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Home My WebLink About851192.tiff c,,,t.R REG b<4T UNITED STATES ° W ' NUCLEAR REGULATORY COMMISSION < i REGION IV N '•°e +� y3 611 RYAN PLAZA DRIVE. SUITE 1000 ° ARLINGTON. TEXAS 76011 AUG 2 7 1985 Docket: 50-267 WELD Cf rIT9 Der - II AUG 3 01985 ' Public Service Company of Colorado ATTN: 0. R. Lee, Vice President Electric Production GREELEY. COLO. P. 0. Box 840 Denver, Colorado 80201-0840 Gentlemen: Public Service Company of Colorado (PSC) is required by Supplement 1 to NUREG-0737 to conduct a detailed control room design review (DCRDR) of the Fort St. Vrain Nuclear Generating Station (FSV) . To date, we have reviewed your Program Plan dated July 13, 1983, and provided comments dated November 22, 1983; conducted an in-progress audit at FSV on March 12-15, 1984, and provided an audit report dated May 7, 1984; reviewed the Summary Report (SR) dated April 30, 1985; and met with members of your staff in Bethesda, on July 16, 1985, to discuss the SR. Supplement 1 to NUREG-0737 further requires all licensees to submit a summary report of the completed review outlining proposed control room changes , including proposed schedules for implementation. The licensee is also required to provide a summary justification for human engineering discrepancies with safety significance to be left uncorrected or partially corrected. Based on our review, we have determined that the FSV DCRDR Summary Report does not meet the above stated requirements of Supplement 1 to NUREG-0737. Although our "Preliminary Evaluation of the DCRDR SR ---" (Attachment 2 to Enclosure) indicated that the SR was satisfactory, our subsequent detailed review identified significant shortcomings in the areas of: 1. outlining proposed control room changes 2. proposed schedules for making changes 3. providing acceptable justification for human engineering discrepancies with safety significance to be left uncorrected or partially corrected. The enclosure to this letter contains a summary of the July 16, 1985 meeting. The summary, in addition to providing minutes of the meeting, serves as documentation of our DCRDR effort status and our request for additional information. While PSC personnel at the meeting provided acceptable verbal responses to most of the concerns presented in the summary, the information needs to be documented for us to complete our review. We, therefore, request that you submit a Supplemental Summary Report within 60 days of your receipt of this letter. q/ r' 851192 Public Service Company -2- of Colorado If you have any question on this subject, please contact the NRC Project Manager. Since these reporting requirements relate solely to FSV, OMB clearance is not required under P.L.96-511. Sincerely, Dorwin R. Hunter, Chief Reactor Safety Branch Enclosure: Meeting Summary cc: Mr. D. W. Warembourg, Manager Nuclear Engineering Division Public Service Company of Colorado P. 0. Box 840 Denver, Colorado 80201 Mr. David Alberstein, 14/159A GA Technologies , Inc. P. 0. Box 85608 San Diego, California 92138 Kelley, Stansfield & O' Donnell Public Service Company Building 550 15th Street, Room 900 Denver, Colorado 80202 /Chairman, Board of County Comm. of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency 1860 Lincoln Street Denver, Colorado 80203 Mr. H. L. Brey, Manager Nuclear Licensing/Fuels Div. Public Service Company of Colorado P. 0. Box 840 Denver, Colorado 80201 Public Service Company -3- of Colorado J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 19§ Platteville, Colorado 80651 L. Singleton, Manager, Quality Assurance Division (same address) Colorado Radiation Control Program Director ENCLOSURE [ NRC Meeting with Public Service Company of Colorado Concerning the Detailed Control Room Design Review of Ft. St. Vrain Nuclear Generating Station Public Service Company of Colorado (PSC) submitted to the NRC a letter, _ dated April 30, 1985, with an attached Summary Report of the Detailed Con- trol Room Design Review (DCRDR) for Ft. St. Vrain Nuclear Generating Station. A review of the letter and Summary Report determined that although PSC responded to the concerns raised in the NRC in-progress audit, there remained areas of the DCRDR where additional documentation and discussion were necessary in order to perform a more conclusive review. Although the information provided in the Summary Report concerning HED resolutions and implementation schedules initially appeared to satisfy the Supplement 1 to NUREG-0737 requirements, a detailed evaluation of the Summary Report determined that the proposed HED resolutions and implementation schedules were not final. Thus, the Summary Report may not be accurate of the final proposed control room changes and implementation schedule and therefore did not meet the requirements of Supplement 1 to NUREG-0737. In order to pro- vide a forum for discussion and documentation review, a meeting was held by the NRC with PSC on July 16, 1985 (see Attachment 1 for list of attendees). The agenda followed was essentially that given in SAIC's preliminary evalua- tion report to the NRC of PSC's Summary Report (see Attachment 2). The results of the meeting are presented below as they pertain to each of the nine elements that comprise the NUREG-0737, Supplement 1 requirements for a DCRDR. 1 . Qualifications and Structure of the DCRDR Team The NRC audit team concluded during the in-progress audit performed at Ft. St. Vrain March 12-15, 1985 that the personnel PSC committed to the DCRDR and that their level of involvement in the various activities performed up to that time was adequate. A review of the Summary Report did not find satisfactory information concerning the assignment and levels of involvement for the personnel who performed the remaining DCRDR activities. Specifically, more information was needed on the assignment and levels of involvement for each of the DCRDR team disciplines in the following activi- ties: 1 o Determination and verification of "Information and Control Requirements" and "Specific Requirements". o Assessment of HEDs. o Selection of Design Improvements. o Detailed study of all control and indicator arrangements and groupings. o Verification that improvements provide the necessary corrections without introducing new HEDs. PSC described in the meeting the assignment and levels of involvement of the DCRDR team disciplines as follows: o "Information and Control Requirements" and "Specific Requirements" were determined by the human factors specialist and the CRDR coordinator (instrument and control engineer) with assistance from operations specialists when needed. The requirements identified were verified in the control room by an engineering technician. o HEDs were assessed by the human factors specialist, CRDR coordinator, engineering technician, operations specialists, and a former shift supervisor. o The selection of design improvements, the detailed study of all control and indicator arrangements and groupings, and the verification that improvements provide the necessary corrections without introducing new HEDs were all performed under the Improvement Design Program. This program included the participation of the CRDR coordinator, engineering technician, and operations specialists. The human factors specialist's role was to review the work performed by the other participants. The assignment and level of involvement of the various DCRDR team disciplines in these remaining activities were found to be appropriate. PSC' s capabilities in performing the Improvement Design Program 2 methodologies appeared to be enhanced by a week-long training course provided by its human factors consultants, Search Technology, Inc. The course consisted of a lecture and interactive workshop approach intended to sensitize PSC participants to human factors principles and methodologies. PSC formed a Control Room Systems Review Group (CRSRG) which reviews changes from the DCRDR and future changes to the control room (see Attachment 3). Although a human factors specialist is not part of the CRSRG, human factors guidance is provided for in its review by human factors design guidelines. The disciplines comprising the CRSRG and the provision for human factors guidance in the DCRDR team, the CRSRG human factors design guidelines, and the human factors training course appear to be acceptable for ensuring that control room related changes are reviewed by a multidisci- plinary team. In order to complete NRC documentation on the qualifications and structure of the Ft. St. Vrain DCRDR team, the resume of the human factors specialist will need to be submitted by PSC. 2. Function and Task Analysis, and 3. Comparison of Control and Display Requirements With a Control Room Inventory The NRC audit team concluded during the in-progress audit that PSC had not performed an adequate analysis of information and control requirements and comparison or verification of the requirements in the control room. A review of the Summary Report and accompanying letter found that although PSC • performed an "Information and Control" needs analysis in response to the NRC audit team comments in the in-progress audit report, sample documentation which illustrates this analysis was not included. PSC provided documenta- tion of its analysis in the meeting. The documentation demonstrates that the analysis determined "information and control requirements" (parameters and control functions) and "specific requirements or characteristics" (indicator units, range, resolution and control types, positions, range, and resolution). Examples of PSC's analysis of information and control needs are given below. 3 Procedure step: Identify abnormal core temperature Parameter: average core outlet temperature Characteristics: units - of scale range - 0 - 1000 resolution - +500F Procedure step: Restart circulators on H2O Control functions: H2O block and control valves, circ speed, He flow Characteristics: type of control - throttle positions - open/closed range - 3000 +500 rpm for circ speed resolution - _ I% flow The information and control needs determined from this analysis were subsequently verified in the control room. PSC stated that further evalua- tion of control design, including characteristics such as detented versus spring-loaded control capability, rate, gain, and response, was performed during the detailed study of control and indicator arrangements and groupings conducted as part of the Improvement Design Program. PSC further stated that validation walk-throughs of the three symptom-oriented EOPs allowed further evaluation of the information and control needs as well as of the EOPs steps and actions, operator traffic patterns, and component locations. The analysis of information and control needs and the evaluation of indicator and control design as performed in the verification, valida- tion, and Improvement Design Program activities appears to be quite thorough. However, PSC needs to submit to the NRC sample documentation of the following: o Analysis of information and control needs o Verification of those needs being satisfied in the control room o Validation of EOP steps, actions, information and control needs, traffic patterns , and component locations 4 4. Control Room Survey The NRC audit team concluded during the in-progress audit that the static portion of the control room survey was comprehensive and systematic but that the dynamic portion of the survey (those criteria that require knowledge of the operator tasks in order to be addressed) was not performed on all controls and displays in the control room. In addition, the NRC audit team concluded that the control room survey was not complete. PSC responded to these concerns in the Summary Report and accompanying letter. A review of PSC's response found that although PSC had performed a detailed study of all control and indicator arrangements and groupings, the specific means by which dynamic criteria or principles were systematically applied were unclear. In discussions during the meeting, PSC stated that the dyna- mic criteria had been considered through various activities in addition to the detailed study of control and indicator arrangements and groupings, including the operator survey, EOP walk-throughs, and the CRSRG review and approval of changes. However, a formal or systematic method of application which ensures that all dynamic criteria have been addressed does not appear to have been performed (e.g., checklisting). Although the iterative and thorough process by which PSC selects design improvements lends greater assurance that the control room Improvement Design Program has adequately considered dynamic criteria, documentation which demonstrates this is needed. PSC should provide sample documentation which is sufficient in content and scope to clearly demonstrate how the following activities have considered dynamic criteria or principles: o Operator survey questionnaires (several samples) o EOP walk-throughs (several samples) o CRSRG review (human factors guidelines) o Detailed study of all control and indicator arrangements and groupings PSC stated in the letter accompanying the Summary Report that control room survey items uncompleted at the time of the in-progress audit were subsequently completed or addressed by the more comprehensive effort 5 performed in the detailed study of all control and indicator arrangements and groupings. In order to demonstrate the comprehensiveness of the control room survey in considering static and dynamic criteria, PSC should perform a comparison of NUREG-0700, Section 6 and the FSV control room survey criteria. Those criteria in NUREG-0700, Section 6 that were not covered in the FSV control room survey should be identified, documented, and submitted to the NRC. 5. Assessment of HEDs The NRC audit team concluded during the in-progress audit that PSC's overall assessment approach had not been well defined and should be described in detail in the Summary Report. A review of the Summary Report found that although PSC's assessment process appeared rigorous and systematic, sample HEDs which demonstrate the use of the rating scales to assess and categorize HEDs and definitions of the four assessment categories would provide a clearer presentation of the assessment process. In the meeting, PSC provided sample HEDs that underwent the assessment process (see Attachment 4) and definitions of the rating scales used in the categorization of HEDs (Attachment 5). Using the rating scales in a top-to- bottom sequence, the DCRDR team collectively reached a concensus on the categorization of each HED. PSC's assessment process accounted for cumula- tive and interactive effects of innocuous and significant HEDs by referencing photographs of control room components. Attached to or written on these photographs was information listing all the HEDs associated with the particular component. PSC stated that the consideration of cumulative and interactive effects lead to the upgrading of some HEDs from Category 4 to categories of higher significance. Due to the relative ease of correcting certain HEDs, PSC placed HEDs such as inadequate labeling and meter scaling in Categories 1 or 2 without performing the assessment pro- cess. Labeling HEDs were typically placed in Category 1 and those meter scaling HEDs that weren't safety-related were placed in Category 2. PSC's proposed implementation schedule does not differentiate between the correction of HEDs in the four assessment categories. Due to the integrated approach PSC has taken to determine the corrections of HEDs and develop a control room improvement package, all HED corrections PSC is 6 intending to perform will be implemented prior to start-up following the fourth refueling cycle of FSV scheduled for February of 1987. 6. Selection of Design Improvements, 7. and 8. Verification That Improve- ments Will Provide the Necessary Corrections Without Introducing New HEDs The NRC audit team concluded during the in-progress audit that PSC's plans for selecting and verifying HED corrections should be adequate but that the Summary Report should include a detailed description of the methodology that would be employed. PSC included in the Summary Report of this a description of its Improvement Design Program methodology. A revimethodology found that although a rigorous and integrated approach to determining HED corrections was performed, PSC did not explicitly mention that it verified HED corrections to ensure that no new HEDs were introduced. PSC stated in the meeting that this verification was performed as part of its Improvement Design Program methodology: In the meeting, PSC described its methodology for determining the integrated control panel improved design in which the verification of HED corrections was implicit. Using a series of control panel drawings, PSC took the following steps: o Color coded the type of HEDs or needed changes implicit to correct the HEDs (e.g., label -relabel , inadequate location-relocation, etc.) to provide an overview of the problem. o Color coded components by system to provide an overview of the functional grouping/system layout. o Revised panel drawings to portray the improved panel design. PSC stated in the meeting that the full-scale mock-up of the panels was used in addition to the drawings to develop the improved design. Approxi- mately 12 Design Directives were developed and integrated in the control room improvement program methodology in addition to other improvement pro- grams (e.g., SPDS). PSC stated that the improved panel design as represented in the drawings and mock-up received operations input. A series of Change Notices (CNs) have been initiated to finalize the control room 7 _ improvement package. As part of the CN process, the control room improve- ment package will be verified and validated by the CRSRG (see Attachment 6). The CRSRG will use human factors guidelines applied in a checklist format to perform this V&V activity. The Summary Report lists 28 CNs that have been created to process the improvement design package through the CRSRG and the rest of the plant modification process. The Summary Report lists all the HEDs identified in the DCRDR, the intended corrective actions , and the CN that will correct each HED. PSC states in the Summary Report that some of the HED dispositions are tentative and that these and the CN assignments may be changed. PSC stated in the meeting that any changes that would occur would be from the originally intended correction to a better correction of any particular HED. PSC assured the NRC in the meeting that the nature of the changes would not be from the originally intended correction to a less effective correction or to none at all. In order for the NRC to reach a conclusion on the adequacy of the process and results of the Improvement Design Program and complete its documentation in this area of PSC's DCRDR, PSC needs to submit the following documentation to the NRC: o The 12 Design Directives o The human factors guidelines the CRSRG uses in its review Due to the brevity and ambiguity of HED descriptions and resolutions in the Summary Report, a conclusive review of the HEDs could not be performed. To enable the NRC to conduct an adequate evaluation of HED resolutions and the overall control room improvement design package, PSC should submit documentation which clearly describes the specific discrepancy in each HED, its fix, and any documentation such as control panel drawings which illus- trates the panel design before and after its reconfiguration according to the control room improvement package. 9. Coordination of the DCRDR With Other Improvement Programs The NRC audit team concluded during the in-progress audit that PSC demonstrated its commitment to ensuring the proper coordination of the improvement programs related to the NUREG-0737, Supplement 1 initiatives. 8 However, the NRC audit team suggested that the Summary Report contain a description of how each program was integrated with the DCRDR. A review of the Summary Report found that the coordination of the DCRDR with EOP upgrade and Reg. Guide 1.97 instrumentation review was clearly described. However, the coordination of the DCRDR with the SPDS and training programs was not well described. In the meeting, PSC described the nature of the coordina- tion of the DCRDR with the SPDS and procedures and with training and staffing as well. In order to complete the NRC documentation of the coordi- nation of the DCRDR with other improvement programs, PSC should submit a description of how the DCRDR is being coordinated with training and staffing (other than to resolve HEDs) and the SPDS. In addition, PSC should submit a schedule outlining dates for completion of its NUREG-0737, Supplement 1 initiatives since PSC's integrated approach for conducting improvement pro- grams affects the DCRDR schedule. 10. Other One of the items about which the NRC audit team expressed concern during the in-progress audit was the adequacy of the scope of the historical documentation review. The NRC audit team commented that PSC would benefit from a review of plant historical documents of significant incidents that occurred prior to the one-and-one-half year cutoff established as the extent of the review. PSC provided a response to these comments in the letter accompanying the Summary Report and further discussed this topic in the meeting with the NRC. PSC assured the NRC that human factors related to operator interface involved in past incidents have been covered in the DCRDR through various review activities such as operator questionnaires, control room survey, and task analysis. PSC has included in its review activities a survey and task analysis of the Remote Shutdown Panel . Since the areas of operator interface in the plant include the Remote Shutdown panel as well as the control room, PSC appears to be realizing the benefits its human factors review can provide. 9 SUMMARY The concerns the NRC had from a review of the FSV DCRDR Summary Report were addressed by PSC in the meeting, and the majority of the concerns were resolved. Although some concerns remain from the meeting, most of the action items left to be performed involve providing documentation of previously undocumented and unsubmitted DCRDR information. In order to allow a complete and conclusive evaluation to be made of the FSV DCRDR, PSC should provide the NRC with the documentation listed below. A schedule for submitting this documentation will need to be negotiated with the NRC. The following documentation of the FSV DCRDR will be necessary to complete NRC review: 1. Qualifications and Structure of the DCRDR Team o The resume of the human factors specialist. 2. Function and Task Analysis, and 3. Comparison of Control and Display Requirements With a Control Room Inventory o Sample filled-in data forms of the analysis and identification of information and control needs. o Sample filled-in data forms of the verification of the needs being satisfied in the control room. o Sample filled-in data forms of the validation of EOP steps, actions, information and control needs , traffic patterns, and component locations. 4. Control Room Survey o Sample documentation which is sufficient in content and scope to clearly demonstrate how the following activities have considered dynamic criteria or principles: 10 - operator survey questionnaires (several samples) - EOP walk-throughs (several samples) - CRSRG Review (human factors guidelines) - detailed study of all control and indicator arrangements and groupings o Those criteria in NUREG-0700, Section 6 that were not covered in the FSV control room survey. 6. Selection of Design Improvements, 7. and S. Verification That Improve- ments Will Provide the Necessary Corrections Without Introducing New HEDs o The 12 Design Directives. o The human factors guidelines the CRSRG uses in its review. o A clear description of each HED, its fix, and any documentation such as control panel drawings which illustrates the panel design before and after its reconfiguration according to the control room improvement package. 9. Coordination of the DCRDR With Other Improvement Programs o A description of how the DCRDR is being coordinated with training and staffing (other than to resolve REDS) and the SPDS. o A schedule outlining the dates for completion of its NUREG-0737, Supplement 1 initiatives since the integration of improvement programs impacts the DCRDR schedule. 11 Page 1 of 1 ATTACHMENT 1 Attendees of the Meeting Held July 16, 1985 to Discuss the Fort St. Vrain DCRDR PSC Representatives Dorsey Glenn PSC Michael Maddox Search Technology Michael Niehoff PSC James Selan PSC USNRC Representatives Timothy 0' Donoghue SAIC Ray Ramirez USNRC Ray Roland SAIC Dominic Tondi USNRC Philip Wagner USNRC 12 • ATTACHMENT 2 Page 1 of 3 INFORMAL TECHNICAL COMMUNICATION Date 24 May 1985 TO: R. Ramirez FROM: M.L. Fineberg U.S. Nuclear Regulatory Commission Science nppliaio International Corp. 1710 Good ridge D.C. 20555 McLean, Virginia c Drive 22102 Attention: Ray Ramirez _ Reference: SAIL Project 1-263-02-020-XX NRC Contract NRC-03-82-096 NRC TAC No. 51162 SAIC Task 1-263-07-557-24 Title: Detailed Control Room Design Review Evaluations , Phases III-V Attachment: Preliminary Evaluation of the Detailed Control Room Design Review Summary Report for the Fort St. Vrain Nuclear Generating Station Message: Public Service Company (PSC) of Colorado has submitted to the NRC a letter dated April 30, 1985 with an attached Summary Report of the DCRDR con- ducted for Fort St. Vrain Nuclear Generating Station. The letter and the Summary Report respond to the concerns raised in the NRC in-progress audit report dated May 7, 1985. The Summary Report meets the Supplement 1 to NUREG- 0737 requirements for a Summary Report in that it (1) outlines proposed control room changes including proposed schedules for implementation, and (2) provides summary justification for human engineering discrepancies with safety signifi - cance to be left uncorrected or partially corrected. Although PSC has responded to previous concerns of the NRC in its letter and Summary Report, there remain areas where additional documentation and discussion are necessary in order to conclude on the adequacy of the DCRDR. To provide a forum for discussion and documentation review, we recommend that NRC cc: S. Bajwa SAIC cc: R. Liner M. Fineberg D. Tondi W. Marshall T. O'Donoghue N. Meyer R. Roland Task File 1-263-07-557-24 AT_A; ?E\" 2 °age 2 o- a meeting with PSC DCRDR representatives be held by the NRC. . PSC should have documentation prepared to address the following areas of remaining concern: 1. The assignment and levels of participation for each of the review team disciplines in the following activities : • Determination and verification of "Information and Control Require- ments" and "Specific Requirements" • Assessment of HEDs • Selection of Design Improvements • Detailed study of all control and indicator arrangements and group- ings • Verification that improvements provide the necessary corrections without introducing new HEDs. 2. The determination and verification of "Information and Control Require- " ments" and "Specific Requirements". 3. The detailed study of all control and indicator arrangements and group- ings which evaluated instruments and controls against dynamic criteria. 4. The assessment and categorization of HEDs. The use of the rating scales to assess and categorize HEDs and the definitions of the four categories are unclear. Examples of HEDs representative of the four categories and documentation of the assessment and categorization process for these HEDs would help to clarify this area of concern. 5. The verification that no new HEDs were introduced in the "Improvement Design Program Methodology." 6. The coordination of the DCRDR with the SPDS and training and staffing (other than to resolve HEDs) . The HED descriptions and resolutions provided in the Summary Report were too brief to allow any evaluation to be made. We recommend that PSC provide copies of all of its HED records (HEDE forms) to the NRC in order for a complete evalua- tion to be conducted. In addition to documentation of these areas, PSC should be prepared to discuss the following areas: • The consideration and review of all significant plant transients in the operating experience review and other DCRDR activities. • The assessment of HEDs concerning labels and meters. ATTACHMENT 2 Page 3 of 3 s The determination of the proposed implementation schedule relative to the HED categorization scheme. • The calendar dates attached to the proposed implementation schedule. • The tentativeness of HED dispositions and Change Notices. ATTACHMENT 3 Page 1 of 1 O ¢ Z W E > W Z W W Z OI 8 0 O W Z CD Z W O re H CC tit 7) CD Z 0 8 W W Q CO W > O W W Z Cr I > V cc W W W M .. Cl) 111 CD 0 Z Cr Cn Z CO Q CC Cn CC 0 co t' M Z O O z It Qa CC J CC cc J d a 0 0 0 O 1- 0 Z Z CC 3 0 CCC O O W 0 I- 0 0 Z • Z W • W y N E" W W Wa" 0 FZN Ps CD W CW = _ 11T-n„-ME G Pace _ 0' u PUBLIC SERb :E COMPANY OF COLOR,- 0 FORT ST. VRAIN NUCLEAR GENERATING STATION Log Number e741?‘ HUMAN ENGINEERING DISCREPANCY EVALUATION HEDE - 1 Form 344 22-4228 • REVIEWER NAME DATE c4Wa ,8-4s A. HED TITLE C04,,__ a/. c bonvaia B. ITEMS INVOLVED INSTRUMENT ITEM TYPE NOMENCLATURE LOCATION DATA FILE NO. PHOTO NO. Lt.40.4•- Gssu.t r.d L.��'�// �n►�— 'C/�14 See_ Ella_- ,if C. PROBLEM DESCRIPTIONS (GUIDELINES VIOLATED) i6.44.2441,�rt°.. �� .. 4--1-s.r42.- a4 !/ ernes/ceded D. LIST THE PROCEDURES OR OPERATIONS THAT USE THE LISTED ITEMS IN A MANNER TO INDUCE THE OPERATOR ERROR :err (7 ,4-44 ,o4-ne ��o.�_ � L • £% Z Fps ,+-E f5V /6,4o-e s'& c6CudleirfAJ c ,L.",-1 Pv 4 a9= I N 0 en I H cc W st e- Si 4 p LL A 0 z aL LU W N • W Y I F I J Y en ]C ^ ^ n JO W v in fa v+ 0 %p10 U A C Z l >> i E r W U .1- . OIt O CT CU L CC 01 o r 'O V L •W O a E V7 L '0 Qt O 0 \O 4J W J \ r ID 0 -0 N O C C v .. u J I O 0 n I 2 I vCu I- C N MO Q % - d NNE N HN N en . 4 a a L, et) a • 7 O s- E O V 4 L w g U N. .4 ¢ O N C •- a 0 .0 N0••-- . ✓C Q r+ r0 C! O. U an O A N r i r Qj L P] V L ji n N '0 U U • QC v V ii h -.1 O r0 -0 0 f1 - 116 r7 U 0- • f Z ¢ H lk y cc d f 0- u. ATTACHMENT 4 Page 3 of 8 FORT ST. VRAIN CONTROL ROOM DESIGN REVIEW RED CATEGORIZATION RECORD RED i oG IDk7 LIKELIHOOD THAT HED WILL CAUSE ERROR CAT. 4 I CAT. 1 OR 3 I rS CAT. 1 OR 2 I I (...-I DEFINITELY VERY PROBABLY MAYBE PROBABLY VERY DEFINITELY LIKELY NOT UNLIKELY NOT RESULT OF ERROR (IF UNCORRECTED) CAT. 3 1 �.t I CAT. 1 OR f2 - ' I EXTENDED EXTENDED NO REQUIRES REDUCTION LOSS OF LOSS OF LOSS OP LOSS OF EFFECT ADDITIONAL IN OPER. COMPONENT SYSTEM SYSTEM PLANT STEPS PERFORMANCE FUNCTION FUNCTION FUNCTION FUNCTION EFFECT ON MAINTENANCE AND/OR RESTORATION OF A CSF CAT. 2 1 CAT. 1 I ` c_ I4..,11 1 I I 1 NO POTENTIAL REDUCED LOSS OF LOSS OF EXTENDED PREVENT EFFECT REDUCTION SAFETY SAFETY CSF LOSS OF CSF RESTORATION TO SAFETY MARGIN MARGIN MARGIN REM 11 11 ARKS �� t-i E11 n 4?V TEAM ACTION CATEGORIZATION . 1 2 3 4 NOTE: DISSENTING TEAM MEMBER(S) OPINION NOTED ABOVE ' TEAM MEMBER TEAM ) (BER SIGNATURE CONCURRENCE DATE Team Manager (T) �� ES NO S�� / r CRDR Coordinator (C) DES NO C Veit Homan Factors Spec. , (H)I o F kLz, t f� NO S�� 94- �1 Senior Reactor Operator (S) �7ZJ4..l, j/%/ —r- E� NO 6- 8- NO S/YES Z(y � Engineering Technician (E) 411/1ft-a__ ATTACHMENT 4 Page 4 of 8 N4.6t.1/4. PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION Log Number /1S,O HUMAN ENGINEERING DISCREPANCY EVALUATION HEDE - 1 Form 344 221228 REVIEWER NAME DATE e GA,e,Prrr/'T Kf/EMEA/ p/c,SPY A. HED TITLE /N,S7,f(Z 3tr zracQO p trAcAd Ow/'S it B. ITEMS INVOLVED INSTRUMENT ITEM TYPE NOMENCLATURE LOCATION DATA FILE NO. PHOTO NO .✓S-6.2JOS 4/08/6 w'riSTE SFCE/✓EE _7:0/ Ao--4-93 SiSszlasre soa'E r,INX/Hirt ! . I I I . - i I C. PROBLEM DESCRIPTIONS (GUIDELINES VIOLATED) T-Eu`// 4 .;n':rcK'hd✓E.t/ f1"`tEFt < Y "`F/:� Poi,rir,✓r /c+,r E /rrEl' CNE- rdihec 'rc rivet cJ_ //.Eon'r Bdr r/YEsrs..crctcr ,-4"/"r M,JOE r jTc'P,a' %/E f.,1 O'CLOLt &,I,C L' c-•JLL✓iree es f,, ,r,,'.4rrj K-LV= F.^,e' r?BTel ,9Mt-, -, t'h`c a4n'Nds...'atc,YS WEEK Nor GEsa6NEd FOE rim- r/i'E cFtOdif..MEHT/,PJiEM offl-4rod.. /Fat'rife e //YFst,PA raid /S A/ECESSAA/SEFOFE A Dec/saod to M0J"EY o2 ,QEPLAcE nittst c. ,re Ns /.S aim) (see ArrdcNEo SHEET) D. LIST THE PROCEDURES OR OPERATIONS THAT USE THE LISTED ITEMS IN A MANNER TO INDUCE THE OPERATOR ERROR 145)40(ID ATTACHMENT 4 Page 5 of 8 PUBLIC SERVICE COMPANY OF COLORADO ,. FORT ST. VRAIN NUCLEAR GENERATING STATION ACTION REQUEST No b'� At- Q6¢ DATE S k'-k4 REOUESTOR DEPARTMENT APPROVAL PRIORITY CHARGE NO. � � C01.�c 0e Gt--'A,E).r 141/ St- 5ii1r64 2.,.& c • l oss.maa) (aa.sl os..mas) I..tsl ismI DESCRIPTION .J c ,...,;• _.., f.,T i/.L6B .r-.+...sT o/2 It z, 'La-c a,, 412.e...,_-.....,, JUSTIFICATION ./ d 4.4s.20.644:41_, 4,;,,‘....6464. r 1C_ - -4 M. Y✓L;q_ f'ba A-..' 4Z ,oa..cL` te. iii i ` T.fJ 4:24_,,,,_,_, G tr REMARKS CQ G C coau rs - 84 057C) .Jli RESPONSIBLE DEPARTMENT_� PREPARED BY ESTIMATED COST DEPARTMENT APPROVAL ��— loaw.svaaI Is.nsl I..a.amaaI Ism) - DISPOSITION clirsig�lr'enty Valer-, --;t4?epr PrNOVALS eft✓-•-;ft\lc mad+'.+arid erv". /jam/! , . j� sit loos C asl IIss/a/�n(•)mi{G Ivaw.m aal Ism) Iww.•v••1 Is.sal new tiwl /'�•..1 Is1G..te s aI (0.10 I..s......I Ir.•al ;"d OE '- Ci ,y PUBLIC SERVICE COM•PA�JY OF COLORP 'fO /nom FORT ST. VR.. NUCLEAR GENERATING SILTIOy Log Number s HUMAN ENGINEERING DISCREPANCY EVALUATION IVESTIGATIVE INFORMATIONAL RECORD �/ I DATE . RE VIE WEM NAME _/'1 6/e./✓ /T' f\ 97/0 Cf//J/n� d V A � �.w..w A. HED TITLE _: �f C , _e_2"• B ITEMS INVOLVED ITEM LOC. DESCRIPTION E-1203 P A I NO. /7`..5- 624,C -virtf Aniot etc o sio fi/-6 z T, -4..�..� -/oo s' P/-63 -L C. PROBLEM DDEES-CRIPPTIONS (GUIDELINES VIOLATED) G.t�C� j- V _ FUNCTIONAL DESCRIPTION OR PURPOSE: s€L a- 4191f4-4-SZ IS tA;p „try al e-x2 �� y Z1-e- ar1,4-.. w :u.,:. 4 Pace 7 C` _ wHEn- Hs- eac,r IS HAN,P4(- Tcj) ro r'-E la. O'ctoc /c INLET vALves Hv -bac5--/ ANA my- gaps-a OPEN ON 3071,0 LlQq 'D wASTE etc-zivER. TANt'S T- (.A.ca AND -r-6A03 SKr L / QuiD 4 � +E $qmP Pwp"IPS IA Awl t8 CAN 'T Sc STARTED 3j• H$- . O / OR NS -6a.0a, S-4,aoS CONTACTS PoSlr/o1 ODD c✓e& TANK IS Bo TN TASK lA 1-I c 1 X X ac-a 2 $ X 3-3c. 3 X yc- 9 y s-sc S X 6c-(o C X • wHEnr Ids-1."S is MANIPULATED ro THE ia O'cLoc< Pos/ T.ow) xBor. CAS wASTG 4NRGE TANKS CT-6303 T -63cq) LAN 3E F /LLEb TWRo4C/ INLET pAd vc S H✓ -L- 3 35 A &.+ D Hv- 6336 wH/CN HAVC BEEN OPENED. 14 4. 33S- . CONTACTS POS/Tto& ODD Evc N TANK I'$ fle•-re-/ TANK I I - IG I X ac- a a X 3 X X rgATHER sysrEM AND I LccTAtCAL. c , Rcui rrtr Iv /LL- 5( Re Qvitdb UUU a/a�8 V ATTACH'1ENT 4 Page 8 of 8 PORT ST. VRAIN CONTROL ROOM DESIGN REVIEW RED CATEGORIZATION RECORD . ' RED S 0 (DO Co LIKELIHOOD THAT RED WILL CAUSE ERROR CAT. 4 I CAT. 1 OR 3 I , "I CAT. 1 OR 2 I I i I� L I4{ DEFINITELY VERY PROBABLY MAYBE PROBABLY VERY DEFINITELY NOT UNLIKELY NOT LIKELY RESULT OF ERROR (IF UNCORRECTED) CAT. 3 = 4 CAT. 1 OR 2 � I I I I (C"111 I N I I II EXTENDED EXTENDED NO REQUIRES REDUCTION LOSS OF LOSS OF LOSS OF LOSS OF EFFECT ADDITIONAL IN OPER. COMPONENT SYSTEM SYSTEM PLANT STEPS PERFORMANCE FUNCTION FUNCTION FUNCTION FUNCTION EFFECT ON MAINTENANCE AND/OR RESTORATION OF A CSF CAT. 2 I ,- . CAT. 1 I I 1 14- I NO POTENTIAL REDUCED LOSS OF LOSS OF EXTENDED PREVENT EFFECT REDUCTION SAFETY SAFETY CSF LOSS OP CSF RESTORATION TO SAFETY MARGIN MARGIN MARGIN - REMARKS i t;- _DC /2. TEAM ACTION CATEGORIZATION . C.3 2 3 4 NOTE: DISSENTING TEAM MEMBER(S) OPINION NOTED ABOVE ' TEAM MEMBER TEAM MEMBER SIGNATURE CONCURRENCE DATE Team Manager CT) \tt. A ES) NO I YES NO c<� I'Y CRDR Coordinator (C) Human Factors Spec. (H) /c ` /"C.94. YES YES NO G�z Senior Reactor Operator (S) ,ilk7=1 "/ ,Cf�t( YES ) NO ,� /�� Engineering Technician (E) I ` 1 l'"..---.02..- -- � 4 NO 5/3/ H u e._r�• _ ✓oe Definition of RED Categorization Scale Markings Definitely Not - RED cannot cause operator error under any operational condition. Example: An unlabeled, non-functional switch. Very Unlikely - The operational conditions under which this BED could result in an error requires simultaneous occurrences of multiple low probability events. Example: The letter size for XCR RED lights is below minimum. All other board or equipment indications of a trip have failed and the operator goes to the back board and is unable to associate the illuminated red light with the resultant equipment trip. Probably Not - The BED will cause an error only if operational requirements are changed. Example: Functional tag letter size marginal, however satisfactory from present operator position. Maybe - Insufficient information available to evaluate the likehood that the BED will cause an error . Example: All Westinghouse vertical indicators reflect control room light. Probably - The RED directly affects at least one aspect of system operation. Example: A non-localized audible alarm. Very Likely - The BID directly affects the essence of system operation. Example: An inching valve control that is not marked as such. Definitely - The BED will result in an operator error under any operating situation. Example: Valve switch position markings disagreeing with valve position, i.e. open - closed. ATTACHMENT 5 Page 2 of 3 No Effect - The error has no effect on any plant system. • Example: Operator depresses stop pushbutton for equipment already idle. Requires Additional - The error requires the operator to perform additional Steps steps to bring about the desired result. No harmful effects are caused. Example: ?allure to clear interlocks results in additional hand switch actuation to energize system. Reduction in Operational - The error reduces the range of operating Performance capability of a plant system. Example: Failure to close recirculation line after opening pump discharge. Loss of Component - The error results in a component of plant system being Function incapable of performing its function. Example: Loss of one condensate pump. Loss of System - The error renders a plant system incapable of performing Function its function. Example: Inadvertent isolation of the Helium Purification System. Extended Loss of System - The error renders a plant system incapable of Function performing its function for an extended period of time. Example: He Purification Block Valve operator motor burns out when valve is closed. Extended Loss of Plant - The error precludes timely plant startup. Function Example: Turbine Bearing is destroyed. ATTACHMENT 5 Page 3 of 3 No Effect - Maintenance and/or Restoration of a CSF is unaffected by error. Example: Loss of a service water pump. Potential Reduction - The error would result in the reduction of a safety to margin only in conjunction with other failures. Safety Margin Example: Loss of Purified Helium header occurring in conjunction with the loss of both recirculators in a loop. Reduced Safety - The error will result in a reduction in safety margin. Margin Fr.tple: Single Circulator Trip. Loss of Safety - The error results in a reduction to the minimum degree Margin of redundancy for maintaining a CSF. Example: Three Circulator Trip. Loss of a CSF - The error results in a challenge to a CSF. Example: Four Circulator Trip. Extended Loss of CSF - The error results in a challenge to a CSF without a change far immediate recovery. Example: Loss of all circulator drive motive force except firewater. Prevents Restoration - F and wl in preclude restoringthe of function within the tie allowed. Example: Leaks in both sections of both steam generators. ATTACHMENT 6 Page 1 of 1 PROCESS NEED FOR CHANGE CONTROL PROCESS NEED TO DEFINE AUDIT CRITERIA NEED TO PROVIDE DESIGN BASIS GUIDANCE N DEVELOP DESIGN DIRECTIVES INTEGRATION PROVIDE INTO DESIGN HUMAN FACTORS PROCESS TRAINING $ CN-PROCESS VERIFICATION / DEVELOP BY CRSRG DESIGNER &CRSRG VALIDATION CRSRG - TABLE TOP - WALK THRU J0,,tio REG1/2 UNITED STATES fir, NUCLEAR REGULATORY COMMISSION m ! S REGION IV t OY qq 611 RYAN PLAZA DRIVE, SUITE 1000 4O p° ARLINGTON,TEXAS 76011 AUG 2 7 1985 W In Reply Refer To: Docket: 50-267/85-08 1 AUG 3 01985 Public Service Company of Colorado did/ ATTN: O. R. Lee, Vice President aREELEY, COL°, Electric Production P. 0. Box 840 Denver, Colorado 80201-0840 Gentlemen: This constitutes the appendix to the Systematic Assessment of Licensee Performance (SALP). It consists of: o Your written commitments o A summary of the SALP meeting o Our conclusions, based on your written comments The written comments of Public Service Company of Colorado (PSC) as delineated in their letter serial P-85216 dated July 3, 1985, are enclosed. A meeting summary of the SALP meeting between representatives of PSC and the NRC which was held May 31, 1985, is also enclosed. Based on the review of your written comments, it is concluded that the licensee has a broad recognition of the issues presented in the SALP report and has developed plans to attack these issues. If you have any questions concerning this letter, we shall be pleased to discuss them with you. Since ely, ' a/4r obert D. Martin Regional Administrator Enclosures: As stated cc: Mr. D. W. Warembourg, Manager Nuclear Engineering Division Public Service Company of Colorado P. 0. Box 840 Denver, Colorado 80201 (cont. on next page) / r Public Service Company of Colorado -2- Mr. David Alberstein, 14/159A GA Technologies, Inc. P. 0. Box 85608 San Diego, California 92138 Kelley, Stansfield & O'Donnell Public Service Company Building 550 15th Street, Room 900 Denver, Colorado 80202 Chairman, Board of County Comm. of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency 1860 Lincoln Street Denver, Colorado 80203 Mr. H. L. Brey, Manager Nuclear Licensing/Fuels Div. Public Service Company of Colorado P. 0. Box 840 Denver, Colorado 80201 J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 19i Platteville, Colorado 80651 L. Singleton, Manager, Quality Assurance Division (same address) Colorado Radiation Control Program Director Public Servicew Public Service Company of Colorado P.0. Box 840 Denver, CO 80201- 0840 OSCAR R. LEE VICE PRESIDENT June 25 , 1985 Fort St. Vrain Unit No. 1 P-85216 Regional Administrator Region IV U.S . Nuclear Regulatory Commission 611 Rvan Plaza Drive, Suite 1000 Arlington, TX 76011 Attention: Mr. Eric H . Johnson Docket No. 50-267 SUBJECT : Response to Systematic Assessment of Licensee Performance REFERENCE: NRC Letter from Mr. R. D. Martin to Mr. O. R. Lee dated May 7 , 1985 (G-85171) Dear Mr . Johnson: This letter formally transmits our response to the Systematic Assessment of Licensee Performance (SALP) report for the period October 1 , 1984 through February 26 , 1985. At our meeting at Fort St. Vrain on May 29 , 1985 , we provided each NRC attendee a binder which summarizes our response and describes the Performance Enhancement Program (PEP) which was initiated in early April, 1985 . It is our view that the programs defined in the PEP and other recent organizational changes address those areas requiring improvement per the SALP evaluation. Based upon the SALP report and several other recent audits and evaluations , we have accepted that changes in our operations are necessary to strengthen our performance. We have already taken corrective action in most areas and have made several organizational changes . In addition, seventy-nine new personnel have been approved for the nuclear organization. 04:41) ! ,-, 1‘) Enclosed is the Nuclear Performance Enhancement Program that was provided at the SALP meeting. It includes an outline of our SALP meeting discussions, organizational changes, the PEP Schedule, key materials from our PEP Project Manager' s Binder, and activities in progress division-by-division. At the SALP meeting, PSC agreed to provide the NRC with quarterly updates , as desired, on our Performance Enhancement Program activities . The first status report covering the period of April and May 1985 is being provided by separate correspondence. We trust that this information more than adequately responds to the SALP findings . Sincerely, /4-2-174:5{— R./� Lee, Vid President Electric Production smc PUBLIC SERVICE COMPANY OF COLORADO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE MAY 29 , 1985 AGENDA A. DISCUSSION OF FINDINGS NUCLEAR REGULATORY COMMISSICN B. OVERVIEW OF PSC POSITION R. F. WALKER, PRESIDENT C. ORGANIZATIONAL CHANGES AND O. R. LEE, VICE PRESIDENT PERFORMANCE ENHANCEMENT PROGRAM TABLE OF CONTENTS I. Discussion Outline * Overview of PSC Position * Organizational Changes and Performance Enhancement Program II . Nuclear Organization Charts * Organization Charts by Division * Summary of Additional Personnel III .Performance Enhancement Program Schedule * Bar Chart Schedule IV. PEP Manager' s Binders - Key Materials * Mission Statement and Introduction * Performance Enhancement Program Manual * Performance Enhancement Program Organization and Key Individuals * Project Manager' s Responsibility * Project Status Report Format * Specific Project Manager Instructions and Guidelines V. Divisional Activities A. Quality Assurance Division B. Nuclear Production Division C. Nuclear Licensing and Fuels Division D. Nuclear Engineering Division PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE DISCUSSION OUTLINE MAY 29 , 1985 Overview of PSC Position. * SALP represents a summary assessment over a seventeen month period, ending February 28 , 1985 . * At the end of this period, we have initiated many changes that obviously would not have impacted our performance assessment evaluation. * These changes are responsive to SALP findings , the NRC Audit Report, and the Management Assessment Report. * We have accepted that changes in our operation are necessary. * The cornerstone of our change is The Performance Enhancement Program. * We have made improvements in our organization. Organizational Changes * You may refer to Section II , Nuclear Organization Charts for details of our organization and the additional personnel being added. * The key point is that the changes have been identified and are being implemented (or have been in the last six months) . * Mr. Oscar Lee now reports to R. F. Walker, President and Chief Executive Officer. * A Nuclear Licensing and Fuels Division has been established. This group is the focal point for all NRC interface matters and licensing issues . Regular bi-weekly meetings with the NRC staff are being held. * Management of the divisions has been strengthened through a reorganization that capitalizes on individual ' s strengths . * A General Manager for the Fossil Production Divisions was created to consolidate this function under one person. * Many other divisional organization changes have or are being made. These are described in more detail in Section V, Divisional Activities . Additional Personnel * A deliberate and conservative approach was taken in approving this substantial increase. * They will enhance the capabilities of all divisions. * A major commitment has been made to training in general and achieving full INPO accreditation for the Nuclear Production staff. * Key Licensing personnel are being obtained that have light water reactor experience to assist in relating regulations to our HTGR. * Plant Engineering staff is being added to increase attention to preventive maintenance and engineering analysis of plant equipment. * Design Engineering staff is being increased to provide more effective control and coordination of change and modifications as well as provide a more effective response time for plant support. * A Master Planning and Scheduling function will assist Management in prioritizing and directing the nuclear activities . * Quality Assurance staff is increased to provide greater coverage to audits , training and inspections. * Greater detail of these additions are in Section II , Nuclear Organization Charts . * Naturally, it will take time for this organization to be brought on board and become an integral , productive part of our organization. Performance Enhancement Program * A program of this magnitude and scope is a new approach for Public Service Company. * Our approach to managing this effort is also new. * A special consulting organization has been established to specifically monitor and guide our progress and identify problems . * Individual Project Managers have been assigned to lead each project . * The Project Managers can task persons in other divisions . * A Matrix organization has been established with these Project Managers . * Each Project Manager has been issued a binder to use to organize his project and lay out the ground rules for this important program. Key materials from this binder are included in Section IV, PEP Project Manager ' s Binder. * Progress is reported against each project at least monthly. * Quarterly status reports will be provided to the NRC, if desired. * There are six major projects with 34 sub-projects . * All six of these projects are described in more detail in the text in Section IV, PEP Project Managers Binder - Key Materials . * All 34 sub-projects are shown in Section III , PEP Schedule. It shows the Project Manager and the planned timetable . The entire program is scheduled to be finished in late 1986 . * It is a dynamic program to which new projects will be added. * Project I deals with organizational issues such as establishing the Performance Enhancement Program, defining organizational responsibilities, missions , charters , and the location of our staff. Performance Enhancement Program (Continued) * Project II establishes a Master Planning and Scheduling organization to assist in prioritizing our workload. Divisional planning and scheduling methods will identify realistic resource requirements for major projects . * Project III will establish a preventive maintenance planning and scheduling organization to prioritize the work and issue to maintenance personnel do-able job packets . In addition, the engineering analysis and feedback procedures will be established. * Project IV deals with a substantial upgrade in procedures and policies throughout our organization. * Project V will improve the training in all divisions . A key objective is INPO accreditation. * Project VI will strengthen our conduct of operations at the plant. * We're excited about the potential for major improvements . II . Organization Charts This section contains the current organization charts for the Electric Production organization and a more detailed list of the additional personnel being added by division. 0 n C 6 01 i E 9 t • °10 i . S W i 3 i n n 1 ' P 3 e 00 l ; i Y W i i e e ... r l' 1 n V O F I.yVy P Z aa O < • cE .bi la at -�� e<5 r ..s -i 0 e O e O • air is N °' Ur�e S_ W ma :a. It.' n n v o P N • O 42i W Sa. _Iro ; 1O2 n i �' o I al 0 O 0 0 C 2 a 0 O a e 3 C . 2 ; 5 6Y=- W 0 i 8 I 1ri n O "• n o C - P 0 W a 0 J O W O w E e W 1 ; e . n 0 a es a \ o • / \ - - 0 a - ; § | [ , 2 iii • I Ila 33 I - - • I- ■� ( o \ ilii ct (C �• ' 0 \ ] 0 f Jai ( § / ] \ f ) \ - � I 1V-1 7 & ) k ) LI ) � E � , a / S — ®"4 ® — ri _ n et E / • ! % i3A 01 go ■ / ) {. a t $ f -et., w ry : |"' - tl . 2 fig ` I 41io i ' ( f ) � | :! | fj = , i | ! ' : E. ) t | = a op | et l 7. ir l } .� ! 1st ' � 1 } ■ \ lYe | ! � i IC C o 2 tt a | ! , is. la | Etti et ic t : _ 2 . 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I ■ - 1 § ( I . f .• . . | , � ! \ ; g � g2 , ! _ ! - - § Q ; 2 : • ' § E. ' ilia , ( 4 C. L - C C ,_. C E N L N ta G O L Y. L C N NJ • L Y NJ C CJ C I.w N o 3 C= L .1/4,.... C L N. N.% in N Y - C • L• O CLY WC. er f J L 46. r . . - c E r V> 8 S. >_ Co• — N in C _C fr. L i a a N v r. Y L L . N C c C C C yC i r. L_ 9C L �- 4. J =9 in ~` C O n c I. d C L L ✓ � C C r Y ✓ L. _ L d L. n v. L L _ C L w+ V,iCJ n C in X C LC> I Si C T ` CC V1 N Cu C. C it,an C_ L A Sv1 ` C. i. c c. c. VL . CO Y C. W C C :.. > C C C+ UJ u N + <L„ ✓`+ =L .. L. C: O Z L C CC C u L I. YN = '— _ =L+ C N % — O C a X.c U^ Cu L Z L - < 0 Z _s hn Ch, I: _ c N 1. V U C >+ L f p cirigL L — V Sin -J C L J - •>L C r J - L c N≤� Jr Summary of Additional Personnel Nuclear Production Division 12 - Training personnel to meet INPO Accreditation requirements . 9 - Engineers and Technical Services personnel to help maintain and develop an effective preventive maintenance and failure trending program. 19 - Operations personnel to meet goals in the areas of Scheduling, Planning and Stores. 5 - Programmers and Clerical personnel to support existing staff in these areas. Nuclear Engineering Division 4 - Engineering Services Group Personnel to reduce time engineers spend on administrative/clerical activities. 7 - Engineers and Technicians to provide an overall planning and scheduling function and coordinate NED Diamond Hill and NED Site work with plant operational needs and the overall Priority System. 6 - Supervisor Engineering Personnel to help in backlog of the Nuclear Design groups and the Construction Group. 2 - Engineering supervisors to decrease backlog and coordinate site projects . Nuclear Licensing and Fuels Division 4 - Clerical personnel to support licensing activities. 3 - Licensing Engineering Personnel to provide direction and guidance in the resolution of complex licensing issues that arise and also to prepare the Technical Specification changes and preparation and independent review of licensing correspondence . 2 - Nuclear Licensing Specialist personnel for procedure review and preparation of written safety evaluations and environmental evaluations . 1 - Nuclear Licensing NRC Coordinator to support the enhanced NRC Commitment Control activities. Quality Assurance Division 3 - Quality Assurance Operations Department personnel to develop, implement, and maintain a Quality Assurance Division Training program commensurate with commitments contained in FSAR Appendix B. 2 - Quality Assurance Engineering personnel to administer and implement the Vendor Evaluation Program, Quality Control Training, and accreditation, Inspection Planning and Scheduling, and Quality Engineering functions. Outside Consulting Assistance * Industrial Engineers for plant maintenance and scheduling activities . * Management Consultants for Master Planning and Scheduling. * Nuclear Engineers for developing Change Notices and Controlled Work Procedures. * Management Consultants for evaluation of work force location studies . * Scheduling Consultants for divisional planning and scheduling activites. * Training Consultants for development of divisional and departmental training functions . * Maintenance Engineers for development of Preventive Maintenance programs . III Performance Enhancement Program Schedule The following schedule summarizes the Performance Enhancement Program sub-projects . It reflects the status as of April 30 , 1985. A revised schedule will be prepared at the end of May. I E • • : 8 � t I ., act tie ' -2 paao a ! 11 .2 % 1' r it.: Z a O o N • ee- • 9 � e- I_ e. • L L L I. : N P • . 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This binder was issued to each project manager on April 26 , 1985 during key organizational meetings held at Diamond Hill and Fort St. Vrain. These materials are provided for information purposes . PERFORMANCE ENHANCEMENT PROGRAM FOR PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN - NUCLEAR GENERATING STATION PERFORMANCE ENEANCEMENT PROGRAM PROJECT MANAGER BINDER PERFORMANCE ENHANCEMENT PROGRAM PROJECT MANAGER BINDER TABLE OF CONTENTS *A. PERFORMANCE ENHANCEMENT PROGRAM * I. Mission Statement and Introduction * II. Performance Enhancement Program Manual *III. Performance Enhancement Program Organization and Key Individuals * IV. Project Manager's Responsibility * V. Project Status Report Format * VI. Specific Project Manager Instructions and Guidelines B. MONTHLY PEP STATUS REPORTS C. PROJECT SECTIONS I. Project Description and Definition II. Project Status Reports III. Project Documentation IV. Project Correspondence V. Project Notes and Miscellaneous Material * Included in this Section. A. PERFORMANCE ENHANCEMENT PROGRAM I . INTRODUCTION In PSC' s March 29 , 1965, response to the NRC, we amplified an Action Plan that pertained to addressing several management and operational concerns at Fort St. Vrain. Attached to that response were additional details describing six overall projects (and associated sub-projects) that have been defined as the initial start-up of the Performance Enhancement Program (PEP) . Each sub-project (from hereon is referred to as a project) is identified with the person responsible and the targeted completion dates . A summary bar chart schedule was prepared to summarize the projects . Performance to this schedule will be monitored as part of the Master Planning and Scheduling function that is being established. The Performance Enhancement Program has been established to identify, monitor, and coordinate several projects that are specifically designed to increase the overall conduct of )perations at Fort St. Vrain. The Mission of this program is as follows : "To assign and complete activities that will improve the overall quality, management and operation of the Public Service Nuclear Organization in a controlled, timely manner. Progress will be monitored by the PEP Manager/Master Planning and Scheduling function. The function will provide Senior Management the ability to make proper decisions for allocation of resources and the prioritization of commitments at the appropriate time and in the proper manner. " The Performance Enhancement Program will start with six overall initial projects which encompass PSC concerns , NRC concerns , the recommendations from the Management Assessment Report, and corrective actions that were already underway. The six initial projects are as follows: PROJECT I - ORGANIZATIONAL CONCERNS The purpose of this project is to address the concerns raised in the Management Assessment Report and Section 4 of the NRC' s letter of October 16 , 1984 pertaining to the management of the PSC Nuclear Organization. The actions taken, or in progress , to resolve organizational concerns include restructuring the Electric Production organization to enhance the span of control of the Vice President, Electric Production; establishment of a Performance Enhancement Program for the Nuclear Organizations ; development of organizational charters to include mission and function statements concurrent with updating of related procedures , policies and guidelines ; development of a policy to formalize the transfer of information and communication throughout the nuclear organization; and identification and augmentation of additional resource and manpower requirements for the nuclear organizations . Additionally, an analysis will be undertaken to determine the feasibility of relocating the Nuclear Engineering Division and the Licensing and Fuel Division to the Fort St. Vrain site . PROJECT II - MASTER PLANNING AND SCHEDULING This project will establish a Master Planning and Scheduling function within the Nuclear organization. The function' s purpose will be to provide senior management attention to major project activities and provide a mechanism to prioritize planned projects , allocate resources , and monitor status and schedule of each project. The function will coordinate the activities of the four nuclear divisions to insure adequate resources are assigned and available to scheduled projects in addition to normal workloads of non-project tasks . An overall schedule of projects and events will be defined covering the short and long-term (two to three years) . PROJECT III - ESTABLISH PREVENTIVE MAINTENANCE PLANNING AND SCHEDULING This project will take the existing preventive maintenance program and incorporate a planning and scheduling function. The function will adapt current procedures and computer systems to specifically define maintenance activities , in relation to estimated manpower requirements by skill, required equipment, tools, and materials . Maintenance tasks will be scheduled based upon engineered frequencies and upon available resources . Priorities will be set and evaluated by plant management . Scheduling of maintenance will insure that a significant amount of time is still made available for emergency or unplanned maintenance. Scheduling will also consider the needs of planned outage or construction activities . This program will interface with the Master Planning and Scheduling function, as appropriate for major preventive maintenance programs . PROJECT IV - UPGRADE NUCLEAR POLICIES AND PROCEDURES This project involves six sub-projects , and addresses the development of or revisions to procedures affecting the Nuclear organization. This includes design change/modification procedures and attendant safety evaluations as well as prioritizing implementation tasks; implementation of a commitment control program and attendant procedures; documentation of policies and procedures used in determining commitments; a review of essential regulatory documents to define items PSC must address; an upgrade program for operating, maintenance , and modification procedures ; and the review and revision of exclusion list documents involved in the procurement process . PROJECT V - IMPROVE MANAGEMENT AND NUCLEAR DIVISION PERSONNEL TRAINING Public Service Company of Colorado recognizes the need for highly trained and well qualified management and technical personnel in order to safely and efficiently operate the Fort St. Vrain Nuclear Generating Station. In order to provide this resource , PSC is implementing new training programs and improving existing programs . In concert with cur Corporate Training and Development Department, PSC is upgrading the management skills program to provide an individualized program for each participant by assessing strengths and weaknesses and applying tailor-made improvement programs . PSC is assessing the current level of involvement of the Nuclear Organization staff in various industry groups, with the goals to improve their understanding of common industry problems and solutions and increase their awareness of events external to Public Service Company of Colorado. Training in each of the four Divisions supporting Fort St. Vrain - Nuclear Production, Quality Assurance, Nuclear Engineering, and Nuclear Licensing and Fuels - will be strengthened greatly. Public Service Company of Colorado has committed to achieve INPO accreditation of the training programs , primarily in the Nuclear Production Division . PSC is firmly committed to a comprehensive training program for all personnel associated with Fort St. Vrain. Significant progress has been made toward INPO accreditation. Consistency in the training programs within the Nuclear Production Division is being accomplished by consolidating the program under the Support Service Manager at Fort St. Vrain. PROJECT VI - PLANT CONDUCT OF OPERATIONS This project will address specific improvements within the Nuclear Production Division to improve its conduct of operations . These activities were not identified by the Management Assessment Report, but are based upon NRC concerns and concerns of PSC operations management. The purpose of these activities is to correct the root causes of various NRC observations , most importantly in the area of failure to follow defined procedures . Also, an evaluation of the adequacy of existing facilities will be completed and a plant signage program implemented. During the implementation of the Performance Enhancement Program, these six major projects will be expanded, with additional projects added to insure that Fort St. Vrain achieves a consistent standard of excellence that will be of benefit to our employees , customers , and shareholders . You have been selected to participate in this program as a Project Manager. Your selection was based on your management skills of coordinating all aspects of a particular project. You were not selected to accomplish each project single handedly. You have been given the • responsibility and authority to task others to provide input to you in order to successfully complete your project. The success or failure of your project, the Performance Enhancement Program, and even the future of Fort St. Vrain lies with the ability of each Project Manager to communicate and manage his project in an effective and efficient manner. II . PERFORMANCE ENHANCEMENT PROGRAM MANUAL The management of the Nuclear Organization, including all Division Managers, the Master Planning and Scheduling Function, and Corporate Staff are at your service to assist you in whatever areas you desire . This manual is but a start in that direction. Please use it, correct it, keep it up-to-date, and question it where appropriate . This manual is divided into several sections . The first section pertains to the details of the PEP and your role as a Project Manager. The second section is for you to keep a current status of the program' s progress as a whole and how your particular project (s) fits into the program. The third section relates directly to your particular project (s) . Each project section is further divided into five sub- sections . They are as follows : 1 . Project Description and Definition: This section contains all the information you, or anyone, needs to know about the project. What it is, goals and objectives , schedules , project team organization, specific task identifications , resource allocations , key contact individuals , and any other project specific information you deem appropriate. 2. Project Status Reports : On at least a monthly basis , you will provide status reports on the progress of your project. Copies of each report should be kept here for record keeping. 3. Project Documentation : All drafts and/or final documents prepared for submission for the project should have a copy placed in this section. Where the documents may be voluminous , a control schedule may be used to monitor and control submissions. 4 . Project Correspondence : All letters , memos , and notes to file should be chronologically filed in this section. This would also include telephone conversation reccrd sheets . 5. Notes and Miscellaneous Materials : Photographs , sketches , random thoughts , or anything else pertaining to the project would be found here. PEP op.cAN:-•,"_CN AV- flY :"D:'i::Ca� III. '-' working in a functional capacity As a Project Manager, you will be is a directly for Oscar Lee , who is responsible for the PEP. This normal t: and does not effect your in his manage organization Lee will managerial/supervisory r_le relationship. PEP Manager ardeCar ietGaudreau, PEP management role by Doug Picard, functions s'retu, establiihe. Seto as Cstrdyoutin thehese management of youreproject. Your established to assist in the following respors'b' 1 4 " e`- and authority are described further following section (A.IV.) . ---------------- gu-sic PRODUCTION 0. R. LEE -- PRODUCTION pcAL:TY ASSURANCE l }ER}ORNAN : SERVICE EfNAMPAGEZ•VT COORDINATOR LEE SINGLETON PROGRAM MANAGER D.D. N. C. - 7 VS= , PROJECT I PLANNING i R�1llAGLFS I AND I I SOLING , I I • NCGLAR LVGINEERING NDUCTIO LICENSING i TDELS PRODUCTION DON xAALM3C:'RG LARRY SREY JACR GAM PERFORMANCE ENHANCEMENT PROGRr.N. KEY INDIVIDUALS LOCATION Telephone O. R. Lee Diamond Hill 571-7105 DIVISION MANAGERS Larry Brey Diamond Hill 571-8404 Don Warembourg Diamond Hill 571-7214 Jack Gahm Fort St. Vrain 785-1200 Lee Singleton Fort St. Vrain 785-1350 CONSULTANTS/SUPPORT Carrie Gaudreau Diamond Hill 571-7107 Jan Stufflebeam Diamond Hill 571-7108 Doug Picard VZM 571-7107/08 Mike Zachary VZM 571-7107/08 Dave Miller VZM 785-1364 Don Kelly VZM 785-1364 John Wogge Stoller Dave Goss Diamond Hill 571-7795 PROJECT MANAGERS Carrie Gaudreau Diamond Hill 571-7107 Jack Gahm Fort St. Vrain 785-1200 Don Warembourg Diamond Hill 571-7214 Chuck Fuller Fort St. Vrain 785-1202 Frank Novachek Fort St. Vrain 785-1201 Jack Reesy Diamond Hill 571-8406 Mike Holmes Diamond Hill 571-8409 Lee Singleton Fort St. Vrain 785-1350 Larry Brey Diamond Hill 571-8404 Ted Borst Fort St. Vrain 785-1203 Doug Picard Diamond Hill 571-7107/08 Mike Zachary Diamond Hill 571-7107/08 Martin McNulty Headquarters 571-3265 PERFORMANCE ENHANCEMENT PROGRAM PROJECT MANAGER RESPONSIBILITIES Essentially, a Project Manager is responsible for completing his/her project on schedule, within the proper scope, and in a quality manner. The PEP Manager/Master Planning and Scheduling function will assist you in the planning, scheduling and monitoring of yours and other PEP projects. Each Project Manager must follow some proven project management techniques . Key ones applicable to this program are described below. 1 . Development of Project Work Plans and Schedules Prior to any work on the project, a work plan should be prepared. The plan should define the desired deliverables (the end product such as procedures , policies , documents, etc) , the detailed step-by-step work tasks (or activities) , manpower estimates (man- days of "doing" time) , persons and/or skills required for each task, and the sequence in which the tasks (prerequisites and interdependencies) will be completed. Based upon the resources available , the overall project schedule can be prepared. Key milestones and their deliverables are identified and then tracked by both the Project Manager and the PEP Manager/Master Planning and Scheduling function. It is the responsibility of the Project Manager to communicate the status of his project. 2. Control of Deliverables The Project Manager should carefully identify and monitor the preparation of deliverables or end products . Depending upon the scope of work, control schedules should be prepared. For example, for Project 1I1 . 3 - Develop Preventive Maintenance Engineering Program, a detail schedule of the procedures being developed (or revised) should be prepared. It would show the procedure, the estimated manpower, person responsible for the procedure and the status (e.g. , preliminary draft, technical review completed) . The control schedule would be constantly updated by the Project Manager . It is the responsibility of the Project Manager to insure the deliverable is in the highest state of quality and is accurate. This includes scheduling for independent reviews , graphics , printing, etc . 3 . Obtaininc Resources for Project Tasks The Project Manager is responsible for getting the proper manpower, equipment, and materials to complete all project tasks. In some cases , these resources will be from other divisions or departments and the Project Manager will have to work through the proper division or department head in order to obtain the desired resources. Should a problem surface at this point, the PEP Manager/Master Planning and Scheduling function will be involved to work out priorities and line management will obtain additional divisional resources as required. 4 . Revising Project Work Plans Any changes to the project scope or tasks should be reflected in current work plans . Additionally, modified or deleted tasks (with justification) should be included in an updated Work Plan . The revisions affecting the overall schedule and milestones should be then provided to the Master Planning and Scheduling function. 5. Report Project Status The Project Manager must report the status of the project on a monthly basis in writing. Status reports will be submitted as deemed necessary by the Project Manager and the PEP Manager/Master Planning and Scheduling function, but not less than at the end of each month. The format identified in Section A.V. should be utilized. Additionally, progress should be indicated on the Current Schedule computer printout by activity showing for each percent complete, change in duration, additional activities representing delay items , or modified prerequisities . The first status report is due Tuesday, April 30 , 1985 and the second or. Wednesday, May 15, 1985 . PERFORMANCE ENHANCEMENT PROGRAM VI . SPECIFIC GUIDELINES AND INSTRUCTIONS 1 . Project Description: Review for accuracy and completeness . Insure that the project is a real one and has a priority for completion. Understand fully what the end product or deliverable will be , what form it should be in, and when is it required. 2. Project Work Plans : Review for accuracy in terms of completeness and that all key activities have been identified. When scheduling individual work plan activities insure that prerequisites are identified and that each activity has a duration in terms of elapsed working days (or weeks) . 3 . Project Schedule : This relates closely to Item 2 above but clarifies that durations of individual activities should not be keyed directly to man-day estimates but should allow for the fact that an individual may not be able to concentrate all of his efforts at one time. For example: Writing a procedure may take 2 man-days of effort spread out over a 10 working day period. You should then use 10 working days as the duration of the activity. Also, insure each deliverable has an identifiable milestone . The activities should be reviewed and . milestones identified. 4. Project Status Report: Submit "Project Status Report" on a periodic basis (minimum once/month) with "Current Schedule" marked up in red to reflect changes in duration, percent complete , and/or activity description . The "Project Status Report" should be filled out showing work completed (by task, ID number/name, when and by whom) , the planned activities for immediate work to be accomplished, and any problems encountered. Problems encountered may range from a lack of resources, changed priorities , incomplete prerequisities cr any item that will affect your ability to meet the schedule. Revised work plans should also be submitted at this time. PERFORMANCE ENHANCEMENT PROGRAM V. PROJECT STATUS REPORT PROJECT: PROJECT MANAGER: Date: Status As Of: Work Completed Since Last Report: (Attach Work Plan Updates) Planned Activities : Problems Encountered: V Divisional Activities The following describe in more detail the work under way in each of the Nuclear Divisions . The division materials describe in more detail the organization changes , specific involvement (and accomplishments) in the Performance Enhancement Program (PEP) and other pertinent activities underway prior to forming the PEP. A. Quality Assurance Division B. Nuclear Production Division C. Nuclear Licensing and Fuel Division D. Nuclear Engineering Division A. Quality Assurance Division I . Organizational Changes * Major organization changes include transfer of the Maintenance Quality Control Unit to the Quality Asssurance Division to provide further independence in performing Quality Control functions and transfer of the Records Center Administration to the Nuclear Engineering Division. * Six new positions were created within Quality Assurance Division during this period. * The additional personnel will support the upgraded Quality Assurance Division training program which reflects the latest INPO and industry guidelines and standards , provide an improved Quality Assurance indoctrination and training program to personnel within the Nuclear Project, and support the maintenance planning and engineering functions . These preceding functions are delineated in the PEP. II . Performance Enhancement Program Activities include : * Upgrading and improving the Quality Assurance Division' s training program and Quality Assurance indoctrination and training program for Nuclear Project personnel with emphasis on INPO accreditation guidelines and criteria. . * Revising the Quality Assurance Division ' s Charter to provide detailed mission and function statements . * Establishing a Quality Assurance function to identify manpower requirements and priorities to schedule division activities. * Reviewing the Exclusion List at Fort St. Vrain governing material access to the site. This will be evaluated, and incorporated into the Fort St. Vrain Administration Procedures Manual as appropriate . In addition, the consultant' s recommendations on procurement will be reviewed, and procedures will be revised as necessary. III . Other Activities in Progress * The Quality Assurance Division has emphasized that time will be devoted to procedure review and training to eliminate root causes for failure to follow procedures. * In order to provide the independence necessary to effectively implement the Quality Assurance Program, all Section Q Administrative Procedures, except O-0 and Q-1 , will be authorized solely under the signature of the Manager, Quality Assurance Division. * A revision to the Administrative Procedures Manual Q-16 , Corrective Action System, has been prepared to address a CAR escalation system. * A review of Quality Assurance receiving inspection procedures will be made and procedures will be provided or revised, as needed, to address inspection requirements . * To provide additional emphasis on and enhance the Maintenance Quality Control Program, an evaluation will be undertaken. * The Quality Assurance Operations Department will further expand the monitoring activities to supplement the areas that are presently covered by the Quality Assurance Audit Program and the Nuclear Facility Safety Committee Audits. * A review of safety related procedures and changes to verify conformance to applicable quality requirements was started in the Quality Assurance Division in January, 1985. * The procedures needed for the review by the Quality Assurance organization of the content and adequacy of the Technical Specification Procedures has been issued. * The review of the Technical Specification Surveillance Requirement (SR) Test Procedures , excluding the Environmental Surveillance Requirements (ESR' s) , will begin in conjunction with the implementation phase of the SR Test Program. B. Nuclear Production Division I. Organizational Chances * The Management of the Nuclear Production Division has been strengthened through a reorganization that redistributes areas of responsibility and capitalizes on individual ' s strengths . * The reorganization change required the addition of 45 technical, training, maintenance, operations , and clerical personnel. * The Support Services Department was created on September 1 , 1984 . The Water Chemistry and Training Units were moved into this department from the operations area. In taking this action, the span of control of the Station Manager was tightened, which has allowed him to concentrate his attention on the operation and maintenance of the facility. * A Scheduling, Planning, and stores organization has been expanded to implement and provide increased attention to the areas of long term planning/ preventive/ predictive maintenance and outage scheduling, and material control. * The Technical Services organization is being expanded to improve management oversight and control and implement a comprehensive preventive/predictive maintenance and failure trending program. * The Training organization is being expanded to accomplish the requirements of INPO accreditation and more importantly, provide the needed performance based training to ensure that plant personnel are well qualified to perform their assigned tasks . * Responsibility for fuel handling activities has been moved to the Technical/Administrative Services Department. This will allow for better coordination with preventive maintenance, spent fuel shipping, and core management programs . II . Nuclear Performance Enhancement Program Activities * A Division Charter has been written which delineates responsibilities and eliminates confusion and redundancy. * A comprehensive preventive/predictive maintenance program is being developed to control and monitor maintenance activities associated with equipment essential for reliable plant operation. * A Planning and Scheduling organization is being implemented, and procedures are being developed to coordinate preventive/predictive maintenance and long term outage activities . * All Division procedures are being reviewed using the INPO Good Practice for adequacy, content, human factors , and format, in order to prevent further problems with procedural compliance . Special attention is being given to Systems Operating Procedures , Maintenance Procedures , and Results Procedures. * Initial and continuing training programs are being developed to meet Public Service Company of Colorado' s commitment to the NRC through Resource Committee (NUMARC) to have all training programs ready for accreditation by the Institute for • Nuclear Power Operations (INPO) by December 31 , 1986. * Management visibility and involvement is being increased through establishment of a plant tour procedure and a comprehensive housekeeping program. * Aggressive actions are being taken to improve Conduct of Operations in the areas of Procedural adequacy and compliance, management responsibilities, operator aids and plant signage, work planning, shift turnover, training, independent verification, Station Service Request (SSR) backlog reduction, and corrective actions, and Controlled Work Procedure (CWP) control improvement. Integration of these components into a comprehensive program will provide positive steps to improve the day-to-day operation of the plant. * A preliminary Facilities Planning report has been completed which addresses the adequacy of the plant facilities 'based on the current plant staff level and anticipated future growth. * A Comprehensive Water Chemistry get well program is being implemented to correct deficiencies noted in previous NRC, INPO, and PSC QA audits . A total of 1126 person days is projected to be necessary to complete this program. III . Other Activities in Progress * Communications within the Division are being improved through the implementation of weekly staff meetings at all levels . These meetings provide the opportunity to communicate policies , goals and objectives, discuss current work activities , and receive feedback from the performance level. All meetings are documented for follow up of open items and future reference. * Several program changes are being implemented to improve our Emergency Response Capabilities in the areas of facility upgrade, training improvements, and the utilization of "dress rehearsal" exercises . An extensive advertising and door-to- door personal contact campaign has been initiated to improve the effectiveness of the Early Warning Alert System. C. Nuclear Licensing and Fuels I . Organizational Changes * In September, 1984 , a Licensing Department was established to serve as a central focal point for all NRC interface matters . * In March, 1985 a new division (Nuclear Licensing and Fuels) was created to handle licensing issues. * In November, 1984 , a Nuclear Licensing Operations Unit was established at the Fort St. Vrain site to address site licensing issues . * Executive Management approval has been given to the addition of nine additional personnel to the Licensing organization. * Temporary personnel are being used to backfit and input selected NRC/PSC correspondence into a computerized licensing document/correspondence data base . II . Performance Enhancement Program Activities * A systematic review of NRC documents will be undertaken, utilizing personnel with light water reactor backgrounds . * An improved system for controlling NRC commitments will be developed. * Improvements will be made in the review and input cf "P" correspondence into a computer data base . * The licensing review and safety basis for new Technical Specifications will be improved. * Improved safety analysis reports for new and revised procedures and tests will be prepared . * A training program for Nuclear Licensing and Fuels personnel is being established. III . Other Activities in Progress * All Fort St. Vrain Technical Specifications have teen reviewed and substantial revisions have been submitted to NRC in order to upgrade and standardize them with the Nuclear power industry. * In addition to daily telephone contact, bi-weekly face-to-face meetings between the Nuclear Licensing and Fuels Division Manager and the NRC were initiated in April 1985 . D. Nuclear Engineering Division I . Organizational Changes * Additional personnel to monitor contractor activities to better coordinate operations maintenance/construction interface . * Establish a second engineering group with Site Engineering to provide better response to plant activities for design or technical support. * Establish a Divisional Planning and Scheduling function to provide coordination of design efforts with plant operation, maintenance, and outage activities . * Establish a training/procedures group to provide training and retraining with the objective of procedural adherance, and to review, revise and issue procedures to effect better overall procedure control. * Establish a Special Projects Department to reduce the engineering backlog of work, provide direct assistance to the Engineering Division Manager, and technical support for activities needing immediate attention. * Overall, the organizational changes required the addition of 21 technical, training, and clerical personnel. II . Performance Enhancement Program Activities * Provide management control, through a Planning/Scheduling function, to coordinate the design, material delivery, and construction activities to be responsive to Plant needs for operation, maintenance , planned and unplanned outages. * Establish a Priority System to all modification work to permit better allocation of resources to accomplish modification activities . * To provide orientation, training, and procedure review, a group is being established with the charter to provide the required procedure training, technical training as appropriate, and procedure review with the objective of improving procedure adherance. * A Task Force has been established to review and simplify the modification process , to eliminate redundancies , and improve overall implementation and response to Plant needs . * Establish a schedule whereby all Nuclear Engineering Procedures will be reviewed and revised to assure procedural compliance with regulations , consistency, eliminate redundancies , simplification where possible all in the interest of improving response and procedural adherance . * An overall study is being performed by a consultant to determine if consolidation of all Nuclear activities at the Fort St. Vrain site is warranted. * Charter/Mission Statements have been established for each Division, Department, and Unit to better define areas of responsibility and authority to eliminate redundancies and duplication of efforts , and to enhance communication and coordination of activities. Meeting Summary Date: May 31, 1985 Place: Fort St. Vrain site, Platteville, Colorado Prinical Attendees: NRC: R. D. Martin E. H. Johnson G. Lainas P. Wagner J. Taylor PSC: R. Walker 0. Lee L. Brey J. Gahm L. Singleton Summary: The NRC briefed the SALP report orally. Copies of the slides used are attached. The licensee also made a presentation of the performance enhancement program; a copy of the material is attached. UNITED STATES NUCLEAR REGULATORY COMMISSION SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION OCTOBER 1 , 1983 - FEBRUARY 28, 1985 SALP PROGRAM OBJECTIVES IMPROVE LICENSEE PERFORMANCE PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES IMPROVE NRC REGULATORY PROGRAM PERFORMANCE ANALYSIS AREAS FOR OPERATING REACTORS PLANT OPERATIONS RADIOLOGICAL CONTROLS MAINTENANCE SURVEILLANCE FIRE PROTECTION EMERGENCY PREPAREDNESS SECURITY AND SAFEGUARDS REFUELING LICENSING ACTIVITIES TRAINING QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY DESIGN, DESIGN CHANGES, AND MODIFICATIONS FUNCTIONAL AREA PERFORMANCE CATEGORY CATEGORY 1 REDUCED NRC ATTENTION MAY BE APPROPRIATE , LICENSEE MANAGEMENT ATTENTION AND INVOLVEMENT ARE AGGRESSIVE AND ORIENTED TOWARD NUCLEAR SAFETY; LICENSEE RESOURCES ARE AMPLE AND EFFECTIVELY USED SO THAT A HIGH LEVEL OF PERFORMANCE WITH RESPECT TO OPERATIONAL SAFETY OR CONSTRUCTION IS BEING ACHIEVED. CATEGORY 2 NRC ATTENTION SHOULD BE MAINTAINED AT NORMAL LEVELS , LICENSEE MANAGEMENT ATTENTION AND INVOLVEMENT ARE EVIDENT AND ARE CONCERNED WITH NUCLEAR SAFETY; LICENSEE RESOURCES ARE ADEQUATE AND ARE REASONABLY EFFECTIVE SO THAT SATISFACTORY PERFORMANCE WITH RESPECT TO OPERATIONAL SAFETY OR CONSTRUCTION IS BEING ACHIEVED. CATEGORY 3 BOTH NRC AND LICENSEE ATTENTION SHOULD BE INCREASED, LICENSEE MANAGEMENT ATTENTION OR INVOLVEMENT IS ACCEPTABLE AND CONSIDERS NUCLEAR SAFETY, BUT WEAKNESSES ARE EVIDENT; LICENSEE RESOURCES APPEAR TO BE STRAINED OR NOT EFFECTIVELY USED SO THAT MINIMALLY SATISFACTORY PERFORMANCE WITH RESPECT TO OPERATIONAL SAFETY OR CONSTRUCTION IS BEING ACHIEVED. TREND IMPROVED: LICENSEE PERFORMANCE HAS GENERALLY IMPROVED OVER THE COURSE OF THE SALP ASSESSMENT PERIOD . SAME : LICENSEE PERFORMANCE HAS REMAINED ESSENTIALLY CONSTANT OVER THE COURSE OF THE SALP ASSESSMENT PERIOD. DECLINED: LICENSEE PERFORMANCE HAS GENERALLY DECLINED OVER THE COURSE OF THE SALP ASSESSMENT PERIOD. EVALUATION CRITERIA 1 , MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY. 2 . APPROACH TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT. 3 , RESPONSIVENESS TO NRC INITIATIVES . 4. ENFORCEMENT HISTORY, 5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS. 6, STAFFING ( INCLUDING MANAGEMENT) . 7. TRAINING EFFECTIVENESS AND QUALIFICATION . STRENGTHS MANAGEMENT ATTENTION TO UPGRADING FSV STRONG ALARA CONTROLS WEAKNESSES MANAGEMENT CONTROLS IN FUNCTIONAL AREAS OF : OPERATIONS MAINTENANCE LICENSING ACTIVITIES QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY DESIGN, DESIGN CHANGES, AND MODIFICATIONS LESS FORMAL MODE OF OPERATION THAN IS COMMON AT OTHER NUCLEAR POWER PLANTS IMPLEMENTATION OF PROGRAM REQUIREMENTS IN QUALITY ASSURANCE AND DESIGN CONTROL PLANT OPERATIONS CATEGORY 3 (SAME) INCREASED AND VIGOROUS MANAGEMENT ATTENTION IS REQUIRED EMPHASIS ON REDUCING PROCEDURAL VIOLATIONS INCREASE MONITORING OF PLANT OPERATIONS CONTINUE EFFORTS FOR IMPROVING TECHNICAL SPECIFICATIONS AND OPERATING PROCEDURES RADIOLOGICAL CONTROLS CATEGORY 1 ( IMPROVED) ASSURE RPM IS NOT OVERLOADED REVIEW CHARCOAL CARTRIDGE MEASUREMENTS UPDATE TRANSPORTATION PROCEDURES ASSURE UNPLANNED/UNMONITORED RELEASES DO NOT OCCUR MAINTENANCE CATEGORY 3 (DECLINED) MANAGEMENT ATTENTION ON WEAK AREAS STRENGTHEN OVERALL MANAGEMENT CONTROLS SURVEILLANCE CATEGORY 2 (SAME) ENSURE ACCURACY OF SURVEILLANCE PROCEDURES PURSUE TS UPGRADE PROGRAM FIRE PROTECTION CATEGORY 2 ( IMPROVED) EMPHASIZE HOUSEKEEPING PRACTICES CONTINUE INVOLVEMENT IN APPENDIX R UPGRADES EMERGENCY PREPAREDNESS CATEGORY 2 (SAME) ENSURE MANAGEMENT CHANGES SOLVE WEAKNESSES NOTED DURING EARLY PART OF SALP PERIOD SECURITY & SAFEGUARDS CATEGORY 2 (DECLINED) AGGRESSIVE APPROACH IN RESOLVING SECURITY ISSUES REFUELING CATEGORY 1 (SAME) PRIOR PLANNING FOR NEXT REFUELING FOR FUEL EXAMINATIONS AND PRIOR AGREEMENT WITH NRC LICENSING ACTIVITIES CATEGORY 3 (SAME) EVALUATE NUCLEAR DEPARTMENT- STAFFING LWR EXPERIENCE WOULD BE DESIRABLE STAY INFORMED OF NRC INITIATIVES FOR OTHER REACTORS AND HOW THEY WOULD AFFECT FSV DESIGNATE AN INDIVIDUAL WITH RESPONSIBILITY FOR COMPLETE, TIMELY, AND CORRECT RESPONSES TO NRC TRAINING CATEGORY 2 (SAME) CONTINUE TO PURSUE INPO ACCREDITATION EMPHASIZE PROCEDURAL COMPLIANCE IN TRAINING PROGRAM PREPARE TRAINING PROGRAM ON REVISED TS AND OPERATING PROCEDURES DESIGN, DESIGN CHANGES, AND MODIFICATIONS CATEGORY 3 (DECLINED) IMPROVE MODIFICATION CONTROLS IMRPOVE INTERDEPARTMENTAL COORDINATION IMPROVE CN PRODUCTION IMPROVE UNDERSTANDING OF 10 CFR 50.59 QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY CATEGORY 3 (DECLINED) PROVIDE INCREASED MANAGEMENT OVERSIGHT OF NUCLEAR ACTIVITIES ENHANCE QA DEPARTMENT INDEPENDENCE AND CAPABILITY TO EFFECT TIMELY CORRECTIVE ACTION TIMELY REVIEW AND IMPLEMENTATION OF CONTRACTOR RECOMMENDATIONS IMPROVE QUALITY OF INTERDEPARTMENTAL COMMUNICATIONS INCREASE AUDIT/MONITORING TO IDENTIFY AND CORRECT WEAK AREAS Hello