ML20137S720
| ML20137S720 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 09/23/1985 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-85336, NUDOCS 8509300485 | |
| Download: ML20137S720 (3) | |
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Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 32@M0VM )
September 23, 1985 H
SFP 2 51985 Fort St. Vrain Unit No. 1 P-85336
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i Regional Administrator Region IV U. S. Nuclear Regulatory Conmission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Attn: Mr. R. D. Martin Docket No. 50-267
SUBJECT:
Independent Verification
REFERENCE:
- 1) G-85195, letter dated May 22, 1985, Johnson to Lee
- 2) P-85178, letter dated May 22, 1985, Gahm to Martin
- 3) G-84392, Assessment
. Report, October 16, 1984, Denton to Walker
Dear Mr. Martin:
By way of Reference 1, the Nuclear Regulatory Commission requested Public Service Company of Colorado to re-evaluate the Fort St.
Vrain
' program for double verification of system or equipment status, particularly in connection with maintenance activities.
Reference 2 (same date as Reference 1) provided an overview of the anticipated program for double verification to be undertaken as part of the Nuclear Performance Enhancement Program (NPEP) at Fort St. Vrain. We have completed our re-evaluation as requested. This letter provides the current status of our efforts.
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Administrative Procedure P-1, Plant Operations, has been completely Oj rewritten, approved and issued.
With 'regards to the independent
)jg d0 verification questions, Station Manager Administrative Procedure Six 0
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3 (SMAP-6), which supports APM P-1, requires the independent review and development of a safety evaluation for all setpoint changes.
Additionally, changes to. the Alarm Index which are affected by l
setpoint changes are independently verified.
Ll' A second. procedure, SHAP-18,. requires 'that the installation and removal of all temporary configurations are independently verified upon issuance and return.
Administrative Procedure P-2, Equipment Clearances and Operation j
Deviations, has been completely rewritten, approved, and i ssued.
-With regards to the independent' verification question, supporting procedure.SMAP-19 has been issued. This procedure requires that all t
equipment ' clearances and all Operations Deviations are independently verified upon issuance and return.
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- All. of the above procedural controls are issued and in place. These procedural controls address the vast majority of situations for which our re-evaluation has determined that independent verification is i
i prudent. Two other area's for_ which we are in the process of incorporating independent verifications are the Results Procedures and system valve line-ups.
For the Results Procedures, which deal with calibration and-i maintenance of instruments, we have determined that additional j
controls beyond those. required for equipment clearances are prudent.
2 Consequently, administrative procedure RPA-01 has been developed and i
is being - used as the basis for the independent verification for i
calibration and. maintenance of-instruments.
The rewrite of-the Results Procedures is addressing these requirements and will be completed in accordance with the NPEP.
j For ~ system valve line-ups, we have d afted the necessary forms to ensure a completely independent system _line-up to be performed at the discretion of the Superintendent of Operations. As-you' are aware we are rewriting our System Operating Procedures per the NPED o
'ule.
- Obviously, _ system valve line-ups are an integral part of u... effort.
j Therefore, we intend to implement _'the' valve 'line-up forms on an
- interim, basis until formal issuance of the System Operating l
Procedures.
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% We beliese that our re-evaluation of the ir. dependent verification issue has'resulted in a comprehensive p rog re.m.
If you have any questions in this regard, please contact Mr. Mike Holmes at (303) 571-7511.
Sincerely, (Yf" J.'W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG:CHF/djc i
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