ML20198D937

Forwards App R Evaluation Re Valve Position & Alignment,As Encl to Walker ,Per Request

ML20198D937
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/15/1986
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Berkow H Office of Nuclear Reactor Regulation
References
P-86370, TAC-54373, NUDOCS 8605270130
Download: ML20198D937 (4)

Text

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Public Service ~

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Companyof Colorado 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 May 15, 1986 Fort St. Vrain Unit No. 1 P-86370 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attn: Mr. H.N. Berkow, Director Standardization and Special Projects Directorate Docket No. 50-267

SUBJECT:

Appendix R Evaluation (Additional Information)

REFERENCE:

PSC Letter, Walker to Berkow dated 4-4-86 (P-86266)

Dear Mr. Berkow,

In response to a request by Mr. Heitner, PSC is submitting 40 copies of Attachment A to the letter referenced above.

The NRC evidently did not receive this attachment concerning valve position and alignment. Therefore, please include the enclosed Attachment A as part of letter P-86266.

Should you have any questions concerning this letter, please contact Mr. M.H. Holmes (303) 480-6960 for further informatitn.

Very truly yours,

,0.N TYbtn/nv7 D. W. Warembourg DWW:DG:jw Enclosure J

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ATTACHMENT A

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VALVE POSITION AND ALIGNMENT The following information is provided to supplement statements made in the December 20, 1985 letter to the NRC (P-85488), response to questions 2a/2b. A commitment for this follow-up was contained in the letter of March 14,1986 (P-86209). Valve alignment for manual valves is controlled at two levels. The first level includes those controls required to monitor realignments during plant operation. The second level controls system / valve alignment af ter plant outages or major maintenance.

Level I controls (plant procedure P-2) require the Shif t Supervisor to sign-off on all proposed volve realignments, using one of two valve / equipment tagging forms. These are the Standard Clearance Form and the Operations Deviation Form, controlled through SMAP-19. Procedures require use of the forms to change valve position / equipment status prior to and after maintenance / repairs, and for the volve to be appropriately tagged. Copies of issued forms are kept in the Shif t Supervisors office and the control room. Prior to close out of the form, an independent verification is performed by operations or other qualified individuals (e.g., health physics, etc.) independent of maintenance personnel.

Following satisfactory independent verification, Shift Supervisor approval is required for the clearance to acknowledge work completion and removal of status tags. Therefore, a system /volve which is not in its normal plant operating position is identified on the referenced forms, tagged, easily identified by plant operators, and controlled to assure it is restored to its proper position.

The second level of control is for major maintenance or outages. For this case, complete system alignment checks are performed in accordance with the plant standard operating procedures (SOP's). These alignment checks are performed prior to declaring that the system has been restored to " operable" status.

The above-are judged to be adequate to assure that volve position is properly controlled during and following maintenance activities, and is consistent with the DC-86-77 1

4 opprooch applied to other Ft. St. Vroin emergency procedures. Outoge times of systems are minimized in order to meet Technical Specification limits. Controls over non-Technical Specification systems / components will be incorporated in the Fire Protection Program Plan, Additionally, the fire protection shutdown model incorporates system monitoring instrurnentation so that proper system operation con be verified.

System verification was included (through reference to the oppropriate instrumentation) in the staffing assessment for local manual operations.

9 DC-86-77 2