ML20207J889

Submits Addl Info Re Performance Enhancement Program Finding 4-10 Concerning Functional Acceptability of Equipment Being Returned to Svc,Per 860611 Request.Controls Verifying Functional Acceptability of Equipment Discussed

ML20207J889
Person / Time
Site:	Fort Saint Vrain
Issue date:	07/23/1986
From:	Gahm J PUBLIC SERVICE CO. OF COLORADO
To:	Heitner K Office of Nuclear Reactor Regulation
References
P-86480, TAC-62169, NUDOCS 8607290284
Download: ML20207J889 (3)

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Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 30651 July 23, 1986 Fort St. Vrain Unit No. 1 P-86480 Director of Nuclear Reactor Regulation Attn: Mr. Kenneth L. Heitner, Project Manager Standardization and Special Projects Director U. S. Nuclear Regulatory Commission Washington, DC 20555 Docket No. 50-267

SUBJECT:

NRC Review of the Public Service Company of Colorado Performance Enhancement Program, Finding 4-10

REFERENCE:

NRC Letter, Heitner to Walker, dated 06/11/86 (G-86304)

Dear Mr. Heitner:

By the referenced letter, additional information was requested concerning the functional acceptability of equipment being returned to service (Finding 4-10). The following response is hereby submitted.

Controls exist at Fort St. Vrain which verify that the functional acceptability of equipment being returned to service will be checked.

The checks are verified by the Shift Supervisor regardless of the reason the equipment was removed from service.

Equipment may be removed from service for one of four reasons:

surveillance testing, plant maintenance, modification installation, or special testing. Activities which require the removal of equipment from service will accomplish the removal, the activity, the required testing and the return to service via established written instructions. Those specific instructions are performed in accordance with appropriate administrative procedures. Implementing procedures have provisions which serve to identify the need and scope of testing, cause specific checks to be developed in written form, implement performance of the required checks, and notify appropriate 00[

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P-86480 July 23, 1986 supervisory personnel of test completion prior to returning equipment to service.

Surveillance tests are administered and performed in accordance with two Station Manager Administrative Procedures (SMAP's). The procedures are SMAP-1, " Technical Specifications Surveillance Testing Program" and SMAP-2, "Non-Technical Specifications Surveillance Testing Program." Specific written procedures are developed and maintained to accomplish surveillance testing requirements. These procedures incorporate steps which have the specific purpose of verifying the functional acceptability of that equipment. The governing procedures and individual Surveillance Tests have provisions for notifying appropriate personnel, including the Shift Supervisor, of test results. The Shift Supervisor is assigned specific responsibilities for taking necessary actions in accordance with the Technical Specifications and with respect to test results.

Maintenance activities at Fort St. Vrain are governed by Administrative Procedure P-7, " Station Service Request Processing."

This procedure includes provisions for identifying, implementing and documenting post-maintenance test activities for each maintenance item. Specific written instructions, used to verify equipment operability following maintenance, are developed in accordance with SMAP-23, " Post Maintenance Testing Implementation." P-7 and specific Post-Maintenance Tests (PMTs) have provisions for notifying the Shift Supervisor of test completion. The Shift Supervisor is assigned specific responsibilities for acknowledging test results and assessing the impact of maintenance work on Technical Specification compliance, plant operations and safety.

The requirements for the development of procedures to control modification installation and selected non-routine maintenance work are described in Administrative Procedure G-9, " Controlled Work Procedures." The specific written instructions which are prepared to meet the requirements of G-9 are governed by Administrative Procedure Q-11. " Test Control". Two procedural mechanisms are used to fulfill the requirements of the governing procedures; Functional Tests (FTs) and Cold Checkout Tests (CCTs). G-9, Q-11, FT's and CCT's all have provisions for notifying the Shift Supervisor of test completion and results. The Shift Supervisor is assigned specific responsibilities prior to returning equipment to service.

Special Tests (T-Tests) are generally used to perform a failure analysis to determine the cause of a failure, to determine the extent of performance deterioration of in-service equipment or components, or for data collection / analysis. T-Test preparation is in accordance with Q-11, and the same controls exist as described above.

. 1 l P-86480

.; July 23,1986 I The system of administrative controls and implementing procedures in use at Fort St. Vrain represent an effective method for confirming

, that the functional acceptability of equipment is checked prior to returning the equipment to service. Should you have any further questions, please contact Mr. Michael Holmes, (303) 480-6960.

Sincerely, 1

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/J.W.Gahm Manager, Nuclear Production

fort St. Vrain Nuclear Generating Station JWG

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