ML20128N741

Responds to 850419 Request for Addl Info Re Util Performance Enhancement Program.Formal Shift Turnover Procedure Written & in Place.Review of in-place Control Room Tags Completed. Illegible Tags Replaced W/New Tags

ML20128N741
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/22/1985
From:	Gahm J PUBLIC SERVICE CO. OF COLORADO
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-85178, TAC-60566, NUDOCS 8506030374
Download: ML20128N741 (11)

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Comp.ny of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 May 22, 1985 Fort St. Vrain Unit No. 1 P-85178 m

E Mr. R. D. Martin Regional Administrator

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_ Region IV b, 611 Ryan Plaza Drive, Suite 1000 u -

Arlington, TX 76011 Docket No. 50-267

SUBJECT:

Response to Request for Additional Information -

PSC Performance Enhancement Program

REFERENCE:

1) G-84392, NRC Evaluation of FSV, dated 10/16/84, Denton to Walker

2) P-85066, PSC Response to NUS Evaluation, dated 2/28/85, Lee to Martin

3) P-85107, PSC Performance Enhancement Program, dated 3/29/85, i.ee to Martin

4) G-85143, Request for Additional Information, dated 4/19/85, Johnson to Lee

Dear Mr. Martin:

By way of Reference 4, the Nuclear Regulatory Commission requested additional information with regards to the actions undertaken and in progress by Public Service Company of Colorado to enhance the performance of Fort St. Vrain. Specifically, the Commi ssion j requested further discussion to address Sections 4.2.5 and 4.2.6 of Reference 1. f l {?n C

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LIn certain areas (e.g.. planning and scheduling) there is a great

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deal of overlap between our own internal reviews, the findings' of the NUS' Corporation's evaluation, and the findings of the Commission. ~

The Performance Enhancement Program (Reference 3) was structured to encompass- the recommendations of each of these evaluations-from a programmatic viewpoint,.rather than a symptomatic viewpoint.

. Attachment 1 is' a listing which summarizes the Commission findings and a' response to each of these findings In keeping with the programmatic approach and the schedules. of the Performance Enhancement Program, these responses are not intended .to be all inclusive. However, they should give you a more representative

' perspective of actions completed or expected to be undertaken to address these specific concerns.

If you have. any further questions" in this area, please contact Mr. Michael H. Holmes at (303) 571-7511.

Sincerely, J M.8 aim h J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/pb Attachment l

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. ATTACHMENT TO P-85178 Item 4.2.5.1--Shift Turnover Procedures Summary of NRC Concerns--The licensee does not have_a formal procedure'for controlling shift turnover, nor associated shift turnover checklists.

PSC Response A formal shift turnover procedure bas been written and is in place. The procedure is based on INP0 Good Practices and on other industry input. To summarize, the procedure provides a specific shift turnover checklist for each of the primary Control Room 10perators (to include the Auxiliary Tenders, the Equipment Operators, the Reactor Operators, and the Senior Reactor Operators) and the Shift Supervisor. This ' procedure was developed in September,.1984. Subsequently, on-the-job training was provided to each of the above named personnel. A break-in period of approximately one month was utilized to familiarize personnel with the new procedure and to make final procedural adjustments. The procedure was formally issued on October 10, 1984, as Station Manager's Administrative Procedure 8 (SMAP-8).

Item 4.2.5.2--Administrative Controls Summary of NRC' Concerns--The licensee does not have a formal procedural requirement for the Shift Supervisor or Operators to review the various logs when returning from an extended absence.

There is no procedural requirement to conduct periodic plant tours, although discussions indicate such tours do take place.

PSC Response We have performed a detailed review of our Administrative Procedure P-1 which describes the administrative controls for the Operations Department functions at Fort St. Vrain. We have compared the results of this review with the high industry standards of INPO Good Practice OP-204. It is our opinion that the Fort St. Vrain Procedure P-1 is already too detailed with regards to a number of items such as the control of temporary configurations, and setpoint changes. We have concluded that a better approach would be to rewrite APM P-1, and support this document by " Level 2" procedures. These Level 2 procedures would be directed at the details of existing P-1 requirements as well as additional items such as the observation of equipment condition, personnel and equipment hazards, and so forth.

As discussed in Reference 3, our schedule for final development and approval of the procedural changes to implement the above is October 4, 1985.

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With regards-"to the conduct of-periodic plant tours, a general housekeeping. procedure has been developed .and is in place

'(SMAP-13). The' requirements for tours to inspect. housekeeping r

are incorporated in this procedure.

-As' discussed ~ in Reference . 3, our present schedule for-incorporation of other. tours is~to be completed by June 28, 1985. .

We are reviewing industry practices concerning the review of logs

after an extended absence. It. is apparent that there; is y' considerable Svariation from, plant-to plant'in this regard. Once this' review is completed, .we will revise-_the Shift Turnover:

procedure (SMAP-8) to provide-formal guidance in this area. This-

. revision is expected to be completed by June 28, 1985.

' Item 4.2.5.3--Operator Aids

' Summary ;of- NRC Concerns--There are several locations throughout-

,-the plant where drawings are kept to assist the Operators during '

the performance of-1their duties. Not all drawings at these J" locations:are controlled. . Additionally, there are- controlled system l operating procedures at; some local, panels, but these' procedures.are not located in a proper receptacle.

PSC Response We. have completed an in-depth review of all locations throughout the plant where drawings' (P&I's) are. used by the staff for referen'ce. From this review,'the locations where it is necessary for controlled ~ drawings-to be.present'have been . identified and compiled. This compilation is. presently under. review by.the Nuclear Engineering Division to determine the 'most practicable

'means of ensuring that'such drawings are' controlled.

Nuclear ' Engineering Division has recently obtained the. equipment necessary to; reproduce the large drawings on-site. Upon. approval of thei finalized: compilation,. controlled ' drawings will be-

' distributed and maintained in'the designated locations.

i The, locations for which ~ controlled sets / subsets of the System.

~ Operating Procedures are necessary have been identified. Various

. receptacles Jfor these procedures havebeen investigated,

-particularly'from a fire hazards perspective. We have selected the appropriate receptacles from this investigation and they are

' currently being manufactured. It is expected that we will receive these receptacles 'and have them in place by the end of the year. '

A ~ procedure- for interim use in the control of Operator aids in the Control Room has been drafted and is in the approval cycle.

This procedure describes the administrative. controls to be implemented for the posting of Control Room charts, graphs,<

tables, and so forth. This procedure will be used as the basis to describe the control of such items throughout the remainder of the plant in accordance with Reference 3.

Item 4.2.5.4--Tagging practices Summary.of NRC Concerns--Some tags have been in place since 1982.

Some tags are not legible. This is part of a larger concern in which the licensee has been using status and clearance tags in place of' design modifications.

The licensee's tagging system is confusing because only one tag with appropriate information and a group of auxiliary tags with only a reference number and no explanatory data are used.

pSC Response We have completed a review of all the Control Room tags which were in place and replaced all old tags with new tags that are fully legible.

A detailed review of all tags associated with Temporary Configurations has been completed. From this review, all tags associated with such configurations that could be removed, have been removed. We have also ensured that all configurations which are desired to be made permanent have a formal request for a permanent design change.

In October, 1984, we reviewed all outstanding Change Notices to ensure that those which were associated with a Temporary Configuration were scheduled for completion during the outage (assuming materials and a work window were available). These design changes have been completed. Additionally, all remaining Change Notices of a similar nature have been re prioritized to ensure that they will receive prompt attention.

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Finally, a' complete' draft rewrite of our tagging Administrative

< ' Procedure P-2 has been completed. This new procedure is directed at utilizing a computer-based system for generation of clearance-tags.- .The computer program :has been~ developed and tested.

' Equipment': necessary = for Control Room personnel to use the system has been obtained and installed. Training on:the new system has

.been completed and operator input considered. ' The implementation of this new system, and the issuance of the revised procedure P-2, is' awaiting completion of the present outage. The Station Manager has determined that it is not desirable from either an equipment or personnel safety standpoint to convert'to a new system with the large number of- clearances outstanding during this outage.

Item 4.2.5.5--Shift Supervisor's Office Location Summary- of NRC Concerns--Locating the Shift Supervisor's office outside the Control Room inhibits access to the Control Room for the performance of the Shift Supervisor's duties. The Shift Supervisor does not have a key to gain access to the Control Room.

'PSC Response As . indicated in Reference 3, the entire subject of office space for the staff is under review by Public Service Company and a consultant specialist. A final report of the study'in progress is not yet available.

As the result of Information Notice 83-36,1 keys which permitted access through Security doors were issued to selected personnel at Fort St. Vrain. These keys were for emergency use only, they did not defeat existing alarms to the Security organization, and

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no instances of unwarranted use occurred. Unfortunately, our' understanding of the generic letter .was apparently beyond the scope of what was intended- regarding " controlled" - access.

-Consequently, a Notice of Violation was received and- the keys were returned to the control of the Security Department until procedural requirements could be better defined.

A key control procedure, SMAP-12, was drafted and presented to the NRC for review prior to implementation. The inspector suggested some. changes. We are presently in the process of revising this procedure. Additionally, we are 'considering revising the Shift Turnover procedure, SMAP-8, to make a specific line entry to ensure that control of the key is maintained.

Item 4.2.5.6--Double Verification

' Summary of NRC Concerns--The licensee's program for the verification of correct operating activities is limited.

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' PSC Response-L We agree that the independent verification of some activities at Fort St. Vrain is not as all-inclusive as that seen at most.

pressurized-water reactors. However, we believe that many of the dissimilarities are due to the design of the Fort St..Vrain HTGR-Las opposed to PWR's/BWR's. Almost all of the systems which are necessary for emergency use are in normal use during the routine operation of the facility, and, in general, they are not required to perform differently in an emergency. Therefore, if the system is performing as designed for routine conditions, it should perform as designed in an emergency.

This- is not to :say that improvements cannot be undertaken, and that is our full intent.

We have completed development of the criteria necessary for the independent verification of activities associated with Results Procedures (Instrument and Control). We are presently well into rewriting all of these procedures, and independent verification is being incorporated for safety-related systems.

The development of a listing 'of selected systems which will undergo an independent verification of. valve lineups prior to restart is in progress. In conjunction with this effort, the required checklists are being developed.

A procedural change to APM P-2 to ensure the independent verification of critical valve positioning is in progress. This change 'is to address the situation in which a critical valve is repositioned as temporarily required by an Operations Deviation Report.

As. previously discussed, we are rewriting the procedure which controls status tags associated with Temporary Configurations.

To supplement this effort, we are using the INP0 Good Practice on the control of jumpered and lifted leads. This Good Practice discusses independent verification for such situations. Guidance contained in the document will be incorporated into our procedures.

The complete rewrite of the Maintenance Procedures is scheduled to be completed by the end of 1985, as previously committed in the Performance Enhancement Program. Included as part of this ,

rewrite, will be'the criteria for the independent verification of mechanical and electrical activities.

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Item 4.2.6.3(1)--Scheduling of Maintenance Work Summary 'of NRC Concerns--There is only an informal understanding between the Maintenance groups and the Scheduling group concerning the priority of maintenance activities. Work assigned and the amount completed during report periods is left to the discretion.of the supervisor. i PSC Response In the- latter part of 1954, Zachary Industries' consultant specialists in the area of scheduling and planning were contracted to analyze the-Fort St. Vrain program and implement changes .where improvements can be made. As discussed in References 2 and 3, the objective is to develop an overall (nuclear projects scheduling / planning program which is supported at each nuclear division-level.

In reference to the above concerns, two full-time industrial engineers are working with the Maintenance, Scheduling, and Stores Departments. These engineers have completed their initial

. analysis of our program, and we are implementing the suggested changes. . For example, methods have been developed for controlling the issuance of work to supervisors in a manner that the work assigned to each supervisor can be-monitored by himself and management more closely to ensure that priority requirements have been met.

The entire flowpath of documentation associated with corrective maintenance has been reviewed. Procedural changes to improve the efficiency of this flowpath have been drafted.

A review of the planning and scheduling practices utilized at six nuclear facilities throughout the United States has been completed. These facilities included Arizona Public Service, Arkansas Power and Light, Carolina Power and Light, Duquesne Light and two units from Duke Powar. The method used for planning and scheduling, systems used, and staff organization for each utility was identified.

An in-depth review of the capabilities of the Public Service Company Power Plant Maintenance Information System (PPMIS) has been completed. From this review, various program changes have either been completed or initiated to improve the manipulation of

< data for the special needs of Fort St. Vrain. These changes have.

been directed at facilitating 'the control of maintenance activites, i

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. Previously, . Station Service Requests (SSR's) had been issued to

the work crew responsible for the activity .as the SSR was

generated. This resulted in a rather long list of backlogged items- - for ~each Maintenance Supervisor. As a result, the scheduling function'was essentially performed by the Maintenance-Supervisor which detracted from his ability to supervise his staff. We have corrected'that situation by " pulling back" all SSR's, and reissuing a limited number to.the work crews. This has _significantly improved the adminstrative control of the

-SSR's, including priority control, and resulted in a more manageable supervisory ~ work load.

, Item 4.2.6.3(2)--Preventive Maintenace Summary of NRC Concerns--The PM program appeared to use a static, non-technical approach, rather than a dynamic, technology basis, engineered method for-ensuring equipment readiness.

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. PSC' Response In June of 1984, Public Service Company of Colorado began the development of a more effective Preventive Maintenance program.

The salient points of the program are to incorporate means for engineering analyses, evaluation of effectiveness, trending, and flexibility of use.

Since that time, we have completed a number of interim' milestones. For example, some areas in which we have

-historically had difficulties have been specifically addressed.

In particular, these include the bearing water pumps and the instrument air compressors. Plant Maintenance Engineers have successfully assisted the Maintenance staff in identifying and correcting maintenance difficulties in these areas.

We .cre in the final stages for the development of a Significant Compoaent List. This is a listing of components whose failure or -

inoperability' could result in a significant moisture ingress or a restriction of-the plant capacity factor. The identification of significant equipment components has been completed; the identification of major valves, electrical relays, and instruments ~is in progress at this time. The Significant Component List will be used as a basis 'for the Preventive Maintenance program. Additional discussion of the PM program may-be found in Reference 3.

Item 4.2.6.3(3)--Spare Parts Maneyement Summary of NRC Concerns--For most components there is no shelf-life = program at Fort St. Vrain.

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'PSC Response As- discussed in Reference 3, Public Service Company is in the

. process of developing a program to review and ducument the .need for a component shelf-life program.

Public Service Company has ' a contractor reviewing the aging.

requirements ~for safety-related equipment as aging is described

'in 10CFR50.49. This review consists of identification of components and comparison of those components 'to a previously established ' data base. Components not within the data base will require evaluation on a case-by-case basis.

The data base developed above will be evaluated and expanded as

.necessary to develop an overall shelf-life program.

Final completion of_this program is scheduled for March 31, 1986.

' Item 4.2.6.3(4)--Maintenance Procedures Summary of NRC Concerns--Some Maintenance Procedures do not appear to be precise. ,

PSC Response Selected Maintenance Procedures have been reviewed for accuracy and adequacy.of detail. Changes to these procedures have been completed.

In the longer term, a complete review of all- Maintenance Procedures (MP's) will be completed by January 3, 1986. This review and rewrite will be based on industry practices, and in particular, INPO Good Practices.

The responsibility for development of. Maintenance Procedures has been ceassigned to the plant Maintenance Engineering group.

Additional staffing for. this group has been requested and approved. It is expected that this transfer of responsibility will result in a more efficient procedure development process as well as a closer tie with other functions performed by the plant engineers.

Item 4.2.6.3(5)--Maintenance Testing Summary of NRC Concerns--Procedures should include requirements that functional testing be performed upon completion of safety-related maintenance, and that these tests be independently witnessed by the Quality Control organization.

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-PSC Response As part of the Maintenance . Procedure (MP) upgrade discussed above, post-maintenance. testing will be specifically evaluated and incorporated into the procedures.

Administrative 1y, revisions to maintenance-related procedures

-(Maintenance Procedures, Electrical Maintenance Procedures, Preventive Maintenance, Electrical Preventive Maintenance, Relay Shop Procedures, Results Procedures, and. Fuel Handling Work Packets) are required to be routed to the Quality Control organization for the incorporation of Hold and' Witness Points.

This. administrative control is specifically required _ by Administrative Procedure G-2. We would intend on continuing this program under the rewrite program.

Item 4.2.6.3(6)--Backlog Summary lof NRC Concerns--There is no immediate means of displaying backlogged maintenance activities (SSR's) to management.

PSC Response We have completed the transfer of manually-maintained information to the computer-based.PPMIS system. We have also purged-the SSR backlog to improve the accuracy of the backlog.

To. summarize, all SSR's have now been identified as falling into

,one of the following categories:

On Hold for:

Plant Conditions Materials Engineering Disposition Required Quality Control Disposition Required Leak Test / Operational Test Required Executable, Awaiting Release Work in Progress Completed and ready for Data History L- In conjunction with the above program, the Station Manager receives a report of all SSR status items. This information is presented in both tabular and graphical form.

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