HomeMy WebLinkAbout851176.tiff 2Jcnn Rect�aro UNITED STATES
NUCLEAR REGULATORY COMMISSION
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REGION IV
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rti ti oym 611 RYAN PLAZA DRIVE, SUITE 1000
ARLINGTON, TEXAS 76011
OCT 0 3 1985
Docket: 50-267
WEL4 COUNTY COMMISSIONERS
Public Service Company of Colorado
ATTN: 0. R. Lee, Vice President 8 ,57-17-17
Electric Production
P. O. Box 840 OCT 71985
Denver, Colorado 80201-0840
Gentlemen: GR`LL
We have reviewed your various submittals which respond to our October 1984
Assessment Report, the NUS Management Audit and our Systematic Evaluation of
Licensee Performance Report for 1984. The results of our review are contained
in the enclosed staff evaluation.
We have found that your submittals are responsive to these reports and that
your Performance Enhancement Program should materially strengthen the conduct
of operations at the Fort St. Vrain Station. However, as discussed in the
enclosed evaluation, there are some findings and recommendations which we
require additional information. We request that you review the enclosure and
provide the information requested therein as a part of the third quarterly
status report on the Performance Enhancement Program, which is due in the
December 1985 timeframe.
If you have any questions on this subject, please contact the NRC Project
Manager.
Since this reporting requirement relates solely to Fort St. Vrain, OMB
clearance is not required under P.L.96-511.
Sincerely,
Dorwin R. Hunter, Chief
Reactor Safety Branch
Enclosure:
Staff Evaluation
cc: (See next page)
851176
! LeL. of /o j4/SS
Public Service Company of Colorado -2-
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
J. W. Gahm, Manager, Nuclear
Production Division
Fort St. Vrain Nuclear Station
16805 WCR 19f
Platteville, Colorado 80651
L. Singleton, Manager, Quality
Assurance Division
(same address)
Colorado Radiation Control Program Director
ENCLOSURE
STAFF EVALUATION
OF PSC PLANS TO ENHANCE THE MANAGEMENT
OF FORT ST. VRAIN ACTIVITIES
1
TABLE OF CONTENTS
I. INTRODUCTION
II. EVALUATION
II.1 PSC Responsiveness to NRC Assessment Report
II . 1 PSC Responsiveness to Third-Party Management Review
III . SCHEDULE
IV. CONCLUSIONS
IV.1 Additional Information to Respond to NRC Assessment Report
IV.2 Additional Information to Respond to Third-Party Management
Review
IV.3 Additional Information on Scope of PEP
V. REFERENCES
_ t
LIST OF TABLES
Table Title
1 NRC Assessment Report Findings
2 Cross-References Between NRC Findings, Consultant's
Report, and Licensee Submittals
3 PSC Responsiveness to Third-Party Management Review
4 Performance Enhancement Program Summary Schedule
5 PSC PEP Responsibilities
I. INTRODUCTION
In October of 1984, the NRC staff issued a preliminary report (Reference 1)
that documented the results of a special assessment of operations at the Fort
St. Vrain Nuclear Generating Station (FSV). The special assessment was
requested by the Director of the Office of Nuclear Reactor Regulation as a
result of several operating problems that had occurred at FSV. Based on the
assessment, the staff concluded that the plant should not be restarted until
the licensee had completed several actions, one of which was the performance
of an independent, third-party review of management structure and practices
related to the operation of FSV.
In November and December of 1984, the NUS Operating Services Corporation
(NUSOSC) performed an independent study of nuclear-related activities within
the Public Service Company of Colorado (PSC). The results of the study are
documented in a report dated January 30, 1985 (Reference 2). The report
contains the following listed five sections, with each section containing
NUSOSC recommendations for consideration by PSC:
A. Conduct of Operations/Management (11 recommendations)
B. Work Control System/Procedures (8 recommendations)
C. Commitment Control (3 recommendations)
D. Training/Retraining (6 recommendations)
E. Organization and Staffing (6 recommendations)
PSC responded to the NUSOSC recommendations by letter dated February 28, 1985
(Reference 3). PSC submitted additional information by letters dated
March 29 and June 25, 1985 (References 4 and 5).
II. EVALUATION
The staff has. evaluated References 3 through 5 for responsiveness to the NRC
assessment report (Reference 1) and to the third-party management review
(Reference 2). The primary documents used during the evaluation were
-2-
Regulatory Guide 1.8 (Reference 6), Regulatory Guide 1.33 (Reference 7) , ANSI
N18.1-1971 (Reference 8), ANSI N18.7-1972 (Reference 9) , the Fort St. Vrain
Updated FSAR (Reference 10) , the Fort St. Vrain Quality Assurance Program
(Reference 11) , and Title 10 of the Code of Federal Regulations
(Reference 12). References 6 through 9 are currently applicable to Fort St.
Vrain. Secondary documents used for additional regulatory guidance were
NUREG-0731 (Reference 13), NUREG-0737 (Reference 14), the Standard Review
Plan (Reference 15), the final Policy Statement on Training and
Qualifications of Nuclear Power Plant Personnel (Reference 16), Generic
Letter 83-28 (Reference 17), ANSI N18.7-1976/ANS-3.2 (Reference 18), and
ANSI/ANS-3.2-1982 (Reference 19).
•
1. PSC Responsiveness to NRC Assessment• Report
The scope of this task is limited to Section 4 (Conduct of Plant
Operations) of the NRC assessment report. Although the report contains
observations that can be construed as weaknesses in the licensee's
conduct of operations, these observations are not listed as specific
staff findings, but are embedded in the text of the report. To
facilitate comparison of the PSC submittals with the assessment report,
the staff has developed the list of 26 specific "findings" shown in
Table 1. The Table includes cross-references to the subsections of the
assessment report wherein the findings are expressed.
The staff then compared the third-party consultant's report (Ref. 2) and
the PSC submittals (References 3 through 5) with the assessment report
findings to determine how responsive the licensee has been to the
assessment report. The results of the comparison are shown in Table 2.
Each assessment report finding from Table 1 is listed in Column 1 of
Table 2; cross-references to corresponding subsections in the
third-party consultant's report and the initial PSC response to that
report (Ref. 3) are listed in Column 2; cross-references to
corresponding subparts of the PSC Performance Enhancement Program
-3-
(References 4 and 5) are listed in Column 3; and explanatory notes are
listed in Column 4. Column 3 is separate from Column 2 because the
numbering system used in the Performance Enhancement Program is
different from the numbering system used in the consultant's report.
Table 2 is sufficiently detailed to enable the reader to determine how
responsive PSC has been to each finding. The Table includes the staff
position (found in Notes 1-26) , including basis, on each item. In
summary, PSC has been fully responsive to 15 of the 26 findings.
Follow-up actions to more fully address the remaining 11 findings are
discussed below in Section IV of this staff evaluation.
2. PSC Responsiveness to Third-Party Management Review
As a separate task, the staff evaluated the responsiveness of the PSC
submittals (References 3 through 5) to the third-party consultant's
report (Ref. 2). Sections A through E of Table 3 contain the full text
of all 34 of the consultant's recommendations, with each recommendation
immediately followed by the staff position (including the basis for the
position) on the PSC response.
In summary, PSC has been fully responsive to 32 of the 34
recommendations. Follow-up actions to more fully address the remaining
two recommendations are discussed below in Section IV of this staff
evaluation.
III. SCHEDULE
The adequacy of the PEP schedule has also been evaluated.
There are six PEP projects, each of which is divided into from three to nine
subprojects. There are a total of 34 subprojects. The titles of the
projects and subprojects, and a timetable for their completion, are given in
Table 4 (extracted from Reference 5).
-4-
Based on the scheduled start dates in Table 4, all PEP subprojects have
begun. Nineteen subprojects are scheduled to be completed in 1985 and 15 are
scheduled to be completed in 1986. Of the 15 subprojects scheduled for
completion in 1986, 11 of them are scheduled to have their initial phases
completed in 1985 (e.g. , initial schedule, initial definition, or initial
assessment) , with final implementation proceeding into 1986. The staff
concludes that this is a reasonable schedule. It is not too compressed for a
program as ambitious as the PEP, yet the scheduled end date is not too far
into the future; and the more extensive projects are given a longer time
frame.
Based on the personnel assignments shown in Table 4, direct responsibility
for the .34 subprojects is spread among 15 individuals, with six individuals
responsible for three or more subprojects. A separate listing of the
subprojects assigned to each of the 15 individuals is shown in Table 5.
Although it appears that multiple assignments have been made in order to keep
subprojects of a similar nature under the same individual (for example, the
six subprojects under employee Fuller are all closely related to day-to-day
activities at the plant site), the number of estimated working hours allotted
to each subproject is not given. Therefore, the licensee should supply
additional information on the scope of each subproject to show that adequate
staff has been assigned to supervise and implement the PEP concurrent with
normal duties.
IV. CONCLUSIONS
In general , the staff finds the PSC submittals to be responsive to the NRC
assessment report and to the consultant's independent recommendations. The
PSC Performance Enhancement Program should materially strengthen the conduct
of operations at Fort St. Vrain. As discussed below, however, there are some
findings and recommendations for which PSC should supply additional
information.
-5-
1. Additional Information to Respond to NRC Assessment Report
Finding 4-2 The licensee should supply details of the plant tour
program.
Finding 4-9: The licensee should submit a more complete description
of procedure ENG-3 for further review by the staff.
Finding 4-10: The licensee should verify to the staff that the
functional acceptability of equipment being returned to
service will be checked and/or verified by the Shift
Supervisor regardless of the reason for having removed
the equipment from service (e.g. , surveillance testing,
inspection, maintenance, modification, etc. ).
Finding 4-13: The licensee should commit to develop a shift turnover
procedure.
Finding 4-14: The licensee should commit to develop a procedural
requirement for licensed operators to read and review
operating logs upon return to the Control Room after an
extended absence.
Finding 4-15: The licensee should supply details of the plant tour
program (the same information is needed to close out
Finding 4-2).
Finding 4-16: The licensee should submit a more complete description
of procedure ENG-3 for further review by the staff (the
same information is needed to close out Finding 4-9).
Finding 4-17: The licensee should commit to improve the control of
system operating procedures in use at local control
panels.
-6-
Finding 4-19: The licensee should take steps to improve access to the
Control Room from the Shift Supervisor's office, or
provide additional explanation of why their current
arrangement is acceptable.
Finding 4-20: The licensee should verify that PEP subproject VI.2
will encompass the verification of the correct
performance of operating activities.
Finding 4-24: The licensee should describe how the "safety-related"
designation is used in their parts management system.
2. Additional Information to Respond to Third-Party Management Review
Recommendation A.4: The licensee should describe how their Master
Planning and Scheduling System will address
surveillance testing in general and "surveillances
requiring shutdown" in particular.
Recommendation A.6: The licensee should clarify how they plan to
analyze for the root cause of procedure compliance
failures.
3. Additional Information on Scope of PEP
The licensee should supply additional information on the scope of each
PEP subproject to show that adequate staff has been assigned to
supervise and implement the PEP concurrent with normal duties (refer to
discussion in Section III above) .
-7-
V. REFERENCES
1. Letter from H. R. Denton (NRC) to R. F. Walker (PSC) transmitting the
"Preliminary Report Related to the Restart and Continued Operation of
Fort St. Vrain Nuclear Generating Station," October 16, 1984.
2. NUS Operating Services Corporation, "An Analysis and Evaluation of the
Management of Nuclear-Related Activities of the Public Service Company of
Colorado," January 30, 1985.
3. Letter from 0. R. Lee (PSC) to R. D. Martin (NRC) , "Public Service
Company of Colorado's Response to the NUS Operating Services
Corporation's Management Assessment of January 30, 1985," February 28,
1985.
4. Letter from 0. R. Lee (PSC) to R. D. Martin (NRC), "PSC Performance
Enhancement Program," March 29, 1985.
5. Public Service Company of Colorado presentation to NRC staff,
"Systematic Assessment of Licensee Performance," May 29, 1985.
6. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.8, "Personnel
Selection and Training," Revision 1-R, September 1975.
7. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.33, "Quality
Assurance Program Requirements (Operation) ," November 3, 1972.
8. ANSI N18.1-1971,"Selection and Training of Nuclear Power Plant
Personnel ."
9. ANSI N18.7-1972, "Administrative Controls for Nuclear Power Plants."
10. Letter from 0. R. Lee (PSC) to Director of Nuclear Reactor Regulation
(NRC), "Fort St. Vrain Updated FSAR," Revision 2," July•20, 1984.
11. Letter from 0. R. Lee (PSC) to Director of Nuclear Reactor Regulation
(NRC) , "Fort St. Vrain Updated FSAR, Revision 2, Appendix B,"
September 28, 1984.
12. Code of Federal Regulation, Title 10, Parts 0 to 199, "Energy," revised
as of January 1, 1985.
13. U.S. Nuclear Regulatory Commission, NUREG-0731, "Guidelines for Utility
Management Structure and Technical Resources (Draft Report for Interim
Use and Comment)," September 1980.
14. U.S. Nuclear Regulatory Commission, NUREG-0737, "Clarification of TMI
Action Plan Requirements," November 1980.
-8-
15. U.S. Nuclear Regulatory Commission, NUREG-0800, "Standard Review Plan,"
Chapter 13, Revision 2, July 1981.
16. U.S. Nuclear Regulatory Commission, 50 FR 11147, "Commission Policy
Statement on Training and Qualification of Nuclear Power Plant
Personnel ," March 20, 1985.
17. U.S. Nuclear Regulatory Commission, Generic Letter 83-28, "Required
Actions Based on Generic Implications of Salem ATWS Events,"
July 8, 1983.
18. ANSI N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance
for the Operational Phase of Nuclear Power Plants."
19. ANSI/ANS-3.2-1982, "Administrative Controls and Quality Assurance for
the Operational Phase of Nuclear Power Plants."
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NOTES:
1. Section 12.3 of the licensee's FSAR, Rev. 2, states that the FSV
"procedure system meets the requirements and intent of ANSI
N18.7-1972." With respect to procedure adherence, Section 5.1.2 of
ANSI N18.7-1972 simply requires that procedures be followed and that
requirements for the use of procedures be prescribed in writing.
The PEP includes a comprehensive program to upgrade and standardize
procedures and to improve compliance with procedures. The Quality
Assurance Division is spending time on procedure reviews and training
to eliminate root causes for failures to follow procedures. The
licensee's actions are consistent with their FSAR commitment.
2. Regulatory Guide 1.39, which endorses ANSI N45.2.3-1973, provides
guidance on housekeeping requirements during plant operation. A
"General Housekeeping Program" for Fort St. Vrain was established in
June 1984. The licensee claims that housekeeping problems have been
resolved and a program is in place to maintain the plant at a level of
cleanliness intended to reduce abnormal degradation of plant equipment
and reduce personnel safety hazards. Procedures have been implemented
to document corrective actions taken in response to plant tours.
The licensee has also committed to develop a formal plant tour program,
which includes general housekeeping as part of the PEP. At the time of
their latest presentation to the staff (Reference 5), they had not made
a final determination of exactly who should perform the tours and had
not finalized the details of a tour program. The licensee should
supply details when available.
3. Section 6.5.5.1 of Appendix B to the licensee's FSAR (Rev. 2) states
that the FSV procedure system conforms to the intent of Regulatory
Guide 1.33, November 1972, and ANSI N18.7-1972. Section 5.3.1 of ANSI
N18.7-1972 requires operating and maintenance procedures to be
sufficiently detailed for a qualified individual to perform the
required function without direct supervision; Section 5.3.2 offers
guidance on acceptable procedure content; Sections 5.3.3 through 5.3.9
give detailed guidance for particular procedure categories (e.g. ,
system procedures, maintenance procedures, etc. ).
The licensee has incorporated plans to improve procedures in several
areas. Those items in the consultant's report and the licensee's
responses that specifically mention procedure enhancements have been
listed in this Table. Several other items will probably also lead to
procedure changes to improve the conduct of activities associated with
Fort St. Vrain. The licensee's actions are consistent with their FSAR
commitment.
-2-
4. The licensee's FSAR does not address the timeliness of maintenance
activities; however, the staff has long considered it good practice to
avoid a backlog of safety-related maintenance actions.
The licensee has responded to the NRC assessment report by initiating a
master planning and scheduling function for nuclear activities. A
maintenance planning group will be established to coordinate
maintenance activities, and up-to-date planning and scheduling
principles will be applied to the existing preventive maintenance
system. The licensee's plans are expected to improve their control of
maintenance actions.
5. Section 3.2 of ANSI N18.7-1972 requires that lines of authority and
responsibility be established from the highest management level through
intermediate levels to the plant manager and the on-site operating
organization. Additional guidance on management control in general and
control of surveillance testing in general is contained in Sections 3.2
and 5.2.8 of ANSI N18.7-1976/ANS-3.2. Section B5 of Appendix B to the
FSAR, Rev. 2 (Quality Assurance Program for Plant Operation), also
states that the Vice President-Electric Production is assigned the
authority and responsibility for all activities associated with
engineering, procurement, operation, maintenance, modification, and
quality assurance at FSV.
Although the NRC assessment report finding addresses management
attention to surveillance activities only, the Table lists
cross-references to several items that should enhance management
attention in general (including surveillance activities).
6. Section 3.2 of ANSI N18.7-1972 requires that the highest management
level recognizes that the plant must be operated under well formulated
and detailed control to assure safety and efficiency. Although this
requirement does not specifically address the review of generic NRC
issuances, the staff considers such review to be a routine function at
a nuclear utility. To assure safety and efficiency, the nuclear
organization must be knowledgeable about industry activities, including
regulatory activities, in general .
The licensee's PEP is responsive to the NRC finding. A method of
reviewing regulatory documents to identify items applicable to FSV is
being established.
7. ANSI N18.1-1971 and ANSI N18.7-1972 give general guidance pertaining to
organizational structures appropriate for the operation and technical
support of nuclear power plants. Although the referenced standards do
not require a central point of contact for licensing matters, the
staff's interactions over the years with numerous licensees have shown
that a single point of contact is very important for accurate and
efficient communications.
-3-
The licensee's PEP is responsive to the NRC finding. The new Licensing
and Field Division separates the licensing and fuels activities from
the Nuclear Engineering Division, thus providing for a stronger
licensing function and a central point of contact with the NRC.
8. Section 6.5.7 of Appendix B to the FSAR, Rev. 2, establishes PSC
quality assurance requirements for the control of purchased material ,
equipment and services. Section 5.3.9 of ANSI N18.7-1972 requires
procedures for the proper procurement, documentation and control of
materials and components necessary for plant maintenance and
modification.
The licensee's PEP is responsive to the NRC finding. They are
assessing the scope and adequacy of their current procurement process
and plan to improve their parts management system. A component
shelf-life program is also being developed.
9. Section B.5.3.7 of Appendix B to the TSAR, Rev.2, establishes PSC
quality assurance requirements for processing changes to design
documents. Although ANSI N18.7-1972 does not specifically address
document revisions, Section 5.2.15 of ANSI N18.7-1976/ANS-3.2 does
contain guidance on the control of documents (instructions, procedures,
drawings and engineering requirements) to preclude the possibility of
use of outdated or inappropriate versions.
On page 26 of the Attachment to their letter dated February 28, 1985
(Reference 3) , the licensee states that current drawing control
practices are effective and that Engineering Procedure ENG-3
establishes formal practices for handling, distributing, numbering, and
storing design documents so that personnel have access to proper and
current documents at all times. Based on the correspondence used in
this review (References 1-5), the staff is unable to close the NRC
finding. PSC is requested to submit a more complete description of
what is in procedure ENG-3 together with an explanation of how it
assures that system modifications are documented prior to return of the
systems to operation.
10. Section 6.5 of ANSI N18.7-1972 requires that tests or inspections be
performed following plant modifications or significant changes in
procedures to confirm that the modifications or changes reasonably
produce expected results and do not reduce safety. Although
Section 5.1.5 (Equipment Control Procedures) of ANSI N18.7-1972 does
not address the return of equipment to service, a later version of the
standard (ANSI N18.7-1976/ANS-3.2, Section 5.2.6, Equipment Control )
does state that, when equipment is ready to be returned to service,
operating personnel shall place the equipment in operation and verify
and document its functional acceptability. Item I.C.6 of NUREG-0737
also requires that the authority to release systems and equipment for
maintenance or surveillance testing or return-to-service may be
delegated to an on-shift SRO, provided the Shift Supervisor is kept
fully informed of system status.
-4-
•
The licensee's PEP is responsive to the NRC finding. A procedure is
being developed to define the responsibilities of Nuclear Production
Division supervisors. A comprehensive preventive maintenance program
is being developed that will include post-maintenance testing. The
licensee should confirm to the staff that the functional acceptability
of equipment being returned to service will be checked and/or verified
by the Shift Supervisor regardless of the reason for having removed the
equipment from service (e.g. , surveillance testing, inspection,
maintenance, modification, etc. ).
11. The Systematic Assessment of Licensee Performance (SALP) process
includes an evaluation of licensee responsiveness to NRC initiatives.
In an effort to improve responsiveness, PSC has implemented or
initiated several PEP subprojects. All the listed cross-references
have some bearing on the need for PSC to focus management attention on
FSV operations and maintenance.
12. The PSC position on Generic Letter 83-28 is being evaluated by the
staff along with the rest of the industry responses to that letter;
however, PSC has included in the PEP an assessment of parts management
and shelf-life needs.
13. Section 5.1.3 of ANSI N18.7-1972 requires a mechanism for disseminating
instructions of general and continuing applicability to the conduct of
business, such as instructions that deal with job turnover and relief.
More detailed guidance is contained in Section 5.2.1.4 of
ANSI/ANS-3.2-1982. Item I.C.2 of NUREG-0737 requires licensees to have
procedures for shift relief and turnover to ensure that each oncoming
shift is made aware of critical plant status information and system
availability.
The licensee's responses commit to a comprehensive procedure review;
however, there is no specific commitment to develop a shift turnover
procedure. The licensee should make such a commitment.
14. Section 5.1.1(6) of ANSI N18.7-1972 makes the plant staff responsible
for reviewing routine operating data to assure safe operation. More
detailed guidance is contained in Section 5.2.1.4 of ANSI/ANS-3.2-1982.
The licensee's responses commit to a comprehensive procedure review;
however, there is no specific commitment to develop a procedural
requirement for licensed operators to read and review operating logs
upon return to the Control Room after an extended absence. The
licensee should make such a commitment.
15. Same as Note 2.
16. Section B.5.6 of Appendix B to the FSAR, Rev. 2, establishes quality
assurance requirements for the control of documents. Additional
guidance is contained in Section 5.1 of ANSI N18.7-1972 and in
Section 5.2. 15 of ANSI N18.7-1976/ANS-3.2.
-5-
•
On page 26 of the Attachment to their letter of February 28, 1985
(Reference 3) , the licensee states that Engineering Procedure ENG-3
establishes guidelines for document control and that the current system
for controlling drawings is effective. Based on the correspondence
used in this review (Reference 1-5, the staff is unable to close the
NRC finding. PSC is requested to submit a more complete description of
what is in procedure ENG-3 together with an explanation of how use of
the procedure assures that only controlled drawings are available for
use of plant personnel .
17. Section 5.1.2 of ANSI N18.7-1972 establishes requirements for
procedural adherence.
The licensee's responses commit to a comprehensive procedure review;
however, there is no specific commitment to better identify system
operating procedures in use at local control panels. The licensee
should make such a commitment.
18. Section 8.5.14 of Appendix B to the FSAR, Rev. 2, addresses quality
assurance requirements for the status tagging of plant systems and
equipment. Section 5.1.5 of ANSI N18.7-1972 establishes requirements
for equipment control procedures, such as locking or tagging to secure
and identify equipment in a controlled status.
The above-referenced section of the FSAR states that the FSV
Administrative Procedures Manual establishes requirements for tagging,
logging, and displaying the status of plant equipment and systems. PEP
subproject VI.4 also appears to encompass tagging practices.
19. Section 5.1.1 of ANSI N18.7-1972 defines and establishes the general
responsibilities and authorities of the plant staff. Additional
guidance on the authority and responsibilities of the Shift Supervisor
is contained in Section 5.2.1.3 of ANSI/ANS-3.2-1982. Additional
requirements pertaining to operator staffing are contained in 10 CFR
50.54(m)(1).
Although the Shift Supervisor's office is not necessarily a part of the
Control Room area, the staff considers it a good operating practice for
the Shift Supervisor to have unobstructed access to the Control Room
area whenever he is in the office. The licensee should take steps to
improve access to the Control Room from the Shift Supervisor's office,
or provide additional explanation of why their current arrangement is
acceptable.
20. Section 5.1.5 of ANSI -N18.7-1972 requires independent verification,
where appropriate, to ensure that necessary equipment control measures,
such as tagging equipment, are implemented correctly. Section I.C.6 of
NUREG-0737 contains additional guidance on procedures for verifying the
correct performance of operating activities.
-6-
The licensee should verify that PEP subproject VI .2, "Revise Conduct of
Operations," will encompass the verification of the correct performance
of operating activities.
21. Section 5.1.6 of ANSI N18.7-1972 requires a maintenance program to
maintain safety-related equipment at the quality required for it to
perform its intended function. A preventive maintenance schedule
should be established and maintained which describes the frequency and
type of maintenance to be performed.
The licensee's PEP includes several subprojects designed to improve the
maintenance function. The intended result is a major upgrade of the
licensee's ability to plan, schedule and accomplish nuclear-related
work, with particular emphasis on preventive/predictive maintenance.
22. Same as Note 21.
23. Same as Note 8.
24. 10 CFR 50, Appendix A, General Design Criterion 1, "Quality Standards
and Records," requires that structures, systems, and components
important to safety shall be designed, fabricated, erected, and tested
to quality standards commensurate with the importance of the safety
functions to be performed. 10 CFR 50, Appendix B VIII requires that
measures be established for the identification and control of
materials, parts and components of safety-related structures, systems
and components. Section 8.5.2.7 of Appendix B to the FSAR, Rev. 2,
defines the FSV safety-related items to which the QA Program applies.
Based on the correspondence used in this review (References 1-5) , the
staff cannot conclude that the licensee's parts management controls
meet the requirements of the regulations. The licensee should describe
how the "quality-related" treatment of parts meets the requirements of
the regulations for "safety-related" items.
25. Same as Note 21.
26. Section 3.2 of ANSI N18.7-1972 requires proper administrative and
procedural controls to ensure recognition at the highest management
level of a utility organization that a nuclear plant shall be operated
under well formulated and detailed control to assure safety and
efficiency.
In an effort to strengthen overall management control and improve the
operation of the Fort St. Vrain plant, PSC has had a third-party
consulting organization perform "An Analysts and Evaluation of the
Management of Nuclear-Related Activities of the Public Service Company
of Colorado" (Reference 2). PSC subsequently initiated the Performance
Enhancement Program (References 4 and 5) to strengthen its overall
conduct of operations.
TABLE 3
•
PSC RESPONSIVENESS TO THIRD-PARTY MANAGEMENT REVIEW
SECTION A
Conduct of Operations/Management
A. 1 Mission and Function Statements
Recommendation:
"The PSC nuclear organization should require that detailed mission and
function statements (charters) be developed for each senior manager's
group. These statements should be reviewed and agreed upon by the
appropriate senior manager and then approved by the senior nuclear
executive. The statements should be developed in such a manner as to be
able to serve as guidance for the development of similar statements at
the departmental and supervisory level . The statements, after approval ,
should become part of the nuclear policies and procedures manual for the
senior nuclear executive."
The licensee has agreed to complete mission statements for each nuclear
division and its subunits. Other relevant documents, e.g. , "Administrative
Procedure APM Q-1 (Organization and Responsibilities)," and the Updated FSAR,
will be reworked as necessary. The existing Nuclear Policies and Guidelines
Manual will be revised to reflect organizational changes and changes in
position responsibilities.
The licensee's response conforms with Sections 3.1 and 3.2 of ANSI
N18.7-1972. Section 3.1 requires that "relationships within an organization
that operates one or more nuclear power plants be clearly defined."
Section 3.2 requires that organizational relationships be "documented and
updated, as appropriate, in the form of organizational charts, functional
descriptions of departmental responsibilities and relationships, and job
descriptions for key positions of personnel having direct operating, support,
or audit responsibility within the organization or in equivalent forms of
documentation." The staff finds the licensee's response acceptable.
A.2 - Management Planning System
Recommendation:
"The PSC nuclear organization ,should •develop and implement an effective
management planning system that encompasses the following basic
elements:
o Define the overall management objectives (results to be achieved)
for the conduct of nuclear activities.
o Identify the work that must be accomplished in order to achieve
the objectives (referred to as critical performance areas) .
-2-
o Group and assign work responsibilities to individual
organizational units within the nuclear organization.
o Select critical objectives for each manager and prepare detailed
and measurable action plans for achieving each of the critical
objectives."
The licensee has agreed to establish a master nuclear planning and scheduling
system that will incorporate state-of-the-art planning and scheduling
techniques. The system will support the identification, coordination, and
monitoring of individual tasks and their relationships to nuclear objectives.
Although the licensee's response does not directly address all of the basic
elements in the consultant's recommendation (e.g. , "critical performance
areas," "critical objectives for each manager," etc. ), their plan to use
"state-of-the-art planning and scheduling techniques" indicates a meaningful
effort to upgrade management planning.
Although ANSI N18.7-1972 does not contain specific guidance on management
planning systems, Section 3.2 of the Standard does state that "a requirement
for proper administrative and procedural controls is recognition at the
highest management level of the organization that the plant shall be operated
under well-formulated and detailed control to assure safety and efficiency."
The staff considers it a good management practice to have a planning system
of the general type proposed by the licensee because it will help upper
management achieve the degree of control anticipated by the Standard. The
staff finds the licensee's response acceptable.
A.3 - Management Skills Program
Recommendation:
"The PSC nuclear organization should implement a management skills
development program."
The licensee has agreed to develop a Management Skills Program containing the
following elements:
o program scope
° . program policy statement
o identify participants (key members of nuclear staff)
o identify strengths and weaknesses of participants
o identify available training courses
o design individual training programs for participants
-3-
The Management Skills Program will focus on nuclear management skills and
should enhance the licensee's existing program for management skills
development at the supervisory, department/division, and executive levels.
Although ANSI N18. 1-1971 and ANSI N18.7-1972 do not contain specific guidance
on programs to develop management skills, it is generally recognized
throughout the industry that a person needs a high degree of managerial skill
in order to administer the complex organization associated with the operation
and technical support of a nuclear power plant. The staff considers it a
good management practice to have a management skills development program of
the general type proposed by the licensee. The staff finds the licensee's
response acceptable.
A.4 - Annual and Long-Range Schedules
Recommendation:
"The nuclear organization should develop and maintain a program of
annual and long-range schedules. The scheduling program should include,
as a minimum, planned plant modifications, plant surveillances requiring
shutdown, major maintenance activities, and plant outages."
The licensee's response to the recommendation covers the scheduling of
Performance Enhancement Program projects, Action Plan projects, planned
refuelings, outage activities, major regulatory commitments, major design
changes, major construction activities, and maintenance; however, it does not
specifically mention "surveillances requiring shutdown." We assume that such
surveillance is encompassed by the term "outage activities," but this should
be confirmed by the licensee.
Otherwise, the licensee notes that scheduling and planning efforts for
maintenance and outages/modifications are being improved and will be
integrated with the master nuclear planning and scheduling system (see
Recommendation A.2). A computer-based Power Plant Maintenance Information
System (PPMIS) has been implemented at FSV, and an outage coordinating
committee has been established. Consulting assistance has been retained for
procurement/warehousing activities, maintenance control , and
critical-path-method (CPM) scheduling.
The licensee's response conforms with Section 5.1.6 of ANSI N18.7-1972, which
requires a maintenance program to maintain safety-related equipment at the
quality required for it to perform its intended function; however,
Recommendation A.4 remains an open item pending clarification by the licensee
of how they plan to address surveillance testing in general and
"surveillances requiring shutdowns" in particular. Surveillance testing
requirements are given in Section 5.1.7 of ANSI N18.7-1972.
-4-
A.5 - Criteria for Change Notices
Recommendation:
"Criteria for evaluation and prioritization of change notices should be
developed. The combination of priority and scheduled start should be
used by all nuclear groups involved to coordinate the preparation for
construction of change notices. The criteria should specify one
individual or position who has safety and design control authority for
Fort St. Vrain. The work control group should function as an advisory
body to this individual ."
The licensee has agreed to develop criteria for the evaluation and
prioritization of change notices. This will be done in conjunction with
their development of a master nuclear planning and scheduling system (see
Recommendation A.2).
The licensee's response to the recommendation implies that the
Manager-Nuclear Engineering has primary design control authority, although
several other individuals are closely involved with the design change process
at FSV. For example, the Manager-Nuclear Production has final authority on
whether a proposed design change will actually be implemented. The Nuclear
Licensing unit performs a safety design review of each change notice, and the
" QA Division approves all design changes from a quality standpoint. The
licensee also considers design control authority to be separate from safety
authority. In matters relating to safety, the Vice President - Electric
Production has final authority. There is also a Work Review Committee that
serves as a link between engineering and operations during implementation of
design changes.
The licensee's response conforms with Section B.5.3 of Appendix B to the
FSAR, Rev. 2, and with Sections 3.2 and 5.1.6.4 of ANSI N18.7-1972. FSAR
Section B.5.3 establishes FSV quality assurance requirements for controlling
design activities (primarily design modifications) during the operational
phase. Section 3.2 of the Standard establishes general requirements for
administrative management controls (i .e. , planning and scheduling), and
Section 5.1.6.4 establishes requirements for plant modifications. The staff
finds the licensee's response acceptable.
A.6 - Review of Procedures
Recommendation:
"A thorough and comprehensive review of procedures should be initiated
as soon as possible. Their review should be geared to identifying and
correcting procedural deficiencies, overlaps, and omissions. In
addition, a detailed analysis of procedures which do not get followed,
should be conducted and the root causes for failure to follow procedures
identified. Verbatim procedure compliance should be enforced."
-5-
Section B.5.5.1 of Appendix B to the FSAR, Rev. 2, states that the FSV
procedure system conforms to the intent of Regulatory Guide 1.33, November
1972, and ANSI N18.7-1972. Section 5.1.2 of the Standard requires that
procedures be followed and that requirements for the use of procedures be
prescribed in writing; Section 5.3.2 offers guidance on acceptable procedure
content; and Sections 5.3.3 through 5.3.9 give detailed guidance for
particular procedure categories (e.g. , system procedures, maintenance
procedures, etc. ).
The licensee has agreed to perform a comprehensive review of procedures. The
policy and procedure process within the nuclear organization will be analyzed
to determine how policies and procedures are written, reviewed, authorized,
implemented, and monitored for compliance.
The licensee's response to the recommendation generally conforms with the FSV
QA Program and with ANSI N18.7-1972; however, the PEP does not explicitly
address the analysis of procedures that do not get followed. Although page 5
of the cover letter submitting the PEP (see Reference 4) states that the
purpose of PEP Project VI is, in part, to correct the root causes of various
NRC observations, none of the subproject discussions explains how this will
be done. Recommendation A.6 will remain an open item pending clarification
of the licensee's position with respect to the analysis of procedure
compliance failures.
A.7 - Quality Assurance Management Attention
Recommendation:
"The Quality Assurance organization should be given additional emphasis
and management attention."
The licensee's response to this recommendation refers to a reorganization
that was designed to improve the management oversight of FSV activities.
Under the reorganization, Quality Assurance was identified as a staff
function rather than a line function. The intent was to enhance the
capability of the QA organization to monitor the line divisions and to direct
executive attention toward finding and eliminating the root causes of
problems. The Manager, Quality Assurance continues to report to the Vice
President-Electric Production, who is the senior executive responsible for
nuclear activities. Under the reorganization, the Vice President -
Electric Production reports to the President and Chief Executive Officer. In
addition, QA concerns will become a separate agenda item at the biweekly
staff meetings held by the Vice President - Electric Production.
The licensee's response conforms with Section 3.2 of ANSI N18.7-1972 which
establishes management authority and responsibility for safe and efficient
plant operation, including off-site technical support and audit activities
(more specific guidance on the quality assurance function is contained in ANSI
N18.7-1976/ANS-3.2). The licensee's response also conforms with guidance on
acceptable off-site organizations contained in Section 13.1.1 of the Standard
Review Plan (SRP) and Section II.B.1 of NUREG-0731. The staff finds the
licensee's response acceptable. The Manager, Quality Assurance has direct
-6-
•
access to responsible corporate management at a level where appropriate
action can be taken (the level of the Vice President - Electric Production)
and has a regular means of reporting on the effectiveness of the QA program
(at the biweekly staff meetings).
A.8 - Establish Effective Tour Program
Recommendation:
"An effective tour program should be established. Problems found during
tours should be summarized by type and location and a periodic report
plantdproblemsl turtooallplevelsarticipofts in order supervisionto andncrease visibility of
management."
The licensee has agreed to issue and implement procedures to enhance the
existing plant tour program.
The licensee's response to the recommendation points out that general
housekeeping, which is part of the overall plant tour program, was addressed
in June 1984 by establishing a General Housekeeping Program at Fort
St. Vrain. The program involves all levels of plant management and is
intended to increase the visibility of housekeeping deficiencies so they can
be more promptly corrected.
The licensee's response conforms with Section 5.1.4 of ANSI N18.7-1972.
Although ANSI N18.7-1972 does not address housekeeping directly,
Section 5.1.4 does require an administrative mechanism for issuing management
instructions that require dissemination; such instructions, sometimes
referred to as special orders, should encompass housekeeping. Additional
guidance on housekeeping is found in Section 5.2.10 of ANSI
N18.7-1976/ANS-3.2. The staff finds the licensee's response acceptable.
A.9 - Policy on Staff Meetings
Recommendation:
"Policies should be developed which require regular and frequent
division, department, and group meetings."
The licensee has agreed to develop a policy for transferring information and
communication throughout the nuclear organization. The policy will formalize
the use of meetings and will be incorporated in the Nuclear Policy and
Guidelines Manual .
The licensee's response to the recommendation also points out that, although
current procedures do not formally address the subject of staff meetings,
such meetings have been occurring (and continue to occur) on a regular basis.
For example, the Vice President- Electric Production has biweekly staff
meetings, periodic division-level meetings, monthly interdivisional
coordination meetings, and periodic lower-level staff meetings.
-7-
Although ANSI N18.7-1972 contains guidance on the management and
administrative control of nuclear power plants, it does not contain specific
requirements on staff meetings. It is the staff's judgment that the
licensee's policy on staff meetings is adequate. The staff finds the
licensee's response acceptable.
A.10 - Industry Group Participation
Recommendation:
"PSC should take steps to allow its personnel to increase their
awareness of events external to PSC. These steps could include
increasing enrollment and attendance with industry groups, as well as
subscribing to information services.
The licensee is assembling a listing of industry groups and professional
societies in which FSV management and professional staff participate. The
licensee plans to examine the degree of employee participation in industry
groups and to consider increasing, participation in standards committees, if
warranted.
Although ANSI N18.7-1972 contains guidance on the management and
administrative control of nuclear power plants, it does not contain specific
requirements on utility participation in industry groups. It is the staff's
judgment that such participation is useful and that the licensee plans to
take adequate steps to examine their degree of participation. The staff
finds the licensee's response acceptable.
A.11 - Visibility of Senior Personnel
Recommendation:
"Visibility of senior personnel should be increased through plant
visits, plant tours and attendance at staff meetings at all levels."
The licensee's response to the recommendation contends that recent
organizational changes (see Recommendation E.2) and staff additions will
increase the visibility of the President and Chief Executive Officer, the
Vice President - Electric Production, and senior management at the Division
level .
The licensee's' response conforms with Section 3.2 of ANSI N18.7-1972, which
states that "lines of authority and responsibility shall be established from
the highest management level through intermediate levels (including off-site
technical support and audit activities) to the plant manager and the on-site
operating organization." Although the Standard does not specifically address
"management visibility," it is the staff's judgment that strong day-to-day
participation in nuclear activities by all levels of management is very
important in achieving safety and efficiency. The staff finds the licensee's
response acceptable.
-8-
•
SECTION B
Work Control Systems/Procedures
6. 1 - Streamline the Modification Process
Recommendation:
"Review the modification process, from initial request to final
installation and test. Provide for the elimination of redundant reviews
and approvals. Change the work procedures to make them as simple as
possible."
The licensee has agreed to establish a task force responsible for reviewing
the FSV modification process and simplifying the procedures. The task force
may visit other nuclear facilities to gather information about their
modification processes.
The licensee's response conforms with Sections 3.1 and 5.1.6.4 of ANSI
N18.7-1972. Section 3.1 of the Standard contains general requirements for
the administrative control of nuclear power plants; Section 5.1.6.4 contains
requirements pertaining to plant modifications. The staff concurs with the
licensee's plans to streamline their modification process. The licensee's
response is acceptable.
6.2 - Planning Group for Maintenance
Recommendation:
"Establish a planning group to prepare jobs for work before their
release to maintenance. Assign job coordination responsibilities to
superintendents in charge of specific maintenance disciplines."
The licensee has agreed to implement this recommendation. Improvements in
maintenance planning will be coordinated with the planning and scheduling
efforts described in the responses to Recommendations A.2 and A.4.
The licensee's response conforms with Section 5.1.6 of ANSI N18.7-1972, which
requires a maintenance program to maintain safety-related equipment at the
quality required for it to perform its intended function. A preventive
maintenance schedule should be established and maintained which describes the
frequency and type of maintenance to be performed. The staff finds the
licensee's response acceptable.
6.3 - Planning and Scheduling Qualifications
Recommendation:
"Policies and procedures should be developed and implemented that
establish the qualifications of planning and scheduling personnel and
-9-
the required guidelines and criteria for planning and scheduling
activities. Personnel currently involved in the planning and scheduling
function should be upgraded through training and experience to the
required criteria. Consideration should be given to the hiring of a
qualified and experienced planning and scheduling manager."
The licensee has agreed to develop and implement guidelines for the
qualification, responsibility, and authority of planning and scheduling
personnel .
The licensee's response to the recommendation notes that several actions have
already been taken in this area, some of which include establishing an
independent planning and scheduling authority at FSV and filling the position
of Supervisor-Planning and Scheduling (in December 1984). See
Recommendations A.2, A.4, and 6.2 for additional information related to
planning and scheduling.
The licensee's response meets the intent of Sections 3.3 and 4.6.2 of ANSI
N18.1-1971. Section 3.3 of the Standard establishes functional levels and
responsibilities for technical support personnel ; Section 4.6.2 establishes
qualification requirements for staff specialists (such as planning and
scheduling personnel ). The licensee should ensure that their final
qualification guidelines for planning and scheduling personnel satisfy the
Standard. The staff finds the licensee's response acceptable.
6.4 - Preventive Maintenance Program
Recommendation:
"Develop a complete preventive maintenance program including engineering
analysis and feedback. Routinely specify and conduct postmaintenance
tests which ensure that the system or component meets its design
intent."
The licensee has agreed to develop and implement a comprehensive preventive
maintenance program to control maintenance activities associated with
equipment deemed essential for reliable plant operation. Some of the things
the program will cover are:
o list of "significant components"
o independent verification of correct operating activities
o maintenance procedures
o training and qualifications
o historical data file
• failure trend analysis
-10-
• system for acting on identified deficiencies
o engineering analysis and evaluation
o maintenance scheduling, tracking, and feedback
o post-maintenance testing
The licensee's response conforms with Sections 5.1.6 and 6.5 of ANSI
N18.7-1972. Section 5.1.6 of the Standard requires a maintenance program,
including preventive maintenance, to maintain safety-related equipment at the
quality required for it to perform its intended function; Section 6.5
requires that tests or inspections be performed following plant modifications
or significant changes in procedures to confirm that the modifications or
changes reasonably produce expected results and do not reduce safety. The
staff finds the licensee's response acceptable.
B.5 - Material Access Exclusion List
Recommendation:
"The exclusion list at FSV governing material access to the site must be
reviewed and corrected."
The licensee has agreed to review and evaluate the FSV "exclusion list"
governing material access to the site and to possibly incorporate it into the
FSV Administrative Procedures Manual .
Section 5.3.9 of ANSI N18.7-1972 requires procedures for the proper
procurement, documentation, and control of those materials and components
necessary for plant maintenance and modification; however, there are no
specific requirements pertaining to the use of an "exclusion list" governing
material access to the site. It is the staff's judgment that the licensee's
plans to review and evaluate the FSV exclusion list are adequate. The staff
finds the licensee's response acceptable.
B.6 - Revision and Control of Drawings
Recommendation:
"Policies and procedures should be developed and implemented to improve
the revision and control of drawings to support plant operations and
maintenance."
The licensee's response to this recommendation states that FSV has new
equipment that will allow on-site reproduction of drawings. This will result
in quick turnaround and distribution of revised drawings. Otherwise, the
licensee feels that existing policies and procedures are sufficient to
maintain design documents up to date, and no further action is planned.
-11-
Section B.5.3.3.7 of Appendix B to the FSAR, Rev. 2, establishes PSC quality
assurance requirements for processing changes to design documents. Although
ANSI N18.7-1972 does not specifically address document revisions,
Section 5.2. 15 of ANSI N18.7-1976/ANS-3.2 does contain guidance on the
control of documents (instructions, procedures, drawings and engineering
requirements) to preclude the possibility of use of outdated or inappropriate
versions. The staff finds the licensee's response acceptable.
6.7 - Procedures for 10 CFR 50.59
Recommendation:
"Develop more explicit procedures and criteria for performing safety
evaluations to meet 10 CFR 50.59."
The licensee considers the current Design Control System (Administrative
Procedure APM Q-3) to be adequate and responsive to 10 CFR 50.59. However,
the computerized licensing-document data base will be expanded and training
on the performance of safety evaluations will be enhanced to ensure that
licensing personnel know the procedure and the data base.
Although the term "safety evaluation" is not used and 10 CFR 50.59 is not
cited, Section 5.1 of ANSI N18.7-1972 requires written administrative
policies to control the issuance of documents, including changes, that
prescribe activities affecting safety-related structures, systems, and
components; these policies shall assure that documents are reviewed for
adequacy and approved for release. In addition, Section 5.1.6. 1 requires
that safety-related maintenance or modifications be performed in a manner to
assure quality at least equivalent to that specified in applicable codes,
bases, standards, design requirements, and Section 5.4 requires plant
management to arrange for review of proposed changes to procedures having
safety significance. Sections 5.2.7 and 5.2. 15 of ANSI N18.7-1976/ANS-3.2
contain additional guidance on those subjects. It is the staff's judgment
that the licensee's plans to expand the licensing document data base and
enhance training on the performance of safety evaluations conform with the
above referenced Standards. The staff finds the licensee's response
acceptable.
6.8 - Separate System for Corrective Action Requests (CARs)
Recommendation:
"Establish a separate system for CARs so that only significant items are
called CARs, and give them proper management attention. The system
should address priorities, schedules, reviews,,. etc. Other items
presently carried as CARs can be handled in a similar system, if
desired."
-12-
The licensee has agreed to establish internal controls to provide for a
Quality Assurance Division appraisal of the significance of potential
Corrective Action Requests (CARs). The purpose will be to ensure that only
significant findings are recorded as CARs. The licensee considers NRC "open
items" and "unresolved items" to be significant and intends to continue
recording them as CARs.
Although ANSI N18.7-1972 does not have a section devoted to corrective
actions, Section 5.2.11 of ANSI N18.7-1976/ANS-3.2 does discuss the use of a
corrective action program to ensure that conditions adverse to plant safety
are promptly identified and corrected. The staff finds the licensee's
response, which discusses the FSV Corrective Action Request (CAR) system,
acceptable. •
-13-
•
SECTION C
Commitment Control
- C.1 - Commitment Control Program
Recommendation:
"Develop and implement policy regarding commitment control . Consider
the following points as a minimum: accountability, measurable
performance goals, requirements, priorities, and analysis."
The licensee has agreed to issue written policy to cover the existing
commitment control program. The policy will define the program scope and
purposes, the identification of a commitment, the assignment and
acknowledgement of responsibilities, the tracking and closure of commitments,
and the organization responsible for overall program management. The program
will be reviewed periodically by executive level management, and regular
analyses will be performed to determine program effectiveness and to identify
areas for possible improvement.
Section 3.1 of ANSI N18.7-1972 requires that proper administrative controls
be in effect to assure that decisions are made at the proper level of
responsibility and with the necessary technical advice; Section 3.2 requires
that the highest management level recognize that the plant must be operated
under well formulated and detailed control to assure safety and efficiency.
Although these requirements do not specifically address commitment control or
the review of regulatory correspondence and other documents, the staff
considers such activities to be routine functions at a nuclear utility. To
assure safety and efficiency, the nuclear organization must be knowledgeable
about plant commitments and regulatory correspondence and documents. The
staff concurs with the licensee's plans to improve these areas of
administration and finds the response acceptable.
C.2 - Regulatory Correspondence Review
Recommendation:
"The methods used for internal review of regulatory correspondence
should be improved and standardized with procedural guidance developed
regarding use, basis, uniformity, and distribution."
The licensee has agreed to develop and implement procedures for the review of
regulatory correspondence. The procedures will include criteria for
identifying commitments in regulatory correspondence and will define how such
correspondence is to be distributed for management/staff action. The
licensee plans to incorporate the review of regulatory correspondence into
the Commitment Control Program (see Recommendation C.1).
-14-
Section 3.1 of ANSI N18.7-1972 requires that proper administrative controls
be in effect to assure that decisions are made at the proper level of
responsibility and with the necessary technical advice; Section 3.2 requires
that the highest management level recognize that the plant must be operated
under well formulated and detailed control to assure safety and efficiency.
Although these requirements do not specifically address commitment control or
the review of regulatory correspondence and other documents, the staff
considers such activities to be routine functions at a nuclear utility. To
assure safety and efficiency, the nuclear organization must be knowledgeable
about plant commitments and regulatory correspondence and documents. The
staff concurs with the licensee's plans to improve these areas of
administration and finds the response acceptable.
C.3 - Regulatory Documents Review
Recommendation:
"Reviews of regulatory documents must be undertaken on a conceptual
basis to determine whether installed equipment, which is often different
from that described by the NRC, might fall under the requirements or
intent of a regulatory directive."
The licensee has agreed to implement a systematic, continuing review of
essential regulatory documents to identify obligations that apply to FSV.
Obligations for all nuclear activities (e.g. , equipment, engineering,
operations, maintenance, quality assurance, management, etc. ) will be
cataloged and distributed to responsible management and unit level personnel.
The licensee plans to expand the duties of the existing Licensing Coordinator
position to include the development of a system for acknowledging and
controlling ongoing obligations.
Section 3.1 of ANSI N18.7-1972 requires that proper administrative controls
be in effect to assure that decisions are made at the proper level of
responsibility and with the necessary technical advice; Section 3.2 requires
that the highest management level recognize that the plant must be operated
under well formulated and detailed control to assure safety and efficiency.
Although these requirements do not specifically address commitment control or
the review of regulatory correspondence and other documents, the staff
considers such activities to be routine functions at a nuclear utility. To
assure safety and efficiency, the nuclear organization must be knowledgeable
about plant commitments and regulatory correspondence and documents. The
staff concurs with the licensee's plans to improve these areas of
administration and finds the response acceptable.
-15-
SECTION D
Training/Retraining
D.1 - Resource Requirement for Training
Recommendation:
"A detailed manpower study should be performed to determine the resource
requirements needed to thoroughly accredit the nuclear organization
training."
The licensee has completed a study of the resources needed to achieve
accreditation of the ten training programs covered by the INPO accreditation
process. As a result of the study, the licensee's staff has received
management approval to add 12 people to the Nuclear Production Division to
help meet INPO accreditation requirements and has identified several changes
that are needed in the training organization.
The licensee's response conforms with the general requirements of Section 5.1
of ANSI N18.1-1971, and it also conforms with the Policy Statement on
Training and Qualifications of Nuclear Power Plant Personnel (50 FR 11147).
The Standard requires that the training program be such that fully trained
and qualified operating, maintenance, professional , and technical support
personnel are available in the necessary numbers at the time required. The
Policy Statement endorses the INPO-managed Training Accreditation Program,
which encompasses the following ten site-related training programs:
• nonlicensed operator
• control room operator
• senior control room operator/shift supervisor
o shift technical advisor
o instrument and control technician
o electrical maintenance personnel
o mechanical maintenance personnel
o radiological protection technician
o chemistry technician
o on-site technical staff and managers
The staff finds the licensee's response acceptable.
-16-
D.2 - Nuclear Training Program
Recommendation:
"A training program should be developed for all personnel involved in
nuclear-related activities at Fort St. Vrain. The training program
should be structured against a job and task analysis conducted for the
various positions."
The licensee has agreed to develop training programs for all positions within
the scope of the INPO accreditation program (see Recommendation D.1. ) These
programs will be based on job/task analyses.
The licensee also plans to address the training of FSV nuclear groups that
fall outside the INPO accreditation program, e.g. , Nuclear Engineering,
Nuclear Licensing and Fuels, and Quality Assurance. Training for these
groups will be based on available INPO technical guidance.
The licensee's response goes beyond the scope of the Policy Statement on
Training and Qualifications of Nuclear Power Plant Personnel (50 FR 11147)
and is acceptable.
D.3 - Formal Training for Entry Into New Positions
Recommendation:
"A formal evaluation should be performed to determine what training is
required for a candidate prior to entry into a new job position. Each
employee should be thoroughly trained and prepared for entry into the
company through a comprehensive, introductory orientation program. The
program should include job-specific requirements, departmental
responsibilities and goals, and the nuclear organization."
The licensee has agreed to develop training programs for all nuclear-related
divisions (Nuclear Production, Nuclear Engineering, Licensing and Fuels, and
Quality Assurance). The programs will include orientation programs, general
employee training, and procedure training. They will be comprehensive
programs designed to give employees the basic knowledge needed to perform
assigned tasks.
The licensee's response conforms with the general requirements of Section 5
of ANSI N18.1-1971 and goes beyond the scope of the Policy Statement on
Training and Qualifications of Nuclear Power Plant Personnel (50 FR 11147).
The staff finds the licensee's response acceptable.
-17-
•
D.4 - Individual Training Requirements
Recommendation:
"Training policies, procedures and methodologies should be developed
that address the assessment of individual performance, the
identification of individual training needs, and successful completion
of training requirements."
The licensee has agreed to develop training programs for all nuclear-related
divisions (Nuclear Production, Nuclear Engineering, Licensing and Fuels, and
Quality Assurance). The programs will include orientation programs, general
employee training, and procedure training. They will be comprehensive
programs designed to give employees the basic knowledge needed to perform
assigned tasks.
The licensee's response conforms with the general requirements of Section 5
of ANSI N18.1-1971 and goes beyond the scope of the Policy Statement on
Training and Qualifications of Nuclear Power Plant Personnel (50 FR 11147).
The staff finds the licensee's response acceptable.
D.5 - Consolidated Site Training
Recommendation:
"All site training activities should be consolidated under one person
who will be responsible for all site-related training."
The licensee has agreed to consolidate Nuclear Production Division training
responsibilities in the Nuclear Production Training Department. Except for
management-related training, all Nuclear Production Division training
activities will be the responsibility of the Support Services Manager.
Section 13.1.2 of NUREG-0800 (Standard Review Plan) and Section II.A of
NUREG-0731 contain guidance on the organization of site training activities.
The licensee's response indicates that Nuclear Production Division training
is a distinct functional area under the Superintendent-Training, who reports
to the Manager-Nuclear Production through the Support Services Manager. The
staff finds the licensee's response acceptable.
D.6 - Retraining of Licensed Personnel
Recommendation:
"The retraining program for licensed personnel should be modified to
accommodate team training and incorporate training needs identified by
on-shift performance and/or evaluation."
-18-
The licensee's response to the recommendation states that, although the
current FSV Licensed Operator Retraining Program is considered to be
adequate, the INPO accreditation process will incorporate team training and
the evaluation of on-shift performance.
Although ANSI N18.1-1971 does not address the use of team training or the
incorporation of training needs identified by on-shift performance, recent
trends in nuclear training support these concepts. For example, the Policy
Statement on Training and Qualifications of Nuclear Power Plant Personnel (50
FR 11147) endorses the INPO-managed Training Accreditation Program in that it
encompasses the elements of effective performance-based training. The staff
also agrees with the use of simulators or other methods to promote
team-building among on-shift crew members. The staff finds the licensee's
response acceptable.
-19-
•
SECTION E
Organization/Staffing
E.1 - Augment Nuclear Staff
Recommendation:
"PSC should augment the nuclear staff with trained personnel having
experience in licensing, maintenance, scheduling, training, and
planning."
PSC has approved the addition of 79 new personnel to the nuclear
organization. A.major commitment has been made to nuclear training;
licensing people with LWR experience are being added to help relate NRC
regulations to HTSR technology; additional plant engineering staff will help
increase attention on preventive maintenance and engineering analysis;
additional design engineering staff will help improve control and
coordination of design changes and plant support; a new Master Planning and
Scheduling function will help management prioritize and direct nuclear
activities; and the QA staff is being increased to allow greater coverage of
audits, training, and inspections. The staff finds that the licensee's
organizational plans conform with the Standard Review Plan and are
acceptable.
E.2 - Vice President, Electric Production (Span of Control )
Recommendation:
"It is recommended that PSC consolidate all nuclear-related operations
under one senior nuclear executive whose responsibilities would be
limited to nuclear activities. The consolidation should bring together
all groups involved with operations, maintenance and support of the Fort
St. Vrain Nuclear Power Station.
The senior nuclear executive position should be provided with full
' authority and management support to conduct nuclear-related business and
operations.
The placement of this position should be such that it is
organizationally capable of executing such authority. Consideration
should be given to placing the senior nuclear executive under the
President PSC."
The licensee recently reorganized to strengthen nuclear management. The key
changes are:
° The Vice President-Electric Production now reports directly to the
President and Chief Executive Officer.
-20-
The span of control of the Vice President-Electric Production has been
modified by consolidating all fossil production under a new position
entitled General Manager-Fossil Production.
o Nuclear activities have been concentrated under three division managers;
The Manager-Nuclear Production, the Manager-Nuclear Engineering, and the
Manager-Nuclear Licensing and Fuels.
o The Nuclear Licensing and Fuels Division will have the senior management
communication link to the NRC.
o The Quality Assurance Division now has a staff (rather than line)
function with direct access to the Vice President-Electric Production
(see Recommendation A.7).
Although the senior executive responsible for nuclear activities (the Vice
President-Electric Production) also has responsibility for fossil production
activities, the creation of the new General Manager-Fossil Production
position is a step in the right direction. The licensee should carefully
monitor the new organization, with particular emphasis on the span of control
of the Vice President-Electric Production and the possible need to
consolidate nuclear activities under a single executive with no non-nuclear
responsibilities.
The staff finds that the licensee's organizational plans conform with the
Standard Review Plan and are acceptable.
E.3 - Manage Licensing/Nuclear Fuels from Site
Recommendation:
"The present makeup of the licensing and nuclear fuels group (Office of
the Executive Staff Assistant) and the QA/QC group appears adequate from
an organizational standpoint. However, it is the recommendation of the
Review Team that these groups be managed from the FSV site."
The licensee has agreed to perform a study to determine whether the Nuclear
Licensing and Fuels Division should be managed from the FSV site. The
licensee's response to the recommendation also notes that the Quality
Assurance Division is currently managed from the site, and that a site
licensing group was established in the Fall of 1984.
The exact location of. a nuclear utility's licensing organization is not
prescribed by the regulations. It is the staff's judgment that the
guidelines of NUREG-0731 and the Standard Review Plan should be followed when
organizing the various administrative and technical support functions. The
staff finds the licensee's response acceptable.
-21-
E.4 - Combined Engineering Functions
Recommendation:
"It is recommended that all engineering and documentation functions be
combined into one organization managed from the FSV site. Functional
areas n 'Nuclear Engineering' would include:
o Site Engineering (including Nuclear Design)
o Nuclear Engineering Records (and Nuclear Documentation Control )
o Nuclear Betterment Engineering (excluding I&C Maintenance Functions)
o Technical Advisors
The engineering group at FSV should be organized such that they may
handle all small and medium projects (4: $1,000,000). All major projects
should be handled by the Systems Engineering Division."
The licensee has agreed to perform a study to determine whether all functions
of the Nuclear Engineering Division should be managed from the F3Tsite (Site
Engineering and Nuclear Engineering Records are currently managed from the
site).
The licensee's response to the recommendation also points out that their
nuclear organization has sufficient engineering support to accommodate
present needs, including major projects.
Except for the Independent Safety Engineering Group (ISEG) described in
Section 13.4 of the Standard Review Plan (SRP) , the exact location of a
nuclear utility's engineering organization is not prescribed. It is the
staff's judgment that the guidelines of NUREG-0731 and the SRP should be
followed when organizing the various administrative and technical support
functions. The staff finds the licensee's response acceptable.
E.5 - Nuclear Production Organization Changes
Recommendation:
"It is recommended that the Station Manager's organization be modified
to absorb I&C maintenance work activities while relinquishing the
engineering functions of Nuclear Betterment to 'Nuclear Engineering' as
discussed in the preceding paragraph. Further, the 'Shift
Supervisor-Training' position should be transferred to the training
organization. This arrangement will result in an 'Operations &
Maintenance' group devoted solely to the objective of operating and
maintaining the plant. Functional areas in 'Station Operations and
Maintenance' will include:
-22-
o Operations
o Maintenance
- Electrical
- Mechanical
- Instrumentation & Control
o Scheduling
o Planning"
The licensee's response states that the recommended reorganization would be
detrimental to commitments made since September 1984 and could undermine
general morale at FSV. The staff tends to agree that a major reorganization
at the station level is not advisable at this time. The licensee should be
given time to get used to the recent upper-level reorganization and to start
working on the many commitments they have made. However, at some point in
the future, the consultant's recommendation should be reconsidered;
additional organizational improvements may become evident as the Performance
Enhancement Program is implemented.
The staff finds the licensee's response acceptable; however, the licensee
should reconsider the recommendation periodically during implementation of
the Performance Enhancement Program.
E.6 - Reorganize Technical/Administrative Department
Recommendation:
"The Review Team concluded that the functions of the Technical/
Administrative Department are redundant to those of other organizations.
Based on expanding 'Nuclear Engineer' [sic] to include all engineering
and documentation, it reduces this group to only security and computer
services. Recommendations are to transfer these activities to 'Support
Services' and entirely dissolve the Technical/Administrative Department.
"Support Services" would therefore be responsible for:
• Health Physics
o Chemistry
• Training
o Security
o Computer Services"
The licensee's response to this recommendation, and the staff's evaluation of
the licensee's response, are basically the same as the response and
evaluation under Recommendation E.5.
The staff finds the licensee's response acceptable; however, the licensee
should reconsider the recommendation periodically during implementation of
the Performance Enhancement Program.
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TABLE 5
PSC PEP RESPONSIBILITIES
Name Subproject Responsibilities
D. M. Picard, I.1 Formalize reorganization & PEP
PEP Manager I.2 Document charters & mission statements
II.1 Establish planning/scheduling function
II.3 Implement planning/scheduling methods
M. Zachary I.3 Document communication policy
C. Gaudreau, I.4 Evaluate staffing
Production Services
Coordinator
J. Gahm, I.5 Complete organizational changes
Manager-Nuclear
Production
D. W. Warembourg, I.6 Evaluate relocation of engineering/licensing
Manager-Nuclear to the site
IV.5 Revise nuclear engineering procedures
V.5 Improve nuclear engineering training
C. N. Fuller, II.2 Develop schedules
FSV Station Manager IV.5 Revise nuclear production procedures
VI.1 Formalize plant tour procedures
VI.2 Revise "Conduct of Operations" procedure
VI.3 Document supervisor responsibilities
VI.4 Implement plant signage (labels, signs, etc. )
program
D. Miller III. 1 Establish maintenance planning group
III.2 Define maintenance planning function
F. J. Novachek, III.3 Develop preventive maintenance program
Technical/ VI.5 Study facility needs at the site
Administrative
Services Manager
J. Reesy IV. 1 Revise design change process
VI .6 Improve parts management
VI.7 Establish shelf-life program
M. H. Holmes, IV.2 Implement commitment control program
Nuclear Licensing IV.3 Develop procedure for reviewing regulatory
Manager correspondence
IV.4 Review essential regulatory documents
V.3 Improve 10 CFR 50.59 training
c + '
-2-
•
M. J. Ferris, IV.6 Revise exclusion list
Quality Assurance
Operations Manager
McNulty V. 1 Upgrade management skills
H. L. Brey, V.2 Review membership in industry groups
Manager-Nuclear V.6 Improve licensing and fuels training
Licensing & Fuels
L. W. Singleton, V.4 Improve QA training
Manager-Quality
Assurance
F. J. Borst, V.7 Develop nuclear production training
Support Services V.8 Consolidate site training
V.9 Retrain licensed personnel
-JO�EP^HEGu UNITED STATES
O
W . '� NUCLEAR REGULATORY COMMISSION
, 0
c REGION IV
611 RYAN PLAZA DRIVE, SUITE 1000
ARLINGTON, TEXAS 76011
Docket: 50-267 OCT 0 2 1985
Public Service Company of Colorado WELD COUNTY C^'""1!mn,Gns
ATTN: 0. R. Lee, Vice President o
Electric Production
0 .
P. 0. Box 840 0CT 71985
Denver, Colorado 80201-0840
Gentlemen: GREELEY. COLO.
We have reviewed the proposed Fort St. Vrain Fuel Surveillance Program which
you submitted by letter dated May 3, 1985 (P-85151) and find that a number of
problems must be corrected prior to our approval . Our comments on the
proposed program are contained in the enclosure to this letter. We request
that you respond to these comments and provide a revised program within 60
days of your receipt of this letter.
If you have any questions on this subject, please contact the NRC Project
Manager.
Since this request relates solely to the Fort St. Vrain Station, OMB clearance
is not required under P.L. 96-511.
Sincerely,
Oektai
D. R. Hunter, Chief
Reactor Safety Branch
Enclosure:
Comments on Program
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
-ru- el, /6/o / /8 s—
Public Service Company -2-
of Colorado
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 19*
Platteville, Colorado 80651
L. Singleton, Manager, Quality
Assurance Division
(same address)
Colorado Radiation Control Program Director
COMMENTS ON THE FUEL SURVEILLANCE PROGRAM
1. As we have stated in our January 3, 1979, February 28,1983, and
October 19, 1984 letters, we do not find it acceptable for changes to be
made to the Post Irradiation Examination (PIE) program based only on the
availability of DOE funding. Therefore, changes to the previously
approved program must be explained, justified, and approved. (i .e. , The
deletion of PIE for SURV-2 was authorized in our February 28, 1983 Safety
Evaluation. )
a. The deletion of a destructive PIE for elements SURV-4 and SURV-6,
following refueling outages 4 an 6 respectively, may be acceptable
provided no significant changes occur in parameters which are
indicative of fuel performance. We, therefore, propose that you
commit to a destructive PIE of those selected surveillance fuel
elements (SURV-4 and SURV-6) if the circulating primary coolant
activity increases to a preselected level or by a predetermined factor
over previous equilibrium levels. Similar considerations should be
incorporated into the nondestructive PIE program for refuelings
subsequent to the tenth refueling outage.
b. The proposed destructive PIE program does not include all of the 13
tasks that were committed to in your June 20, 1978 (P-78102)
response to our May 10, 1978 requirement for a PIE program of the
fuel test elements (FTEs). Many of the deleted tasks do not appear
to be extremely difficult to perform and should be included in the
PIE program. Provide an evaluation, including a cost-benefit study,
for any of the 13 tasks which are not incorporated (as stated in
P-78102) into the proposed program.
2. Items 2) and 3) of the proposed program indicate that "significant
abnormalities" will be evaluated and reported. A revision to the program
should define what is intended by "significant abnormalities."
3. The reporting of program results (Items 4) , 6) , and 7) ) to the NRC needs
to be changed from "as it becomes available" to a specific time following
restart from the refueling outage (i .e. , 120 or 180 days following
restart).
4. The commitment (Item 5)) to visually examine the "canyon walls" of the
Segment 9, H-451 elements needs to be -revised to indicate that records of
these examinations shall be established and maintained. (The approval of
the use of H-451 graphite in License Amendment No. 40 was based, in part,
on previous commitments to perform these visual examinations and other
PIE. )
5. Item 6) c) stipulates that gamma scanning is subject to the availability
of the gamma scanning robot. Since, as stated in your June 20, 1978
submittal , the development of this device by General Atomic was funded by
-2-
DOE for FSV fuel examinations, we were under the assumption that it would
always be available for these examinations. In addition, we stated in
our January 24, 1983, that gamma scanning was a necessary element of an
acceptable PIE program. Therefore, provide: a) an explanation of what
is meant by the availability of the robot, and b) if gamma scanning is
not to be included in the examination, the justification for this
deletion.
6. The commitment to perform destructive PIE on FTE-2 contained in your
February 10, 1983 response to our January 24, 1983 position needs to be
fulfilled. Provide your schedule for completion of subitems d, e, f,
and g.
Hello