ML20136J118

Forwards Description of Changes to Rev 3 to App B to Updated Fsar,Per 851216 Telcon.Changes Do Not Involve Reduction in QA Commitments.Conflict in FSAR or Organization Changes & Existing Tech Specs Will Be Resolved

ML20136J118
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/31/1985
From:	Singleton L PUBLIC SERVICE CO. OF COLORADO
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-85494, NUDOCS 8601130210
Download: ML20136J118 (8)

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!g i R - 31986 December 31, 1985 Fort St. Vrain

,> Unit No. 1 P-85494 Regional Administrator Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attn: Mr. Eric H. Johnson Docket No. 50-267

SUBJECT:

Updated FSAR Appendix B, Rev. 3

Dear Mr. Johnson:

As requested by Mr. John Boardman in a telephone conference with members of our staff December 16, 1985, please find enclosed a oescription of changes made to Appendix B of the Fort St. Vrain Updated FSAR per Revision 3.

PSC has determined that none of these changes involve a reduction in Quality Assurance commitments. The attachment to this letter provides justification supporting this conclusion.

Section B.5.1 and Figures B.5-1 and B.5-2 reflect the current Fort St. Vrain Organization and conflict with the existing Technical Specifications, which are currently being upgraded. PSC submitted proposed changes to the Administrative Controls Section of the FSV Technical Specifications per a letter dated June 10, 1985, Lee to Johnson,(P-85155). These proposed changes are in agreement with FSAR, Appendix B organization revisions, with the exception that FSAR Figure B.5-1 references the Manager, Production Services Division as reporting to the Vice President, Electric Production. This has since been changed by the creation of a new management position, General Manager, Fossil Production which now reports to the Vice President, Electric Production. This discrepancy will be revised in Revision 4 to the FSAR, due to the NRC July 22, 1986. No other conflicts with the Technical Specifications were noted.

8601130210 851231 g[ DR ADOCK 050 27

-g-If you have any questions please call Mr. Mike Holmes at (303) 480-6960.

Sincerely, A( f' W & f* & Y' L. W. Singleton LWS:PFM/cim

-Attachment

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Page 1 of 6 DESCRIPTION OF CHANGES TO APPENDIX B 0F THE UPDATED FSAR (REVISION.3)

Table of Contents App'endix B List of Tables

' Appendix B List of Figures All three of the above were revised to indicate those sections, tables, and figures that were revised with Rev. 3. (NOTE: No changes. were made to Table B.5-2. However, it was submitted on the backside of Table 8.5 and, therefore, reflects Revision 3).

B.5 Quality Assurance Program for Plant Operation Added " Licensing and Fuel" to last paragraph page'B 5-1. New division within PSCo -- no reduction in QA program commitments.

.Added Ref. 24 to last paragraph in section B.S. No reduction in '

QA' program commitments. -

B.S.1 Organization Extensively revised organization description to include the new Nuclear Licensing and Fuels Division, addition of all supervisors within the Nuclear organizations and the addition or' transfer of responsibilities within the division as a result of reorganization.

Key revisions include' transfer of Maintenance Quality Control responsibilities to QA Services (formerly under

. Nuclear Production) and transfer of the records system to Nuclear Engineering (formerly under QA Services).

These revisions are the result of PSC reorganization and do not represent a reduction in QA program commitments.

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Page 2 of 6 B.5.2.1 Program Description ~

Deleted Table 1.4-3. To eliminate redundancy, this table was incorporated into tables 1.4-1 and 1.4-2. No reduction to QA program commitments.

Deleted Alternate Cooling Method (ACM) from second paragraph. This was moved to section B.S.2.7 since its classification was. upgraded to. safety related. -

Deleted exception of routine maintenance from last paragraph and indicated that the Saintenance QC group now reports to the QA -Services Manager. These changes represent an increase in QA program commitments.

B.5.2.7- FSV Safety-Related Items Deleted Table 1.4-3 from a) and b). As stated before, this table was incorporated into tables 1.4-1 and 1.4-2.

No reduction to QA program commitments.

Added Alternate Cooling Method (ACM) equipment. No reduction in QA Program commitments.

B.5.3.3 Design Control System Changed "All design tasks for FSV" to "All design modifications designated for permanent change to FSV".

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.This- change eliminates confusion when temporary modifications are required which do not require the full change notice procedure. No reduction in QA Program commitments.

B.S.3.4 Design Control Procedure e) Revised information concerning the control of performance test programs to ensure that the testing includes actual normal operation as well as the " worst possible case" conditions. No reduction in QA Program commitments.

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m Page 3 of 6 g) Revised information concerning the review and approval of certain safety related and non-safety related changes.

This change ensures that safety related design changes, as well as non-safety related security and fire protection design changes, receive an adequate review by personnel with sufficient technical knowledge. This is an increase in QA Program commitments.

1) Revised information to delineate the type of projects requiring environmental evaluation. No reduction in QA Program commitments.

B.5.3.6 Design Quality Assurance Provisions Added " safety related" and referenced non-safety related design documents associated with the security and fire protection systems.

This change clarifies the necessity for acceptance criteria on safety related and certain non-safety related design documents. Sections B.1 and B.5 identify that the QA Program applies to safety related portions of the plant. No reduction in QA Program commitments.

B.5.3.7 Design Document Changes Added " permanent".

This change eliminates confusion when temporary changes are required which do not require the full Change Notice procedure. No reduction in QA Program commitments.

B.5.3.8 Materials, Parts and Component Selections Added " safety related".

This change clarifies the requirement for safety related material, parts, and component selection. No reduction in QA Program commitments since the primary purpose of the QA Program is to apply controls to safety related portions of the plant, per Section B.1 and B.S.

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- B.5.4.3 Purchase Order-Review

. Changed '"The final Purchase Order fs" to " Safety related

' Purchase Orders are".

This change clarifies the requirement for review and approval of. safety related purchase orders by the Quality Assurance. Division. No reduction -in QA Program commitments since the. QA Program applies to safety related portions ofs the plant.

B.S.4.4 Purchase Order Changes B.5.5.2 Work Control Procedures B.5.8.2. Modification and Replacement Items Added " safety related" to all three sections.

These changes clarify the scope of the affected

-paragraphs. Sections B.1 and B.5 identify that the QA Program' applies to safety related portions of the plant.

No reduction in QA Program commitments.

B.S.10.1 Maintenance Inspections Indicated -that Maintenance Quality Control-personnel now .

report to the QA Services Manager. This is the result of reorganization and is an increase in QA program commitments.

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B.5.10.2 Inspections Other than Maintenance Indicated that the QA/QC unit of the QA Division performs inspections other than maintenance type inspections.

With the addition of Maintenance QC to the QA Division, it was necessary to make this distinction. No reduction in.the QA program commitments.

B.S.14.3 Procedure Requirements for Operational Items

-Deleted MQC from second paragraph. MQC is now part of QA Division. No reduction in the QA program commitments.

B.5.16.1 FSV Corrective Action Systems

'Added " corrective" and " CAR". The CAR form is now a unique form. No reduction in the QA program commitments.

Page 5 of 6 8.5.16.2 Quality Trends Analysis and Reporting Same as B.5.16.1.

• B.5.16.3 Reporting Changed Plant Trouble Reports (PTR) to Station Service Requests (SSR). A computerized SSR system replaced the PTR system. No reduction in the QA program commitments.

8.5.19.1 b) Specific Exceptions P

Inspection (Section 11)

Changed " Plant" to "QA" in first sentence. MQC personnel are now in QA. No reduction in QA program commitments.

Changed "QA Division" to "QA/QC" in second sentence to properly designate those personnel involved with welding and nondestructive testing. No reduction in QA program commitments.

B.S.19.7 ANSI N45.2.6-1973 Last paragraph (page B.5-43) - editorial change, added dash between TC and 1A. No reduction in QA program commitments.

Table B.5-1 Policies and Guidelines

18. Changed Drug / Alcohol Abuse Policy to Fitness for Outy Policy. Policy was revised to include mental and physical impairments. No reduction in QA program commitments.

Table B.5-3 (Page 1)

Revised First Level-Inspection to reflect transfer of Maintenance Quality Control activities to QA Division.

This is an increase in QA program commitments.

Table 8.5-3 (Page 2)

No changes were made. Bar mark added in error, i

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e Page 6 of 6 Figure B.5-1 Revised to reflect current organization. No reduction in QA program commitments.

Figure B.5-2 Revised to reflect current organization. No reduction in QA program commitments.

Figure B.5-3 Revised to reflect organizational changes and procedural responsibilities.

Radiation Protection Department is now Support Services Department. Record Center is now under Nuclear Engineering Division. Water Chemistry is now under Support Services Department. MQC is now under Quality Assurance.

The transfer of Records Center to Nuclear Engineering Division will serve to strengthen the QA program as it provides QA the necessary independence in conducting audits.

No reduction in QA program commitments.

B.6 References for Appendix B Editorial changes to provide consistency in formatting.

Reference #24 added. No reduction in QA program commitments.

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