ML20127C819

Amends 850418 Response to NRC Re Violations Noted in Insp Rept 50-267/84-30.Corrective Actions:Memo Issued to Personnel to Provide Interim Methodology Used in Applying QA Program to Security & Fire Protection

ML20127C819
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/07/1985
From:	Singleton L PUBLIC SERVICE CO. OF COLORADO
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20127C790	List: IR 05000267/1984030 ML20127C819
References
P-85157, NUDOCS 8506240016
Download: ML20127C819 (3)

Text

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Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 May 7, 1985 Fort St. Vrain Unit No. 1 P-85157 Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attn: Mr. E. H. Johnson Docket No. 50-267 3

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SUBJECT:

AMENDED RESPONSE TO I&E INSPECTION REPORT 84-30

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NAY I D E

REFERENCES:

1) NRC Letter, Johnson to i Lee, dated 03/22/85 I'.

d (G-85110)

2) PSC Letter Gahm to Johnson, dated 04/18/85 (P-85133)

Dear Mr. Johnson:

This letter provides an amended response to the Notice of Violation (50-267/8430-02) received as a result of inspections conducted at Fort St. Vrain during November and December, 1984,'and initially responded to in Reference 2).

In order to provide clarity, the amended respor.se is indicated by revision marks in the left margin of the letter.

Notice of Violation:

Failure to Document QA Program Title 10 Code of Federal Regulation Part 50, Appendix B, Criterion II, requires the licensee's quality assurance (QA) program to be documented by. written policies, procedures, or instructions.

8506240016 850612 hb PDR G

ADOCK 05000267 PDR

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Contrary to the above, the NRC inspector determined that applicable portions of the licensee's QA program, as defined in- their Final Safety Analysis-Report, Revision 2, for the Alternate Cooling Method (ACM) Equipment, the Fire Protection System, and the Plant Security

. System, were not documented by- written policies, procedures, or r

instructions.

This is a Severity Level IV Violation. (Supplement I.D.)

(50-267/8430-02). ,,

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

1 A memo has been issued to all Quality Assurance, Nuclear i Engineering, Nuclear Production, and Nuclear Licensing Personnel t 'l 'to provide the interim methodology to be used in applying the QA I Program to ACM, Security and Fire Protection until the Change l Notices addressing these three areas are. issued, approved and-l implemented, and attendant procedures are revised and effective.

l The provisions of this memo-became effective May 6, 1985.

l The instructions for treatment.of these systems are provided in '

I accordance with the Table listed below,= and will remain in effect .

until the appropriate provisions.are addressed in Administrative l

1 l Procedure Q-2, Quality Assurance' Prciaram. At 'that time, the 4

l contents of this memo shall be superseded.

e I oC SSR INSPECTION 1.D.V. SElSMIC l REQUIRED QUALIFIED ENVIRONMENTAL SAFETY REQUIRED SYSTEM CLASSIFICATION RELATED (1) (2) PROCUR[ MENT VENooR QUALIFICATION

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Safety Related Yes Yes Yes N-o rde r Yes No l AcM Non Sarety ReIated No Yes Yes N-O rde r No No

-l Security Non Safety Related No Yes Yes N-orde r No No f l Fire (3) (3) l Protection (3) (3) f i

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4 l (1) Inspection required by BTP 9 5-1 and QA plan for security.

l (2) Independent Design Verification on all cN's and DR's affecting equipment in these systems.

-l (3) Except existing class # 4 (safety related) portions.

l Definitive results of this measure cannot be-quantified due to l the time element involved with its implementation, and processing

-l of this amended response.

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

NED will develop three change notices (CN's).

CN-1962 will address the ACM System, and will be issued by NED in October, 1985.

CN-1963 will address the Fire Protection System, and will be issued by NED in August, 1985.

CN-1964 will address the Security System, and will be issued by NED in September, 1985.

The three CN's will establish the following:

a) Incorporation of ACM components into the plant component data base as safety-related items.

b) Creation of an identifier in the plant component data base to identify fire protection (other than existing safety-related fire protection components) and Security components.

Administrative Procedure Q-2 will be revised as required to reflect the contents of the three CN's.

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

Full compliance will be achieved by January 15, 1986 based on issuance, approval, and implementation of the provisions of the three Change Notices and attendant Administrative Procedures.

If you have any further questions, please contact Mr. M. H. Holmes (303) 571-8409.

Sincerely,). /

. YWMy L. W. Singlet 6a)

Manager, Quality Assurance Fort St. Vrain Nuclear tienerating Station LWS:MJF/cim

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