ML20199D341
| ML20199D341 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/11/1986 |
| From: | Heitner K Office of Nuclear Reactor Regulation |
| To: | Walker R PUBLIC SERVICE CO. OF COLORADO |
| References | |
| TAC-55294, TAC-62169, NUDOCS 8606200214 | |
| Download: ML20199D341 (9) | |
Text
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. June 11, 1986 z.
Docket No.-'50-267.
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~Mr. R. F. Walker,-President Public Service' Company of Colorado Post Office Box 840 Denver, Colorado. 80201-0840 l
Dear Mr. Walker:
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SUBJECT:
NRCREVIEW0FTHEPUBLICSERVICE-COMPANY.0FCOLORADO(PSC)
PERFORMANCE ENHANCEMENT PROGRAM By letter dated January 15, 1986, you submitted responses to certain
. questions the staff raised in our first-evaluation of the PSC Performance Enhancement Program. Our first review was transmitted to you by letter dated October 3. 1985. We_have reviewed your current responses, and our
. evaluation is enclosed. We found that all but one of your. responses are acceptable. The one remaining response concerns Finding 4-10.
Your response to Finding 4-10 does not confirm that the functional acceptability
- of equipment will be checked prior to being returned to service.
We request that'you provide a method to confirm such functional acceptability..As a minimum, this functional acceptability should reflect
.that the equipment has satisfactorily met its surveillance requirements as o
required by the Technical Specifications'or governing plant procedures.
However,-the Shift Supervisor should have the option of requesting
< additional testing should it be believed it to be necessary.
.We request that you provide a response to this open item within 45 days of the date of this letter.
The information requested in this letter affects fewer than 10 respondents;
Sincerely, e
original signed by Kenneth L. Heitner, Project Manager B606d00214 860611 Standardization and Special ADOCKOU00g7 Projects Directorate PDR G
Division of PWR Licensing-8, NRR
Enclosures:
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PNoonan FAllenspach Ireland, RIV See next page.
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June 11, 1986
-Docket No. 50-267 Mr. R. F. Walker, President Public Service Company of Colorado Post Office Box 840 Denver, Colorado 80201-0840-l
Dear Mr. Walker:
l
SUBJECT:
NRCREVIEWOFTHEPUBLICSERVICECOMPANYOFCOLORADO(PSC)
PERFORMANCE ENHANCEMENT PROGRAM By letter dated January 15.-1986, you submitted responses to certain questions the staff raised in our first evaluation of the PSC Performance Enhancement Program. Our first review was transmitted to you by letter dated October 3, 1985. We have reviewed your current responses, and our evaluation is enclosed. We found that all but one of your responses are acceptable. The one remaining response concerns Finding 4-10. Your response to Finding 4-10 does not confinn that the functional acceptability of equipment will be checked prior to being returned to service.
We request that you provide a method to confirm such functional acceptability. As a minimum, this functional acceptability should reflect that the equipment has satisfactorily met its surveillance requirements as required by the Technical Specifications or governing plant procedures.
However, the Shift Supervisor should have the option of requesting additional testing should it be believed to be necessary.
We request that you provide a response to this open item within 45 days of the date of this letter.
l The information requested in this letter affects fewer than 10 respondents; l
therefore, OMB clearance is not required under P.L.96-511.
Sincerely, Kenneth L. Heitner, Project Manager Standardization and Special Projects Directorate Division of PWR Licensing-8, NRR
Enclosures:
As stated cc w/ enclosure:
See next page
..o Mr. R. F. Walker
'1 Public Service Company of Colorado Fort St. Vrain cc:
Mr. D. W. Warembourg, Manager Albert J. Hazle, Director Nuclear Engineering Division Radiation Control Division Public Service Company Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201 Mr. David Alberstein, 14/159A Mr. J. W. Gahm, Manager GA Technologies, Inc.
Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. L. W. Singleton, Manager Public Service Company of Colorado Quality Assurance Division P. O. Box 840 Fort St. Vrain Nuclear Station Denver, Colorado 80201 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Senior Resident Inspector
' U.S. Nuclear Regulatory Commission P. 0. Box 640 Platteville, Colorado 80651 Kelley, Stansfield & 0'Donnell Public Service Company Building Room 900 550 15th Street Denver,dolorado 80202 Regional Administrator, Region IV U.S. Nuclear Regulatory Comission 611 Ryan Plaza Drive. Suite 1000 Arlington, Texas 76011 Chairman, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency 1800 Lincoln Street Denver, Colorado 80203 8
't Enclosure NRC Staff Evaluation of the
-Performance Enhancement Program of the Public Service of Colorado Fort St. Vrain Nuclear Generating Station Public Service Company of Colorado (PSC) provided by letter dated January 15, 1986, a status report on their Performance Enhancement Program (PEP). This letter also contained a response to a request for additional information providedinanNRCMemorandum(BeckhamtoLainas),FortSt.VrainResponseto ManagementAudit(TACNo.55294),datedAugust 16, 1985, and the report of an audit performed by the S.M. Stoller Corporation (SMSC) December 25, 1985, to measure the progress of this program.
Part I below contains the staff's evaluation of PSC's response to a request for additional information. Part II contains staff coments on the SMSC audit report.
I.
Response to Request for Additional Information The numerical designations below, such as Finding 4-12, correspond to the' request for additional information in Reference 8.
Findings 4-12 and 4-14:
The Ifcensee should supply details of the plant tour program.
PSC has established a Management Tour Policy, NPG-22, that is being implemented under SMAP-13, Procedure for Plant Tours by Management.
The staff considers this program to be responsive to the NRC assessment report and to the consultant's independent reconnendations.
Findings 4-9 and 4-16:
The licensee should submit a more complete description of procedure ENG-3 for further review by the staff.
4 PSC has provided parts of procedure ENG-3 for our review. They have revised Section 4.11 of ENG-3 to assign responsibility for maintaining up-to-date drawings to the Supervisor Site Construction. Revised drawings are sent to the Site Procurement Control for distribution to special handling locations.
The staff considers revised ENG-3 to be responsive to the NRC assessment report and to the consultant's independent reconnendations.
Finding 4-10: The licensee should verify to the staff that the functional acceptability of equipment being returned to service will be checked and/or verified by the Shift Supervisor regardless of the reason for having removed the equipment from service (e.g.,
surveillance testing, inspection, maintenance, modification, etc.).
PSC has described certain activities that are performed by the Shift Supervisor in respect to the surveillance testing program and maintenance activities that show that the Shift Supervisor has control of the functional acceptability of returned equipment. However, the response does not confirm that the functional acceptability of equipment will be checked prior to being returned to service. The Ifcensee should provide a response to close this open item.
Finding 4-13: The licensee should commit to develop a shift turnover procedure.
The Itcensee has established a Shift Turnover Procedure, SMAP-8. This shift turnover is modeled after INPO Good Practice OP-201, Shift Relief and Turnover.
2
.)
ThestafffindsthatFortSt.Vrain(FSV)hasbeenresponsiveto the NRC assessment report and to the consultant's independent recomendations.
Findino 4-14: The licensee should commit to develop a procedural requirement for licensed operators to read and review operating logs upon return to the Control Room after an extended absence.
FSV shift turnover procedure has a requirement for operators to read and review operating logs since the last time the operator was on shift.
The staff finds that FSV has been responsive to the NRC assessment report and to the consultant's independent assessment.
Finding 4-17: The licensee should commit to improve the control of System Operating Procedures in use at local control panels.
FSV has determined the locations where controlled System Operating Procedures should be placed. Special receptacles to hold procedures have been installed at these locations, and the appropriate controlled procedures have been placed at these locations.
The staff finds the licensee has been responsive to the NRC assessment report and the consultant's independent recommendations.
Finding 4-19: The licensee should take steps to improve access to the Control Room from the Shift Supervisor's office, or provide additional explanation of why their current arrangement is acceptable.
FSV has revised the procedure regarding the key to vital areas, such that this key is in the possession of the Shift Supervisor. The staff considers that this resolves the problem of access to the Control Room by the Shift Supervisor in the event of the failure of the key card system.
1 Finding 4-20: The licensee should verify that PEP subproject VI.2 will encompass the verification of the correct performance of operating activities.
FSV has stated that PEP subproject VI.2 encompasses the verification of the correct performance of operating activities. The licensee has rewritten Administrative Procedure P-1, Plant Operation, based on the INP0 Good Practices.
The staff concludes that the licensee has been responsive to the consultant's independent recommendations.
Finding 4-24: The licensee should describe how the " safety-related" designation is used in the parts management system.
The licensee has stated that the parts management system derives from safety related systems, structure, equipment and components identified in the FSAR, and supplemented by other drawings and documents.
The staff concludes that the licensee has been responsive to the NRC assessment report.
Recommendation A.4:
The licensee should describe how the Master Planning and Scheduling System will address surveillance testing in general and "surveillances requiring shutdown" in particular.
The licensee's Scheduling and Planning Department takes into account surveillance and testing in general.
Surveillances requiring shutdown are scheduled into a planned outage. Two shutdown surveillance outages are scheduled between refuelings.
e The staff concludes that the licensee been responsive to the consultant's independent recommendations.
Recomendation A.6:
The licensee should clarify planning to analyze for the root cause of procedural compliance failures.
The licensee has determined that there are four primary contributors for the procedural compliance failures and has taken steps to remedy the causes. These steps include rewriting System Operating Procedures, Results Procedures, and Maintenance Procedures to incorporate human factor considerations, providing controlled procedures at local work stations, informing personnel of the process to get procedures changed, if necessary, and informing personnel that disciplinary measures will be taken if they do not follow procedures.
The staff finds that the licensee has been responsive to the NRC assessment report and the consultant's independent recommendation.
Additional Information on Scope of PEP The licensee should ^ supply additional information on the scope of each PEP c
l subproject to show that adequate staff have been assigned to supervise and implement the PEP concurrent with normal duties.
l The licensee is taking steps to ensure adequate resources are available to supervise and implement the PEP, including hiring additional staff. However, additional workload, such as the work on equipment qualification, has caused some j.
dates to slip. The SMSC audit report (Part II of this review) contains
[-
further information on this subject.
l
[
II. SMSC Audit of PSC Performance Enhancement Programs (PEP) l In October 1985, Public Service of Colorado retained SMSC to conduct an independent audit of the implementation program. The results of this.
a..
I audit are contained in a report dated December 20, 1985.
The audit report considers the PEP program an ambitious program which, when completed, should improve the overall quality, management and operation of the Public Service Nuclear Organization. At this stage, when some projects have not been completed, and the changes have not functioned as a whole,.it is difficult to measure improvement. However, they find the implementation progress encouraging. The report discusses concerns in principally two areas.
The first is the area regarding some delays in meeting the schedule of the PEP. Some of these are attributed to unrealistic optimism in scheduling, others reflect the intrusion of other, higher priority tasks. While these delays are not considered serious, PSC will have to put in more effort to reverse the trend of these delays.
The second problem area regards the difficulty with attaining the expanded staff of properly trained and experienced people, as specified by the PEP.. This human resources problem has the potential for forestalling j
the goals of the PEP. PSC has recognized the seriousness of this problem and has added a Project VII - Morale and Human Productivity Management - to the PEP, to focus on the human resources issue.
In addition, they have engaged the services of "The Training Company" to assist in this effort.
The staff considers that PSC has been responsive to the SMSC independent audit of their improvement program. !
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