ML20099G637
| ML20099G637 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/30/1985 |
| From: | Deist B NUS CORP. |
| To: | |
| Shared Package | |
| ML20099G601 | List: |
| References | |
| TAC-60566, NUDOCS 8503150042 | |
| Download: ML20099G637 (32) | |
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- ATTACHMENT TO P-85066 n
Copy Number D
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An Analysis and Evaluation of the Management of Nuclear-Related Activities of the 1 Public Service Company of Colorado I b Prepared for Public Service Company of Colorado
!N aanuery 30, lees by I
T. W. Deist NUS Operating Services Corporation 350 Motor Parkway I Suite 201 Hauppauge, New York 11788 d .
8503150042 850228
Table of Contents Page j l
j Summary and Conclusions i l I-l !
1 Introduction II-l II Purpose and Scope III An Analysis and Evaluation of the Management of Nuclear-III-l Related Activities of the Public Service Company of Colorado 111 - 1 A. Conduct of Operations / Management 111- 1
- 1. Introduction III-2
- 2. Observations III-4
- 3. Recommendations d B. Work Control Systems / Procedures
- 1. Introduction III-8 III-8
- 2. Observations III-8 111- 10
- 3. Recommendations 111- 12 f
C. Commitment Control
- 1. Introduction III-12 111- 1 2
- 2. Observations
- 3. Recommendations III-13 III- 14 m D. Training / Retraining r 1. Introduction 111-14 L III-14
- 2. Observations 111- 15
- 3. Recommendations E. Organization / Staffing III-16
- 1. Introduction III-16
- 2. Observations and Recommendations III-16 Appendix A Critique of HTGR Considerations A-1 Appendix B Project Description B-1 I
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SUMMARY
AND CONCLUSIONS rm
- The NUS Operating Services Corporation (NUSOSC) performed an extensive M study of the management of nuclear-related activities within the Public Service Company of Colorado (PSC) to assist PSC in addressing concerns that were a
raised by the NRC in their assessment of the Fort St. Vrain (FSV) operation that was conducted in July 1984 and which was reported to PSC in the NRC preliminary report issued on October 16, 1984.
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-LJ The NRC report covered several areas of plant activities, including Conduct ,
According to the NRC, the Conduct of Operations at FSV l r
of Operations.
l L " contained weaknesses that could be the result of deficiencies in the Public Service Company of Colorado (PSC) operating philosophy. " The NRC re-ported that the philosophy appears "to subscribe to less formality and less rigid control of operations in terms of the use of procedures, detail and verification addressed in the procedure, and adherence to the procedures than is common in other commercial nuclear power plants."
The investigation activities of NUSOSC confirmed the basic concerns that were identified by the NRC and, as a result of its investigations, NUSOSC developed a number of recommendations which, if aggressively implemented on a timely basis, should correct the identified weakness.
' The NUSOSC investigation team concluded that a key contributing factor to the PSC management philosophy for FSV operations appeared to be the gen-P eral attitude that the HTGR reactor concept was unique and that the many generic directions and regulations for operation and maintenance of commercial nuclear power plants did not apply. Contributors to this perception of prob-lems include the post-TM1 regulatory emphasis on water reactors, and the limited knowledge of and assistance available from outside groups regarding the HTGR. This is discussed further in Appendix A.
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- f I INTRODUCTION The Nuclear Regulatory Commission (NRC) conducted a special assessment of Fort St. Vrain (FSV) operations in July 1984. This special assessment was conducted by members of the Office of Nuclear Reactor Regulation and the Region IV Inspection and Enforcement group.
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The NRC report concluded that PSC should " undertake initiatives that are designed to strengthen overali management control and that will improve plant operations." Further, the NRC stated that the PSC initiatives would " require an assessment of the root causes of operational problems and identification of broad-ranged corrective measures." The NRC stated that the assessment "should be performed by a third party consulting group, the scope and schedule for which must be determined prior to restart."
The NRC required that the work and report be done without consultation or influence from Public Service Company of Colorado. The report was to be submitted simultaneously to both Public Service Company of Colorado and the NRC, Region IV.
PSC requested that the NUS Operating Services Corporation (NUSOSC) review the NRC report and develop a plan of action and a proposal to address the ,
NRC concerns. NUSOSC was subsequently contracted by PSC to provide consulting assistance for the assessment of nuclear management controls within PSC and at the Fort St. Vrain nuclear station.
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O II PURPOSE AND SCOPE This report was developed by NUSOSC at the request of the PSC. It repre-sents an analysis and evaluation of the management of nuclear-related activi-ties within PSC. The report will be utilized by PSC to prepare a response to the NRC preliminary report issued on October 16, 1984.
The report contains five sections: 1) Conduct of Operations / Management, 2)
Work Control Systems / Procedures, 3) Commitment Control, 4) Training / Retrain-ing and 5) Organization and Staffing. Each section provides an introduction describing in general terms the areas examined followed by important observa-tions of the NUSOSC Review Team. Each section concludes with a list of recommendations that the Review Team has submitted for consideration by PSC.
Activities associated with the assessment began on November 14, 1984 follow-ing a joint meeting of PSC, NRC and NUSOSC representatives in Arlington,
, Texas. The study was essentially completed on December 21, 1984 with the final analysis of data and report development beginning on December 27, 1984.
The scope of the study entailed approximately 2500 man-hours of labor with over 60 PSC people being interviewed. The s:udy itself is described in Appen-dix B of the report us si ,
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Ill AN ANALYSIS AND EVALUATION OF THE MANAGEMENT OF NUCLEAR-RELATED ACTIVITIES OF THE PUBLIC SERVICE COMPANY OF COLORADO l
A. CONDUCT OF OPERATIONS / MANAGEMENT
- 1. Introduction Conduct of Operations / Management focuses on issues such as identification of group and individual responsibilities, manage-ment philosophy, PSC attitudes toward procedures, compliance, intra- and inter-group communication, and leadership, as well as opinions and assessments of various PSC activities in these areas.
Other factors considered for this section include interfaces between various PSC and industry organizations, the diverse organizational units within PSC, the effectiveness of the organization, the roles of various levels of management and their reporting relationships, the alignment of various functional activities, the locations of the various groups, the knowledge levels of personnel involved and how PSC management viewed issues such as violations of regulations, management and supervisory skills, staffing levels and PSC/NRC relations.
The section contains observations ranging from PSC's need to deal systematically and firmly with the failure-to-follow-proce-dures problem to the isolationist attitude which is pervasive throughout the nuclear organization. It is the general con-sensus of the Review Team that the majority of the Fort St.
Vrain problemla stem from management's attitudes and philosophy.
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- 2. Observations e The Review Team concluded that no overall, concrete, effective management plan or philosophy regarding con-duct of operations at FSV exists. Rather, it appears that outside stimuli are required before action is taken to correct problems and/or deficiencies.
e Management control is ambiguous, and communication 7 within PSC appears to be nonsystematic and ineffi-cient. Staff meetings are rarely held at all levels.
Information regarding organizational changes, policy decisions, and events is not always disseminated at either the site or support locations.
e During interviews, it was learned that support per-sonnel do not fully appreciate the requirements that must be met at the plant, and support personnel indicated that the plant staff do not adequately define what is expected of them. In addition, interviews with PSC supervisory personnel indicated that they often do not know what other work groups are doing or what the status is for important tasks that may impact their functional areas.
e Despite the long-standing problem with failure to follow ,
1 procedures, PSC has not developed and implemented an effective, systematic program of cause identification and correction. There is a general reluctance to enforce
. discipline when necessary. Management is prone to l
acknowledge mistakes and errors as part of " human nature." A survey of the Senior Resident Inspector's Reports for 1981-1984 shows that there are about two violations per month on the average. The nature of most of these violations is failure to follow procedures.
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st 2. Observations (continued) e Quahty control / quality assurance activities do not receive continuous, aggressive management attention and have resulted in problems regarding definition and control of safety-related material.
e The licensing single-point contact and the contributions or responsibilities of other PSC organizations with regard to licensing activities are not adequately defined.
v' e There does not exist a person with final authority to determine whether or not a design change should be accomplished.
e Personnel interviewed reported that plant departments
, or groups applied diffarent policies for the same situa-tions. Managers conceded that they knew that policies were applied dif ferently even within their department, but they had not taken steps to correct these dif fer-ences. Supervisors stated that they knew written policies existed , but in some instances they had not obtained copies (or felt that they did not have access to these policies).
e Most indications are that the nuclear organization of Public Service Company of Colorado is too narrowly focused on HTGR technology. There is little evidence of outside . contact or learning. For example, there is minimalhttendance at industry-wide functions or partic-ipation in standards committees. PSCf is routinely asked to evaluate NRC light-water-reactor-based regulations in light of HTGR dif ferences.
- Since no one in PSC has m-3
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- 2. Observations (continued)
$ extensive light water reactor experience, they tend to overlook similarities and parallels. (See Appendix A, f f
i HTGR considerations.)
I e Persons interviewed displayed open antagonism toward the NRC, and for the most part either lack an appre-.
ciation of, or refuse to acknowledge, the NRC's position regarding the regulatory process.
e Managers and superintendents demonstrated a general l lack of understanding regarding the conduct of plant f tours and inspections. Most information obtained through interviews indicated that they generally looked for items that had previously bt on identified by either l NRC or INPO. In addition, they had very little infor-mation about what their subordinates were inspecting 8'f- during their tours and admitted 'to having very little or no control over these activities. Results of plant tours are not normally documented and reviewed to identify problem areas or practices to establish trends / rates of reoccurrence. .
e Plant tours conducted by the Review Team revealed poor maintenance practices and problems with the plant. The problems included damaged plant equipment, damaged maintenance equipment, poor operational prac-tices and potential personnel or equipment hazards. It should be noted that many people interviewed felt that they "could not keep ahead of the Resident Inspector" in identifying problems even though they collectively represent a much larger group.
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y 3. Recommendations A.1 The PSC nuclear organization should require that detailed ,
1 l mission and function statements (charters) be developed l 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 stataments, after approval, should become part of the nuclear policies and procedures manual for the senior nuclear executive.
A.2 The PSC nuclear organization should develop and imple- ,
I ment an effective management planning system that encom-passes the following basic elements. l e Define the overall management objectives (results to be achieved) for the conduct of nuclear activities.
e Identify the work that must be accomplished in order to achieve the objectives (referred to as critical performance areas).
e Group and assign work responsibilities to indi-vidual organizational units within the nuclear organization.
e ISelect critical objectives for each manager and prepare detailed and measurable action plans for achieving each of the critical objectives.
A3 The PSC nuclear organization should implement a manage-ment skills development program.
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- 3. Recommendations (continued) l
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A.4 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, rhnt surveillances requiring shutdown, major maintenance activities and plant outages.
A.5 Criteria for evaluation and prioritization of change notices should be developed. The combination of priority and l scheduled start should be used by all nuclear groups involved to coordinate the preparation for construction of change notices. The criteria should specify one individ-ual or position who has safety and design control author-ity for Fort St. Vrain. The work control group should function as an advisory body to this individual.
- A.6 A thorough and comprehensive review of procedures should be initiated as soon as possible. The review should be geared to identifying and correcting procedural deficiencies, overlaps and omissions. In addition, a de-tailed analysis of procedures which do not get followed should be conducted and the root causes for failure to follow procedures identified. Verbatim procedure compli-ance should be enforced.
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A.8 An effecMve tour program should be established. Pro b-lems found during tours should be summarized by type and location and a periodic report provided to all tour participants in order to increase visibility of plant problems to all levels of supervision and management.
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- 3. Recommendations (continued)
A.9 Policies should be developed which require regular and trequent division, cepartment, and group meetings.
A.10 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.
A.ll Visibility of senior personnel should be increased through plant visits, plant tours and attendance at staff meetings at all levels.
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B. WORK CONTROL SYSTEMS / PROCEDURES
- 1. Introduction This section addresses conditions varying from logistics and l
problems related to maintenance, to procedure matrices and design change notices for nuclear activities. Problems identi-fled in this area ranged from outdoor storage of components to l
the lack of detailed planning.
- 2. Observations )
l e PSC has not developed an effective work control system. In addition, the programs for preventive main-tenance and postmaintenance testing are inadequate.
No ongoing engineering analysis is conducted to assess l the effectiveness of the preventive maintenance pro- ;
gram. Many work items do not have postmaintenance testing specified, e The procedures for engineering activities are extremely l complex. Over two dozen steps are required for a design change request and modification. Most of those steps are not performed for technical or regulatory j reasons , but rather are efforts to bridge the gap between the usr?; the designer, and the constructor.
e No cen're ' n enance facility exists . This often causes spwdown s n' completion of jobs when more than one discipline is involved. There is no effective coordDnation of maintenance activities and no central warehouse. Many jobs do not have required parts
- ordered until the individual respcasible for maintenance W -
has been assigned . Parts on hand have frequently required rework and considerable cleanup because they were inappropriately stored outdoors.
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- 2. Observations (continued) e The plant has had a high equipment failure rate, which in the opinion of some supervisors interviewed is attributable to a lack of, or inadequate, preventive
! maintenance. A large part of the plant work backlog consists of rework items.
e I.evel one procedures require approval from all of the 7 organizations involved at Fort St. Vrain. In contrast, there is no requirement that lower level procedures be reviewed for interfaces with other organizations. As a result, they are not, and there is evidence that proce-dures contain conflicting requirements and responsibil-ities. Also, engineering procedures are exempt from the requirements of G-2 that provide administrative 7 control of procedures.
e There are too many Corrective Action Requests (CARS)
' The CAR system is not being properly uti-written.
l lized. A corrective action system should be used to l 1
4 identify significant oefects. The PSC system does not differentiate between the significant and the insignificant.
e There is no effective method for escalation of CARS to higher management. Many CARS stay open for years.
Several 1982 items are still open, some with no recent correspondence to indicate that any action is being taken.
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1 sp 3. Recommendations B.1 Review the modification process, from initial request to final installation and test. Provide for the elimination of redundant reviews and approvals. Change the work pro- j cedures to make them as simple as possible, f B.2 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.
B.3 Policies and procedures should be developed and imple-mented that establish the qualifications of planning and scheduling personnel and the required guidelines and criteria for planning and scheduling activities. Personnel i
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.
l B.4 Develop a complete preventive maintenance program includ-ing engineering analysis and feedback. Routinely specify and conduct postmaintenance tests which ensure that the system or component meets its design intent.
B.S The " exclusion list" at FSV governing material access to the site must be reviewed and corrected.
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- 3. Recommendations (continued)
B .6 Policies and procedures should be developed and imple- ;
mented to improve the revision and control of drawings to l support plant operations and maintenance.
B.7 Develop more explicit procedures and criteria for perform-ing safety evaluations to meet 10CFR50.59.
B .8 Establish a separate system for CARS so that only signifi-cant items are called CARS, and give them proper manage-ment attention. The system should address priorities ,
schedules, reviews, etc. Other items presently carried as CARS can be handled in a similar system, if desired.
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) f C. COMMITMENT CONTROL
- 1. Introdu -tion This section of the report covers the Review Team observations 4
and recommendations regarding the process, methodology, and nonregula-practices of PSC in the control of regulatory and tory commitments.
Problems identified in this section ranged from the use of the commitment log to the inadvertent dropping of past commitments from consideration.
- 2. Observations e The second paragraph of PSC's letter transmitting its technical response to the NRC Generic Letter 83-28 implied that PSC did not agree that there was a need to protect HTGRs against ATWS events.
In addition, the PSC technical response ignored the fact that components might have vendors that are not the l
NSSS supplier, and therefore a complete FSV program should address more than the NSSS vendor.
e The Commitment Log, which serves as the primary tool for tracking commitments, does not define what should I
be on the log and is controlle,1 in a fragmented manner. In addition , the contents and schedules associated with the Commitment Log are not properly to responsible individuals for correct commynicated action.
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- 2. Observations (continued) e The control system does not prevent past commitments from being inadvertently dropped, and no meaningful statistical analysis of progress toward completion of commitments is performed or maintained by PSC.
e No controls exist for responses to commitments other than those . requiring correspondence to NRC.
Log" e The Review Team was told that the " Commitment includes only requirements for government interactions, The PSC i.e., NRC, state, and county requirements.
commitment to NUMARC/INPO was not being tracked on j
that system and consequently, the due date for meeting this commitment was not forwarded to the person responsible for response.
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- 3. Recommendations l I
C.1 Develop and implement policy regarding commitment control. Consider the following points as a minimum:
accountability, measurable performance goals, require-ments, priorities, and analysis.
C.2 The methods used for internal review of regulatory correspondence should be improved and standardized with procedural guidance developed regarding use, basis, uniformity, and distribution.
C.3 Re31ews 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 require-ments or intent of a regulatory directive.
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i D. TRAINING / RETRAINING
- 1. Introduction Training and retraining were examined at the site and support locations. Areas included both operator and nonoperator training.
- 2. Observations 1 e PSC has not adequately addressed the overall training needs and requirements of the nuclear organization, e.g., training for most nonlicensed staff is essentdy nonexistent. In addition, the current personnel respon-sible for training activities in the nuclear organization do not have the requisite training and educational skills l
to plan, develop and implement effective training.
li e Except for operations and maintenance personnel, there I' is no policy concerning minimum entry training. There is no retraining policy for personnel other than licensed
, personnel.
e Interviews with training personnel indicated that they do not fully understand the mechanics of instruction system design (ISD) or of accreditation requirements.
Although the personnel exhibited a great deal of ;
I dedication and concern regarding accreditation, they ,
I are not optimistic that they will meet the projected schedule for accreditation.
e The Review Team considers the training program for initial licensing adequate but is of the opinion that retraining for licensed personnel is inadequate in that it does not provide for team training or for addressing i
training needs identified by on-shift performance and/or evaluation.
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- 3. Recommendations A detailed manpower study should be performed to D .1 determine the resource requirements needed to thoroughly accredit the nuclear organization training.
D .2 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.
D.3 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, depart-
- mental responsibilities and goals, and the nuclear organization.
D.4 Training policies, procedures and methodologies should be developed that address the assessment of individual per-f ormance, the identification of individual training needs, and successful completion of training requirements.
D.5 All site training activities should be consolidated under one person who will be responsible for all site-related training.
D.6 The retraining program for licensed personnel should be modified to accommodate team training and incorporate training peeds identified by on-shif t performance and/or evaluation.
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E. ORGANIZATION / STAFFING
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- 1. Introduction ;
l This section considers factors such as span of control, resource l allocation, and reporting relationships.
Other factors of less significance are the logistics involved because of the physical separation between the Diamond Hill facility and Fort St. Vrain, wasted motion occurring because of duplication of effort, and failure to address issues in a timely fashion. In addition, information derived from the previ-ous four sections was considered in the development of recommendations.
It is the Review Team's opinion that all appropriate functional areas have been identified and are included in either. the PSC on-site or off-site nuclear groups. However, optimum organiza-tional efficiency is difficult to realize within the constraints of the organization as it currently exists. A redundancy exists in assigned engineering functions such as site engineering, design engineering, results engineering, and plant engineering. The work activities and number of personnel involved do not 1
support such a wide, diverse variety of engineering organiza-tions. Therefore it is suggested that PSC consider a reorgani- i zation that would include Divisional / Departmental shif ts with a I resultant reallocation of resources and a modification of the division managers' reporting relationships. The organization recommended by the Review Team is in accordance with general nuclear industr,y practice and is illustrated in Figure 1.
- 2. Observations and Recommendations E.1 PSC should augment the nuclear staff with trained personnel having experience in licensing, maintenance ,
scheduling, training, and planning.
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SENIOR NUCLEAR EXECUTIVE a
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OA/QC U
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I I OPERATIONS L CENSING NUCLEAR SUPPORT AND ENG!NEERING l MAIN ENANCE 1 FUELS i
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- e Licensing e Sate / Design e Operations e Health Physics e Fuels e Records & Docume n tation e Maintenance e Chemistry e Betterment - Electrical e Training e Technical Advisors - Mechanical e Security
-Instrument & Control i e Computer Services e Schedulmg e Planning Figure 1. Recomm.inded Organizational Changes
- 2. Observations and Recommendations (continued)
E.2 The Vice President, Electrical Production has four nuclear-related divisions reporting to him. Logistically, these divisions, when combined with fossil production responsibillties and committee involvements, result in a total of nine individuals reporting to this position. The Review Team is of the opinion that this position is overextended. f 1
This overextension has resulted in reduced attention to l detail and diluted involvement as a key decision maker, i l
.This results in a need for individual organizations to act i independently, of ten out of synchronization with others.
Based on these considerations, 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.
i 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 posit.on 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.
I E.3 The present makeup of the licensing and nuclear fuels
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- 2. Observations and Recommendations (continued) standpoint. However, it is the recommendation of the Review Team that these groups be managed from the FSV site.
E.4 It is recommended that all engineering and documentation functions be combined into one organization managed from ,
the FSV site. Functional areas in " Nuclear Engineering" would include:
e Site Engineering (including Nuclear Design) e Nuclear Engineering Records (and Nuclear Documentation Control) e Nuclear Betterment Engineering (excluding I&C Maintenance Functions) e Technical Advisers The engineering group at FSV should be organized such thu they may handle all small and medium projects
(< S1,000,000). All major projects should be handled by the Systems Engineering Division.
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E.5 It is recommended that the Station Manager's organization be modified to assorb I&C maintenance work activities while relinquishing the engineering functions of Nuclear Betterment to " Nuclear Engineering" as discussed in the precedirM paragraph. Further, the "shif t supervisor-t raining" position should be transferred to the training organization. This arrangement will result in an
" Operations & Maintenance" group devoted solely to tne W objective of operating and maintaining the plant .
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- 2. Observations and Recommendations (continued)
Functional areas in "S tation Operations and Maintenance" will include:
e Operations e Maintenance Electrical Mechanical Instrumentation & Control e Scheduling e Planning E.6 The Review Team concluded that the functions of the Technical / Administrative Department are redundant to those of other crqanizadons. Based on expanding
" Nuclear Engineering" 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:
e Health Physics e Chemistry e Training e Security
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'I APPENDIX A CRITlQUE OF HTGR CONSIDERATIONS 1
The Fort St. Vrain power reactor of Public Service Company of Colorado is a high-temperature, gas-cooled reactor (HTG R) and as suen represents a unique facility in the United States. Since the project initiation, this plant l has evolved from an experimental reactor to a demonstration plant and finally to a commercial power plant. The PSC staff assembled during construction of Apparently,
! the plant had the primary goal of making the facility work.
because of design and equipment considerations, the emphasis of " making it work" lasted for several years and has only recently begun to be replaced by an " operating" attitude.
commercial power reactors in the United States are Since all other water-cooled, it is to be expected that regulatory concerns would be primarily directed toward this type of plant. In addition, regulatory action has been almost entirely focused on the " lessons learned" from the TMI accident, and .
the tremendous amount of subsequent correspondence that was directed toward licensees was almost totally concerned with water reactors. It appears that this regulatory emphasis has caused PSC to feel estranged and to have l contributed to the development of attitudes that are not conducive to productive relations with the USNRC. In addition, water reactor concerns, h
combined with limited budgets, have apparently not allowed the NRC to acquire and train a complement of HTGR personnel. It is apparent that the perceived need to continually educate NRC personnel in cas reactor tech-nology has added to the frustration of PSC personnel.
The Review Team is of the opinion that the uniqueness of the HTGR has contributed to the development of an inappropriate sense of isolation of Fort St. Vrain from the rest of the nuclear industry. PSC personnel have elected I
,to minimize interaction with the rest of the industry by infrequent attendance at sponsored meetings or laser groups because they feel such involvement would be of no benefit. They place little or no value on associating with water reactor aroups. Only recently has this situation imoroved througn interaction with INPO.
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-n programs, procedures, and methods developed over the years by the rest of w the nuclear industry to deal with similar-type problems being faced by PSC.
Therefore, it is suqqested that the above circumstances have contributed directly to the difficulties experienced at Fort St. Vrain over the past few N years.
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W APPENDIX B PROTECT DESCRIPTION _
- 1. General W' The activities of NUSOSC in regard to the project were structured to specifically address the NRC requirements as specified in the NRC W report.
To that end, the effort was divided into units of work that addressed the areas identified by the NRC.
Accordingly, NUSOSC incorporated appropriate data into the study from the following:
- Licensee event reports filed from January 1,1982 to May 31, 1984
- 1982 and 1983 Systematic Assessment of Licensee Performance Board Reports
- Licensee response to Generic Letter 83-23
- Conduct of Operations
- Maintenance Practices The project team was broken down into five groups: a management review team and individual teams for operations and mainte nance, licensing, procedures, and training / administration.
The primary goal was to assess the status of nuclear management controls and evaluate the nuclear operating philosophy of the Public Service Company of Colorado. The assessment covered broad areas W
such as management involvement, operation, and commQnications.
operating "att:tudes , " plant
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l used for the assessment were j The basic criteria that were
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performance and oblectives criteria similar to those established by INPO for corporate and plant evaluations.
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- 2. Objectives and Criteria The broad-based program objectives established for the project were to review and assess:
- Management Structure
- Management Practices / Attitudes
- Deficiencies Identified in Region IV Reports
- Deficiencies in Two Previous S ALP Reports
- Operating Philosophy / Commitments Communications
- Training and Retraining Practices
- Work Control Systems / Procedures These areas were condensed during the final project assessment phase into the final report format of five sections.
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- 3. Initial Investigation and Work Plan Development The investigation phase was initiated with the preparation of a detailed work plan for the investigation. The work plan was reviewed and approved by PSC and NRC. Verbal assignments were issued to t
the team which included areas of responsibility, specific topics ,
matters or items to be investigated, and documentation requirements.
- 4. Material Review Process
, Material review was done on documents that reflect the NRC concerns and included the S ALP Reports for 1982 and 1983, PSC's response to Generic Letter 82-38, and all INPO evaluations. In addition, documen-tation and PSC magerial related to the project were reviewed. They )
included procedure' manuals , training manuals , construction work !
packages, corrective action requests, nonconformance reports, enange notices, and procedures. ,
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Material Review Process (continued)
Material was reviewed in an ongoing process throughout the project to assess the suitability and adequacy of the administrative, manage-ment, and technical control systems. In addition, the material review process provided the investigating team with information on manage-ment involvement in the performance of operations, maintenance, licensing and training.
' 5. Interview Process The interview process represented the primary source of information for the overall project. The interview process was structured so as to gather information through questioning on the program objectives.
Managers, supervisors and employees at both the plant and corporate locations were interviewed.
The interview process was structured and performed in accordance with a detailed schedule with over 60 PSC employees being inter-viewed. Most individuals were interviewed more than once.
A total of 83 interviews were conducted.
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- 6. Project Review Project reviews were established to allow the investigating team to meet on a regularly scheduled basis to review the status of their activities and compare information. Project reviews were conducted daily. This process was augmented with reports covering input from the ongoing material review. The project review sessions had two 1
primary objectives: (1) to maintain the investigating teams in synchronization any (2) to provide for a thorough, consistent approach for each successive review.
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Project assessment was the final information and documentation phase that provided input into the final report. Project assessment W gathered and summarized information from the material review process and the interview process to identify observations and recommendations.
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ATTACHMENT TO P-85066 NUS OPERATING COAPORATION SERVICES 3dC MCTTCA AAAKWAY, SUITE 201 HAUPPAUGE. NEW YCAK 11788 (5182 435-C235 OMSD #85-027 February 12, 1985 Mr. Oscar R. Lee Vice President Electrical Production Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201
Dear Mr. Lee:
The purpose of this letter is to clarify certain aspects of the Analysis and Evaluation of the Management of Nuclear-Related Activities of the Public Service Company of Colorado.
Specifically, I wish to report that to the best of our knowledge and belief, neither myself nor any member of the review team observed or was cognizant of any activities or actions that were in violation of your license or federal regulations.
Sincerely, NUS OPERATING SERVICES CORPORATION 4a da B. W. Deist General Manager Operations Management Services BWO:cw ,
cc: Mr. Larry Brey Executive Staff Assistant i
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