ML20214R602

Safety Evaluation Opposing Performance Enhancement Program Response to Finding 4-10 of 1984 NRC Assessment Rept

ML20214R602
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/02/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214R594	List: ML20214R592 ML20214R602
References
TAC-62169, NUDOCS 8612080034
Download: ML20214R602 (2)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO THE PERFORMANCE ENHANCEMENT PROGRAM RESPONSE TO FINDING 4-10 0F THE 1984 NRC ASSESSMENT REPORT PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION DOCKET NO. 50-267

1.0 INTRODUCTION

Public Service Company of Colorado (PSC) provided by letter dated July 23, 1986, additional information in respect to Finding 4-10 of the 1984 NRC Assessment Report. Finding 4-10 states that, "the licensee should verify to the staff that the functional acceptability of equipment being returned to service will be checked and/or verified by the Shift Supervisor regardless of the reason surveillance for having testing, removed inspection, the equipment maintenance, frometc.

modification, service (e.g.f." The following is our evaluation of the information provided by PSC in their letter of July 23, 1986.

2.0 EVALUATION Section 5.2.6 of ANSI N18.7-1976/ANI 3.2, Administrctive Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants state. that, "haen equipment is ready to be returned to service, operating personnel shall place the equipment in opoiation, and verify and document its functional acceptability. Attention shall be given to restoration of nonnal conditions, such as removal of jumpers or signals used in maintenance or testing or such as returning valves, breakers or switches to proper startup or operating positions from " test" or " manual" positions.

When placed into service, the equipment should receive additional surveillance during the run-in period."

In addition, the clarification section of Item I.C.6 of NUREG-0737, states that, "for the return-to-service of equipment important to safety, a second qualified operator should verify proper systems alignment unless functional testing can be performed without compromising plant safety, and can prove that all equipment, valves, and switches involved in the activity are correctly aligned." Both of the above positions focus on shift personnel under the direction of the Shift Supervisor taking an active role in verifying the functional acceptability of operating equipment when it is returned to service.

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PSC's response appears to focus on the Shift Supervisor having been notified of a test completion. This notification appears to depend on the fulfillment of procedural requirements completed by other departments. This approach does not fulfill either the ANSI standard or the requirements of NUREG-0737 as noted above. The key factor in both documents is the active involvement of operating personnel in determining functional acceptability. This approach is not reflected in the licensee's letter.

3.0 CONCLUSION

The PSC submittal of July 23, 1986 does not provide assurance that appropriate operating personnel are actively involved in assuring the functional acceptability of equipment being returned to service. There-fore, we find the PSC response to Finding 4-10 unacceptable.

Reviewer: F. Allenspach, DPWRL-B Date: December 2, 1986

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