ML20212M102

Forwards Assessment of Addl Concerns Per 870226 Request Re Restart of Facility.Events & Circumstances Involving Contracts Had No Adverse Impacts Re Plant Safety or Safe Plant Operations

ML20212M102
Person / Time
Site:	Fort Saint Vrain
Issue date:	03/05/1987
From:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-87090, TAC-63576, NUDOCS 8703110089
Download: ML20212M102 (6)

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P.o. Box 840 Denver, Co 80201-0640 2420 W. 26th Avenue, Suite 100D, Denver, Colorado 80211 R.O. WILUAMS, JR.

NS(([a$k"Enous March 5, 1987 Fort St. Vrain Unit No. 1 P-87090 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Docket No. 50-267

SUBJECT:

Assessment of Additional Concerns Regarding Fort St. Vrain Restart Gentlemen:

At the Fort St. Vrain restart briefing on Thursday, February 26, 1987, the NRC Commissioners requested that the General Counsel and the NRC Staff review the matters relating to the indictment issued by the U. S. Attorney for the District of Colorado on February 25, 1987, against three former Public Service Company of Colorado (PSC) employees and the recent resignation of one of these employees, the Fort St. Vrain Manager of Nuclear Production. The Commissioners requested that this review be completed prior to the Commissioners issuing a final decision on the restart of Fort St. Vrain.

Attached for your information is PSC's assessment of the additional concerns discussed at the Fort St. Vrain restart briefing. PSC will utilize Mr. R. O. Williams, Jr., Vice President, Nuclear Operations in an acting role to maintain executive oversight of plant operations and fulfill the administrative functions of the Manager of Nuclear Production. PSC will also utilize the plant operational background and experience of Mr. D. W. Warembourg on an interim basis acting as Manager of Nuclear Production for those responsibilities related to operational matters (as described in the Technical Specifications).

PSC's interim staffing plan for the Manager of Nuclear Production position will assure that effective executive oversight of plant operations is maintained, and that the conduct of plant operations are directed by a senior manager with an in-depth knowledge of Fort St. Vrain plant operations.

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.' P-87090 Paga 2 March 5.-1987 As further detailed in the attached assessment, PSC has concluded that events and circumstances described in the indictment involving Fort St. Vrain contracts have not had any adverse impacts on plant safety or safe plant operations. PSC believes that a favorable determination allowing restart and operation of the Fort St. Vrain plant within the restrictions of the proposed Power Ascension Plan is warranted and is hereby requested.

If the NRC requires any further information relating to these matters, 'please do not hesitate to contact us. Your early consideration and prompt resolution of these matters is greatly appreciated.

Very truly yours,

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R. O. Williams, Jr.

Vice President, Nuclear Operations R0W/MHH:jmt Attachment cc: Regional Administrator, Region IV Attn: Mr. R. D. Martin Office of Nuclear Reactor Regulation Attn: Mr. F. J. Miraglia Office of Inspection and Enforcement Attn: Mr. J. M. Taylor Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain

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Attichment 4' '

to P-87090 LPage 1- ,

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ASSESSMENT l0F ADDITIONAL CONCERNS

'REGARDING FORT ST.',VRAIN RESTART INTRODUCTION Publien Service Company of Colorado'and the NRC staff met with the Commission on February 26, 1987 to present information concerning the status .of the plant and progress of PSC in addressing previously identified management concerns, all in support of a request for restart of Fort St. Vrain.

Two significant : events occurred in the days just prior'to the meeting. On Monday, February 23, 1987, Jack Gahm,= Manager of the '

Fort St. Vrain. Nuclear Production Division, resigned from the company.

' for personal ~ reasons. _ On Wednesday, February 25, .1987, .a Federal.

Grand Jury Indictment was made public. The indictment named O. R.

Lee (former Vice President of Electric Production for PSC, the person to: whom 1the. Fort St. Vrain organization reported), Jack Gahm..and others as defendants. 'The indictment identified, among other things, two contracts associated with the management and operation of Fort St. Vrain which had allegedly been instruments in certain " kickback" operations engaged in by the defendants.

Neither the Commission, the Staff, nor.PSC was, on the day of the Commissioners meeting, able-to fully assess the possible impact; of these events on PSC's request for restart.

Immediately following the resignation of Jack Gahm, R. O. Williams, the Vice President, Nuclear Operations, named himself acting in the position of Manager of Nuclear Production, thereby maintaining the necessary continuity-of chain of command and delegation of authority.

This -information was provided at the Commissioners meeting on February 26, 1987. PSC also identified at that meeting-that PSC had initiated appropriate steps to secure a replacement, and that an external search had been initiated.

Since the meeting with the Commissioners, PSC has further examined the two concerns that were identified at the meeting: the interim measures to be taken by PSC to ensure that senior management attention, support, and direction of the conduct of operations is fulfilled during the period that the Manager of Nuclear Production position remains vacant, and a reexamination of the conduct of work associated with the contracts identified in the indictment as supporting Fort St. Vrain. The results of the examinations and the actions to be taken are discussed below.

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Attachment:

to P-87090'

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-INTERIM STAFFING PLAN:

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The departure of Mr. . Gahm from the organization'has been_ assessed from.the perspective of.PSC's immediate need to assure that effective-

executive oversight of the operations is-maintained, and that the conduct of operations are overviewed by a senior manager with _in-

, depth knowledge - of Fort St. Vrain operations. Interim actions have been identified toLaddress these two key requirements.

Longer ' term-organizational plans which address these requirements and. incorporate- '

the results of several key organizational studies which have been in progress will be accelerated.

Since the meeting with the Commissioners, the Vice President, Nuclear Operations has had extensive discussions with the three managers who report. to the position of Manager of Nuclear Production. From these

' discussions, it was concluded that much of the key administrative

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activity already involved Vice Presidential review and approval and -

that the direct involvement of the Vice President in these. matters on an interim basis would be beneficial. Typical activities involve staffing, resource allocation, planning, and the performance of the organization in support of operations. These activities are already

, - receiving significant attention by the Vice President and the concensus of these discussions was that his direct involvement at ,

this time would, in fact, provide more timely resolution of a number of pending items. Thus, the. acting role of the Vice President will remain in place for all administrative matters.

The_ role of the Manager of Nuclear Production in the conduct of

operations, including those responsibilities described in the

, Technical Specifications, was discussed extensively with the Station Manager, C. H. Fuller, and D. W. Warembourg,- former Manager of Nuclear Production (1978-1984) and currently Manager of Nuclear

. Engineering. From these discussions, it was concluded that those l- responsibilities and . duties. associated with plant conduct of operations could be clearly identified and assigned to Mr. Warembourg g on an interim basis. This arrangement avoids diluting senior management attention to conduct of operations with administrative duties, assures that the necessary checks and balances remain in force, and provides the Station Manager with the most seasoned and.

i- knowledgeable advice, guidance, and direction available, while l permitting the Vice President to pursue his responsibilities and

[ maintain executive oversight.

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' Attachment t@ P-87090

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Mr. -- Wa'rembourg , - already maintains an < office :at the site and has devoted approximately fifty percent of his time to the review and management of work; at the ~ site. His increased direct attention, together_with the enhanced _on-site attention byo Mr. Williams --will provide- : effective. executive- and operational oversight of the

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operations in~this interim period.

As a part :of the Performance Enhancement Program, PSC has-been examining the . effectiveness of the current . organization. These activities were reviewed with the Region IV and NRR staff during the January-1987 PEP progress l review held at the Region .IV. offices.

Studies relating to improvements in the utilization of our technical

-staff' in the efficient and. effective support of operations, consolidation and. enhancement of -training, planning and _ outage management, and the effectiveness of systems and procedures, are all nearing' completion and will be. factored into organizational plans which.PSC will implement- in the near future. The factors _of-

-executive oversight and continuity of oversight of the conduct of operations by persons with an in-depth knowledge of Fort St. Vrain will continue to receive PSC_'s highest attention as we move from the interim _ measures discussed above to a permanent organizational configuration.- PSC will continue to keep Region IV and'the NRR staff informed of our progress on these matters.

ASSESSMENT OF WORK PERFORMANCE UNDER ZACHARY CONTRACTS Performance Enhancement Program In ~ response to an analysis and evaluation of the Management of Fort St. Vrain by the NUS Operating Services Corporation in January 1985, Public Service Company submitted to Region IV an implementation plan for the Performance Enhancement Program (P-85107). In early 1985, PSC hired VZM (Zachary) to assist with the implementation and monitoring of that program.during its early phases of development.

During 1985, the primary responsibility of VZM was to assemble-material submitted by PSC Project Managers and to track project performance until that responsibility could be passed to an internal function.

Although PEP projects were initiated and tracked during 1985, the involvement of VZM was insignificant in terms of the evolution of the PEP program as it exists today.

It is the opinion of Public Service Company, that the work done by VZM on the Performance Enhancement Program was quality work and had no adverse impact on the goals and objectives of the PEP program or safe operations of Fort St. Vrain.

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Attachment to P-87090 Page 4 Maintenance Contract In August of 1985, PSC signed a contract with Zachary Industries for the management of maintenance activities at Fort St. Vrain.

Throughout the duration of this contract, the majority of maintenance employees, employed under a previous contract, remained on site and were. unaffected by the reassignment to the Zachary contract.

Furthermore, all safety .related work was. conducted under the

-provisions of Fort St. Vrain Quality Assurance Program, which was administered and controlled by PSC personnel.

It is the opinion of the Fort St. Vrain Station Manager and Quality Assurance management in place in 1985, that the workmanship performed-under the Zachary contract was quality work and had no adverse impact on the quality and safe operation of 'the Fort St. Vrain Nuclear Generating Station.

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