ML20207C536

Documents 861204 Discussion W/K Heitner Re Maint Procedures for safety-related & Reactor Trip Sys Components,Per Generic Ltr 83-28.Util Procedures Cover All Mod & Maint Activities & Satisfy Item 2.1 of Generic Ltr 83-28

ML20207C536
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/19/1986
From:	Brey H PUBLIC SERVICE CO. OF COLORADO
To:	Berkow H Office of Nuclear Reactor Regulation
References
GL-83-28, P-86676, TAC-52840, NUDOCS 8612300167
Download: ML20207C536 (2)

Text

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2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 December 19, 1986 Fort St. Vrain Unit No. 1 P-86676 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. H. N. Berkow, Director l Standardization and Special Projects Directorate Docket No. 50-267

SUBJECT:

Generic Letter 83-28 Action Item 2.1

REFERENCE:

1) PSC Letter, Gahm to Johnson, dated June 12, 1985 (P-85204)

2) PSC Letter, Gahm to Berkow, dated October 31, 1986 (P-86610)

Dear Mr. Berkow:

In response to Generic Letter 83-28, PSC submitted information

(Reference 1) related to PSC's identification of Reactor Trip System l

(RTS) components. In Reference 2, PSC further described the use of plant procedures and the identification of safety related equipment in response to Action Item 2.1 of Generic Letter 83-28. In a recent conversation with Mr. Ken Heitner and members of the NRC staff (December 4, 1986) PSC clarified, in some detail, how maintenance procedures are used when work is done on safety related components, including RTS components. This letter documents that discussion.

Fort St. Vrain Administrative Procedure P-7 describes the process for the use of a Station Service Request (SSR) for work authorization, control, and documentation for corrective maintenance and preventive maintenance activities. The SSR package for any individual maintenance project consists of a control document (the SSR form) and 6

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. P-86676 Pag: 2 Decemb r 19, 1986 attachments. Documents which accompany the SSR are procedures, special instructions, excerpts from approved documentation, drawings, and other . supporting information 'as applicable. Procedures and drawings which are attachments to the SSR are controlled, approved, and issued under strict administrative controls.

Procedure _ P-7 specifies the planning, preparation, approval, implementation, and inspection of work done under an SSR. The SSR form, as a control document, requires that certain individuals or organizations indicate that the maintenance work has been controlled and approved. Supporting documentation for an SSR is required by P-7 to be properly assembled. Approved procedures, copies cf controlled drawings, etc. are verified to be appropriate as part of the SSR process. All procedures used on safety related equipment are written to safety related standards, even if they are used for non safety related maintenance. The SSR form - clearly specifies that the maintenance activity is either safety related or non-safety related.

The determination as to whether a piece of equipment is safety related is made by use of a controlled safety related equipment list and controlled drawings. Changes to these documents are made only through the use of a Change Notice package which implements the requirements of 10CFR50, Appendix 8. This single list is the controlling source for safety related equipment. Furthermore, safety related components are identified as such on controlled instrumentation, piping, and control drawings.

A similar procedure (G-9, " Controlled Work Procedures") applies a thorough set of administrative controls to all modification work and selected non-routine maintenance work not covered by Procedure P-7.

Procedure G-9 implements the same types of controls on safety related work as does P-7. Together with other design control procedures, G-9 fully implements the requirements of 10CFR, Appendix B.

PSC is of the opinion that all modification and maintenance activities are thoroughly covered by FSV administrative procedures.

These procedures require proper review, approval, and implementation of activities affecting both safety related and non-safety related components. Furthermore, these administrative controls are fully responsive to the intent of Action Item 2.1 of Generic Letter 83-28.

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

Very truly yours, Wh H. L. Brey, Manager Nuclear Licensing and Fuels Division HLB /DCG:jmt