 480-6960.

Very truly yours,

&6h A. C. Crawfod Vice President, Nuclear Operations ACC/ DOG:geb oc: Regional Administrator, Region IV ATIN: Mr. G. L. Constable Chief

'Ibchnical Support Section Division of Reactor Projects Mr. J. B. Bald Senior Resident Inspector Fort St. Vrain

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