ML20137M125

Vol 1 to Audit of Fort St Vrain Performance Enhancement Program

ML20137M125
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/20/1985
From:	Stern G, Stoller S, Van Howe K S.M. STOLLER CORP. (SUBS. OF ARTHUR D. LITTLE, INC.)
To:
Shared Package
ML20137M100	List: ML20137M096 ML20137M103 ML20137M125
References
NFSC-G-85-03, NFSC-G-85-03-V01, NFSC-G-85-3, NFSC-G-85-3-V1, TAC-60566, TAC-62169, NUDOCS 8601280197
Download: ML20137M125 (33)

Text

_~ . _

O i

Appendix B Audit of Fort St. Vrain Performance Enhancement Program Volume !

Performed by:

The S.M. S toller Corporation 191914th Street, Suite 500 Boulder, Colorado 30302 (303) 449-7220 December 20,1985 D5C1. AIMER The S. M. Stoller Corporation (SMSC) has exercised its best efforts to meet the objectives of this assignment and to that end has applied to the work professional personnel having the required skills, experience, and competence. SMSC's liability, if any, for any damages, direct or consequential, resulting therefrom are limited to the amount paid for this assignment.

8601280197 060115 PDR ADOCK 05000267 o PDR

\

NFS C-C-8 5 -0 3 i Audit Report

. Page l of 16 EXECUTIVE

SUMMARY

In late October, The S.M. Stoller Corporation (SMSC) was engaged by Public Service Company of Colorado (PSC) to conduct an independent audit of a sweeping program to enhance performance of their nuclear program. That program had been defined and formally committed to the NRC in an Action Plan of February,1985, and a Program Plan in March,1985, primarily in response to an assessment of the PSC management of its nuclear operations performed by an outside consultant, and in recognition by PSC that the past performance of the nuclear operations has been less than satisfactory.

The Performance Enhancement Program (PEP) assigned the corrective actions to six specific projects; implementation of each of the more than thirty specific sub-projects was assigned and sdeduled. The principal function of the SMSC audit was to measure progress of that implementation process. In addition, and as appropriate, our judgment was sought as to the likely success of the PEP arid /or its individual components. The work was to be conducted mder PSC procedures governing Quality Assurance audits.

We conclude that the PEP is a well thought out and well structured program. If carried through with a strong sense of management commitment, which appears to be present, its implementation should improve the conduct of the nuclear operations -

substantially.

We are concerned with slips in the implementation schedule. These, if corrected, do not threaten the objectives of the PEP. However, to the extent they are due to delays in hiring the additional staff required, a problem aggravated by excessively high loss of people from the nuclear organization, that would potentially have a serious impact.

PSC is aware of the urgency to act on the human resources issue, and has initiated a number of measures which should improve that particular situation, and should also benefit the effectiveness of the working organization more generally.

i I

t

NFSC-G-85-03

. Audit Rsport Page 2 of 16

1.0 INTRODUCTION AND BACKGROUND

in November 1984, Public Service Company of Colorado (PSC) contracted with a consultant for an independent assessment of Public Service Company's management controls for its nuclear activities. PSC had recognized the need for such an independent assessment as a result of evaluations by NRC, as well as from internal reviews, and had committed to its performance in a PSC/NRC meeting held at the Region IV offices in Arlington, Texas on September 20, 1984. The scope of the assessment was further defined in response to certain areas of concern that were identified in the NRC Report of October 1984 (Reference 1).'

By letter of January 2,1985, Mr. R. F. Walker inf armed NRC that PSC would produce an Action Plan addressing the recommendations of the Cormultantt Report 30 days af ter review of the report. The Consultants' Report was in f act received on January 30,1985 (Reference 2)', and by letter of February 28,1985 (Reference 3)', Public Service delivered the promised Action Plan to NRC. In that Action Plan, which constituted a first-phase response to the Consultantf report, PSC stated its conclusion that existing management controls of its nuclear program would be strengthened by adopting a structured approach, and the Performance Enhancement Program (PEP),

was developed for this purpose. That program translates the Consultants' recommen-dations, sorne of which were necessarily quite general and subjective, into a series of assigned projects, each with an individual identified as responsible ior its implementa-tion, and each with its own schedule.

On March 29, 1985, PSC amplified and extended the preliminary Action Plan, (Reference 3) above, and transmitted to NRC the comprehensive structure and additional detail of the PEP (Reference 4)* to implement those amplified responses.

The PEP was divided into six overall projects (and associated subproiects), and a coordinating organization within PSC was set up to monitor the progress of implemen-tation.

The implementation was to be continuously monitored; a system of monthly detailed progress reports from each project manager was established from which the PEP

• These references are not physically integrated with this report; they are all readily available from PSC records.

2

NFS C -G-85-03

• Audit Rc;) ort Page 3 of 16 Project Coordinator could develop a monthly overall status report. A typical such monthly status report covering the month of September,1985, is included (Refer-ence 5)*. Further, at roughly quarterly intervals, the status was to be reported to NRC; the second such status report covering the four month period from June 3 through September 30, submitted to the NRC on October 21, 1985 is also included (Reference 6)*. The status was also given NRC verbally by the PSC stalf in advance of that report in a meeting with Region IV in Arlington, Texas on October 11,1985. "

As noted above, the initial six projects of the PEP encompassed those concerns identified by NUS, and the NRC, and defines the corrective actions to address those concerns, some of which were already underway at the time PEP was of ficially adopted and transmitted to NRC. The six projects and the subprojects included within them are listed on Attachment 1. It was intended that during the implementation of these six major projects, and as warranted by the results of that implementation, other projects might be added, or the current sx projects would be expanded, to ensure that Fort St. Vrain achieves a consistent standard of excellence. The PEP was thus seen as a "living document," which would need to be adjusted as this comprehensive new system of management controls proceeded.

1.1 Scope of The S.M. Stoller Corporation Assignment in late October,1985, PSC requested The S.M. Stoller Corporation (SMSC) to carry out an independent audit of the implementation program. The scope of that assignment defined in a letter, S.M. Stoller to Leroy Singleton of November 1,1985, is given in Section 3.0.

This report is responsive to that assignment. In all some 36 PSC people were inwrviewed. SMSC expended some 1000 manhours in th2 effort.

The report is organized as follows. Af ter this introduction, Section 1.0, general perspective is offered in the Discussion and Summary, Section 2.0. The next Sections 3.0 through 7.0 in ef fect represent the formal Audit Report. Section 8.0 documents a special area of concern with human resources which in our view, is

• ibid.

" Revised 1/9/86 l

l 3

i NFSC-G-35 -03 Audit Report Page 4 of 16 sufficiently important to warrant being singled out for attention. A list of references, two attachments, Appendices 1 and 2 and a Summary Status Report (Table A),

complete the Report.

It should perhaps be noted here at the outset that although the audit was carried out in conformance with the PSC procedure for Quality Assurance Audits the nature of the subject matter appears'to us to warrant additional comment, as in Section 3.0, which goes beyond the formal structure generally used in such audits.

2.0 DISCUSSION AND

SUMMARY

The PEP was specifically designed to enhance the overall conduct of operations at Fort St. Vrain and the overall control of management over those operations. The mission of the PEP was stated to be as follows (Reference 7, page 1)*:

"To assign and complete activities that will improve the overall quality, management and operation of the Public Service Nuclear Organization in a controlled, timely manner. Progress will be monitored by the PEP Manager /

Master Planning and Scheduling function. The function will provide Senior Management the ability to make proper decisions for allocation of resources and .

the prioritization of commitments at the appropriate time and in the proper m anner."

As defined in the mission statement, the PEP addresses itself to the problems of management control and the classic components. of such control e.g., organization, personnel resources, planning, scheduling, provision of adequate f acilities, communi-cation, and training.

The program seems to us to be very commendable as defined, and the structure is relatively straightforward to monitor. It is very comprehensive in scope, representing a sweeping review and re-arrangement of virtually every aspect of PSC governance of its nuclear activity. It is a very ambitious program, and a costly one. If implemented and followed through diligently and with a strong sense of management commitment, as it appears to be, it should improve the conduct of nuclear operations at PSC substantia!!y.

• ibid.

4

e NFSC-C-85 -03 Audit Report Page 5 of 16 Specific comments regarding that progress are given later in this report (see I

Sections 3.0 through 8.0); a summary of the PEP stava is tabulated by project and subproject project in Table A following.

At this stage, when some of the projects are not yet complete, and when this massive change in management and operating procedure has not yet functioned as a whole, such improvement in perf ormance cannot yet be docv aented. A more explicit judgment could better be made in six months to a year, when a re-audit would be appropriate.

Albeit we find implementation progress encouraging, wt .se concerned about some of the delays that have occurred, some of which may simply reflect unrealistic optimism in sdieduling, but others clearly reflect intrusion of other high priority tasks, such as Environmental Qualification (EQ). Since this is a situation that will continue to occur, it must be controlled. We are also particularly concerned with delays in assembling

. the expanded staff of properly trained and experienced people as specified by the PEP.

At this stage, we do not view the delays as especially serious or threatening to the objectives of the PEP, but the pattern of delays must be stopped and the trend revers 2d.

3.0 PURPOSE The purpose of this audit, carried out taider PSC procedures for QA audits, was:

To verify that the Performance Enhancement Program (PEP) has met (or reasonably will meet when completed) the commitments made to the NRC in the PSC ACTION PLAN dated January 30,1985 (Attachment to P-850566) and in the PEP dated March 29,1985 (Attachment to P-85107).

To verify that the implementation of the PEP is being performed (or reasonably will be performed when implemented) according to the provi-sions defined by th.e PEP.

To verify that implementation of the provisions defined by the PEP has (or reasonably will when implemented) eliminated the deficiences relevant to the PEP identified in: (1) the NUS Management Audit dated January 30, 1985 (Attachment to P-85066), (2) the OctoLer 1984 NRC Assessment Report (G-84392), and (3) the NRC Systematic Assessment of Licensee Performance Report f or October 1,1983 through February 28,1985 (G-85171).

l

• ibid.

l f

5

i l

NFSC-G 85-03 l

. Audit Report )

Page 6 of 16 j 4.0 SCOPE A pre-audit investigation has been performed consisting of a review of the following documents a) The NUS Management Audit dated January 30,1985 (Attachment to P-85066) (Reference 2)*.

b) The October,1984, NRC Assessment Report (G-84392) (Ref erence 1)*.

c) The NRC Systematic Assessment of Licensee Performance Report for October 1,1983, through February 28,1985 (G-85171) (Ref erence 10)*.

d) The PSC ACTION PLAN dated January 30,1985 (Attachment to P45066)

(Ref erence 3)*.

e) The PEP dated March 29,1985 (Attachment to P45107) (Reference 4)*.

f) Documentation for the various PEP Sub-projects The scope excludes projects Vil and VIII defined in PSC document CRG-85 008.

For each sub-project, checklists were prepared identif ying program commitments, implementation practices and dispositions of observations / recommendations by the implementation of the PEP. Commitments were identified f rom documents d) and e) above. Im%ementation practices were identified from the documents of f) above and observations / recommendations were identified from documents a), b), and c) above.

Only those observations / recommendations directly related to the PEP were identified from documents b) and c)above.

Interviews were conducted with the individuals responsible for the various PEP sub-projects as well asindividuals who are or will be implementing the provisions resultmg f rom the PEP. Based upon these interviews and the review of the documentation, the subproject checklists were completed. In addition, general interview discussions covering the overall scope of the PEP were held with L. Brey, Manager Nuclear Licensing and Fuels and R.F. Walker, President, PSC. The human resources issue was covered in an interview with C. Ewald, Vice President, PSC.

• ibid.

6

I

- NFS C-C-8 5 -03 Audit Report Page 7 of 16 5.0 METHOD An Audit Plan - Performance Enhancement Program (NFSC G-85 03), November 1985 (Reference 9)* was prepared describing the purpose, scope, notification, references, sdiedule and checklists for the audit. Auditors and a Lead Auditor were selected and qualified in accordance with ANSI N45.2.23-1978.

A procedure for conducting the audit of the PSC Performance Enhancement Program was prepared and followed, as described:

- The audit was performed in accordance with NFSC.G 85-03 (Reference 9)*

and the PSC Guidelines for Quality Assurance and Nuclear Facility Safety Committee Audits - QAAP-i ', Reference 8)*.

- The auditors completed and maintained iniormai notes on a pre-audit piase of the program.

. . Checklists were then prepared for each sub-project to be audited listing commitments from documents P45107, P45066, CFR-85 408 and signifi-cant items from G-85171, G-84392 and the Attachment to P-85066 (NUS report). These commitments were related to the PEP program through a series of questions.

- Each "B" checklist covering a specific subproject contained a space for references to the source document (s).

- Space was provided for evidence examined and referenced in the Checklist "B" f or each subproject.

t

- Notes were added to the auditors' checklists evaluating the responses by the interviewees, when called f or.

A f ter completing checklist "B" a summarizing checklist "A" already prepared, was filled in by the auditors comparing the commitments made in P45107, P45066, and implemmtation for each subproject with the ac-complishments to date and estimating the likelihood of meeting the commitments as scheduled.

- The Lead Auditor reviewed Checklists "B" and "A" and along with SMSC audit personnel prepared tentative findings, observations and comments for review and discussion with PSC QA management and the auditors in a meeting held before the post-audit conference.

• ibid.

i 7

- ---- - , , , - . ..n., , - , . , - . . , . - . , . . - , . ,

-- n. , -.,- ,--- - . - - - - - . . .

8 NFS C-C-8 5 -03 Audit Report Page 3 of 16 The audit team members were given orientation and training based on 10CFR Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Repro-cessing Plants" and in accordance with ANSI /ASME 45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities" A pre-audit conference was held at Fort St. Vrain on November 21,1935 (Attach-ment II). At that time PSC attendees were briefed on the procedure to be followed, given copies of the Checklists 'S" and "A" in their specific areas and requested to set up specific dates, times and designate PSC personnel to be present to participate in the interviews. Attachment I lists the Sub-Projects by number and title, the PSC personnel participating and the SMSC auditors.

The Checklists 'B" and "A" which formed the basis for the conclusions, findings and recommendations or included in this report as an Appendices 1 and 2.

6.0 FINDINGS As noted earlier, the audit findings (See Checklists "B" and "A" in Appendices 1 and 2) indicate that the Performance Enhancement Program (PEP) implementation is pro-ceeding under a strong and sincere mandate from management, but there have been schedule slippages in its impiementation.

Apart f rom the general concern above, the specific Findings are:

o Subproject I.4 (Evaluate Staffing L evels). Staffing needs have been identtfied, but filling those needs has not yet been completed (Refer-ence 11)*. Certain senior and experienced positions need to be filled urgently. PSC is aware and taking action. The problem is aggravated by loss of key people (see commen. on Checklist 1.4).

o Subproject IV.1 (Review and Revise Design Change Modification Process).

While there has been substantial effort made to simpitly the procedures-pertaining to Change Notices (CN's) within NED, there has been little progress in coordinating the inter-divisional responsibility for CN's. It is particularly important that coordination between NED and NPD be strengthened. A prioritization system for CN's has been proposed but has not yet been approved or implemented.

• ibid.

3 I

s NFS C-G-85 -03 Audit Report Page 9 of 16 7.0 OBSERVATIONS The Observations are: .

o Subproject I.8 (Evaluate Staff Retention). Sixty-seven of seventy-eight new positions have been filled by transfers and new hiress however, at the same time, forty-two have been lost by transfer out of nuclear or by resignation. The material available for review by the audit team presents data as to the numbers of resignations and transfers, but there is no analytic support data as would be required to provide an adequate picture of the underlying causes; e.g., as might be established f rom " exit interviews". It would also be useful to do more detailed comparisons with other nuclear utilities; for those utilities whis seem to be managing this problem reore successfully,information might be solicited as to the means employed, including compensation comparisons.

o Subproject 11.3 (Implement Planning and Schedulina Methods and Procedures). The commitments to establish planning and scheduling functions at each division have been met, and all divisions are being I

coordinated by the Master Planning and Scheduling Function. While progress toward meeting all commitments is moving well, objective meas-ures of success will not be apparent for at least six months to a year, af ter planning and scheduling has been operating for a period of time. Because this subproject covers a very important itsiction, it is important that planning and scheduling continue to receive management attention and that implementation proceed expeditiously.

o Subproject V.7 (Develop Nuclear Production Division Training f or INPO Accreditation). The traarung programs being developed address job require-ments, but are not addressing departmental responsibilities and goals of the-nuclear organization as committed to on Page 34 of P-85066. The NPD Training Department is presently leaving training on departmental respons-ibilities and goals of the nuclear organization to the individual department super-isors.

o Subproject V.9 (Retrain Licensed Personnel). Although the current requirement of 10 CFR 55 and the proposed changes are understood, it is not possible to make sure that the program covers a!! requirements until they are issued. -The lack of a plant simulator may make it difficult to meet all requirements of the proposed danges.

o Schedule slippage. There have been some schedule delays in a number of subprojects. Most of these are already acknowledged in PEP status reports, and th reasons for the delays have been documented. These delays do not appear at present to be serious, and in many cases the task, while delayed from its original sdedule, has been completed. in cases where projects are still not complete, schedule does require continued close attention.

Items of schedule slippage include:

• ibid.

9 l

0

. NF5 C-C-85 -03 Audit Report Page 10 of 16

- Subproject 111.3 (Develop PM Engineerina Program). The existing preventauve maintenance and current maintenance procedures will be rewritten by January 3,1986, but they will not complete the review cycle and be issued f or another month or two.

~Subproject IV.! (Review / Revise Design Change Modification Process). Target compienon dates for subtasks REV-PROC 5 and TRAINING identified in the Target Schedule of November 20, 1985, have apparently slipped in their schedule.

- Subproject IV.4 (Review Essential Regulatory Docum ents). The schedule for Task 1 (Review the Essential Regulatory Documents) of this subproject has slipped from a Target completion date of Novem-ber 1,1985, to an exprcted completion date of January 15,1986. The reason for this schedule slip has been difficulty in resolving some commitments..

- Subproject IV.5 (Review and Revise Nuclear Production Procedures).

It is now anucipated that the SOP's and RP's will be revised by Mard 31,1986, rather than January 3,1986. The delay was caused by attention being given the the Environmental Qualification (EQ) prog, ram and the resulting unavailability of plant personnel to retype and review the revised SOP's and RP's. It is now anticipated that the l EP's will be revised by December,1986, due to reasons similar to that for SOP's and RP's.

- Subproject IV.6 (Review and Revise Exclusion List and Related

! Procedures). Some procedure changes have received some inter-

! divisional review; however, they still require a DCCF review. The schedule originally called for a reissue of these procedures by October 1. This date slipped to November 15 and is currently set at December 20,1985. The reason f or this slip in schedule appar ently is the increase in the eff ort required as the scope of the project increased.

l

- Subproject V.3 (Enhance 10 CFR 50.59 Training). Training of NED personnel in compleung 10CFR 50.59 revtews was scheduled to be completed by October 15, 1985. This date has slipped to December 9, 1985, and is likely to slip further to at least January 1,1986. The reason for the sdedule slip has been the involvement of NED personnel in other tasks (see NLG-85-341).~

- Subproject V.7 (Develop Nuclear Production Division T~ raining for INPO Accreditation). Part 1 operator accreditation will not be completed until March 1,1986, as compared to the January 3,1986, date in P-85107 (Page 4). The reactor operator lesson plans will be completed by January 3,1986, but the senior reactor operator and non-licensed operator training will take longer. The delay appears to be produced by the availability of experienced plant personnel to

• ibid 10 e

.- - . . _ . , _ _ _ . _ . - _ _ = _ - _ _ _ ___.._.___ _._ _ ._ _ _ - __. ____ ____

NFS C-G.35 -03

- Audit Repore Page 11 of 16 participate in the training program development effort due to other responsibilities including: control rod drive rework and evaluation, plant operations and maintenance activities, review of revised tech-nical. specifications, and the environmental qualification program.

- Subproject V.9 (Retrain Licensed Personnel). As with the develop-ment of an INPO accredited training program, the completion of Part 1 Training Program Development for Retraining will be delayed.

beyond January 3,1986. Operator retraining will be complete on Mardi 1, 1986, and non-operator training on September 30, 1936, consistent with the Initial Training Program Development * *.

- Subproject VI.6 (Improve Parts Manaaement' System). Althou$ the Initial Assessment of Part I may be completed by December 31, 1985, the revisions to the procedures will most likely not be com-pleted at that date. Draft revisions of Administrative Procedures Q-4, Q-7 and a new draf t procedure G-14 are available but not fully finalized. Two versions of the draf t procedure G-14 " Procurement System"~are available. The most recent draf t dated !!/19/85 defines five classifications. "Q" for Safety Related, "C7 for Commercial Quality which may be used in safety related systems,"N7 for non-safety related, "NS" for non-safety related but where high quality is desired, and "Cl" for commodity items not used in the plant. This classification system has not yet been adopted.

- Subproject VI.7 (Establish Component Shelf-Life Program). The original schedule for compleung the Aging Study has slipped from November 1,1985, to November 15, 1985, until February 3,1986 (in the November 20,1985, Target Schedule). Currently this latter date appears achievable. The reason for the slip has been EQ commit-ments and the need to reanalyze some of the original study results.

As a result of this schedule slip, the installation task has slipped f rom March 31,1986, to June 2,1986.

3.0 A B ASIC CONCERN The reasons for the poor operating history of Fort St. Vrain over the past years are obviously many and complex. There have been serious problems with the unique HTGR technology. This nuclear plant is complex to operate and maintain, and requires constant diligence and dedication by the operating forces, which goes beyond knowing their formal job responsibilities. This has been recognized as a f act of lif e in all j' nuclear systems, but certain aspects of the HTGR require extraordinary attention by the operating staff, e.g., avoiding water ingress throuph the helium circulator seals, where in a matter of minutes, enough water can get into the system to require months

• ibid

• At the Post-Audit Conf erence (12/16/85), it was pointed out that this subproject has been readdressed and with the addition of personnel,is now back on schedule.

11

_ . - . . _. . _ . . .- _._y, - . _ -.m _ , . _ , . _ . _ . , . . . , - , - , . _ ~ . , . . . _ .

U NFS C-G-85 -03

. Audit Report Page 12 of 16 to remove. Also, the reactor facility is an old one and is very crowded and difficult to work in. Albeit part of the PEP is devoted to general enhancemmt of the f acilities so ,

as to improve working efficiency, the reactor building circumstances, as a practical )

matter, are very difficult to remedy. l The Consultants' repnrt alto made a .zabstantial point that the tmiqueness of the HTGR technology has engendered an"isolatknist" attitude at Fort St. Vrain. Unf ortunately, their recommendation tecued to key on more general participation in industry organizations, which we do not fuel is the main point. Actually, we believe (see Checklist V.2 B), that PSC has a reasonable activity level in such aff airs, many of which are of little direct value to PSC. In fact, it is too easy for nudear utilities to become committee " groupies", and with the limits on PSC resources, this must be controlled. However, to the extent that an " isolationist" attitude may have inhibited earlier planning for the EQ problem. PSC clearly needs to be alert to that attitude. A

, positive example was the analysis of the Davis Bess? event (subprojectll!A), which was worthwhile and well done; such activities should be encouraged on a selective

, . basis.

Among the numerous analyses and audits of the past performance of Ft. St. Vrain, lack of management control has been identified as an portant factor. The PEP is, of course, aimed at that problem and is a responsible approach to it. At the same time, it is equally clear that successful operation must include those aspects whid bear on human effectiveness. The prior assesments by NRC,INPO and the Consultant's Report make it clear that the human side of the PSC nuclear enterprise has not been operating effectively.

This is not an unexpected finding given the f rustrations in Ft. St. Vrairts operating history over the past several years. However, an environment where employees are likely to have become increasingly defensive and frustrated cannot be allowed to go on ,

without serious efforts to correct that environmc.nt. We would expect that a dramatic change can be expected of and by itself when the plant goes back into operation. A successful operating campaign at reasonable power levels, would be the best single morale booster, but it involves matters including regulatory jurisdiction, over whid PSC has limited control and it should not diminish the need to pay special and urgent attention to changing the human environment.

• ibid 12

NFS C-C 03 Audit Report Page 13 of 16 1

j One of the clearest and most dramatic manif estations of this can be found in the data on retention of the employees in the nuclear program at PSC (Reference 12)*. It is beyond the scope of this audit to investigate those data in detail and our understanding of them is limited from the data available. However, the statistics on'their f ace I demonstrate a serious problem, e.g., such los* in retention on a normalized basis is some 2.6 times that of the average loss in other departments at PSC. The resignations undoubtedly reflect a number of individual and personal considerations, including compensation, which is likely one of the key f actors. At the same time, the transf ers out of nuclear, many at the same pay grades, clearly underscores the presence of other factors, and appears to bear on the conclusions of low morale and high stress found by Wilson surveys and other analyses by the personnel specialists at PSC. This loss of experienced people, and the corollary pressure on additional training, clearly threatens the timely implementation of the PEP program.

PSC has recognized this and is giving priority attention to human resource progrtms which extend beyond the defined limits of PEP sub-projects. There is little question that compensation policies and special recognition, at least- for selected crincal positions in'the nuclear divisions,is an area currently under detailed review. PSC has also embarked on an expanded career planning and employee motivation effort including techniques which appear to be representative of the best such techniques in use in U.S. industry today. For example, the excellent results of an abbMviated special motivatonal training session have encouraged PSC to authorize an extended and qJite comprehensive program, using the services of an expert outside consultant organization, to strengthen the sense of responsibility and personal commitment by the employees (Reference 13)*.

The steps noted above are commendable, and clearly are moving in the right direction.

Management commitment to solving the human resources issues is so icenta.1 that we think a human resources action plan should be f ormalized and pr obaialy 3tructured in the same general form as the PEP. Our concern is that, absent such a structured commitment, putting the proper number and of quality hunian resources in place, and retaining them, at Fort St. Vrain could take so long as to frus': rate the very worthwhtle objectives intended by the PEP.

• ibid 13 l

. . - . . - . . , , , . . - - . ~ - . . - - - - . . _ -

l1 NFS C- C-3 5 -03 .

Audit Report Page 14 og 16 9.0 ATTACHMENTS [not included]

9.1 Table A Summary Status Report 9.2 Attadtment ! A~udit Participation Summary 9.3 Attachment !! PEP Project Description and Audit Personnel J

l l

• ibid l

l 14

?

I NFSC-G-85-03 Audit Report Page 1 of 1

_ .' 4 x v' E l /

G. Stern Date LeadAudito/j/

blzA*/v'

! S. M. Stoller

/sbhDate Auditor AW /2ht/b'

/

K. R. V[n Howe Date Auditor M modA ilixtv M. H. Raudenbush Date Aud or Yi bhl I 3G E. A. . Olson' Date Auditor a

h If/ 1 W. A. Franks Date A"dit #

Reviewed:

%M. J.% h ris w wl- '

W Date

^\ Operations Manager lX  :- /2 20~ A~[

P. M. Burck Date Supervisor, QA Auditing Approved:

N M-b h h L. W. Singlet ~ Date Manager, Qual Assurance

i NFS C-C-85 -0 3

. Audit hport Page 16 of 16 R ef erences*

1. NRC Assessment Report, G-84392, October 1984 4

2. NUS Management Audit Report, January 30, 1985 l (Attachment to P-85066)

3. Letter, February 28, 1985, O. R. Lee to R. D. Martin. - PSC Action Plan dated January 30,1985 (Attachment to P-85066) 4 PEP dated March 29,1985 (Attachment to P-85107) )

5. Perf ormance Enhancement Program - S tatus Report as of 9/30/85 (CRG-85-003)

6. Status Report, Performance Enhancement Program, As of September 30, 1985 (CR G-85-006)

7. PEP - Project Manager Binder - current issue.

8. Guidelines For Quality Assurance And Nuclear Facility Safety Committee Audits, (QA AP-1), Issue 2,12/6/84.

9. Audit Plan Performance Enhancement Program (NFSC-C-85-03), November, 1985

10. NRC Systematic Assessment of Licensee Performance Report f or October 1, 1983 through February 28,1985 (G-85171).

11. Memorandum - Gregory Thielan to Oscar Lee, 11/19/85.

12. Memorandum - Duane Rogers to Oscar Lee, 11/27/85.

13. Proposal from 'The Training Company, Inc.", !!/18/85.

'These references are not physically integrated with this report; they are all readily available from PSC records.

! 16 t

_ , , , , _ . _ _ y. -

. I Appendix C Response to NRC Questions Regarding Performance Enhancement Program The purpose of this appendix is to respond to questions that were raised in a letter dated October 3, 1985 to Mr. O. R.

Lee from Mr. Dorwin R. Hunter, Chief Reactor Safety Branch, Nuclear, Regulatory Commission (NRC), Region IV. The questions are in regard to Public Service Company (PSC) of Colorado's responses to the NRC Assessment Report from October, 1984 and the third-party management review completed in January,,1985 by NUS Operating Services Corporation. The' Performance Enhancement Program (PEP) was formulated March 29, 1985 (letter P-85107 from PSC to NRC) to implement recommendations in the two evaluations.

A. Additional Information to Respond to NRC Assessment Report Finding 4-2 The licensee should provide details of the plant tour program.

Nuclear Policy and Guideline 22 (NP&G-22), Management Tour Policy, was issued by executive management to be effective on August 9, 1985. The policy states the objectives, responsibilities and requirements for the plant tour program. To summarize, the policy includes obtaining information regarding adherence to standards, performing housekeeping, observing material condition, and executing work. Other objectives are to improve communication with performance level personnel and to faqilitate management visibility. Responsibilities and requirements are presented in tabular form for the executive level down through the supervisory level.

Implementation of NP&G-22 is accomplished via Station Manager Administrative Procedure 13 (SMAP-13),

Procedures for Plant Tours by Management. Of most direct impact is the requirement for plar t management to conduct tours of assigned areas at least weekly.

Observations concerning material condition- and housekeeping are documented and entered into a computer based tracking system that -includes the individual responsible for resolution. A . weekly report- is generated. to ensure that problem areas are being promptly addressed. In addition, the Station Manager receives a compiled report on a weekly basis to facilitate proper management attention to identified deficiencies.

Finding 4-9 The licensee should submit a more complete description of procedure ENG-3, for further review by the staff.

Procedure ENG-3, Control of Design Documents, indicates the steps to be taken to insure that the Process and

Instrumentation Diagrams, electrical schematics 'and electrical logic drawings (P&E, E and E-1203, IB and IC) are revised to show the modified plant prior to the system being returned to service. A new revision to ENG-3, to clarify and stronghten the detail instruction and to efficiently identify responsibilities, was issued and became effective. January 8, 1986. The procedure identifies the Supervisor, Nuclear Site Construction as being responsible for maintaining.the "special handling location" drawings and that the Drawing Coordinator will implement the requirements. Controlled Work Procedures (CWP's), Deviation Requests (DR's) and Change Notices (CN's) will be utilized to update a sepia of those specific drawings. The sepia is a copy of the latest revision of the controlled design document. Certain controls are to be implemented to record what CWP's and CN's have been incorporated as well as any DR's that were authorized during construction. Documents will be stamped to indicate "as constructed" and dated. For the detailed steps please refer to a copy of section 4.11 of ENG-3, copy attached as Exhibit I.

Finding 4'-10 Confirm 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 hav.ing the equipment removed from service.

The surveillance testing program requires an independent review of test results and the approval of those test

results by the responsible department supervisor. Upon completion of these review steps, the~ Shift Supervisor 1 is required to sign the surveillance test. The Shift Supervisor verifies that he has been informed of the test results (including any deficiencies), that he.has taken actions required by the Technical Specifications with respect to such deficiencies, and that such deficiencies have been noted in the Station Log Book and/or the Technical Specification Compliance Log.

Maintenance activities which require the removal of equipment from service are performed under the system clearance program. New procedure SMAP-19, Processing of Equipment Clearances .and Operation ~ Deviations, specifically requires the- authorization of the Shift Supervisor before the clearance is hung and requires the-initials of the Shift Supervisor upon return of the clearance.

1 Work that is performed under the clearance is either routine maintenance via the Station Service Request program or plant modification via the Controlled Work Procedure program. Each of these work programs has specific post-work testing requirements that must be satisfactorily completed before the clearance is returned and the equipment is placed back in service.

Thus, the Shift Supervisor has ultimate control of the

! # actional acceptability of returned equipment, since it

I

~

EXHIBIT I Public FORT ST. VRAIN NUCLEAR GENERATING STATION ENO-3 Issue 9 SerVICS PUBLIC SERVICE COMPANY OF COLORADO page 1 of 61 l CONTROL OF DESIGN COCUMENTS IS S L., AN C E

• 7 "'i' &- u,7 V i W ,gju l

PORC I E::ECTI' E A EVIEW l C.M E l-T-%6 INDEX Pa r'e 1.0 PURP0SE..................................................... .2 2.0 A P P L I C A B I L I TY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3.0 GENERAL................... ................................... 2 4.' PROCECURE 4.1 Cesign Occurent Nu-ter assignrents .... ....... ...... 4 4.2 Sign-off Recuire ea 3 'cr Cesign Cccurents ........ .... 5 4.3 New Cesign Docu-a- s ................ ................. 6 4.4 Revised Cesian 0 curents ............... .. ........... 3 4.5 Controlled Stcrsce c' resica Documents .. ............. 9 4.6 Entry and vari' caticr cf Ces cr Occumen-Informa*4cn into Ca*.a 5ases...... ........... . ...... 11 4.7 Centrolled Dis *ri u t'en o f Ces i g" Docu en s . . . . . . . . . . . . 13 4.3 NCnControl'ed Cecies ......... . ....... ...... . ... 14 I 4.9 Control of Security 9 elated Cocu.ents.... ........... '5 1 4.10 GA Controlled Cocu ents........ . ...... ... .... ... 15 4.'l Ucdatina resign Occuments for 5:ecial Pancling Lccations . ....... ... . ......... 16 4.12 Stamping Design Occu ents te Shew Unircer:: rated Change Notices . . . .................. ......... ... 18 4.13 D e s i g n D i r e c t i v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 4.14 Wo r k S p e c i ' i c a t 1 c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

5.0 REFERENCES

.. ........ .. ... ........ ........ ... ....... 22 6.0 4TTAChMENTS.................................................. 22 7.0 COMMITMENTS......... .......................... . . . . . . . . . y ;. e ,.,3.;

E. 6 . . '* . . : J

p. , . . . .

. , . . ,4 7.ILi*

O 3C AM Os 372 .'2 Md2

-- .A

• _ sN

i l

Public FORT ST. VRAIN NUCLEAR GENERATING STATION ENG-3 OSerVICO'" Pusuc sanvics comPAmy or cotonAco h'16of61 1

4.11 UPDATING DESIGN DOCUMENTS FOR SPECIAL HANDLING LOCATIONS 4.11.1 The Supervisor, Nuclear Site Construction is responsible for maintaining the r.erked up sepias for P&Is, E-1203s, IC & 18 drawings for the special handling locations as defined by the .FSV-00H, so these documents reflect the latest configuration of the plant.

4.11.2 The Drawing Coordinator (DC) is responsible to the Supervisor, Nuclear Site Construction, for implementing these requirements.

l 4.11.3 The DC shall utilize completed Controlled Work Procedures (CWP) and Document Update Change Notices I (CN) to update a sepia of the affected P&Is, ICs, IBs and E-1203s to the current configuration of the plant.

4.11.4 Prior to revised documents being inserted into special handling locations, the DC shall compare the revised CN Caution Stamp items, and the revision update record to the existing plant configuration sepia. The resultant revised document will reflect current plant configuration at the time of that update.

4.11.5 Upon receipt of the completed CWP or the Document Update CN, DC shall review the CWP, or Document Update CN, to determine those P&Is, ICs, 18s or E-1203s that are affected, a) If drawing update is required, update I appropriate document using DC copy as master, I stamp drawing with Control Room Document Update Status stamp (Attach. ENG-3M) and have checked by the Supervisor, Nuclear Site Construction. A Control Room Document Update Record (Attachment ENG-3L) is also' completed.

b) The DC forwards the marked up sepia to Site Document Control.

c) Site Document Control shall prepare the necessary rumber of copies and place them in the locations specified by the FSV-00H.

d) Site Document Control will return the marked up sepia to the OC.

80AMIC)372 22 300 l

Public FORT ST. VRAIN NUCLEAR GENERATING STATION ENG-3 O$4rVlCG*Pusuc senvsca cOGAPAffY OF C04.OnADO I

' If of 61 4.11.6 Upon receipt of a revised sepia from Site Document l Control, the DC shall compare the document to DC file sepia as follows:

a) If revised sepia incorporated all outstanding changes then this sepia will become new OC master and distribution made per Paragraph 4.11.5(c).

b) Highlight incorporated changes on the Control Room Document Update Record.

c) If revised ~ sepia incorporates a change not l implemented into the plant, the DC shall remove that change from the sepia, stamp sepia l with the Control Room Document Update Status stamp and complete the Control Room Occument Update Record sheet.

d) If revised sepia does not incorporate all outstanding changes, use newly received sepia and incorporate outstanding changes. If the outstanding change requires extensive redrawing then the revision block may be changed to show current revision.

e) fdake distribution per paragraphs 4.11.5(b) and 4.11.5(c).

4.11.7 Upon receipt of a completed Deviation Request (OR) the DC shall determine those Pals, ICs, IBs or E-1203s that are a f fected. The DC shall then update the Control Poem and Shift Supervisor's j Office documents and place a copy of the completed OR in binders that are maintained by the OC in the ,

document update Incations and in the DC file. j a) The affected Control Room and Shift l Supervisor's Office documents shall be stamped I by the DC with a completed "As Constructed Document Vodate" stamp or label (Attachment ENG-3P).

b) If there is no room on the face of the document for the above stamp (or label), place the completed stamp (or label) on the back of the document and annotate the face of the document with "See back of document for As Constructed Update Stamp."

soamom.u me

_ __ _ . _ _ _ _ _ _ _ __ _ - . - ~ .

Public FORT ST. VRAIN NUCLEAR GENERATING STATION ENG-3 O SerVIC9"'Pusuc sanylca COMPANY OF COLORADO ,' gg c) The DC shall maintain a list of unincorporated "As Constructed" changes, d) When a document which is held by the Control Room and Shift Superviser's Office is revised, the DC shall replace the superseded document.

When necessary, the DC shall transfer all "As Constructed Document Update" stamps or labels to the revised document. The DC shall also update the list of unincorporated "As Constructed" changes by deleting all "As Constructed" changes that have been incorporated into the revised document.

4.11.8 Upon receipt of documents that are released for test, either the DC or Site Document Control may make insertions to the Control Room, Shift Supervisor's Office and the Results Shop.

l 4.11.9 The DC shall maintain a separate drawing record sheet for each document. The drawing record shall show the status of each document including the document number, CN affecting it, drawing revision, update information, and applicable date and initials.

4.12 STAMPING DESIGN 00CUMENTS TO SHOW UNINCORPORATED CHANGE NOTICES 4.12.1 See ENG-1 for procedural information on stamping design documents to show unincorporated Change Notices.

4.12.2 Denver Document Control and Site Document Control shall process controlled design documents affected by unincorporated Change Notices as follows:

a) Review the Document Update List (DUL) page(s) in the CN and/or CN reissue packages to determine which CN issues and reissues affect which documents, and update the document stamping status of documents listed on the CN DUL's accordingly.

NOTE: The Design Document Status Index may also be used to determine document i stamping status in conjunction with the OUL.

l l

l Nmusc v2 n-me 1

1 I

.T cannot be returned until the required testing is satisfactorily completed.

Finding 4-13 The licensee should commit to develop a Shift Turnover Procedure.

Procedure SMAP-8, Plant Operations Shift Turnover Procedure, has been in place since October 9, 1984.

This shift turnover procedure is modelled after INPO Good Practice OP-201, Shift Relief and Turnover.

To summarize, specific responsibilities have been developed for the Shift Supervisor, the Senior Reactor Operator, the Reactor Operators, the Equipment Operators, and the Auxiliary Tenders which are -directed at their particular job functions and the interface of their functions with other operators. Salient points are the requirements for:

• reviewing and understanding the Shift Turnover checklist applicable to the position before assuming the shift,

~ '

assuring that the on-coming relief is fully aware of existing conditions,

• on-coming relief is mentally requiring that the and physically fit to competently assume the duties, and turning over equipment that is in a stable condition.

Finding 4-14 The licensee should commit to develop a procedural requirement for licensed operators to read and review operating logs upon return from an extended absence.

The requirement to review' operating logs has been included in the Shift Turnover Procedure described above. In general, the requirement for narrative log review is to be performed since the last time the individual stood the shift or for ten days previous. -I n addition, there are specific requirements for reviewing clearances, Operations Deviation Reports, Temporary Configurations, the Start-up Book, etc.

Finding 4-15 Supply details of the plant tour program.

Please refer to the response for 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).

Please refer to response for Finding 4-9.

L.

Finding 4-17 The licensee should commit to improve the control of system operating procedures in use at local control panels.

A program to improve the control of system operating procedures at local control panels has been developed and 'is in place. The program is maintained via the existing controlled distribution program. To summarize the program, the following has been accomplished:

l

• a' complete walk-down of the plant was performed to

! identify areas where controlled System Operating Procedures should be placed, l

• special metal receptacles were manufactured and I

installed,

• appropriate procedure locations were appended to the governing Document Distribution Handbook, and . controlled distribution procedures were were placed, and non-controlled procedures removed.

Finding 4-19 The licensee should take steps to improve l access to the Control Room from the Shift Supervisor's office, or provide additional explanation of why their current arrangement is acceptable.

A formal mechanism for Operations department control of the access to vital areas has been developed and implemented. This program is defined by new procedure SMAP-12, Control of Vital Access Door Key. In general the procedure requires that the Shift Supervisor retain the key to Vital areas in his personal possession at all times, unless there is a card reader failure concurrent with a plant emergency. Control of the key under the Shift Supervisor is specifically logged in the Shift Turnover procedure for the Shift Supervisor.

Concurrent with the implementation of the above program we have evaluated the feasibility of making design modifications to the Control Room. Although not ruleda out at the present time', we have concluded that such change. could involve significant changes to the Control

. Room, electrical cabling, ventilation ductwork~, fire protection systems, and the Security system. In

> addition, modifications to ~the control room could adversely impact the implementation of Control Room Design Review considerations required by NUREG-0737.

Finding 4-20 The licensee should verify that PEP subproject VI.2, Revise Conduct of Operations, will encompass 'the verification of the correct performance of operating activities.

PEP subproject VI.2, Revise Conduct of Operations, does encompass the. cited requirement. To date, we have

~

i a

.\ s completed and implemented a number of items directed at ensuring the verification of operating activities.

J Examples follow.

Thg clearance' (tagging) program now requires the independent verification of the hanging of tags and the pulling of tags on equipment-returned to service.

t The governing document for the conduct of operations (Administrative Procedure P-1, Plant, Operations) has been completely rewritten, based on INPO Good Practices and Regulatory Guide 1.114. Specifically addressed are the line of responsibility, operation of reactor controls, operational communications, personnel responsibilities, general operating practices, and control room practices.

All Temporary Configurations (not just safety-related) now require the development of a Safety Evaluation by an independent organization (Licensing).

All setpoint changes now require the development of a Safety Evaluation by an independent organization (Licensing).

All changes to the Alarm Index now require an independent review by a cognizant engineer.

All maintenance-related procedures are independently reviewed by the Quality Control organization.

Under the direction of the Superintendent of Operations, valve lineups are performed' independently by two members of the Operations staff.

We are also in the process of rewriting all Results Procedures (RPs). As part of this rewrite effort, we are incorporating independent verification of' appropriate steps.

Effective January, 1986, the Quality Control department will be monitoring the performance of selected surveillance tests. This will supplement the independent review of test results that presently is in place.

l , Selected maintenance activities (at the discretion of QC) are now independently monitored for correct performance by Quality control.

Finding 4-24 The licensee shculd describe how the " safety-related" designation is used in their parts management system.

The term Safety-Related is applied to systems, structures, equipment and components which are identified in the FSAR and as detailed and supplemented by applicable P&I, IB and IC diagrams, E and E-1203

-S-

I O

schematics and the SR6-2 and SR6-8 lists. The parts management system utilizes these drawings and lists to determine what equipment must be purchased to specific requirements applicable to that device (i.e.

Environmental and/or seismic requirements, vender qualification, etc.).

The term " quality-related" as used at Fort St. Vrain does introduce' confusion. For this reason it is to be evaluated to determine whether it will be maintained.

The evaluation is considering using only the terms

" safety-related" and "non-safety related."

B. Addi'tional 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.

These two items _are a part of' the planning and scheduling functions being implemented. Surveillances have always been scheduled based upon defined frequencies and plant conditions. A scheduler in Scheduling and Planning (Nuclear Production Division) releases the surveillances to either- Results or Operations in much the same way that equipment maintenance will be released to Maintenance. The

! surveillance package which includes step-by-step procedures (presently being revised) is assigned to the appropriate organization to complete. In the future, surveillance scheduling will be enhanced and include detailed manloading of the surveillance against available resources.

Surveillances requiring shut-down are scheduled into a planned outage specifically for this purpose. These outages are shown on our Master Schedule in much the same way as a refueling outage but with a shorter duration - usually one month. Two shutdown surveillance outages are scheduled between refuelings.

Recommendation A.6 The licensee should clarify how they plan to analyze for the root cause of procedural compliance failures experienced at Fort St. Vrain.

We have determined that there are four primary contributors for the procedural compliance failures experienced at Fort St. Vrain -and are taking the appropriate actions:

1. Ease of use of the procedures

Procedures in use at Fort St. Vrain had not been specifically evaluated for " user friendliness." We have undertaken a major rewrite ef fort of all System Operating Procedures, Results Procedures, and I

, , , - - , , . . -- , ,- - - - , , , . _ , , + , -- , - .-

Maintenance Procedures to be completed under PEP projects. In each case we are using professional assistance with one of the specific goals being to incorporat'e human factors considerations.

2. Availability of Controlled Procedures at Work Stations:

As described in the response to- Finding 4-17, controlled procedures are now availible at local work stations. This. action has substantially reduced the need to paraphrase operational steps or the tendency to use non-controlled information.

3. Personnel unfamiliarity with the process for changing procedures:

Personnel have been informed that they will'either follow the proceduce as written or revise the procedure so it can be followed. In some cases, personnel were not familiar with the process of how to initiate procedural revisions. This has been corrected by increasing the attention to this process and by. holding supervisory personnel. responsible for following up on employee suggested changes.

4. Personnel Commitment:

In some cases personnel have not followed procedures because of lack of commitment to do so. All personnel have been informed that management views such lack of commitment as unacceptable work performance and that failure to follow procedures as a result of inattentiveness or negligence will result in formal disciplinary action, including termination.

C. Additional Information on Scope of PEP.

The licensee should supply additional information on the scope of each PEP subproject -to show that adequate staf f has been assigned to supervise and implement the PEP concurrent with normal duties.

The schedules for eacn project were established by the project managers based upon an assessment of project objectives and scope and available resources. The project managers are responsible for coordinating .the completion of all project tasks -

not necessarily completing the tasks. Indeed, a number (11) of project managers have two or more projects that must be supervised in addition to their normal duties. These are shown in Exhibit II with brief comments on how the work is being completed. Various approaches have been taken to insure adequate resources are available to the projects. Some are:

• approval and hiring of additional permanent staff, l' i i

6

• delegation: 'of project respons'ibilities to different supervisors, (e.g., System Operating Procedures to Operations and I&C calibration procedures to Results),

• use of contract and/or consulting personnel to supplement PSC staff,

• delegation of tasks to project team members,

• staggering start and complete dates of tasks and projects to minimize overlap,

• " stretching" project completion to accommodate availability of resources, and

• deferring projects where adequate resources are not available.

We have been primarily concerned with completing project objectives in a- quality manner rather than completing projects as scheduled. Consequently, some projects have slipped past their original scheduled completion.

__ m

, <* e Appendix C Exhibit II PSC PEP RESPONSIBII.ITIES (For Project Managers with Two or More Projects)

Current Project Manager Projects Status Comments D.M. Picard, PEP Manager I.1 Formalize Action Plan, Reor- Complete Scope was sufficiently small to complete in desired genization and Performance timetable.

Enhancement Program I.2 Document Chartern, Missions, Complete Responsibility for completion was distributed and Function Statements throughout nuclear organization. Pruject Manager responsibility was primarily coordination of all involved.

I.7 complete Organization Partly Responsibility for incomplete part has been distributed Decision Crida Complete to all divisions.

11.1 Establish Nuclear Master Complete Planning and Scheduling Function II.3 Implement Planning and Sche . Complete Part I was completed by original project manager duling Methods & Procedures but Part 2's scope was large and the implementation Part 1, Initial Definition was split into projectr by division.

III.4 Evaluate Davis-Besse Event Partly Work retpossibillcy has been distributed among project Complete team menNe:2.

C. Fuller, Station II.2 Develop Annual and bong- Partly Contract staff was utilized to complete Part 1.

Man:ger Range Schedules Complete Part 2 is contingent on another project.

IV.5 Review and Revise Nuclear Partly Mr. Fuller is coordinating this effort. The scope Production Procedures Complete is very large and contractorc are Part 1, Initial Definition being used to supplement plaat staff.

Part 2, Nuclear Production Procedures Development Part 3,; Review and Revise Emergency Procedures IV.9 Review and Revise Level I In process Mr. Fuller is coordinating this effort. The work has Plant Procedures (P s G) been distributed throughout the site organization.

Part 1, Revise 'P' Procedure No one individual has an excessive workload.

VI.! Formalize Plant Tour Pro- Complete Scope was sufficiently small to complete. Much of.the cedures and Reporting work was delegated to plant staff.

VI.2 Revise Conduct of Operations Complete Scope was sufficiently small to complete.

Much of the work was delegated to plant staff.

M M

O t

e cII o n

x i t f

s dr nad e.

di f a e nb a sl ei e e ph r n t t yl px o o s cai r AE f ie elt a e t r e je r ca h oDg s e n t r n t h us p i n t f' g . . e af t ng sPb tf e

, sn i n iE l a t e ia ri hPt ut e l ht i r t o ss l p

b tl ha en n a u h rh ot m l rs t ot s cn o i on oo f n a c a f o nt no el o

v c dai dp a d f e e t i t ee ot ddi so t vd a ees tt l o oi t c evo u l n rs li nop r

ono a m

pt ud e pu se e pd rpe di s r aO ed nt y

a r aav ai e o o d l s r . at l er ed t

e. ed erp ga n cd wer es re nep nwa ra 'n i e

rl uo fi a. c o li c oh f h . r sl e i

) s a d su reh ed f s en t ge yo ent t e f ro snr an pn iz u t

e ai l e of ui s r t s l el er l ar so ql s

j na abi d i a

o s e n t e net st r t it oeu t t o pl i u w P n cc ir ca i u eu eg e e i e t ag t es pn p e m f j i n jq ise r m f o ddi oe der oi o L o o ur dne rd dh ce c I M C Sp Aab Pa At a Sb S T r d

l, o d s

! e s s e

! o t s s r. t p w e r e e e ee r e l T t s t a c c t t c a t S nu e t o o ye eo t e N h et l S r r l l l r S l t r a p d P P t p pP p

'O I a r t m i t rm m t m S w uS o o o n n ao on o o l C C l l N i I PC CI N C l

i s

r P o E q - g -

P a n n n n n - n -

n o p

- - o a i o emo i e

C a t o i l n i t ai f S M s o f r t F nnt nrt ,i , c P e q i dP a aoin i gi t n t sn t H a c d n t e li no aonng nl t a c n e n a& n c Ptii Mri ei eann e r g p a e n cf t Pf ep mS mceepi n t j

o i S gs m a enea e o s S t nd e n cuDt vgDol ot orie r i l n io l e nF n i n l a l ipir P v t a e nh p t a l e t il ecsermau r n c mt nt m n ngam nravit vCoMd r e a i en ae I i enie eeiet ne C e o p l n l a l M a titl vet DieDf t c F u P h pl P D M nl ip eni rn ot so

( Ss c mP g P p iunm rinMCoM nor e t e I t n N hu adII PgIP pPraPP ti n T na so Me n gm ec nt em s ,t a el s , ir h ,, pE , ,no,di ,g ei ma en2 mue5 l G ec12 o 1 2iC3 nf4ii in ml er so n edr b ag i nS l e ect tst t antt t

ui l g ii ti l eut tt cb po vt ra ph d r t n fdrr vnrrinrmgrs s oi mr eaar mcea si enaa eaaaxaaeiae t Ds IP RCPT I ScP En DaPP DnPPEcPRSPT c

e )

I 2 3 j 4 7 3 . . .

o . . . . I I I r I I V 1 I I I P V V I 1 I I I

/ s l e g ac n ci i iv l nr u he

. r d cS e e e g Dh Te a Pc v n NS ,i a kt M ,& ea r hr t eg ct c l n asr e li vie j in ong o Mn Nia r, a mn P .l .da DP FAM

, 4

)

~

o CII e r e x u f s r i t d f i a da e a nb r. c t t s ei i o s i n ph r o px o p s A d se AF e h t O n rm

.h n w . h n a ea kt o t c a h pr e i y c a t t t f hn t s e EA l i c o ci i e j O u w e we ah d e o s j Tmi vt d R . r .e n . e o a d p of r oi Nw . e th rt cf t

e p .T

.d re i

n M

r i

l z f o

o f n fi et ds a l p

m s

i e.

g re Mt d y i n e i o h am a e b t o s sA c t l i yg z u i sl tO t be de l

i l

i d

d e

n g

t a

t ia hu td u

oot to.s n o

e tl t il r ed t a i n i d

nn l e d e

uuo t u e e e gv li qf f an h . b m ns ao at k f ne e t e id i mu r st e ie r dc e l t n et sd o i c db e ee r p aa gi w ef r w mj a m n rd yr tjo os ro i i o ad l e e v

co oa . s or f p s

f dt r'

l a th nt a ert jpn chn t t o n n o od yn eo h o u gki a se a oe ri i . reo nrr t . ah t t cng e ch se ph m l ioa l f wt l r vd it l t t a n ewzi uf u a si . e fi ae s t b sa eg s t isn ss f w ul i oe c en nt cn n s so i u u dp ht h e sha os r i o sai st im t t j i t g c ot c d a t eg pn n vo d o s r s f a e rna se t c f es r t tf o e n e r rez oi ir d ot t P n co d 'C k i d e eei ce r ny ac e e t iS sd i g Fbn sb eu pc il ece e m jt n sP a. r s g a r pil r m osa t t o t a .sg ee on oa odf S o o rol PMp uo o u t rar hr co we cee E M C Ot Ac O S Mho Ta Sc Tn Sdr I

T r I. o d l s r s e s s s s i o s r. s t s s s s H w e e e e r e e e e e I T t n c t c c a c c c t c S nu o e o o t o o o ye o N h et r l r r S r r r l l r O; t ra P p P P P P P rp P l i rt m t am Q w uS n o n n o n n n eo n E C I C I I N I I I NC I D s r s P e e F g r P a u -

n I d - f t I C a l e n n t l n S M l Gc a g n e e l P e o l i e h n e dd t v& r P s m S o v nn D c P e a p e aa E g e Ie. P s Dn g t n L n N n j I e o a n om o gr i o e 'G i ei n e Ca e) t nd e n r ss t st a n r s0 s i o s i P ie' vr e i i a vc M o p

l g i(

v a

v nh i v

a l l o nt r r eus i ei s m ar es i ae e T o Rdi c Rf t omtP H e D l M R r ev a i r Cas r P .

D f

dce Fy dd a rne du A gs ds E noR d no P h gI f nd Q t ne ne N ar eu aM s o , i. ae g nir ar P , t t s e ir I c en el u u e w 2 eS wes vm l P2 - wo vi mud wd b et l pg ege oe b f er on ed e ee o i nt var mn i nc vao rt ps aetl tf re iP v

ri pa lpheco ic vo r

p s el a oi ehr my ah eA mr mcr er m t nlP- Cn RCP I S s i. P S E1 RQ IT I SP RP I c

j e 0 9 5 I 6 7 1 3 8 o . . . 4 . 5 r V I V I I V . I V P I V I V V I V I I V r n l e i r a g as e fi a re g f c n Tr a ae Aa u n t p OM Dd a SS Eer M / ,s Nco

,t sn ot t yns io ,ra c sat ri mPn e et c rt u i j ese ea a&d o Rij Fr D r r so .ep go P . sr .no 1 AP MO MiC

o ** D 1

Appendix C-F.x h ib i t 11 PSC PEP HES PGNS I H II.lTI ES (For Project Managers with Two or More Protects!

Current Project Manager Projects _

Status , Comments D. Goss, NRC 1.icensing IV.2 Implement NRC Commitment Complete Senpc was suf'iciently f small to implement.

Coordinator Control Program IV.3 Document Procedures for Complete Scope was sufficiently small to implement.

Regulatory Correspondence Review IV.4 Review Essential Requ- in Process outside consultants are supplementing PSC's latory Documents _ st a f f <>n the.projoets.

Part 1, Review Essential Requiatory Documents .

Part 2, Define Additional Staqqered start after completion of Part 1 Ongoing Obligationn V.3 Enhance 10CFR50.59 In Progress Project is being supplemented with temporary Training clerical personnel.

Part 2, tipda t e Te x t Data Base J. Johns, Supervisor V.1- Fnhance 10CI'R 50. 5 9 Engineering /Licenr.ing Training Part 1, Conduct Traintnq Complete Scope in suffacaently small to. implement with PSC st a f f .

Part 3 Traan Nt'D Persernel In Process R. Husted, Nuclear V.6 Improve NI.FD'Traantnq In Procens Outside consultants are assisting. The scope Fuels Supervisor is very large, 11.3 Implement Planning & In Process Additional PSC staff has been hired for this function.

Scheduling Methods 6 Procedures Part 3, N!.P Imple-mentatinn.

V . '1 Develop NPD Training in Process Scope is quite larae. The Nuclear Production T. Borst, Support training organizatnon is dedicated to this project &

Services Manager for INPO Accreditation is being supplemented by out s ade consult ants. Also, several permanent staft' were added.

V.B Consolidate Site Training Complete Scope was nufficiently small.

V.9 Retrain I.acensed Personnel Partly Similar response to Project V.7.

Complete

~

.-l

_ _ _ _ _ _ _ _