ML20210E300

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Revised Administration Procedures Consisting of Issue 7 to G-3, Action Request-Preparation & Processing, Issue 21 to G-2, Fort St Vrain Procedure Sys & Issue 6 to G-6, Compliance w/10CFR21 Requirements
ML20210E300
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 02/03/1987
From: Gahm J
PUBLIC SERVICE CO. OF COLORADO
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-87051, PROC-870203, NUDOCS 8702100273
Download: ML20210E300 (110)


Text

{{#Wiki_filter:__ - _-_ _ _ _ _ _ l G-3 Issue 7 FORT ST. VRAIN NUCLEAR GENERATING STATION Page 1 of 16 0Public Service

  • PusuC SERVICE COMPANY OF COLORADO TITLE: ACTION REQUEST-PREPARATION AND PROCESSING PONSIBLE
       ;"" "'"                     AuxsA?h2"i a rr 'imwut'P PORC                   /                                                                                 EFWECTIVE       I REVIEW v

PORC 7 0 9 JAN 2 01987 DATE /'A7'87

              ,JBER (S)               87-012 O
                                                                                                                                     \

O 8702100273 870203 PDR ADOCK 050002 P PD FORM (D)772 22 3M2

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G-3 FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 Page 2 of 16 m O Public service

  • PUBLIC SERVICE COMPANY OF COLORADO ,

U TABLE OF CONTENTS Section Title Page 1.0 PURP0SE...................................................... 3 2.0 AP P LI CAB I LI TY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.0 GENERAL REQUIREMENTS ........................................ 3 4.0 PR0CEDURE.................................................... 5 4.1 Design Change Action Requests (DCARs).................. 5 4.2 Procedure Change Action Requests (PCARs) . . . . . . . . . . . . . . 8 4.3 Test Requests (TRs).................................... 10 4.4 General Services Action Requests (GSARs) . . . . . . . . . . . . . . 12

5.0 REFERENCES

.................................................. 14 6.0     ATTACHMENTS.................................................. 14 6.1    G-3A, Action Request              Form.............................. 15 6.2    G-3B, Action Request Di stribution. . . . . . . . . . . . . . . . . . . . . . 16 l        7.0     COMMITMENTS.................................................. 14 l

i t N FoRMtC)372 22 3643 l l l l .A

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 "9" 0 Service" PUBUC SERVICE COMPANY OF COLORADO O

 .O 1.0 PURPOSE l        This procedure describes the preparation and processing of l        Action Requests (ARs). Action Requests provide a formal means l        to request action between Nuclear Divisions. Action within l        divisions is generally controlled administratively.

2.0 APPLICABILITY l This procedure applies to inter-unit, department or division l requests for services. Specific requests include: 2.1 Design Change (DCs) l 2.2 ProcedureChange(PCs) l 2.3 Test Request (TRs) 2.4 General Service (GSs) 3.0 GENERAL REQUIREMENTS l 3.1 Descriptions of ARs (~% Q l l 3.1.1 DCAR - A Design Change Action Request formally requests a design change to resolve an identified l design problem. DCARs are controlled to receive l Work Review Committee (WRC) and Station Manager approval, and are commonly submitted to Nuclear Engineering Division. 3.1.2 PCAR - A Procedure Change Action Request formally requests a procedure change based upon an identified need by a person outside the organization responsible for the procedure. 3.1.3 TRAR - A Test Request Action Request formally requests a test, commonly in the form of.a T-test. Test requests are commonly submitted to Nuclear Betterment (Results) Engineering and may come from other Production Division personnel. 3.1.4 GSAR - A General Service Action Request formally requests a service or review between Nuclear Divisions. Special types of service requests ! include (1) vendor document review and inclusion l into design documentation, (2) review of other relevant information for inclusion into design documentation, (3) OIAG reviews for applicability, ! (4) requests for engineering reviews of I recommendations, and (5) other requests for services requiring formal documentation. FonMIC1372-22 3643

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7

                                                                               #9'          U 0 SerVIC9" PUBUC SERVICE COMPANY OF COLCRADO                                              ,

q O 3.2 Program Description (All ARs) 3.2.1 Any individual may originate an AR. The individual's Supervisor initiates formal tracking by approving the AR and obtaining an AR number. l 3.2.2 QA action to track and control ARs in this procedure is performed by the QA Computer Specialist, or designee. l 3.2.3 A unique number for each AR is obtained from QA. The requestor will furnish QA with a brief description of the AR and the department which will receive the AR. l 3.2.4 The receiving organization responds to the AR with a recommendathn, response, and/or disposition as appropriate. If the disposition involves followup action, the followup disposition is not signed until the followup action control is initiated (e.g., a CN, CWP or DCCF number has been assigned for followup). m l 3.2.5 The originating organization accepts the (j disposition, and the AR is closed out. Dispositions not accepted by the originating organization are resolved by management for re-disposition, if necessary, and closure. l 3.2.6 Where AR form entries are not. referenced by Section 4.0 (for the AR type as identified in Section 2.0), those entries shall be considered for information only or controlled by other procedures or administrative policies. i l 3.2.7 QA will maintain an AR file and generate periodic reports for control and followup; the file will be maintained up-to-date with hard copies for open ARs. QA updates the Status-keeping System and l transmits completed (dispositioned and accepted) ARs to Records Storage. l l 3.2.8 AR Priorities are established in accordance with l Nuclear Policies and Guidelines 25, Prioritizing l Work for Nuclear Organization Policy. FORMIC 1372 22 3643 I

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G-3 Issue 7 Public FORT ST. VRAIN NUCLEAR GENERATING STATION 0 Service" PUBUC SERVICE COMPANY OF COLORADO E o 4.0 PROCEDURE 4.1 DESIGN CHANGE ACTION REQUESTS (DCARs) RESPONSIBILITY ACTION REQUESTOR CAUTION: Any approval stage requires a copy sent to the QA l Computer Specialist for tracking. These are indicated with "'s. Rejections, likewise, require l a copy sent to the QA Computer Specialist. These are indicated with #'s below.

1. Identifies plant modification need.
2. Enters a clear description of the request. Lists any attachments or references.
3. Enters justification, including a cost benefit analysis for non-regulatory

'( required DCARs.

4. Signe, datas, and checks "DC".
5. Forwards DCAR to supervisor.

REQUESTOR'S SUPERVISOR

6. Reviews DCAR for appropriateness.

a) Rejected DCARs are returned to the originator with a written explanation for rejections b) Approved DCARs continue through the review process below.

8. Enters signature and date of approval.
9. Enters letters of responsible division, department, or unit.
                                                            *10. Enters the serial number obtained from QA, and date.

O FORMtC)372 22 3643

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7

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0SerVlCe* PUBUC SERVICE COMPANY OF COLORADO , U

11. Forwards original to Plant Engineering for Work Review Committee and a copy to QA for tracking.

WORK REVIEW COMMITTEE (WRC)/ WRC DESIGNEE

12. Evaluates the DCAR.
                              *13. Makes recommendations resulting from evaluation, prioritizes (per NPG 25),

signs and dates.

14. Coordinates plant management approval.

PLANT MANAGE *4ENT

15. If approved appropriate manager signs and ,

dates, enters budgetary source (if applicable), and reviews recommended priority code or target date and changes or approves. Enters name of receiving. organization, and manager.

                               *16. Forwards approved original to appropriate organization manager and copies to the requestor's supervisor and QA.
17. If not approved, appropriate manager enters " CANCELLED, basis for cancellation and initials, and signs and dates to indicate rejection.
                               #18. Forwards cancelled original to QA and a copy t'o the requestor's supervisor.

. ENGINEERING ' j ORGANIZATION

19. Evaluates the DCAR and preoares the engineering response, inciteding preliminary design documentation, cost
  • l estimate, and other documents, j
20. If desired, returns a copy of the initial response to the WRC while pursuing followup action completion.
                               *21. Obtains followup safety evaluation f' rom Nuclear Licensing and Fuels and attaches.
22. Er.ters budgetary source (if applicable),

disposition summary, and estimated cost. FORM (C)372 22 3643

G-3 FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 0Public service

  • PUBUC SERVICE COMPANY OF COLORADO 9
23. Preoarer signs and dates.
24. Approver signs anc' dates, and
                        *25. Forwards original DCAR and Engineering Response to Plant Engineering for WRC review and a copy of DCAR Coversheet to QA.

WORK REVIEW COMMITTEE (WRC)

26. Reviews responses.
                         *27. Resolves questions with preparing organizations. Accepts or rejects response.

1

                        #28. Returns rejected response to preparing organization manager if rejection is final.
29. Determines Technical Specification change -

need.

30. Enters cost adjustment for license amendment fee, if required, reviews and updates the priority.
31. Signs and dates.
32. Coordinates plant management approval.

PLANT MANAGEMENT

                         *33. If approved, appropriate manager signs l                                and dates.

1 a) To indicate rejection of DCAR response, appropriate manager identifies the DCAR rejected, attaches the basis for rejection, and initials, underneath the basis ' ! (or on a separate sheet), signs and dates (the DCAR).

                               #b)     If DCAR is rejected, forwards original to the QA Computer Specialist, a copy to the requestor's supervisor, and a copy to the engineering organization approver.

FORMt0372 22 3643 l l . . . _ . . _ _ . , - . . _ . _ - . _ _ , -__ . . _ _ . _ _ _ _ . _ .

G-3 Issue 7 Public FORT ST. VRAIN NUCLEAR GENERATING STATION

                                                                                                                            #9' U 0 service
  • PUBUC SERVICE COMPANY OF COLORADO r

i WORK REVIEW COMMITTEE (WRC)

34. If approved, but PORC and/or NFSC review is required, obtains approval to proceed while reviews are being performed or places DCAR on hold according to plant management direction.
35. (PORC and NFSC review and approve, if required).
36. Forwards original of approved DCAR to QA, and copies to the engineering organization approver and the requestor's supervisor.

ENGINEERING ORGANIZATION

37. Upon receipt of the approved DCAR copy, initiates CN preparation.

4.2 PROCEDURE CHANGE ACTION REQUESTS (PCARs) p RESP 0NSIBILITY ACTION Q REQUESTOR CAUTION: Any approval stage requires a copy sent to the QA l Computer Specialist for tracking. These are indicated with *'s. Rejections, likewise, require l a copy sent to the QA Computer Specialist. These are indicated with #'s below. NOTE: PCARs are not usually used within a division.

1. Identifies procedure change need i (revision, initiation, or cancellation).
2. Enters a clear description of the exact wording or modification required.

(Marked up copy may be used and attached.)

3. Enters justification.
4. Signs, dates, and checks "PC".
5. Forwards PCAR to supervisor.

FORM (C)372 22 3643

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G-3 FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 0PublicSerVlC9" PUBLIC SERVICE COMPANY OF COLORADO #9' n U ' REQUESTOR'S SUPERVISOR

6. Reviews PCAR for appropriateness.

a) Rejected PCARs are returned to the originator with a written explanation for rejection. b) Approved PCARs continue through the review process below.

7. Enters signature and date of approval.
8. Enters letters of responsible division, department, or unit, and priority if known.
9. Enters the serial number obtained from QA, and date.
                                      *10. Forwards PCAR to superintendent / manager and a copy to QA for tracking.

p SUPERINTENDENT / ' Q MANAGER

                                      "#11. Reviews PCAR and approves or rejects.

Forwards to assigned organization superintendent / manager as appropriate. RESPONSIBLE DEPARTMENT

                                      *#12. Dispositions request. Describes changes to be made, estimated completion date, or
the rsason(s) for dental.
13. Preparer signs and dates.
                                      *14. Approver signs and dates and returns a l

copy to initiating organization and a copy to QA.

15. Initiates a DCCF as followup if change is l

required. Enters DCCF number assigned.

16. Preparer signs and dates followup.
17. Approver signs and dates followup.
                                      *18. Forwards original of PCAR to the requestor's manager / superintendent, and a copy to QA.

l FORM (Cl372 22 3643

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 0 SerVIC9" PUBLIC SERVICE COMPANY OF COLORADO 9' (} V

 .      INITIATING ORGANIZATION
                                    *#19. Acknowledges disposition, accepts / rejects and transmits completed PCAR to QA or rejected response to the dispositioning organization to resolve.

4.3 TEST REQUESTS (TRs) RESPONSIBILITY ACTION REQUESTOR NOTE: TRs are generally requested of other units or departments than the originator's. CAUTION: Any approval stage requires a copy sent to the QA l Computer Specialist for tracking. These are indicated with *'s. Rejections, likewise, require l a copy sent to the QA Computer Specialist. These are indicated with #'s below. V 1. Identifies a specific test requirement.

2. Enters a clear description of test proposal, the purpose and the expected results.
3. Enters justification.
4. Signs, dates, and checks "TR".
5. Fon/ards TR to supervisor.

REQUEST 0R'S SUPERVISOR i 6. Reviews TR for appropriateness. a) Rejected TRs are returned to the originator with a written explanation for rejection. b) Approved TRs continue through the review process below.

7. Enters signature and date of approval.

O 1 FORMtC1372 22 3643

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7

                                                                                                               #9' 0 $9tVIC9                              PUBUC SERVICE COMPANY OF COLOR /' DO 7's (U  I
8. Enters letters of responsible division, department, or unit and priority, if known.
9. Enters the serial number obtained from QA, and date.
                                                      *10. Forwards TR to superintendent / manager and a copy to QA for tracking.

SUPERINTENDENT / MANAGF.R

                                                      *#11. Reviews TR and approves or rejects.

Forwards to the assigned organization superintendent / manager as appropriate. RESPONSIBLE DEPARTMENT

                                                      *#12. Dispositions request. Describes action to be taken, estimated completion date, or reasons for denial.
13. Preparer signs and dates.
                                                      *14. Approver signs and dates and returns a copy to the initiating organization and a copy to QA.
15. Initiates a Test Request as followup.

Enters test number assigned.

16. Preparer signs and dates followup.
17. Approver signs and dates followup.
                                                      *18.      Forwards original to requestor's manager / superintendent, and a copy to QA.

INITIATING ORGANIZATION

                                                     *#19   . Acknowledges disposition, accepts / rejects and transmits completed TR to QA or rejected response to the dispositioning organization to resolve.

I i l O l FORM (C1372-22 3643

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G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 0 service

  • PUBLIC SERVICE COMPANY OF COLORADO O' n

4.4 GENERAL SERVICES ACTION REQUES75 (GSARs) RESPONSIBILITY ACTION l REQUESTOR NOTE: GSARs are usually requested of other departments, or divisions than the originator's. CAUTION: Any approval stage rquires a copy sent to the QA l Computer Specialist for tracking. These are indicated with *'s. Rejections, likewise, require l a copy sent to the QA Computer Specialist. These are indicated with #'s below.

1. Identifies general services or support need.
2. Enters a clear description of the service or support activity.

l t l fhy 3. Enters justification. l

4. Signs, dates, and checks letters "GS".
5. Forwards GSAR to supervisor.

REQUESTOR'S SUPERVISOR

6. Reviews GSAR for appropriateness.

a) Rejected GSARs are returned to the originator with a written explanation for rejection. b) Approved GSARs continue through the review process below.

7. Enters signature and date of approval.
8. Enters letters of responsible division, department, or unit, and priority, if known.
9. Enters the serial number from QA, and I date.

1

                                      >o    'rresas^a*         ar't8        t'   er C'D                                       and a copy to QA.

F FORM 4C 372 22-3643

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 S' 0 SerVlCe* PUBLIC SERVICE COMPANY OF COLORADO , V SUPERINTENDENT / MANAGER

                                                                                                                                                                                                       *#11. Reviews GSAR and approves or rejects.

Forwards to the assigned organization superintendent / manager as appropriate. CAUTION: Many GSAR dispositions potentially involve commitments, design document update, such as changes to approved vendor documentation, or other action. Safety-Related/ Enhanced Quality documentation update is generally priority B-3. Other documentation update is generally priority B-4. RESPONSIBLE DEPARTMENT

                                                                                                                                                                                                       *#12. Dispositions request. Enters response (description, action, evaluation,etc.),

estimated cost, completion date, or denial as appropriate. Determines p followup need. V 13. Preparer signs and dates.

                                                                                                                                                                                                       *14. Approver signs and dates and returns a copy to the initiating organization and a copy to QA.
15. Performs followup activity required, such as CN, CWP or DC initation. Enters appropriate tracking document numbers.

' 16. Preparer signs and dates followup.

                                                                                                                                                                                                       *17. Approver signs and dates followup.

1.8. After budgetary source approval, if required, performs necessary services or support activities. l *19. Forwards original to the requestor's l manager / superintendent and a copy to QA. l INITIATING l ORGANIZATION l *#20. Acknowledges disposition, accepts / rejects j and transmits the completed GSAR to QA or rejected response to the dispositioning O' l l organization to resolve. j FORMtC)372 22 3643 l t

G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7

                                                                                                 #9' 0 Service
  • PUBLIC SERVICE COMPANY OF COLORADO O

5.0 REFERENCES

5.1 Procedure G-2, "FSV Procedure Systems". l 5.2 Procedure G-9, "CWP Processing". l 5.3 Procedure P-7, " Station Service Request Processing". l 5.4 Procedure Q-3, " Design Control". . l 5.5 Procedure Q-11 " Test Contrei". l 5.6 TASMAP-7, " Fort St. Vrain l Work Review Comittee Guidelines". 6.0 ATTACHMENTS G-3A, " Action Request Form". l G-3B, Action Request Distribution. l 7.0 COMMITMENTS l None 0 4 l O l FORMtc)372 22 3643

G-3 Attach. G-3A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 7 m O Service'" PUBUC SERVICE COMPANY OF COLORADO Page 15 of 16-ACTION REQUEST FORM

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G-3 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Attach. G-3B 0 Service" PUBUC SERVlCE COMPANY OF COLORADO Pa 1 of 16 /D V l ACTION REQUEST DISTRIBUTION l ARs are transmitted between the following superintendents l or managers for control purposes for the AR types given. l NPD l Superintendent of Maintenance (GS,PC) l Superintendent of Scheduling and Planning (GS, PC) l Superintendent of Nuclear Betterment Engineering (GS,PC,TR) l Superintendent of Technical Services Engineering (GS, PC, DC) l Superintendent of Training (GS,PC) l Superintendent of Operations (GS, PC) l Work Review Committee (GS, PC, DC, TR) via Superintendent of l Technical Services Engineering and Station Manager. l Manager, Station (GS,PC,TR,DC) l Manager, Technical /AdministrativeServices(GS,PC) Manager, Support Services (GS, PC) {s l l All DCARs must be approved by the Station Manager. l NED l Manager, Site Engineering (GS,PC,DC) l Manager, Nuclear Design (GS,PC,DC) l Manager, Engineering Services (GS,PC) l NLF l Manager, Nuclear Fuels and Analysis (GS, PC, DC) l Manager, Nuclear Licensing (SE) (GS,PC) I 9A l Manager, QA Services (GS,PC) l Manager,QAOperations(GS,PC) l QA Computer Specialist (GS, PC, TR, DC) for AR Log update end l document control. All Managers for disposition response, followup approval.or rejection. FORMtC1372 22 3643

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Pane 1 of 78 0 Service

  • rusuc SERVICE COMPANY OF COLORADO O TITLE: FORT ST. VRAIN PROCEDURE SYSTEMS PONSIBLE
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G-2 " Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 2 of 78 , i

  .s i OSerVICe* PUBUC SERVICE COMPANY OF COLORADO b

TABLE OF CONTENTS ,' Page . 1.0 PURP0SE....................................................... 3

                                                                                                                                                                  ^

2.0 AP P LI C AB I L I T Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . 3 ~f 2.1 G E N E RA L . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.2 E X C E P T I ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 l 2.3 PORC APPR0 VAL........................................... 4 s 3.0 GENERAL....................................................... 5 , 3.1 DE FI N IT I ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5' 3.2 RESPONSIBILITY ......................................... 6 3.3 PROCEDURE CATEGORY GUIDELINES......................:... 10 , 3.4 PROCEDURE IDENTIFICATION .............................. 11 ~J . t im i 3.5 PROCEDURE INITIATION ..................................'.12 r V 3.6 P ROC EDU R E FO RMAT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 -

                                                                                                                                                                                  ~.

3.7 P ROC EDU RE C0NTENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 3.8 P ROC EDURE REVI EWS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3.9 GENERAL WRITING GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . : .i'. . 22 . 3.10 PROCEDURE DEVIATION REP 0RTS............................s23 - 4.0 PROCEDURE.................................................... 24 , 4.1 PROCEDURE INITIATION / REVISION PROCESSING .............. 24-I l 4.2 TYP0 GRAPHICAL ERROR CORRECTION INITIATION.............. 30 4.3 PROCEDURE PERFORMANCE.................................. 30 ~ 'w 4.4 PDR INITIATION / PROCESSING....................... ...... 35 l 4.5 APPROVED POR IMPLEMENTATION - WORKING PROCEDURES ..... ,.38 .

5.0 REFERENCES

..................................... ............ 39                                                                             ,
 /"'N                     6.0      ATTACHMENTS.................................................'.                                                        40 N~-                                                                                                                                                                                      ,

[ 7.0 C 0 K ' I TM ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 0 FORM (01372 22 3M3

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 3 of 78 j-0SOrVlCG* PUBLIC SERVICE COMPANY OF COLORADO lJ ,

                                     -l '. 0 PURPOSE This procedure describes the system of procedures and procedure
                                     ..,      controls used at the Fort St. Vrain Nuclear Generating Station.

2io APPLICABILITY 2.1 GENERAL This procedure applies to all procedures identified in Attachment G-2A and addresses the following: 2.1.1 Development 2.1.2 Control 2.1.3 Use 2.1.4 Deviation n 2.2 EXCEPTIONS

 .,         u-f"                                  2.2.1  License Basis Documents.
                     -_                                2.2.2 Security Plans and Procedures.

2.2.3 Nuclear Policies and Guidelines. l 2.2.4 Nuclear Engineering Division (NED) and Nuclear

                              'l                              Licensing and Fuels Division (NLF) procedures are l                             processed separately with equivalent controls.
l. a) Nuclear Engineering Division (NED) reviews, I approves, and processes NED procedures in
                            -l                                     accordance with ENG-6.

l b) Nuclear Licensing and Fuels (NLF) reviews, l approves, and processes NLF procedures in l accordance with NLF-1. l c) For NED and NLF procedures, organizations or

  • l personnel equivalent to Nuclear Documents, l Technical Services, and Training (within the o l Nuclear Production Division) are designated to l perform the functic1s of these org:ni:ations

. [ (procedure preparation, DCCF, PDR, and PORC l

                                )                                   requirement review and processing).

8-G . l - ~Q, 1 amoim .m.=

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 4 of 78 0 $9fVIC9' PUBLIC SERVICE COMPANY OF COLORADO p L) I d) For all references to Nuclear Documents, l Technical Services, and Training (within the l Nuclear Production Division) in this l procedure, the equivalent organizations or l personnel at NED and NLF apply. 2.2.5 Emergency procedures for commitment identification. 2.2.6 Welding Procedures for format. 2.2.7 Radiological E.mergency Response Plan (RERP) procedures for format. l 2.2.8 Administrative Procedure G-2 requirements apply to all procedure issues initiated after the effective date of the current issue of Administrative Procedure G-2. 2.2.9 All new or revised procedures must conform to G-2 formatting unless specified in lower level governing procedures. l 2.3 PORC APPROVAL

 'O        l             2.3.1 All Level         1 procedures (G, P, and Q) require PORC l U         l                     approval.

l l 2.3.2 Procedures requiring PORC approval may be l identified by memo, the PORC Approval Procedure l Li st (PAPL), issued and updated separately by the l Nuclear Divisions (see Technical Specification AC ( l 7.4b and Regulatory Guide 1.33, November, 1972). l 2.3.3 Procedures identified by the PAPL require PORC l approval. l t O FORM (D)372 22 3643

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 5 of 78 p 0 SerVICO*PUBUC SERVICE COMPANY OF COLORADO V 3.0 GENERAL 3.1 DEFINITIONS 3.1.1 Reference Administrative Procedure G-1 for the following definitions: a) Administrative Procedure b) Working Procedure c) Health Physics Notification Point d) Health Physics Control Point e) Procedure Master Copy f) Procedure Working Copy g) QC Witness Point h) QC Hold Point 3.1.2 Procedure Deviation a) Reference Administrative Procedure G-1. b) Permanent - A deviation which must be incorporated into the procedure on a permanent basis, l c) Long Term Temporary - A deviation required for a fixed time interval less than sixty days, due to temporary conditions. , d) Single Use Temporary - A deviation required l due to unique circumstances on one performance of a procedure. - e) ODR - A deviation resulting from an Operations Deviation Report (DDR) required for the duration of the ODR. f) Non-nmbiguous typographical, spelling, or grrnunatical error corrections are not considered deviations. g) Corrections to numerical values, acceptance I criteria, dimensions, specifications, and other objective criteria are always deviations. FORM (D1372 22-3643 ,

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3.1.3 Procedure Manual A controlled, compiled copy of procedures which may be used to prepare working copies for use in the field. 3.2 RESP 0NSIBILITY 3.2.1 All Personnel All personnel are responsible for. a) Complying with authorized procedures. b) Obtaining approval via Procedure Deviation Report (PDR) when compliance with the procedure is not possible or does not meet the procedure intent. c) Initiating changes to correct technical content of procedures. d) Ensuring adequacy of procedures. O O FORM (D)372 22 3643 l

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 7 of 78 0 SGIVice' PUBUC SERVICE COMPANY OF COLORADO 7-~s \--] 3.2.2 Supervisory Personnel Supervisory personnel are responsible for: a) Ensuring correct use of authorized procedures. b) Informing personnel of procedures, procedure changes, and procedure deviations that affect their work. CAUTION: The approving supervisor must ensure that the deviation does not change the final intent of the procedure. c) Evaluating and approving Procedure Deviation Reports. d) Ensuring revisions to procedures are initiated to maintain current, workable procedures. e) Resolving conflicts with higher level ()/ \_- procedures. f) Performing periodic reviews of procedures. 3.2.3 Responsible For Party The Responsible For party is responsible for: l a) Initiating, reviewing, and approving, new l and revised procedures. b) Resolving documented comments during the procedure review process. c) Reviewing and approving Procedure Deviation Reports (POR's) and PDR extensions. d) Performing periodic procedure reviews. e) Verifying conflicts with higher level procedures are resolved. bsJ FORM (D)372 22 3643

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V 3.2.4 Authorized By party The Authorized By party is responsible for: a) Ensuring supervi sory control of use of procedures. b) Ensuring adequacy of developed proceoures. c) Reviewing and approving Procedure Deviation Reports (PDR's). l d) Approving new and revised procedures. 3.2.5 Plant Operations Review Committee The Plant Operations Review Committee (PORC) is responsible for: a) Performing reviews of procedures in accordar.ce with Technical Specification AC 7.4 and NPAP-8. I l (~'T b) Reviewing all Procedure Deviation Reports

 \/                                             (PDR's) requiring PORC review        (PDR's
against PORC approved procedures) within 14 days of the last approval date on the deviation.

3.2.6 Quality Assurance Quality Assurance is responsible for: l a) Reviewing all new or revised procedures to determine the need for Quality Assurance review. b) *#*7.1*#* Reviewing all r?w or revised procedures involving enhanced quality / safety related activities prior to issuance. I (_/ l -oi m . m . =

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3.2.7 Licensing Licensing is responsible for: a) Preparing safety evaluations when required. b) Preparing Environmental Evaluations when required. c) Reviewing procedures as requested for Licensing impact. 3.2.8 Technical Services Technical Services is responsible for: a) Reviewing procedures for potential unreviewed safety questions. b) Reviewing procedures for potential environmental effect. c) Determining PORC review requirements.

    ~/            l            3.2.9 Environmental Equipment Qualification Reviewer l                   The     Environmental Equipment Qualification (EQ)

Reviewer is responsible for: a) Reviewing proposed procedure changes identified as potentially affecting EQ, for EQ impact and approving Document Coordination and Concurrence Forms (DCCF's). b) Reviewing an'd approving Procedure Deviation Reports (PDR's) . identified as potentially affecting EQ. 3.2.10 Clerical Organizations Clerical Organizations are responsible for: a) Informing supervisory personnel of all new and revised procedures. I b) General tracking of Document Coordination I and Concurrence Forms (DCCF's) without l Procedure Deviation Reports (PDR's) to l ensure timely procedure issuance. FORM (D)372 22-3643

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 10 of 78 0 $9fVICe* PUBUC SERVICE COMPANY OF COLORADO (3, Lj' l c) Distributing controlled, non-controlled, l and temporarily controlled working copies of procedures and PDR's in accordance with Administrative Procedure G-10 and the Document Distribution Handbook (DDH). l d) Maintaining a list of employee signatures cross-referenced with employee initials and conducting an annual update of the j list. 3.3 PROCEDURE CATEGORY GUIDELINES 3.3.I When requirements for procedure initiation or revision are identified, the following logic shall l be applied to categorize the procedure: 1 a) Level 0 License basis documents and Nuclear Policies and Guidelines. ! . b) Level I Administrative policies, rules, and/or N regulations applicable to all personnel, or l instruments for activities for all nuclear Divisions. c) Level II Detailed administrative or technical instructions applicable primarily to one Division or Department, although associated l requirements may involve other Divisions / Departments. Level II procedures i generally provide additional guidance below I the scope of a Level I^ procedure. , d) Level III Specific instructions for operating, ! maintaining, or supporting the plant, usually within a Department or Unit. 3.3.2 Level I procedures take precedence over Level II procedures, and Level II procedures take precedence over Level III procedures. l I FORM (on372 22 3643

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 11 of 78 0 SerVICG*PUBUC SERVICE COMPANY OF COLORADO l b} 3.4 PROCEDURE IDENTIFICATION 3.4.1 Paper Procedure pages use bordered sheets (see Attachment G-28), but may be issued using plain paper when necessary. 3.4.2 Procedure Numbering Procedures are uniquely numbered. Numbers for I deleted procedures are not reassigned. 3.4.3 Effective Date In general, procedures become effective five working days after the date of final approval. Other effective dates may be specifically approved by the Plant Operations Review Committee (PORC). 3.4.4 Page Numbering Each page is consecutively identified and numbered in the upper right hand corner as shown in the O l examples below: G Text: G-2 Issue 17 Page 5 of 98 Attachments: G-2 Attachment G-2A or Attach. G-2A or Attachment A Issue 17 Page 98 of 98 3.4.5 Revised Text Flagging Revised text employs a bold vertical line on the left edge of the page for that issue of the procedure. 3.4.6 Procedure Manual Index An index listing procedure number, title, effective date, and issue number, is provided for each procedure manual. a ronutom2 22 3e43 f

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3.5 PROCEDURE INITIATION 3.5.1 Within Division Procedure proposals within a Division (Nuclear Production, Nuclear Engineering, Quality Assurance, or Nuclear Licensing and Fuels) are initiated via the Document Coordination and Concurrence Form (DCCF) process (reference Attachment G-2C).

    .                       3.5.2 Outside A Division Proposals    initiated     by individuals outside a Division are initiated utilizing a Procedure Change Action     Request    (PCAR)    in   accordance   with Administrative Procedure G-3.

3.5.3 Fuel Handlino Procedure Work Packages Fuel Haridling Procedure Work Packages are initiatrd in accordance with the Fuel Handling Procedu e Manual. l 3.5.4 Controlled Work Procedures O ( l Controlled Work Procedures (CWP's) are initiated in l accordance with Administrative Procedure G-9. G V FORM (D)372 22 3843

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 13 of 78 0 SOTVICO'PUBUC SERVICE COMPANY OF COLORADO /s b 3.6 PROCEDURE FORMAT 3.6.1 Block Paragraph Structure Text shall be single spaced in standard block form. Procedure titles shall be typed in upper case letters. 1.0 TOP LEVEL INDENTATION TITLES - Top level indentation titles shall be upper case and underscored. 1.1 SECOND LEVEL INDENTATION TITLES Second level indentation titles shall be upper case and underscored. 1.1.1 Third and Further Level Indentations Third and further level indentation may be used as required with the following guidelines: , a) Capitalize titles and underscore if s ,,/ appropriate. b) Do not use excessive indentation. c) Maintain outline form and block structure. 3.6.2 Playscript Format Playscript format is used when different individuals / organizations a're involved to clearly associate the responsible party with actions. Playscript is formatted as follows: 1.7 TITLE RESPONSIBILITY ACTION DEPARTMENT OR INDIVIDUAL 1. Numbered and sequenced action item or step instruction. O FORM (D)372 22 3643

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t/ 3.6.3 Procedure Table of Contents l A Table of Contents should be provided on Page 2 of each procedure. Second level indentations (for example, 4.1) should be included in the Table of Contents if titled. 3.6.4 Warnings, Cautions, and Notes a) Warnings, cautions, and notes should precede the step (s) they apply to. b) Warnings, cautions, and notes should not contain action requirements normally performed, but may include actions taken in abnormal conditions. c) A warning is the strongest statement, followed by cautions and notes. A warning generally alerts a personnel hazard while a caution generally alerts an equipment damage hazard. d) Notes should not contain any information required for procedure performance, but rather f} v helpful or informational statements, e) Warnings are formatted as follows: WARNING: Body of text of warning. Body of text of warning. Body of text of warning. Body of text of warning. f) Cautions are formatted as follows: CAUTION: Body of text of caution. Body of text of caution. Body of text of caution. Body of text of caution. FORM (DI372 22 3643

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  • PUBUC SERVICE COMPANY OF COLORADO I ,O L] g) Notes are formatted as follows:

NOTE: Body of text of note. Body of text of t note. Body of text of note. Body of text of note. 3.6.5 Quality Control Hold and Witness Points ! Quality Control (QC) Hold and Witness points are generally formatted as indicated below. Other formats accomplishing the same intent, such as ( stamps, may be used. l

98. QC HOLD POINT:

! Body of text of step. Body of text of step. l Body of text of step.

                                                                                                    /

Init. Date l / QC Init. Date

 \                                                 99. QC WTINESS POINT:

Body of text of step. Body of text of step. Body of text of step.

                                                                                                      /

Init. Date

                                                                                                    /

QC Init. Date 1 O FORM (D)372 22 3643

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V 3.6.6 Health Physics Notification and Control Points Health Physics (HP) Notification and Control Points are generally formatted as indicated below. Other formats accomplishing the same intent, such as stamps, may be used.

98. HP NOTIFICATION POINT:

Health Physics Technician has been notified. Enter Technician name. HP Technician Name l / l Init. Date Body of text of step. Body of text of step. Body of text of step. Init. Date

99. HP CONTROL POINT:

Body of text of step. Body of text of step. Body of text of step.

                                                                                                                                 /

l Init. Date I / l HP Init. Date 3.6.7 If/Then Format If/Then statements are generally formatted as follows: 5.7 LF text of 'if' statement, THEN text of 'then' statement. O j FORM tDI372 22 3643

G-2 Issut 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 17 of 78 0 $9tVIC9' PUBUC SERVICE COMPANY OF COLORADO l 3.6.8 *#*7.2*#* Commitment Identification a) Commitment Initiation Procedures or procedure revisions which result from commitments shall be specifically identified. Commitments may be internal to PSC (Corrective Action Requests (CAR's), Production Commitment Log, etc.) or external (NRC, INPO, State of Colorado, etc.) b) Commitment Content / Format

1) The commitment reference shall precede revised steps or sections.
2) The symbol '*#*' shall be placed before and after the commitment reference.
3) Example of step:
99. *#*7.1*#* Body of text for step or section.

p '

4) Example of commitment statement:

%) Step 99 is a result of corrective action made in response to CAR 84-999.

5) Commitment statements should include correspondence or document numbers when possible for future reference.
6) For new procedures generated in response to a commitment, the commitment reference shall be placed in the ' Purpose' (or equivalent) section.

l 3.6.9 Environmental Equipment Qualification (EO) Flag l a) Procedures l Maintenance and Results procedures which are l applicable to Environmentally Qualified (EQ) l equipment should have a designat' ion of 'EQ' in l the procedure number itself if the procedure l is primarily involved in EQ activity or is l critical to the equipment's EQ qualifica9on. (D %) com ioim .m.=

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 18 of 78 OSerVICO*PUBLIC SERVICE COMPANY OF COLORADO A l b) Steps l Single EQ steps critical to maintaining EQ are l flagged as EQ commitments using '"#*EQ*#*' l preceding the step. These are not detailed in l the Commitment section. 3.7 PROCEDURE CONTENT

                                                                                            ~

3.7.1 Abbreviations and Definitions in Procedures a) Abbreviations Abbreviations should be spelled out completely with the abbreviation placed immediately following, and then be used consistently throughout the procedure. If a procedure is long and the term does not recur until much later, the term should be redefined as a courtesy to the reader. b) Definitions Procedures which introduce key words and O definitions for activities should provide a () formal definition. Administrative Procedure G-1 provides a partial list of unique definitions. O FORM (D)372 22 3643

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 19 of 78 0 SerVICO*PUBUC SERVICE COMPANY OF COLORADO x) 3.7.2 Administrative Procedures Sections 1.0 PURPOSE Establishes the purpose. 2.0 APPLICABILITY Delineates the scope of the application. 3.0 GENERAL OR GENERAL REQUIREMENTS - Surnarizes general information such as definitions, responsibilities, etc. 4.0 PROCEDURE Provides the instructions to fulfill the addressed requirement or achieve the stated purpose.

5.0 REFERENCES

References key documents. O(j 6.0 ATTACHMENTS l Lists all attachments by number and title. l l 7.0 COMMITMENTS l Provides a description of commitment origins. 1 i i l O MM {o} N

  • N ' M

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V 3.7.3 Abnormal Operating Procedure Sections 1.0 INTERIM ABNORMAL OPERATIONS Contains abnormal operations concerning that l system or major components within the system. 2.0 COMMITMENTS Provides a description of commitment origins. 3.0 APPENDICES AND ATTACHMENTS Lists all appendices and attachments. 4.0 CROSS REFERENCE INDEX Contains cross reference information for use during implementation of Interim Abnormal Operating Procedures. 3.7.4 Surveillance Test Procedures Surveillance Test Procedure content is addressed in rN NPAP-4 and SMAP-1. b 3.7.5 Results Procedures Results Procedure content is addressed in RP-A-03, 3.7.6 Maintenance Procedures Maintenance Procedure content is addressed in l MAP-11, MAP-13, MAP-14, and SHAP-27. 3.7.7 Systems Operating Procedures System Operating Procedure' content is addressed in SOAP-1, 3.7.8 Emergency Procedures Emergency Procedure content is addressed in SOAP-2. O a l FORM (o)372 22 3843

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Q) 3.7.9 Non-Routine or Special Test Procedures Reference Administrative Procedure Q-11. 1.0 PURPOSE OF TEST 2.0 PRECAUTIONS, LIMITATIONS, AND SPECIAL ASSISTANCE 3.0 PREREQUISITES 4.0 PROCEDURE 3.7.10 Post Maintenance Tests Post Maintenance Test content is addressed in SMAP-23. 3.7.11 General Format Sections Procedures which are not adaptable to the formats described above may utilize a ' General' format. The format is not limited to the sections listed below (with the exception of the Commitment (s Section), and sections may be used in any combination. Section titles and section numbering ('- are to be used as deemed appropriate by the responsible Department Manager. 1.0 PURPOSE 2.0 RESPONSIBILITY, or APPLICABILITY, or PRINCIPLE OF METHOD 3.0 GENERAL, or APPARATUS

                                                  ' GENERAL'          may      include     precautions, limitations, cleaning, housekeeping, special tools requiren, as found/as left conditions, corrective e. tion,            material   and        parts, inspection, records, etc.

4.0 PROCEDURE, or REAGENTS 5.0 TEST PROCEDURE, or PROCEDURE 6.0 ACCEPTANCE CRITERIA, or REFERENCES 7.0 TOOL LIST, or ATTACHMENTS g 8.0 COMMITMENTS Y FORM (D)372 22 3843

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3.8 PROCEDURE REVIEWS Periodic reviews of procedures are required as identified l in NPAP-8, ENG-6, and NLF-1. 3.9 GENERAL WRITING GUIDELINES 3.9.1 The procedure should completely address the subject involved. Additional reference material should not be required to use the procedure. 3.9.2 Related procedures should be referenced. 3.9.3 Only required information should be included. Use minircum wording. 3.9.4 Words should convey precise meanings. 3.9.5 Performance steps should consist of short, concise action (command) statements rather than narrative style paragraphs. 3.9.6 *#*7.4*#* Performance steps should be presented in I the order they are expected to be performed. O i V 3.9.7 Each performance step should deal with only one idea / task. 3.9.8 Forms / data sheets should reflect procedure steps and should use text corresponding to the procedure text. 3.9.9 Sentence length should be short. 3.9.10 Minimal punctuation should be used. 3.9.11 Acceptance criteria should be explicitly identified. 3.9.12 Administrative type procedures normally do not require sign off blanks within the procedure. Control is normally documented using forms or checklists. 3.9.13 If normal procedure performance involves the use of

                                  'NA' entries, these should be called for by the procedure text.

3.9.14 When steps are to be performed by personnel other than the primary procedure performer, that (q y performer's identified. work specialty should be clearly FoRMIDI372 22 3843

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() t. 3.10 PROCEDURE DEVIATION REPORTS 3.10.1 Conditions for Use of Procedure Deviations a) The procedure intent cannot be changed, b) A Procedure Deviation Report (PDR) form must be prepared and approved (reference AttachmentG-20). c) *#*7.3*#* Procedure Deviation Reports (PDR's) must not be written against completed working procedure sections or steps. 3.10.2 Procedure Deviation Report Approval a) Emergencies When essential to mitigate a situation that will adversely affect personnel or public safety, personnel may deviate from approved procedures without prior approval. Such deviations must subsequently be documented wh'en conditions permit, (nj b) Level I, II, and III Procedures

1) Two members of plant management staff, at least one of whom holds a Senior Reactor Operator's license (reference Delegation of Authority memo).
2) One responsible for person listed in Attachment G-2A.
3) One authorizer listed in Attachment G-2A.

c) NED and NLF Level II and Level III Procedures NED and NLF procedures require one authorizer listed in Attachment G-2A. d) Controlled Work Procedures Controlled Work Procedure (CWP) Deviation Requests (DR's) are processed per Administrative Procedure G-9. 3 (V FORM 10)372 22+3843 m , - - - , _ , , , , _ , , . - - - . , - - _ - ,

                               -<r -----       a

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 'Y 3.10.3 Procedure Deviation Report Numbering Procedure         Deviation              Reports     (PDR's)         are sequentially numbered within the year.

l 3.10.4 PDR Effective Date l PDR's are effective when the last required l approval is obtained unless noted otherwise by the l " Procedure Authorizer" listed in Attachment G-2A. l 3.10.5 Procedure Deviation Incorporation l a) Responsible organizations will coordinate l incorporation of PDR's into new procedure l issues to maintain procedure quality. l b) Generally, a goal will be to revise a l procedure with a new issue by the time three l (3) permanent PDR's have been written. 4.0 PROCEDURE 4.1 PROCEDURE INITIATION / REVISION PROCESSING C(~h Step numbers listed below correspond to numbers shown on Attachment G-2C.

                ,     RESPONSIBILITY                                 ACTION INITIATOR                  1. Enters procedure number.
2. Enters procedure title.
3. -If a permanent PDR initiated the DCCF, attaches copy of PDR and enters PDR Number on DCCF.
4. If DCCF is not a result of a permanent PDR, checks 'N/A'.
5. Enters description of new procedure, l ,

change, or deletion. l a) Must be adequate to summarize all changes in the procedure. b) Should , identify paragraphs to be changed, renumbered, or deleted. p) y c) If applicable, references instead of rewriting changes. PDR l FoftMIDl372 22 3843

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v

6. Enters the justification.

a) Lists any references required to understand the change. b) If in response to a commitment, references the document number initiating the commitment. l 7. Enters nurr.ber of pages of DCCF. l 8. Enters name and date. l 9. Forwards to supervisor. INITIATOR'S l SUPERVISOR 10. Reviews proposed procedure or procedure change. l 11. Lists applicable Technical Specifications l and verifies compatibility.

12. If the procedure or procedure change is denied, attaches justification, initials

(~] V and dates DCCF, and returns to initiator.

13. If the procedure or procedure change is unacceptable, attaches clear constructive comments on the action required, signs and dates the ' Mandatory Changes Attached' section, and returns the procedure package to the initiator.
14. Reviews the procedure or procedure change for compatibility with other existing procedures.
15. If incompatibility is identified, places procedure 'On Hold' and initiates appropriate procedure changes.
16. If the procedure or procedure change is acceptable, signs and dates the
                                           ' Approval,     Document      May     Be Issued' section, and forwards            the    procedure package to Nuclear Documents.

NUCLEAR DOCUMENTS 17. Enters DCCF number.

18. Updates DCCF Log.

O v FORM (D)372 22 3843 ,

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19. Files copy of DCCF in interim file.
20. Forwards procedures requiring QC Hold and Witness Points to QC. Forwards other procedures to Nuclear Documents / appropriate clerical section.

Procedures requiring QC Hold and Witness Points are as follows: Fuel Handling Procedures Maintenance Procedures (including Electrical Maintenance Procedures) Results Procedures Surveillance Procedures (Technical Specification, safety related) QUALITY CONTROL 21. Incorporates QC Hold and Witness Points.

22. Forwards to Nuclear Documents / appropriate clerical section.

NUCLEAR DOCUMENTS / APPROPRIATE CLERICAL 23. Prepares the procedure. Incorporates O typographical corrections. O 24. Notes typographical correction - information on the DCCF.

25. Attaches appropriate procedure review checklist.
26. Forwards package to initiator.

INITIATOR 27. Reviews package.

28. Forwards to ' Responsible For' person.

RESPONSIBLE FOR PERSON 29. Reviews proposed procedure or procedure change and determines necessity for procedure / procedure change.

30. If the procedure or procedure change is denied, attaches justification, initials and dates DCCF, and returns to Nuclear Documents.

Oj FORMID)372 22 3843

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LJ

31. If the procedure or procedure change is unacceptable, attaches clear constructive comments, signs and dates the ' Mandatory Changes Attached' section, and forwards the package to Nuclear Documents / appropriate clerical section for correction.
32. If the procedure or procedure change is acceptable, verifies compatibility with Level I and other procedures, signs and dates the ' Approval, Document May Be Issued' section, and forwards the package l to the Environmental Equipment Qualification Reviewer.

NUCLEAR DOCUMENTS 33. If the procedure or procedure change is denied, updates the DCCF log and the interim DCCF file, and informs the initiator of the denial. EQ REVIEWER 34. Determined if EQ review is required, checks appropriate box, initials, and dates. If no EQ review is required, forwards to Quality Assurance. l 35. If the environmental equipment qualification aspects of the proposal are not adequate, attaches clear constructive comments on the actions required to resolve the problem, signs and dates the

                                                            ' Mandatory Changes Attached' section, and returns the procedure package to the
                                                            ' Responsible For' person for resolution.
36. If the procedure is acceptable, signs and dates the ' Approval, Occument May Be Issued' section, and . forwards the procedure package to Quality Assurance.

RESPONSIBLE FOR PERSON 37. Resolves EQ Reviewer comments if required.

38. Forwards to Quality Assurance.

QUALITY ASSURANCE 39. Determines if QA review is required, checks appropriate box, initials, and dates. If no QA review is required, forwards to the ' Responsible For' person. O V romioim.n.no

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40. If the quality aspects of the procedure or procedure change are not adequate, attaches clear constructive comments on the actions required to resolve the problem, signs and dates the ' Mandatory Changes Attached' section, and returns the procedure package to the ' Responsible For' person for resolution.
41. If the procedure is acceptable, signs and dates the ' Approval, Document May Be Issued' section, and forwards the procedure package to the ' Responsible For' person.

RESPONSIBLE FOR PERSON 42. Resolves QA comments if required.

43. Signs and dates DCCF.
44. Signs procedure cover sheet.
45. Forwards to ' Authorized By' party (ies).

AUTHORIZED BY O) is

    "            PARTY (IES)            46. If not approved, attaches comments and returns to the ' Responsible For' person.
47. If approved, signs and dates the DCCF, and signs the procedure cover sheet.

Forwards to Technical Services. TECHNICAL SERVICES 48. Reviews for potential for affecting the environment.

49. Reviews for potential for involving an unreviewed safety question.
50. Determines if PORC review is required per Fort St. Vrain Technical Specifications in accordance with TSP-4.
51. Signs and dates.
52. If the potential for affecting the environment or the potential for an unreviewed safety question exists, forwards to Licensing.
53. If not, proceeds to Step 56.

G

 ,V FORMtDI3TJ.22 3843

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  • PusuC SERVICE COMPANY OF COLORADO I) v LICENSING 54. Prepares Safety Evaluation Form in accordance with Administrative Procedure Q-3.
55. Prepares Environmental Evaluation Form in accordance with Administrative Procedure Q-3.
56. Forwards to Training Support.

TRAINING SUPPORT 57. Reviews for training impact, and signs and dates.

58. Forwards to PORC Clerk.

PORC CLERK 59. Prepares for PORC.

60. Enters DCCF number (s) on the procedure cover sheet.

PORC 61. Reviews and approves / rejects.

62. Forwards to the PORC Clerk.

( ( PORC CLERK 63. Enters the procedure issue number. If a new procedure, enters 1. If deleting or revising a procedure, enters the next issue number.

64. Enters the effective date.
65. Enters initials.
66. Updates the DCCF log.
67. Removes copy of DCCF from interim file.
68. Forwards to Nuclear Documents / appropriate clerical organization.

NUCLEAR DOCUMENTS / APPROPRIATE CLERICAL 69. Updates procedure manual index.

70. Distributes in accordance with Administrative Procedure G-10 and the Document Distribution Handbook.
71. Transmits DCCF and attachments to the Fort St. Vrain Records Center.
72. Notifies supervisory personnel of O procedure issuance on a periodic basis.

FORM (ol372 22 3843

t G-2-{: . Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 30 of 73 O SerVICO*PUBUC SERVICE COMPANY OF COLORADO (v) - , 4.2 TYPOGRAPHICAL ERROR CORRECTION INITIATION ,}. CAUTION: See Section 3.1.2 for guidance. 4.2.1 The individual identifying a typographical error should inform the appropriate clerical organization of the error. This may be by telephone call, informal memo, or marked up copy of the procedure page. 4.2.2 The appropriate clerical organization will identify the error for correction during the next revision to the procedure. 4.3 PROCEDURE PERFORMANCE 4.3.1 Procedure Review l a) Issue Verification fm l With the exception of procedures temporarily ' h l l controlled (such as under Station Service Requests), the procedure performer ensures the current issue of the procedure is being used by referring to a controlled copy of the procedure. l b) Procedures Authorized for Performance by SSR l 1) SSR's authorize the use of Maintenance l and Results Procedures via Adminstrative l Procedures P-7 and P-12. l 2) Any SSR issued fo'r work more than 15 days l beyond the planned completion date should I be checked for current procedure issue by l the workman, before starting work (see l Administrative Procedure P-7). l FORM (o)372 22 3843

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( #

           )

E;j7 l c) Content Review y l Prior to performing any procedure, the ~ l performer should review the procedure, its l requirements, and understand what the l procedure calls for, prior to starting work.

 -r                 l                        The performer should be familiar with any l                        complicated procedure via training and prior l                        performance under supervision before working l                        the procedure as the primary performer.

- 4.3.2 Procedure Deviation Report (pDR) Review

   ,                                    a)   The procedure performer reviews the procedure cover sheet to identify any applicable PDR's, and reviews the PDR expiration date.

b) If identified, the procedure performer annotates the working copy of the procedure with the deviation information as stated in Section 4.5.

  ,,                             4.3.3 Procedure Performance Documentation
  ,g p                                   a)  All entries documenting procedure performance are to be made in ink.

b b) Documentation may be by initials, signature, initials and date, or signature and date, as specified in the procedure being performed, or the governing Administrative Procedure. c) *#*7.4*#* Procedures steps are signed off as soon as practical following completion. Work may be documented and transferred to the working copy where required. If sign off must be completed after work performance, and a transfer working copy 'or work log has not been kept, sign off should indicate the actual date/ time of sign off, rather than estimated ! time of work completion. Completed work must be documented before the performer leaves the site for that shift. d) For sections required by procedure, all entry blanks must have an entry or 'NA'. e) Sections not required by procedure do not require any documentation. f) 'NA' called for in the procedure does not require any other documentation. (

                                     )

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 <J g)    'NA'  may be used when the procedure step intent is clearly met, provided an explanatory note and performer initials and date are added for 'NA' entries not called for in the procedure text (for example, when procedure step requirement is           satisfied     prior     to performance of step).

h) *#*7.7*#* Corrections to entries made on procedures shall be made by lining out in ink the incorrect information and initialing and dating the correction. The use of ' white out' is prohibited. Reference Administrative Procedure Q-17.

1) Authorization to sign for or by may be used when a telephone conversation verifies performance of a step. Signoff must document who is signing for whom and 'per telecon'.

j) l Clarifications, explanations, and l documentation notes are desired in working

           ]                       procedures        and  forms      as legible notes, I                       initialed and dated,           at    the    point     of l                       application in the procedure.

l k) Administrative Procedures are revised by PDR l only; no annotation by the workman is allowed. 4.3.4 Step Sequence

                              *#*7.4*#*       Steps must be performed in the sequence given unless otherwise permitted by the procedure, or another controlling document such as a Station Service Request (SSR).         Reference Administrative Procedure P-7.

{ 0

                                                                                             ~

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G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 33 of 78 0 SGIVlCG'PusuC SERVICE COMPANY OF COLORADO V l 4.3.5 Clarifications l a) When procedure intent is not clear, the

                !                        performer will stop work and ask for l                       clarification             via    his    supervisor. The l                        supervisor will provide clarification directly l                       or by consulting with a technically cognizant l                       person for clarification.

l l CAUTION: No master or manual procedure copy is to l be annotated without a PDR. g l b) Clarifications to the procedure will be l entered onto working copies, as documentation l with initials and date, at the procedure step l clarified. l c) Recommendations to improve clarity should be l provided to supervisory personnel via DCCF l initiation. O- l 4.3.6 Page Additions O . When additional pages are needed to document performance, these pages may be added to the procedure package with a reference to the page within the procedure and a reference to the procedure on the page. For administrative procedures, this is via forms.

I 4.3.7 QC Hold and Witness Points and Hp Notification and Control Points The procedure performer is to not1fy Quality Control when a QC Hold Point or QC W1tness Point is encountered in a procedure.

The procedure performer is to notify Health Physics when a HP Notification Point or HP Control point is encountered in a procedure. l 4.3.8 Root Cause Determination , *#*7.10*#* Wherever a cause or reason or justification is required in a procedure or form, that cause (reason or justification) should include i identification of the root cause. l (a FORM (o)372-22 3843

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l 4.3.9 *#*7.11*#* Procedure Deviation Requirement l l CAUTION: See Section 4.3.5 for procedure clarity. I a) Procedure deviation via PDR is required when: l 1) Objective criteria (acceptance criteria, l specifications, ranges, values, limits) I l is changed. l 2) Step sequences must be changed that are l not allowed by the procedure. l l CAUTION: Any question about procedure performance requirement or intent } l l should be referred to supervisory l personnel immediately. m l 3) Procedure clarity is not acceptable, as l determined by supervisory personnel l responsible for the actual work l performance. l b) Procedure deviation is not required when: l 1) Procedure clarity can be resolved by l supervisory personnel for matters of l interpretation. l 2) Procedure clarity is not in doubt even l though grammatical punctuation, spelling, l or other cosmetic errors are present. l Supervisory personnel responsible for the l actual work performance will make this l determination, when required. l 3) Deviation represents a wording l preference, as determined by supervisory l personnel. l c) Procedure overall, final, or ultimate intent l may not be changed by deviation (although work l scope changes are allowed for maintenance under Administrative Procedure P-7 with proper (S f- l l authorization). FORM (D)372-22 3643

G-2 issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 35 of 78 O $9tVIC9' PUBUC SERVICE COMPANY OF COLORADO [ l d) Procedure intent questions will be resolved by l appropriate supervisory personnel, with the l ' Responsible For' individual for that l procedure acting as the final authority. 4.4 PDR INITIATION / PROCESSING l NOTE: Copies of approved permanent and long term temporary PDR's (and appropriate DCCF, if applicable) may be attached to the procedure in lieu of initiating a duplicate PDR. Approved PDR's are those with a last appruval date that is less than- 14 days old, or a PORC approved PDR that has not expired. Step numbers listed below correspond to numbers shown on Attachment G-2D. RESPONSIBILITY ACTION INITIATOR 1. Enters procedure number and issue number.

2. Enters title / title description.
3. Lists page(s), and/or paragraph number (s)
 ]                                            of procedure section(s) being changed.

CAUTION: *#*7.5*#* The PDR must clearly document both the change and the reason and should conform to the original procedure format and level of detail (Steps 4, 5, and 6, below).

4. Enters existing wording or 'as written'.
5. Enters new wording. If 'as written' was entered in Step 4, enters 'as attached' and attaches marked up copy clearly showing the changed wording.
6. Enters reason for change. If PDR is a result of an ODR, enters 'per ODR attached' and attaches copy of ODR.
7. Enters number of PDR pages.

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IV) 8. Signs and dates the first page of the PDR.

9. Forwards to immediate supervisor.

INITIATOR'S SUPERVISOR 10. Determines whether or not procedure being deviated was PORC approved and checks appropriate box. PORC approved procedures require PDR approval by PORC.

11. Determines whether or not EQ review is required and checks appropriate box. EQ review is required for all Maintenance, l Results, Administrative, and test l (Surveillance Tests, Cold Checkout Tests, l Functional Tests, T Tests) procedures.
12. Determines whether or not QC review is required and checks appropriate box. QC review is required as follows:

a) If associated steps indicate that Quality Control ~1s required or e involve testing or maintenance l activities on safety related or l enhanced quality equipment, forwards to QC. b) For working procedures, if an associated Station Service Request (SSR) indicates QC coverage is required, forwards to QC.

13. Indicates deviation category.
14. Enters expiration date for long term temporary deviations. -
15. Attaches DCCF if a permanent deviation.
16. Attaches a copy of the ODR if the deviation is a result of an ODR.
17. Determines procedure intent is not changed.
18. Signs and dates first page of PDR.

l 19. Forwards to Environmental Equipment Qualification Reviewer if required. If O not, proceeds to Step 22. FORM (D)372 22 3843

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 37 of 78 OSGIVlC9' PUBUC SERVICE COMPANY OF COLORADO q U EQ REVIEWER 20. Performs EQ review.

21. Signs and dates first page of PDR.
22. Forwards for Quality Control if required.

If not, proceeds to Step 24. QUALITY CONTROL 23. *#*7.8*#* Performs QC review. Adds or deletes QC Hold and Witness Points as appropriate. Signs and dates first page of PDR.

24. Forwards to initiator.

INITIATOR 25. Obtains approvals as required by Section 3.10.2. l 26. Obtains PDR number from PDR Log. Enters l number on PDR. Completes PDR Log. The l PDR Log is typically located in the l Nuclear Documents office during normal l working hours and in the Shift l Supervisor's office during off normal l working hours. N

   ,)                                   27. Forwards original of PDR (and DCCF if applicable) to the PORC Clerk within 14 days of last approval date of PDR.

PORC CLERK 28. Prepares for PORC. PORC 29. Reviews and approves or rejects.

30. Forwards to PORC Clerk.

PORC CLERK 31. Enters PORC meeting number and date.

32. Forwards to Nucle'ar Documents / appropriate clerical organization.

NUCLEAR DOCUMENTS / APPROPRIATE CLERICAL 33. *#*7.9*#* Annotates controlled procedure sets if PDR category is long term l temporary, permanent, or DDR, in [ accordance with Section 4.5.

34. *#*7.9*#* Updates controlled sets of procedures upon PDR expiration or, if applicable, return of an ODR.
     .           NUCLEAR DOCUMENTS      35. Routes original PDR's nearing expiration date to ' Responsible For' person.

l l FORM (Ol372 22 3643

G-2 Issua 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 38 of 78 0ServlC9' PUBUC SERVICE COMPANY OF COLORADO b RESPONSIBLE FOR PERSON 36. Approves / rejects PDR extension. If approved, enters extension expiration date.

37. Forwards to PORC clerk.
38. Proceeds to Step 28.

NUCLEAR DOCUMENTS 39. Updates PDR Status Index.

40. Transmits PDR's to the Records Center in accordance with the Record Center Retention Schedule.

4.5 APPROVED PDR IMPLEMENTATION - WORKING PROCEDURES RESPONSIBILITY ACTION INITIATOR 1. Attaches copy of PDR (and copy of DCCF if permanent PDR) to procedure being deviated.

2. *#*7.6*#* Annotates procedure being deviated as follows:

a) Writes the deviation number on the cover page of the procedure. b) Marks steps or sections affected by the deviation with a reference to the deviation, initials, and dates. c) Minor changes may be made as

                                                      ' markup' entries.                The    deviation must be referenced, initialed, and dated.

d) Copied pages of the deviation may be added following the affected step or steps for work documentation. The original page(s) are then marked to reference the deviation similar to the example below, and are initialed and dated. Original pages of the procedure are not to be removed or replaced.

                                                            'see PDR-85-XXXX for work'
3. Proceeds with work.

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5.0 REFERENCES

5.1 ANSI N18.7-1972, Paragraph 5.1.2, American National Standard-Administrative Controls for Nuclear Power Plants. 5.2 Regulatory Guide 1.33, Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors. 5.3 Technical Specification AC 7.1.2, Plant Operations Review l Committee, and Technical Specification AC 7.4b, Procedures l - Administrative Controls. 5.4 Technical Specification AC 7.4(a), Procedures, Administrative Controls. 5.5 INPO Procedure Writing Guides. 5.6 Administrative Procedure G-1, Definitions 5.7 Administrative Procedure G-3, Action Request Preparation and Processing. 5.8 Administrative Procedures G-9, Controlled Work Procedures. 5.9 Administrative Procedure G-10, Data Management. f3 5.10 Administrative Procedure P-2, Equipment Clearances and Operations Deviation. 5.11 Administrative Procedure P-7, Station Service Request Processing. l 5.12 Administrative Procedure P-12, Plant Maintenance l 5.13 Administrative Procedure Q-3, Design Control. l 5.14 Administrative Procedure Q-5, Instructions, Procedures, and Drawings . l 5.15 Administrative Procedure Q-11, Test Control. l 5.16 Administrative Procedure Q-17, Quality Records. l 5.17 NPAP-4, Surveillance Procedure Preparation. l 5.18 NPAP-8, Procedure Reviews. l 5.19 ENG-6, NED Procedure System. l 5.20 NLF-1, Nuclear Licensing and Fuels Division Procedure l System. FORM (o)372-22 3643

G-2 Issue 21 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 40 of 78 0 SOTVlCe*PuaLIC SERVICE COMPANY OF COLORADO O l 5.21 SMAP-1, Technical Specifications Surveillance Testing Program. l 5.22 SMAP-19, Processing Equipment Clearances and Operation Deviations. l 5.23 SMAP-23, Post Maintenance Testing Implementation. l 5.24 SMAP-27, Preventive Maintenance Equipment Review. l 5.25 MAP-11, Maintenance Procedures. l 4.26 MAP-13, Maintenance Procedure Writer's Guide. l 4.27 MAP-14, Maintenance Operation Procedure Preparation. l 5.28 SOAP-1, Guidelines for Preparation of System Operating Procedures. l 5.29 SOAP-2, Guidelines for Preparation of Emergency Procedures. l 5.30 RP-A-01, General Requirements Governing Procedures for the Calibration and Maintenance of Plant Instrumentation. l 5.31 TSP-04, Technical Services Procedure Review. l 5.32 Delegation of Authority Memo. l 5.33 Document Distribution Handbook (DDH). 6.0 ATTACHMENTS G-2A FSV Procedure Structure G-2B FSV Procedure Paper G-2C Document Coordination and Concurrence Form (OCCF) G-20 Procedure Deviation Report (PDR) Form 7.0 COMMITMENTS The step (s) and section(s) listed below may not be deleted without issuance of comparable controls. The procedure itself, ! if initiated as a result of commitment corrective action, may not be deleted without issuance of comparable controls. l l 7.1 Step 3.2.6(b) is a result of co m itments made in response l l to Commitment Log Item 956. i l FORMiDI372 22 3643 i

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G 7.2 Section 3.6.8 is a result of commitments made to the NRC l in in response to I&E Inspection 84-15. 7.3 Step 3.10.1(c) is a result of commitments made in response to CAR 85-077. 7.4 Steps 3.9.6, 4.3.3(c), and 4.3.4 are a result of commitments made in response to CAR 85-078. 7.5 The ' CAUTION' prior to Steps 4, 5, and 6, of Section 4.4 is a result of commitments made in response to CAR 85-079. 7.6 Step 2 of Section 4.5 is a result of commitments made in response to CAR 85-079 and CAR 85-080. 7.7 Step 4.3.3(h) is a result of commitments made in response to CAR 86-041. 7.8 Step 23 of Section 4.4 is a result of commitments made in response to CAR 85-081. 7.9 Steps 33 and 34 of Section 4.4 are a result of commitments made in response to the 1985 INPO Evaluation in Production Commitment Log Item 03003, CAR 86-047, and CAR 86-085. l 7.10 Step 4.3.8 is a result of commitments made in response to Commitment Log Item 353. I 7.11 Section 4.3.9 is a result of commitments made in response l to CAR 85-082. 1 (O FORM (D)372 22 3M3

m G-2 l Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 42 of 78 OSerVlCO* PUBUC SERVICE COMPANY OF COLORADO V FSV PROCEDURES STRUCTURE LEVEL 0 Facility Operating License / Technical Specifications Establishes operating parameters, controls, and limitations. Includes the Technical Specifications contained in Appendices A and B. Responsible For: Nuclear Licensing Manager Authorized By: VP, Nuclear Operations NFSC NRC . Onal Environmental Statement (FES) Provides a summary of environmental impact and adverse effects p) involving operation of Fort St. Vrain and includes, where appropriate a discussion of problems and objections raised by other Federal, State, and Local agencies, and v private organizations and individuals in the review process, and the disposition of the issues involved. Responsible For: Nuclear Licensing Manager Authorized By: NRC Nuclear Policies and Guidelines Provides management policies and Nuclear Organization charters. l Responsible For: VP, Nuclear Operations ! Authorized By: VP, Nuclear Operations Security Plan Document required by the Facility Operating License which establishes the physical protection program at Fort St. Vrain pursuant to applicable Federal regulations. Responsible For: Security Supervisor Authorized By: ~ Plant Security Officer l l FORM (D)372 22 3843 ,

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b' FSV PROCEDURES STRUCTURE LEVEL 0 Updated Final Safety Analysis Report (UFSAR) Establishes complete updated description of Fort St. Vrain Generating Station and PSCo commitments for control thereof. Responsible For: Nuclear Licensing Manager Authorized By: VP, Nuclear Operations O O FORM tD)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 44 of 78 O $9fVlC9' PUBUC SERVICE COMPANY OF CCLORADO (v~'t FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure G-1 Definitions Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-2 Fort St. Vrain Procedure Systems Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-3 Action Request Preparation and Processing Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED l Manager, NLF Manager, NPD Manager, QA I l O FORM (D)372-22 3843

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 45 of 78 OSerVICO*PUBUC SERVICE COMPANY OF COLORADO r N}J FSV PROCEDURES STRUCTURE 1 LEVEL I Administrative Procedure G-4 Security, Visitor, and Reactor Building Access Control Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-5 Personnel Emergency Response f ( Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-6 Control of Special Nuclear Material Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA m FORM (D)372 22 3643

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 ,e V

FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure G-7 FSV Project Training and Qualification Programs Responsible For: Superintendent of Training Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-8 Compliance with 10CFR21 Requirements Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-9 Controlled Work Procedures Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED l Manager, NLF Manager, NPD Manager, QA FORMtDI372-22 3643

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V FSV PROCEDURES STRUCTURE IEVEL I Administrative Procedure G-10 Data Management Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-11 Unclassified Safeguards Information Responsible For: Technical / Administrative Services Manager l Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-12 l Classified Documents l I Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED Manager, NLF l Manager, NPD l Manager, QA Administrative Procedure G-13 Fitness for Duty Responsible For: Technical / Administrative Services Manager Authorized By: VP, Nuclear Operations o i FORM (D)372 22 3643

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FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure G-14 FSV Commitment Control Procedure Responsible For: Nuclear Licensing Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure G-15 Control of Vendor Manuals n () Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NED l Manager, NLF Manager, NPD Manager, QA l Administrative Procedure G-16 i l l Environmental Qualification of Electric Equipment l Responsible For: Technical / Administrative Services Manager l Authorized By: Manager, NED l Manager, NLF l Manager, NPD l Manager, QA l O FORMtot372 22-3643

G-2 i Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 49 of 78 O SerVICO'PUBUC SERVICE COMPANY OF COLORADO FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure P-1 Plant Operations Responsible For: Station Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure P-2 EquipmentCkearancesandOperationsDeviations - Responsible For: Station Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure P-3 Radioactive / Contaminated Waste / Area Control Responsible For: Support Services Manager Authorized By: Manager, NED Manager, NPD Manager, QA Administrative Procedure P-4 Deleted FORMID)372 22 3643

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 <1 U

FSV PRDCEDURES STRUCTURE LEVEL I Administrative Procedure P-5 Material Control Responsible For: Station Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure P-6 Deleted s 1 Q Administrative Procedure P-7 Work Control Responsible For: Station Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure P-8 Fire Fighting and Prevention Responsible For: Station Manager Authorized By: Manager, NED Manager, NPD Manager, QA Administrative Procedure P-9 Deleted FORM 101372 22 3643

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FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure P-10 Industrial Safety Program Responsible For: Support Services Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure P-11 Recording of Plant Transients Which May Be Considered Operating Cycles Responsible For: Nuclear Fuels and Analysis Manager Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Administrative Procedure P-la Plant Maintenance - Mechanical, Electrical, and Relay Shop Responsible For: Station Manager - Authorized By: Manager, NED l Manager, NLF Manager, NPD Manager, QA Administrative Procedure Q-0 Quality Assurance Policy Responsible For: Manager, QA Authorized By: VP, Nuclear Operations FORM (D)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 52 of 78 s O $9tVIC9' PUBUC SERVICE COMPANY OF COLORADO G FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure Q-1 FSV Organization and Responsibilities Responsible For: Manager, QA Authorized By: VP, Nuclear Operations Administrative Procedure Q-2 Quality Assurance Program Responsible For: QA Operations Manager Authorized By: Manager, QA (V] Administrative Procedure Q-3 Design Control Responsible For: QA Services Manager Authorized By: Manager,QA Administrative Procedure Q-4 Procurement Document Control Responsible For: QA Services Manager Authorized By: Manager, QA Administrative Procedure Q-5 Instructions, Procedures and Drawings Responsible For: QA Operations Manager Authorized By: Manager, OA FORM (Ol372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 53 of 78 OSerVICe* PUBUC SERVICE COMPANY OF COLORADO (. V FSV PROCEDURES STRUCTURE LEVEL I Administ ative Procedure Q-6 Document Control Responsible For: QA Operations Manager Authorized By: Manager, QA Administrative Procedure Q-7 Control of Procured Items Responsible For: QA Services Manager ( O Authorized By: Manager, QA N. Administrative Procedure Q-8 l Identification and Control of Materials, Parts and Components Responsible For: QA Services Manager Authorized By: Manager, QA Administrative Procedure Q-9 l Control of Special Process , Responsible For: QA Services Manager Authorized By: Manager, QA Administrative Procedure Q-10 Inspection Responsible For: QA Services Manager Authorized By: Manager, QA O O I FORM (D1372 22 3643

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V FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure 0-11 Test Control Responsible For: QA Services Manager Authorized By: Manager, QA Administrative Procedure Q-12 Control of Measuring and Test Equipment Responsible For: QA Operations Manager Authorized By: Manager, QA Administrative Procedure Q-13 Handling, Storage and Shipping Responsible For: QA Services Manager Authorized By: Manager, QA Administrative Procedure 0-14 Inspection, Test and Operating Status Responsible For: QA Operations Manager Authorized' By: Manager, QA Administrative Procedure 0-15 Control of Nonconforming Items Responsible For: QA Services Manager Authorized By: Manager, QA O FoRMtol3'2 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION . Issue 21 Page 55 of 78 OSerVice* PusuC SERVICE COMPANY OF COLORADO 7-s ( FSV PROCEDURES STRUCTURE LEVEL I Administrative Procedure 0-16 Corrective Action System Responsible For: QA Operations Manager Authorized By: Manager, QA Administrative Procedure Q-17 FSV Station Vital Records Responsible For: QA Operations Manager p Authorized By: Manager, QA Administrative Procedure Q-18 Quality Assurance Audit and Monitoring Program Responsible For: QA Operations Manager Authorized By: Manager, QA FORM (D)372 22 3843 1

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FSV PROCEDURES STRUCTURE LEVEL II Computer Services Procedures Provides administrative and/or detailed instructions for Computer Services personnel. Responsible For: Technical Services Supervisor Authorized By: Supt. of Technical Services Engineering Controlled Work Procedures Manual (CWP Manual) Provides detailed instructions for the planning and completion of controlled work procedures. Responsible For: Nuclear Site Engineering Manager Authorized By: Nuclear Design Manager Nuclear Site Engineering Manager Engineering Directives (ED) Provides administrative guidance for NED and NLF personnel that are generally non-regulatory in nature. Responsible For: Staff Assistant, Special Projects Authorized By: Any One NED Manager . Any One NLF Manager Engineering Procedures (ENG) Provides detailed instructions for Nuclear Engineering Division personnel. Responsible For: Engineering Services Manager Authorized By: Manager, NED l FORM (D1372 22 3843

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FSV PROCEDURES STRUCTURE LEVEL II Engineering Standards (STD) Provides detailed technical criteria and instructions applicable to both quality related and non quality related activities and materials. Responsible For: Engineering Services Manager Authorized By: Menager, NED Fuel Handling Procedure Manual (FHP Manual) Provides instructions and forms needed to prepare procedures for o Fort St. Vrain fuel handling or fuel deck activities.

  'Y                          Responsible For: Supt. of Technical Services Engineering l                 Authorized By:     Technical / Administrative Services Manager Incorporated       Manual of Ooerating and Emergency Procedures for Radiography Provides operating and emergency instructions / procedures used in Public Service Company's radiography program.

Responsible For: QA/QC Supervisor Authorized By: Health Physics Supervisor QA Services Manager I Maintenance Administrative Procedures (MAP) Provides administrative instructions for Maintenance personnel. Responsible For: Supt. of Technical Services Engineering Authorized By: Superintendent of Maintenance b O l FORM (D)372 22 3843 L

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(3) FSV PROCEDURES STRUCTURE LEVEL II Maintenance Quality Control Inspection Manual (M0CIM) Provides administrative and/or detailed instructions for Maintenance Quality Control personnel. Responsible For: Maintenance QC Supervisor Authorized By: QA Services Manager Material Receipt Inspection Manual (MRIM) Provides specific instructions for QA/QC receiving inspection activities. Responsible For: QA/QC Supervisor Authorized By: QA Services Manager Modification and Procurement Review Manual (MPRM) Provides detailed instructions and checklists for QA/QC personnel. Responsible For: QA Engineering Supervisor Authorized By: QA Services Mana.ger Nuclear Design Manager Administrative Procedures (NDMAp) Provides guidance regarding work performed for or by this department. Responsible For: Nuclear Design Managar Authorized By: Nuclear Design Manager Nuclear Site Engineering Manager i O FORM (D)372 22 3843

G-2 Attach. G-2A FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 59 of 78 O PublicService

  • PUBUC SERVICE COMPANY OF COLORADO V

FSV PROCEDURES STRUCTURE LEVEL II Nuclear Licensing and Fuels Division Procedures (NLF) Provides detailed instructions for Nuclear Licensing and Fuels personnel. l Responsible For: Any One NLF Manager Authorized By: Manager, NLF Nuclear Production Administrative Procedures (NPAP) Provides administrative and/or detailed instructions for Nuclear Production associated activities. O wJ l Responsible For: Appropriate NPD Department Manager Authorized By: Station Manager Support Services Manager Technicas/ Administrative Services Manager l Nuclear Records Management Manual (NRMM) Provides detailed instructions for entry of documents into l various computer systems and transmittal to STAIRS Data Bases. Responsible For: Engineering Services Manager Authorized By: Manager, NED l l Ouality Assurance Auditing Procedures (0AAP) l l Provides guidelines for personnel engaged in formal audit activities related to Quality Assurance. Responsible For: 0A Auditing Supervisor ! Authorized By: QA Operations Manager (q v/ i FORM (Dl372 22 3643 l

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issu2 21 Page 60 of 78 O Service

  • PUBUC SERVICE COMPANY OF COLORADO CS U

FSV PROCEDURES STRUCTURE LEVEL II, Quality Assurance General Precedures (OAGp) Provides detailed instructions for Quality Assurance personnel. Responsible For: QA Operations Manager Authorized By: Manager, QA Quality Assurance Monitoring Manual (0AMM) Provides description of pre planned instructions and checklists used in QA Monitoring Procedures (QAMP's). l Responsible For: Supervisor, QA Technical Support V Authorized By: QA Operations Manager Quality Assurance Operations Procedures (OAOP) Provides specific instri.ctions for Quality Assurance Operations Department personnel. Responsible For: QA Technical Support Supervisor Authorized By: QA Operations Manager Quality Assurance Training Manual (QATM) . Provides policy and instruction for QA'QC t rsonnel training. Responsible For: QA Technit3' St.r .r . Supervisor Authorized By: QA Operations Manager n ( ) l  %/ FORMG372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issuo 21 Page 6I of 78 OSerVlCO* PUBUC SERVICE COMPANY OF COLORADO v FSV PROCEDURES STRUCTURE LEVEL II Quality Control Inspection Manual (OCIM) Provides detailed instructions and checklists for QA/QC personnel. Responsible For: QA/QC Supervisor Authorized By: QA Services Manager Results Procedures - Administrative (RP-A) Provides administrative instructions for Results personnel. Responsible For: Results Engineering Supervisor Authorized By: Superintendent of Nuclear Betterment Engineering Security Administrative Procedures (SAP) Provides detailed instructions on Security Department administrative functions. Responsible For: Security Supervisor Authorized By: Plant Security Officer Site Engineering Manager Administrative Procedures (SEMAP) l Provides guidance regarding work performed for or by this l department. l Responsible For: Nuclear Site Engineering Manager Authorized By: Nuclear Design Manager Nuclear Site Engineering Manager i O 1 FORM (o)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 62 of 78 j 0 Service

  • PUBUC SERVICE COMPANY OF COLORAM Iv FSV PROCEDURES STRUCTURE LEVEL II s

Station Manager Administrative Procedures (SMAp) Provides administrative and/or detailed instructions for Station Manager associated activities. Responsible For: Station Manager Authorized By: Station Manager Support Services Manager Technical /!.dministrative Services Manager Status Keeping Manual (SKM) p Provides detailed instructions for the tracking of Management significant activities. Responsible For: QA Technical Support Supervisor Authorized By: Manager, NED Manager, NLF Manager, NPD Manager, QA Superintendent of Operations Administrative Procedures (SOAP) Provides administrative and/or detailed instructions for Operations personnel. - l Responsible For: Shift Supervisor Authorized By: Superintendent of Operations J FORMID)372 22 3843

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issu'e 21 Page 63 of 78 0 SerVICO' PUBUC SERVICE COMPANY OF COLORADO A (~-) FSV PROCEDURES STRUCTURE LEVEL II Support Services Manager Administrative Procedures (SUSMAP) Provides administrative and/or detailed instructions for Support Services Manager associated activities. Responsible For: Support Services Manager Authorized By: Station Manager Support Services Manager Technical / Administrative Services Manager Technical Services Procedures (TSP) Provides administrative and/or detailed instructions for Technical Services personnel, (a) Responsible For: Technical Services Supervisor Authorized By: Supt. of Technical Services Engineering Technical / Administrative Services Manager Administrative Procedures (TASMAP) Provides administrative and/or detailed instructions for Technical / Administrative Manager associated activities. Responsible For: Technical /Admini'strative Services Manager Authorized By: Station Manager Support Services Manager Technical / Administrative Services Manager Training Directives (TD) Provides detailed administrative instructions to personnel performing work on, or participating in, Nuclear Engineering Division training activities. Responsible For: Engineering Training / Procedures Coordinator

T                           Authorized By:              Engineering Services Manager (V

FORMIDl372 22 3643

                                       - , . _ . _    m

l G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 64 of 78 OService* PUBUC SERVICIE COMPANY OF COLORADO 1 1 FSV PROCEDURES STRUCTURE LEVEL II Training Management Procedures (TMP) Provides administrative guidance for analysis, design, development, implementation, and evaluation of training programs. Responsible For: Superintendent of Training Authorized By: Station Manager Support Services Manager Technical / Administrative Services Manager Training Programs Admisiistrative Manual (TPAM) Provides administrative and/or detailed instructions for training of personnel. Responsible For: Superintendent of Training Authorized By: Station Manager Support Services Manager Technical / Administrative Services Manager I l O FORMIDI372 22 3643 i

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 65 of 78 0 SerVIC9' PUBUC SERVICE COMPANY OF COLORADO 79 C# FSV PROCEDURES STRUCTURE LEVEL III Abnormal Operating Procedures ( A0P) - Provides guidance for system operations under abnormal, but

      '                   non-emergency conditions.

Responsible For: Superintendent of Operations Authorized By: Superintendent of Operations Abnormal Procedures for Shutdown Cooling (APSC) Provides guidance for operating personnel in event of abnormal shutdown situations. Responsible For: Superintendent of Operations l Authorized By: Superintendent of Operations Appendix R Fire Evaluation Procedures (APR) Provides guidance for plant personnel for re-establishing required safety related equipment following fires in selected areas of the plant. Responsible For: Superintendent of Operations Authorized By: Station Manager Cold Checkout Tests (CCT), Functional Tests (FT), and Special Tests Ill Provides detailed test instructions and data sheets for special or nonroutine tests. Responsible For: Fesponsible Supervisor Authorized By: Station Manager l O v FORM fD)372 22 3643 ,

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 66 of 78 OService* PUBUC SERVICE COMPANY OF COLORADO q LJ FSV PROCEDURES STRUCTURE LEVEL III Core Management Guides (CMG) Provides detailed instructions for core management activities. Responsible For: Technical Services Supervisor Authorized By: Technical / Administrative Services Manager Design Directives (DD) Provides detailed guidance regarding various design activities. Responsible For: Nuclear Design Manager Authorized By: Nuclear Design Manager

 '-                                             Nuclear Site Engineering Manager I

l , Emergency Procedures (EP) Provides guidance for Operations personnel in the event of an emergency situation. l Responsible For: Superintendent of Operations Authorized By: Station Manager l Fire Suppression and Prevention Manual (FSP) Provides detailed instructions concerning fire suppression and prevention for specific plant areas. Responsible For: Superintendent of Operations l l Authorized By: Superintendent of Operations O FORM (D)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 67 of 78 O Service

  • PUBUC SERWCE COMPANY OF COLORADO 3

(O F3V PROCEDURES STRUCTURE LEVEL III Fuel Handling Procedure Work Packages (FHPWP) Provides detailed instructions for fuel handling or fuel deck activities. Responsible For: Supt. of Technical Services Engineering Authorized By: Technical / Administrative Services Manager Health Physics Procedures (HPP) Provides detailed instructions for Health Physics personnel. Responsible For: Health Physics Supervisor L' Authorized By: Support Services Manager Maintenance Operating Procedures (MOP) Provides detailed instructions for Maintenance Department personnel concerning the operations and maintenance of auxiliary equipment and tools utilized in the performance of maintenance activities. Responsible For: Supt. of Technical Services Engineering l Authorized By: Superintendent of Maintenance l l Maintenance Procedures (MP) l Provides instructions for specific mai +.enance. Responsible For: Supt. of Technical Services Engineering

Authorized By
Superintendent of Maintenance t

l FORM (D)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 23 Page 68 of 78 O Service

  • Pusuc senwcs company or cotonApo (Oh.

FSV PROCEDURES STRUCTURE LEVEL III Maintenance Procedures, Calibration (MPC) Provides instruction for mechanical calibration activities. Responsible For: Supt. of Technical Services Engineering Authorized By: Superintendent of Maintenance Maintenance Procedures, Electrical (MPE) Provides instructions for specific electrical maintenance. Responsible For: Supt. of Technical Services Engineering Authorized By: Superintendent of Maintenance . Maintenance Procedures, Electrical Calibration (MPEC) Provides instructions for electrical calibratiun. Responsible For: Supt. of Technical Services Engineering Authorized By: Superintendent of Maintenance Maintenance Procedures, Fuel Handling (MPF) Provides instructions for specific fuel handling maintenance. Responsible For: Supt. of Technical Services Engineering l Authorized By: Superintendent of Maintenance Maintenance Procedures, Relay Shop (MPR) Provides instructions for specific relay shop maintenance. l Responsible For: Supt. of Technical Services Engineering Authorized By: Superintendent of Maintenance FORM to)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 69 of 78 O SerVIC9' PUBUC SERVICE COMPANY OF COLORADO A b FSV PROCEDURES STRUCTURE LEVEL III Maintenance Procedures, Security (MPS) Provides detailed instructions for maintenance on security related equipment. Responsible For: Security Supervisor Authorized By: Plant Security Officer Medical Emergency Plan (MEP) Provides guidance for response to medical emergencies. Responsible For: Superintendent of Operations Authorized By: Station Manager Metallurgical Laboratory Procedures (MLP) Provides guidance for Metallurgical Laboratory activities. Responsible For: QA Materials Engineering Coordinator Authorized By: QA Services Manager Operations Orders Provides specialized instructions to Operations Section personnel. Responsible For: Superintendent of Operations i Authorized By: Superintendent of Operations Overall Plant Operating Procedures (OPOP) , Provides guidance on integrated operation of plant systems. Responsible For: Superintendent of Operations Authorized By: Station Manager FORMtD)372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 70 of 78 O SOTVICO' PUBUC SERVICE COMPANY OF COLORADO (3 V FSV PROCEDURES STRUCTURE LEVEL III Plant Engineering Procedures (PEP) Provides detailed instructions and/or guidance for Plant Engineering personnel. Responsible For: Plant Engineering Supervisor Authorized By: Supt. of Technical Services Engineering i Preventive Maintenance Procedures (PM) , Provides instructions for performance of preventive maintenance. (m') Responsible For: Supt. of Technical Services Engineering Authorized By: Superintendent of Maintenance. Preventive Maintenance Security Procedures (PMS) Provides detailed instructions for performing Security related preventive maintenance. Responsible For: Security Supervisor Authorized By: Technical / Administrative Services Manager Radiochemistry Procedures (RCP) Provides specific instructions for radiochemistry laboratory personnel. Responsible For: Radiochemistry Supervisor Authorized By: Support Services Manager FORM (Dl372 22 3843

G-2 Attach. G-2A Public FOF4T ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 71 of 78 0SerVICG* PUBUC SERVICE COMPANY OF COLORADO

 ,m FSV PROCEDURES STRUCTURE LEVEL III Radiological Emergency Response Plan (RERP) - Implementing Procedures Provides detailed guidance for response to plant emergencies.

Responsible For: Technical / Administrative Services Manager Authorized By: Manager, NPD Radiological Emergency Response Plan (RERP) - Plant Provides guidance for response to plant emergencies. Responsible For: Technical / Administrative Services Manager h G Authorized By: Manager, NPD Records Center Manual (RCM) Provides procedures and instructions for records center personnel. Responsible For: Records Center Supervisor Authorized By: Engineering Services Manager Relay Shop Procedures (RSP) Provides detailed instructions for testing and calibrating relays. Responsible For: Supt. of Technical Services Engineering

                                        ^

Authorized By: Superintendent of Maintenance

 /7 V

FORM (of 372 22 3843

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 I OService* PUBUC SERVICE COMPANY OF COLORADO Page 72 of 78 ( \ 'G FSV PROCEDURES STRUCTURE l 1 LEVEL III Results Procedures (RP) Provides detailed inspection, test, and calibration instructions for specific equipment and systems. Responsible For: Results Engineering Supervisor Authorized By: Superintendent of Nuclear Betterment Engineering Safe Shutdown and Cooling With Highly Degraded Conditions (SSCWHDC) Provides guidance for operating personnel for shutdown involving q degraded system performance. Responsible For: Superintendent of Operations Authorized By: Station Manager Security Guidelines (SG) Provides specific instructions and operator aids for operation of Security related equipment and for implementation of Security Procedures and Instructions. Responsible For: Security Supervisor Authorized By: Plant Security Officer Security Instructions Provides detailed instructions for security personnel.

                                                                                ~

Responsible For: Security Superviser Authorized By: Plant Security Officer FoRMiDi372 22 3643

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 73 of 78 0 Service

  • PUBUC SERVICE COMPANY OF COLORADO

(~S 'w) FSV PROCEDURES STRUCTURE LEVEL III Startup Tests (SVT) Provides specific instructions for system testing. Responsible For: Superintendent of Nuclear Betterment Engineering l Authorized By: Superintendent of Operations Surveillance Recuirement Procedures (SR and ESR) Provides detailed instructions for test and calibration of specific equipment and systems for both Technical Specification f-~ and non-Technical Specification required surveillances. l Responsible For: Appropriate NPD Supervisor l Authorized By: Appropriate NPD Superintendent or Technical / Administrative Services Manager i or l Support Services Manager System Operating Procedures (SOP) Provides detailed procedures for plant system operations. Responsible For: Shift Supervisor Authorized By: Superintendent of Operations Training Procedures (TP) Provides detailed instructions for Training personnel. Responsible For: Superintendent of Training Authorized By: Support Services Manager m FoAMiol372 22 3843

G-2 Attach. G-2A Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 21 Page 74 of 78 0 Service

  • PUBUC SERVICE COMPANY OF COLORADO f~)

O FSV PROCEDURES STRUCTURE LEVEL III User Guides (UG) Provides detailed instructions for use of computer data bases for inquiry purposes. Responsible For: Engineering Services Manager Authorized By: Engineering Services Manager Water Chemistry Procedures (WCP) Provides specific instructions for Water Chemistry laboratory personnel. Responsible For: Chemistry Supervisor Authorized By: Support Services Manager Welding Manual (WM) l Provides general instructions for welding activities. Responsible For: QA Materials Engineering Coordinator Authorized By: QA Services Manager Station Manager Welding Procedure Specifications (WPS) Provies detailed instructions for specific types of welding activities. Responsible For: QA Materials Engineering Coordinator Authorized By: QA Services Manager Station Manager O FORM (o)372 22 3643

G-2 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Attach. G-28 0 Service

  • PUBLIC SERVICE COMPANY OF COLORADO e o

V FSV PROCEDURE PAPER FORT sr. VRAIN NUCLEAR GENERATING STATION OPublic Service

  • rueuc senvoca comeram or coumano l

RESPONSISLE FOR AUTHORIZED SY PORC EFFECTIVE RE*AEW DATE DCCF NUMSER ($1 O i ID M B.M O FORMIC)372 22 3643

G-2 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Attach. G-28 O Service'" PUBUC SERVICE COMPANY OF COLORADO ' 7 7g FSV PROCEDURE PAPER roRT sr. vRAIN NUCLEAR GENERATING STATION 0PublicService'- rusuc senvoca conneAm oc cotonAoo O l l 904WeQ 371 23 3M3 FORMIC)372 22 3643 t

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m G-2 FORT ST. VRAIN NUCLEAR GENERATING STATION Attach. G-20 OPublic$9fVIC9"" PUBUC SERVICE COMPANY OF COLORADO 7 of 7g o L. ) v PROCEDURE DEVIATION REPORT (PDR) FORM FORT ST. VRAIN NUCLEAR GENERATING STATICN , , , Pubile k6, 0!^ $gry[CG. Pusuc sanvica COMPANY OF COLORADO PROCEDURE DEVIATION REPORT PAGE h OF h eag as a.a.

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G-8 Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 1 of 15 0 Service

  • pumuc SERWCE COMPANY OF COLORADO
                                                                                                                                                                                                                  ~

O TITLE: COMPLIANCE WITH 10CFR21 REQUIREMENTS RESPONSIBLE AUTHORIZED ,

                                                                                                                                                                                              "        ~
                                                                             ~

PORC EFFEp" f VE REVIEW EORC 7 0 9 JAh 2 0198/ DATv /-J 7-77 DCCF NUMBER (S) h ,I I O FORM (01372 22 3042

G-8 Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 2 of 15 0SerVlCe* PusuC SERVICE COMPANY OF COLORADO v TABLE OF CONTENTS Section Title Page 1.0 PURP0SE...................................................... 3 2.0 APPLICABILITY................................................ 3 3.0 GENERAL REQUIREMENTS ........................................ 3 4.0 PROCEDURE.................................................... 4 4.1 Posting of Reporting Requi rements. . . . . . . . . . . . . . . . . . . . . . 4 4.2 Initial Reporting...................................... 5 4.3 Part 21 Report Evaluation.............................. 5 4.4 NRC Notification ...................................... 7

5.0 REFERENCES

.................................................. 7 6.0     ATTACHMENTS..................................................                        7 l 7.0     COMMITMENTS..................................................                        8 u

I l l l l FORMIDl372 22 3843

G-8 Issue 6 Publi3 FORT ST. VRAIN NUCLEAR GENERATING STATION Page 3 of 15 0 Service

  • PUBUC SERVICE COMPANY OF COLORADO n

( ) 1.0 PURPOSE This procedure describes the method and responsibilities for reporting defects or noncompliances as required by Part 21. 2.0 APPLICABILITY This procedure applies to all personnel associated with the FSV Project. 3.0 GENERAL REQUIREMENTS l 3.1 Title 10, Part 21 of the Code of Federal Regulations [ establishes procedures and requirements for implementation l of section 206 of the Energy Reorganization Act of 1974. l That section requires any individual director or l responsible officer of a facility such as Fort St. Vrain l who obtains information reasonably indicating: l a) That the facility, activity or basic component l supplied to such facility or activity fails to l comply with the Atomic Energy Act of 1954, as l amended, or any applicable rule, regulation, order, l or license of the Commission relating to l substantial safety hazards or l b) that the facility, activity, or basic component l supplied to such facility or activity contains l defects, which could create a substantial safety l hazard, l to immediately notify the Commission of such failure to l comply or such defect, unless he has actual knowledge that l the Commission has been adequately informed of such defect l or failure to comply. l 3.2 The general intent of 10CFR21 is to ensure that the l Commission is made aware of circumstances which.could l generate substantial safety hazards so that an assessment l of the implications and appropriate dissemination of l information to the ramainder of the industry can be made. l 3.3 A " Substantial Safety Hazard", as defined in 10CFR21.3, l means a loss of safety function to the extent that there j is a major reduction in the degree of protection provided l to public health and safety. m FORM (D)372 22 3843

G-8 Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 4 of 15 0 Service

  • PUBLIC SERVICE COMPANY OF COLORADO

( V 4.0 PROCEDURE 4.1 POSTING OF REPORTING REQUIREMENTS 4.1.1 Posting of 10CFR21 related informational material is required in conspicuous locations on Company bulletin boards. Posting of the material is the responsibility of: a) Manager, Nuclear Production b) Manager, Nuclear Engineering c) Manager, Quality Assurance l c) Manager, Nuclear Licensing and Fuels l e) Manager, Materials Management Division 4.1.2 Where practical, the preferred posted material shall consist of the following: a) 10 CFR Part 21 Regulation p v b) Section 206 of the Energy Reorganization Act of 1974. c) Procedure G-8, " Compliance with 10CFR21 Requirements". d) Part 21 Report Forms An acceptable alternative to the posted material is as follows: a) Section 206 of the Energy Reorganization Act of 1974. , b) A notice describing the regulations /proce-dures with directions indicating where the regulations / procedures may be obtained for reference (see Attachment G-8A for typical example). O FORM 101372 22 3M3

G-8 Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 5 of 15 0 service

  • PUBUC SERVICE COMPANY OF COLORADO pb 4.2 INITIAL REPORTING l 4.2.1 Any individual within the Company (including one l working as contractor for the Company) who identifies a defect, or a failure-to-comply with regulatory requirements that creates, or could create, a substantial safety hazard is required to initiate, or cause the intiation of, a Part 21 Report (Attachment G-8B) in accordance with instructions provided on the back of the Form.

4.2.2 Suppliers of safety-related items are required by procurement documents to comply with 10CFR21 requirements and to provide a copy to the buyer as described by Procedure Q-4. Any PSCo individual receiving a copy of a Supplier Defect or Failure-to-Comply item is required to initiate a Part 21 Report, attach the supplier document, and forward l the package to the Technical / Administrative Services Manager 4.3 PART 21 REPORT EVALUATION 4.3.1 All Part 21 Reports are evaluated by The Evaluation p/ w Team consisting of the following or their designated alternates: a) Technical / Administrative Services Manager-Production Division, Evaluation Team Leader. b) Nuclear Site Engineering Manager, Nuclear Engineering Division, i c) QA Services Manager--Quality Assurance Division. 4.3.2 On receipt of a Part 21 Report, the Technical / Administrative Services Manager: a) Logs the Report and date received. b) Assigns a serial number, c) Based on initial review, arranges for the earliest possible meeting of the Evaluation Team which may not be more than five working days after receipt of the Report. O FoRMIDl372 22 3H3 , i _--. __ - - . . . . , _ . - - _ . . , ~ _ , , - _ - - _ _ _ - - - ,. - _ ---_- - ---_ - -

G-8 Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 6 of 15 0 Service

  • PUBLIC SERVICE COMPANY OF COLORADO O l If the reported Defect or Failure-to-Comply has previously been reported to the NRC under a non-Part 21 procedure, no additional report will be necessary provided the other report included all appropriate information required for a Part 21 notification.

4.3.3 The Evaluation Team employs Part 21 Report Evaluation Form (Attachment G-8C) to document and aid in determining if the reported Defect or l Failure-to-Comply should be treated as a 10CFR21 l notification or as a Reportable Event governed by the reporting provisions of the Technical Specifications. I 4.3.4 Following prompt evaluation, if the Team's conclusion is: a) That the reported Defect or Failure-to-Comply is a Reportable Event, the reporting provisions of the Technical Specification are implemented, b) That the reported item does not require 10CFR21 reporting, the Part 21 Evaluation l report (Attachment G-8C) is distributed as required by the Form. c) That a substantial safety hazard was created, the Technical / Administrative Services Manager:

1) Prepares a Part 21 Report to the NRC (AttachmentG-80).
2) Assigns a serial numb'er.

i 3) Drafts and forwards a submittal letter to l the NRC for signature by the Vice l President, Nuclear Operations addressed to the Director, Office of Inspection and l Enforcement, Washington, D. C.and/or the Regional Administrator, Region IV U.S. NRC Nuclear Regulatory Commission (Arlington, Texas). l f 4 r l FonMtois72 22 3eo l

G-8 Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 7 of 15 0 Service

  • Pusuc senvics comeAmy or cotonaoo

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l 4) Distributes copies of the Part 21 l Evaluation Report (Attachment G-8C), as l required by the form.

5) Updates the Part 21 Report Log.

4.4 NRC NOTIFICATION Upon receipt of a completed evaluation package reasonably indicating that a failure to comply or defect exists, the l Vice President, Nuclear Operations (or designated alternate): a) Reviews the contents of the package and the Evaluation Team's conclusion that a Substantial Safety Hazard does exist, b) Within two (2) days following receipt of the evaluation package, makes initial notification to the Director, Office of Inspection and Enforcement l Washington, D.C., or the Regional Administrator, l Region IV, Arlington, Texas, c) If initial notification is by means other than written communication, submits a written report to

O the appropriate of fice within five (5) days b following receipt of the evaluation package. Three copies of the report shall be submitted to the Director, Office of Inspection and Enforcement.

NOTE: Copies of the signed letter and report are distributed within PSC via the normal P-Letter distribution.

5.0 REFERENCES

5.1 Technical Specification AC 7.1.3, " Nuclear Facility Safety Committee" . 5.2 Technical Specification AC 7.5.2, " Reportable Events" 5.3 10CFR21 Regulation, " Reporting of Defects and Noncompliances" 5.4 Section 206, Energy Reorganization Act - 1974 ' 5.5 Procedure Q-4, " Procurement Document Control" 6.0 ATTACHMENTS G-8A - Notice of 10CFR21 Requirements G-8B - Part 21 Report Form G-8C - Part 21 Report Evaluation Form G Part 21 Report to the NRC Form O V FORM (ol372 22 3M3

I G-8 l Issue 6 Public FORT ST. VRAIN NUCLEAR GENERATING STATION Page 8 of 15 O Service

  • Pusue senvice comeAmy or cotonApo O

l 7.0 COMMITMENTS l None

O i

O FORM 101372 22 3043

bA ,

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1

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                                                                        ~

Attach.?C-BA

  • issue 6 Page 9 or 15 i
                                                            . 1DCTR PART 21 REQUIRED POSTING i

A. Section 206 or the Energy Reorganization Act of 1974:

                                                                      " Noncompliance:

Section PO6 (a) Any individual director, or responsible of ficer or a firm constructing, owning, operating, or supplying the components '7 of at y racility or activity which is licensed or otherwise regulated pursuant to the Atomic Energy Act or 1954, as j amended, or pursuant to this Act, who obtains information reasonably indicating that such racilILy or activity-- . (1) rails to comply with the Atomic Energy Act of 1954, as amended, or any applicable rtete, regulation, order, or j license or the Commission relating to substantial safety hazards, or 4 (2) Contains a derect which could create a substantial safety hazard, as derirted by regtelations whicle the Commission shaII p rom:s t ga te, shall immediately notify the Commission or such falltere to comply, or or such defect, tin l e s s such person has actita l knowledge that the Commission has been adequately informed or such defect or railure to j comply. , (b) Any persose who knowiragly and consciously rails to provide the notice required by sesbsection (a) or this section shall he sithject to a civil penalty in an amotent eqteal to the apotent provided by Section 234 of the Atomic Energy Act or 1954, as amended. ) (c) The requirements of this section shall be prominently posted on the premises of any facility licensed or otherwise ] regulated peerstaant to the Atomic Energy Act of 1954, as amended. (d) The Commission is authorized to condtset such reasonable inspections and other enforcement activities as needed to instern compliance witte the provision of this section." i D. Reporting perects and Noncompliance, 10CIR21 1 1 1. Pa rt 21, Title 10 or the Code or rederal Regulations sets forth procedures, controls, and requirements for implementation of the rnergy Reorganization Act of 1974 whereby the directors or responsible orricors or a racility stech as Fort St. Vrain are required to evaluate, and if warranted, to report to the NRC information that is brought to his attention that; a) Indicates the racility, activity, or basic components of the racility rails to comply with the Atomic Energy Act

,                       or 1954 or the Energy Reorganization Act or 19T4 or any applicable rule, regulation, order, or license or the i

Commission relating to substantial safety haza rds, or; b) That the racility, activity, or basic component supplied to the racility or activity contains defects which could create a substantial haza rd . II. To racilitate implementation of these regulations, PSC has developed a procedure, C-8, " Compliance with 10CFR21 Requirements". These procedures provide instructions, guidelines, and reporting forms whereby any PSC individual who has knowledge of defects or activities which could create a substarttial safety hazard can report this information for appropria te evaluation. A copy of the evaltration is returned to the reporting individual. For your reference and use, the procedures and the reporting form can be obtained from the Technical Services Department. Contact the Technical Services Engineering Supervisor. I

G-8 Attach. G-8B Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 6 s 0 service

  • PUBUC SERVICE COMPANY OF COLORADO Page 10 Of 15 i

PART 21 REPORT FORM FORT ST. VRAIN NUCLEAR GENERATING STATION PubilC REPORT EVM.UATCN 0 $9fVlCO Pusuc ssRVICs COMPANY OF COLORADO NO. PART 21 REPORT NOTE: SEE REVERSE SIDE OF FCMM FOR MSTRUCTIONS ON HOW TO COMPLETE THIS FORM. (A) Ininator (Print / Work Locaten Phone (B) Basic Component of ActMty involved (C) Defect or Faaute-to Comply O (D) Subetontial Safety Hazard Created By Defect Or Feilure,to-Comply (D INITIATOR NOTE: SEND THIS COMPLETED PART21 REPORT TO TECHNICAL / ADMINISTRATIVE SERVICES MANAGEM. FORT ST. VRAIN IMMEDIATELY. A COPY SHALL DE GIVEN TO THE wrTIATOM'S IMMEDIATE SUPERVISOM FOR INFORMATION. O ws.mm am FORM (C)372 22.J643

G-8 Attach. G-8B FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 6 0 PublicService- PUBLIC SERVICE COMPANY OF COLORADO Page 11 of 15 h V PARY 21 FORM INITIATION INSTRUCTIONS PART 21 FORM INITIATION INSTRUCTIONS THE FOLLOWING INFORMATION SHALL BE SHOWN ON THE PART 21 REPORT: (A) Write down your nome, work location and phone number., (B) Narne the plant facility, basic component or activy associeted with the defect of failure-to comply. (C) Desenbe the defect, or failure-to comply. (D) Desenbe how you believe the identified defect or failure-to-comply has, or will cause a substantial safety hazard. Qj) NOTE: A SUBSTANTIAL SAFETY HAZARD MAY EXISTIF: A situation could contribute to the release of licensed meteriel. A situation could contribute to public radioactivity exposure exceedmg the calculated ex. posures of FSAR D8 A number 2 by 25 percent. A situation could result in failure of a safety-roisted corr.ponent or of a device to operate. A deficiency in the design, construction, inspection, tesdng.'or use of licensed facility or matenal could downgrede the margin of safety, or cause a safety limit to be exceeded. A situation could result in a failure of the physical security system to meet the approved security plan. IF YOU ARE IN DOUBT AS TO WHETHER THE DEFECT OR FAILURE-TO-COMPLY INVOLVES ONE OR MORE OF THE PREREQUISITES, PREPARE THE PART 21 REPORT AND SUBMIT IT FOR FORMAL EVALUATION BY THE EVALUATION TEAM. j (E' Apply your signature and the date. i J FORMIC 1372 22 3643 (

G-8 Attach. G-8C Public FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 6 0 Service

  • PUBLIC SERVICE COMPANY OF COLORADO Page 12 of 15-10CFR PART 21 REPORT EVALUATION FORM FORT ST. VRAIN NUCLEAR GENERATION STATION NO. P 21 PAGE 1 of I I l A. DESCRIBE DEFECT OR FAILURE-TO-COMPLY l l l l l l l l 1 1 I I 1 I l l l l l l l l l l l l B. PRELIMINARY EVALUATION l l l l ANSWER EACH OF THE FOLLOWING l

( l YES NO l Q] l l

1. o o Safety related plant structure, system, component, part?

l l ll 2. o o Plant features described and taken credit for in l l the FSAR? l l 3. o o Plant features addressed in the technical l l specification? l ll 4. o a Subject of an applicable NRC regulation? l l S. o a Situation is not reportable under the criteria of l ll tech spec AC 7.2c or 7.5.2. l l NOTE: At least one "Yes" box must be checked above for the defect or l l failure-to-comply to have the potential for creating a l l substantial safety hazard. l l l C. DETERMINE IF A SUBSTANTIAL SAFETY HAZARD EXISTS USING l ll THE FOLLOWING GUIDELINES l l l l o A situation which could contribute to the relente of licensed l l material; . l l c A situation which could contribute to pulblic radioactivity l l exposure exceeding the calculated exposures of FSAR DBA No. 2 l l by 25 percent. l l c A situation which could result in failure of a safety related l l component or device to operate. l l c A deficiency in the design, construction, inspection, testing, l l or use of a licensed facility or material which could downgrade l l the margin of safety, or cause a safety limit to be exceeded. l l o A situation that could result in a failure of the physical l l security system to meet the approved security plan. l l o The defect or failure-to-comply meets none of the above criteria. FSV-246-A FOftM(D)372 22 3643

G-8 Attach. G-8C FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 6 0Public SerVlC9' PUBLIC SERVICE COMPANY OF COLORADO Page 13 of 15 PART 21 REPORT EVLUATION FORT ST. VRAIN NUCLEAR GENERATION STATION NO. P 21 PAGE 2 of l l l D. EVALUATION NOTES AND COMMENTS l 1 1 l I l i' l I l' I I I l I l l l l l E. EVALUATION TEAM AND OTHER PARTICIPANTS

                                                                                                          .                                l l

1 2 3 l l I 1 4 5 6 l l l 1 l l l F. CONCLUSION - l The Evaluation Team has concluded o UNANIMOUSLY o BY MAJORITY VOTE l A l that the defect or failure-to-comply described on the attached l i,j l Part 21 Report a DOES o DOES NOT create a substantial safety l hazard. l l - l l l Majority l t (Signature) (Signature) (Signature) l l l l l l Minority l l (Signature) (Signature) (Signature) l ( 1 l l l o REPORT NOT REQUIRED l l l G. PART 21 REPORT TO THE HRC NO. 50-267/ l l l l Evaluation Team Leader l l l (Signature) (Oate) l l l H. REMARKS l l , l l l 1 l l l l DISTRIBUTION: Vice President, Eng/ Plan l lVice President, Nuclear Operations l JNuclear Site Engineering Manager Manager, QA Division l lQA Services Manager (Original) Manager, Nuclear Engineering [ l l Tech / Admin Service Manager Manager, Nuclear Production l l Records Storage Building Manager, Nuclear Lic/ Fuels l lPart 21 Report Initiator Manager, Nuclear Production l Manager, Materials Management l ll Division h d l FSV-246-A l FORM (D)372 22 3643

G-8 Attach. G-8D FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 6 Page 14 of 15-0 Public SGIVlCO* PUBUC SERVICE COMPANY OF COLORADO 10CFR PART 21 FORM FOR REPORTS TO THE NRC FORT ST. VRAIN NUCLEAR GENERATION STATION NO. 50-267/ PAGE 1 of ' I I i1 FACILITY: FORT ST. VRAIN NUCLEAR GENERATING STATION. I I I I2 BASIC COMPONENT OR ACTIVITY THAT FAILS-TO-COMPLY OR CONTAINS A I I DEFECT: l I I I I I l I I I I i  ! I I I I I I I I I I I I I3 IDENTIFICATION OF FIRM CONSTRUCTING THE FACILITY OR SUPPLYING THE I I BASIC COMPONENT OR ACTIVITY THAT FAILS-TO-COMPLY OR CONTAINS A l l DEFECT: 1 i i I I I I I I I I I I I I I I I I I I 4 NATURE OF THE DEFECT OR FAILURE-TO-COMPLY AND THE SAFETY HAZARD I l l WHICH IS CREATED OR COULD BE CREATED BY SUCH DEFECT OR FAILURE- l L l T0-COMPLY: 1 I I I I I I I I 1 I I I I l I l l l l I I I 1 1 j FSV-247-A O V FORM (D)372 22-3643 l

G-8 Attach. G-BD Pubile FORT ST. VRAIN NUCLEAR GENERATING STATION Issue 6 Page 15 of 15 0SerVlCO* PUBUC SERVICE COMPANY OF COLORADO PART 21 REPORT TO THE NRC FORT ST. VRAIN NUCLEAR GENERATION STATION NO. 50-267/ PAGE 2 of I I II5 DATE ON WHICH THE INFORMATION OF DEFECT OR FAILURE-TO-COMPLY WAS I I OBTAINED: I I 1 116 IN THE CASE OF A BASIC COMPONENT WHICH CONTAINS A DEFECT OR 1 i FAILURE-TO-COMPLY, THE NUMBER AND LOCATION OF ALL SUCH COMPONENTS 1 I IN USE AT THE FACIL'TY: I I I I I l l l l l l l 1 I i i I II7 CORRECTIVE ACTION THAT HAS BEEN OR WILL BE TAKEN, THE NAME OF THE I I INDIVIDUAL OR ORGANIZATION RESPONSIBLE FOR THE ACTION, AND THE I I LENGTH OF TIME THAT HAS BEEN OR WILL BE TAKEN TO COMPLETE THE I s l ACTION: I l' I i . I I I

                 !                                                                                I I                                                                                I I                                                                                I Ii8 ADVICE RELATED TO THE DEFECT OR FAILURE-TO-COMPLY ABOUT THE                      I I      FACILITY, ACTIVITY, OR BASIC COMPONENT THAT HAS BEEN, IS BEING            l

, 1 OR WILL BE GIVEN TO PURCHASERS OR LICENSEES. I f I I I I I 1 ( l I I I I I I I l l9 NOTIFICATION TO THE NRC BY: l l I l . l ll R.O. WILLIAMS I I VICE PRESIDENT, NUCLEAR OPERATIONS I 1 PUBLIC SERVICE COMPANY OF COLORADO I I P.O. BOX 840 I l DENVER, COLORADO 80201 1 I I I ' I

               ,1                            (Signature)                            (Date)        l Os              I FSV-247-A I

j FORM (D)372 22-3643

j O Public Service- . . , * . Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 February 3, 1987 Fort St. Vrain Unit No. 1 P-87051 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Docket No. 50-267

SUBJECT:

Procedure Distribution

Dear Gentlemen:

We are transmitting herein revisions to the Administrative Procedures, G-2, Issue 21, G-3, Issue 7 and G-8, Issue 6.If difficulties or questions arise in filing these procedures, please contact Mr. M. H. Holmes at (303) 480-6960. Sincerely,

                               'h s
                            / J. W. ahm Manager, Nuclear Production JWG/sa Attachments cc: Regional Administrator, Region IV ATTN: Mr. M. E. Skow cc: Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain g\

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