IR 05000267/1987035

Final SALP Rept 50-267/87-35 for May 1987 - Aug 1988. Category 1 Assigned in Areas of Maint,Fire Protection & Radiological Controls

ML20244A664
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/07/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244A567	List: IR 05000267/1987035 ML20244A564
References
50-267-87-35-01, 50-267-87-35-1, NUDOCS 8904180124
Download: ML20244A664 (75)

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SALP BOARD REPORT -

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Inspection Report 50-267/87-35 Public Service Company of Colorado Fort St. Vrain Nuclear Generating Station May 1,1987, through August 31, 1988 ii" G904180124 890407 l gDR ADOCK 05000267  ;

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I .. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated Nuclear Regulatory Commission (NRC) staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. The program is

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supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of the facility's performance in each functional are An NRC SALP Board, composed of the staff members listed below, met on October 20, 1988, to review the observations and data on performance, and to assess licensee performance in accordance with NRC Manual Chapter 0516,

" Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this repor The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuanc This report is the NRC's assessment of the licensee's safety performance l at Fort St. Vrain Nuclear Generating Station for the period May 1,1987, i through August 31, 198 The SALP Board for Fort St. Vrain was composed of:

A. B. Beach, Deputy Director, Division of Reactor Projects J. L. Milhoan, Director. Division of Reactor Safety (DRS)

R. L. Bangart, Director, Division of Radiation Safety and Safeguards (DRSS)

J. A. Calvo, Director, Project Directorate IV, NRR T. F. Westerman, Chief, Reactor Projects Section B R. E. Farrell, Senior Resident Inspector K. L. Heitner, NRR Project Manager The fellowing personnel also participated in the SALP Board meeting:

C. M. Abbate, Project Engineer R. E. Baer, Chief, Facilities Radiological Protection Section, DRSS I. Barnes, Chief, Materials and Quality Programs Section, DRS J. E. Cummins, NRR Team Leader R. J. Everett, Chief, Security and Emergency Preparedness Section, DRSS P. W. Michaud, Resident Inspector R. P. Mullikin, Project. Engineer, DRP B. Murray, Chief, Reactor Programs Branch, DRSS W. C. Seidle, Chief, Test Programs Section, DRS

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2 Licensee Activities During this assessment period the licensee experienced the two best months of electrical production in the plant's history. A new plant record for electrical production for a single calendar month was set in March 1988. This record was surpassed in June 1988 with net electrical production of 167,699 megawatt hour The plant operation during March, May, and June 1988 demonstrated the licensee's capability to operate the plant continuously with a high capacity factor. Additionally, the October 1987 fire, the western states electrical grid instability in April 1988, and the loss of main condenser in April 1988, all demonstrated the operating staff's ability to respond promptly and appropriately to complex operating event .

There was no refueling outage during this assessment period. The licensee planned to operate the plant steadily until the fourth refueling outage projected for 1989. However, failure of the "C" Helium Circulator in July 1987 caused the plant to be shut down until early October 1987. As the plant was restarting on October 2, 1987, failure of a thermal relief valve on the plant's hydraulic system led to a fire in the turbine building. Although the plant was shut down safely, significant fire damage required another forced outage. The plant restarted from this outage in December 198 Plant operation continued until April 4, 1988, when the plant was manually scrammed due to electrical grid instabilit The plant was restarted but, on April 7, 1988, a circulating water system expansion joint failed, flooding the circulating water pump The plant was manually scramrtid and cooled utilizing the decay heat exchange The plant restarted on April 21, 1988, but scrammed following a !

helium circulator trip on April 29, 198 l l

The plant was subsequently restarted and operated until July 6, 1988, when it entered a planned maintenance outage to replace helium circulator bolts. The plant continued in this maintenance outage through the end of the assessment perio B. Inspection Activities i NRC inspection activity during this assessment period included 41 NRC inspections performed with 5,305 direct inspection hours expende These inspections incluoed an Operational Safety Team Inspection (OSTI) led by NRC Headquarters personnel and an open items team inspection led by Region IV personnel. Additionally, an Augmented Inspection Team (AIT) followed up on the October 2, 1987, turbine building fire immediately after the even __ _ -- - - -

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3-p 'I SUMMARY OF RESULTS .

.The. licensee's performance <1s summarized in the table below, along with j w the performance' categories from the pr2vious SALP evaluation perio :

Rating Rating Last PeriodL This Period

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(05/07/86 to (05/01/87 to Performance- i Functional Areas 04/30/87) 08/31/88) Trend Plant Operations 2 2 Improving

' Radiological Controls 1 2 ' Declinin . Maintenance / Surveillance N/A* 3 . Emergency Preparedness 3 2 Improving ! Security 2 1 Improving Engineering / Technical N/A* 2 Declining Safety Assessment / N/A* 2 Quality Verification Maintenance 2 N/A*

9-. Surveillance 1 N/A*

1 Fire Protection 1 N/A*

' Support 11. Outages 2 N/A*

12. Quality Programs and 2 N/A*

Administrative Controls Affecting Quality

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1 Licensing Activitins 2 N/A*

14. Training and 2 N/A*

Qualification Effectiveness

• The notation "N/A" represents that the functional area was not assessed during the period indi ate c In comparison with previous SALP Reports, it should be noted that functional areas have been redefined pursuant to'NRC Manual Chapter NRC-0516, revised June 6,1988, titled, Systematic Assessment of Licensee Performance." Consequently, many of the ratings c ,

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l1 tab'ulated above do not correlate'directly between the last period (May 7,

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'l u 1986, through April 30,1987), and this period (May 1, 1987, through- 'j August 31,1988). j III. CRITERIA Licensee performance was assessed in seven selected functional area Functional areas normally represent areas significant to nuclear safety 1 and the environment. Some functional areas may not be assessed because of little or no licensee activities-or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to access each functional area-

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i Assurance of quality including management involvement and control; -l

! Approach to the resolution of technical issues from a safety i standpoint; i i Responsiveness to NRC initiatives; Enforcement history; Operational events (including response to, analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra However, the NRC was not limited to these criteria, and others may have been used where appropriat ' Based upon the NRC's assessment, each functional area. evaluated is rated according to three performance categories. The definitions of these i performance categories a're as follows:

Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat Category 2: . Licensee management attention to and involvement in the  !

performance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant end personnel performance is being achieve NRC attention may be maintained at normal level :

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Category 3: Licensee management attention _to and involvement in the

. performance of, nuclear safety,or safeguards activities are not' sufficien ~

l The licensee's performance does not significantly exceed that needed to

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meet ininimal' regulatory requirements. Licensee . resources appear to be etrained or not effectively use NRC attention should be increased above normal level ~

I PERFORMANCE ANALYSIS-  ! plant Operations Analysis The assessment of this functional area encompassed the control and executionLof.. activities directly related to operating the plant. It was intended to include activities such as plant startup, power operation, plant. shutdown,'and system lineup Thus, it included activities such as monitoring and logging plant. conditions, normal operations, response to transient and off-normal conditions, manipulating the reactor.and auxiliary controls,: plant-wide housekeeping,. control room professionalism, and interf ace with activities that support operation This functional area has been inspected on a continuing basis by the NRC resident inspectors, the headquarters Operational Safety Team Inspection (OSTI), and on several occasions-by NRC regional .

inspectors. The results of these. inspections indicated that-plant' operations appeared to be 'well managed during this perio The operations staff appeared knowledgeable and capable, and demonstrated a positive attitude for safe plant operation Routine startups and normal shutdowns were performed safely and professionally. Although plant operation was limited because of equipment outages, control room operators displayed a high degree of professionalism during normal activities and in response to complex challenges. Three events occurred during this assessment period that demonstrated the ability of control room operator.s to respond to complex system challenges,

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j The first event, a fire which occurred on Friday, October 2, 1987, occurred just before 12 midnight. The plant had just returned to power from a 2-month equipment outage. The plant's main phone lines were among the first cables to burn, thus i hampering the licensee's response capability. The operations i crew on duty used~ alternative phone lines still intact to alert l an off-duty shift supervisor at his home who actuated the ;

emergency response notification syste ;

The plant operators shut down the plant using normal systems, and operations management was able, within six hours after the fire, to verify the availability of both trains of safe shutdown !

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cooling required by Appendix R to 10 CFR 50 requirement However, this method of cooling was not needed because the plant i was cooled using normal system configuration '

The second event occurred when a load swing of more than 200 megawatts on the grid due to an event outside of the licensee's system caused a manual reactor scram. This load swing also caused several plants throughout the western United

. States to trip. The operators manually scrammed the plant a fraction of a second prior to an automatic scram as result of an equipment protection turbine tri The third event, a loss of the main condenser with the plant at 72 percent power, required the use of a shutdown cooling flow path which had not been used for several years. During this event the flexible coupling from the circulating water pump failed and flooded the circulating water pit. All circulating pumps were tripped as a result of the flooded condition. The operators followed their procedures and successfully shut down the plan During this assessment period, the station manager and operations manager demonstrated a high level of involvement in all aspects of operations; they were frequently observed in the control room by the NRC inspectors. Corporate management, usually the Vice President, Nuclear Operations, was frequently and effectively involved in site activitie Operations staff positions were identified, and authority and responsibilities were well define The licensee has five operations crews. However, there are only enough licensed reactor operators for four crews. This situation has resulted in excessive overtime by the operator Although operator moraie and professionalism appeared high, the licensee does need mere licensed operators. A current licensed operator class should relieve current overtime pressure in this are The licensee, in all cases, was very responsive to NRC concern The licensee took prompt corrective actions and usually took effective action to prevent recurrenc However, several procedural weaknesses were identified during the assessment period that resulted in eight violations of NRC requirements in this functional area. It appears that the licensee's procedures assumed substantial operator experience and were not always adequately detailed and thorough. Further, this less reliance on procedures, caused by the assumption of substantial operator experience, resulted in additional violations for failure to follow procedure _ ___- __ __ __ _ ______ __-____ _ -

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In addition, a walk-through of emergency operating procedures, conducted by'the NRC exposed weaknesses in the identification and classification of emergency response plan conditions. Man procedures noted during this walk-through did not contain: a adequate specific information and relied on the experience'of I the personnel to not only perform the' activity correctly, but also to ensure the activity was adequately controlled. To correct these weaknesses, the licensee has initiated a long-term i procedure enhancement progra j There ware eight reportable' events during the assessment period ,

in tH fe nctional area. Two of these events were scram '

actuasw, as.the result of electronic noise while the reactor was shut down. This type of actuation has only occurred when the reactor was shut down and the signal on the nuclear channels was very small. The licensee-has a continuing program to reduce electronic noise problem However, NRC attention may be warranted since electronic noise continues to be a proble Four reportable events during this assessment period were attributed to operator error which occurred during the first half of the assessment period. Each of these events received strong management attention and, apparently, effective corrective actions were take Previous SALP reports have recommended reduction of the large number of deficiency report tags (DRTs) throughout the plant with special attention to the DRTs directly affecting the control room. The licensee has been concentrating on the.DRTs in the control room, and by bringing management attention to this problem, achieved limited success during this assessment

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perio The previous SALP reports-have also recommended that the licensee pursue a " black board concept" (all annunciators dark when plant conditions are all normal). Included in this recommendation was the elimination of nuisance alarms which divert operator attention from things requiring attention. The licensee has expended engineering effort toward this concept and has planned several modifications scheduled toward achieving this concep Another ongoing program, the plant signage program, has contributed to the licensee's recent operational success during this assessment period. New large, easy to read signs have made maintenance, operation, and testing easier and more error fre i The licensee's fire protection program implementation was i inspected by region-based inspectors and on continuing basis by the NRC resident inspectors. During this assessment period no violations were identified in fire protectio l

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The following observations were made:  :

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Combustible materials, flammable and combustible liquid, '

and gas usage were. restricted or properly controlled in areas containing safety-related equipment and components in accordance with the approved procedure .Two fire doors were not closin'g completely because of the i air pressure differential. ' An. hourly fire watch was q

established in accordance with the Technical Specification The required fire brigade complement was maintained independent of other duties. The training records for fire 3 brigade and'the fire drills were up to date and the fire '

drills were conducted at the specified. interval . Management involvement in assuring quality in this area has-improved during this SALP period. The licensee-did not have a dedicated fire protection engineer for'this area during the previous assessraent period. Since the licensee ,

hired a-dedicated fire protection engineer,.the fire protection program at FSV has improve The licensee.has very extensive fire protection program, which the licensee aggressively pursued, with good progress in this are Much of the licensee's effort during this assessment period has been directed to the Technical Specification Upgrade Program.

1 The licensee has expended substantial resources in preparation I to implement upgraded Technical.. Specifications. This effort has contributed to a heightened awareness of current Technical Specification requirements and interpretation . Performance Rating The overall assessment of this area indicates an improvement in performance. While there have been instances of personnel error, they have been isolated and have been resolved appropriatel The licensee is aware of procedure deficiencies and is working to correct them. Operations procedures often require extensive experience to be used. Emergency procedures classify emergency response plan conditions from lowest to highest rather than from

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highest to lowest and are not easily use !

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Overall, the licensee is improving in this functional are Management is strong and involved in daily plant activitie {

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Control: room operators are professional in conduct and very b capabl ,

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. The -licensee is considered to be in' Performance Category 2 in - 1 this functional are '

3 ', Recommendations NRC Actions

. NRC inspection effort in this area should'be-consistent with the Fundamental Inspection Progra . The licensee's ongoing electronic noise reduction program should be reviewed for effectivenes Licensee Actions Licensee management is encouraged to continue improvement-

efforts in-this functional area,-including

. Revision and improvement of plant operating procedures-

. Improved operator training on emergency operating procedures with special attention to emergency a condition identification and classification-

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. Reduction of nuisance' alarms by working toward a black-board concept

. Reduction of the backlog of deficiencies indicated by the high number of deficiency report tags in the control room

. Increase number of licensed reactor operators to fully man all crews B. Radiological Controls i Analysis

This functional area consists of activities directly related to ;

radiological controls including occupational radiation safety (e.g., occupational radiation protection, radioactive materials and contamination controls,. radiation field control,

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radiological surveys and monitoring, and as low as is reasonably achievable programs), radioactive waste management (i.e.,

processing and onsite storage of gaseous, liquid and solid wastes), radiological effluent control and monitoring (including gaseous and liquid effluents, offsite dose calculations, radiological environmental monitoring, and confirmatory

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measurements), and transportation of radioactive materials (e.g., procurement of packages, preparation for shipment, selection and control of shippers, receipt / acceptance of shipment, periodic maintenance of packagings, and point-of-origin safeguards activities).

The occupational radiation safety program was inspected once during the assessment period by region-based radiation specialist inspectors in addition to the resident inspector's !

routine inspection Five violations were identified during the i assessment period, and all five involved the occupational 1 radiation protection progra The licensee has implemented an adequate ALARA program. The licensee has experienced a high turnover rate in the radiation protection section; however, the licensee has maintained an adequate staff. The experience level within the radiation protection section is low, but appears adequate. The number and type of violations identified indicated that the licensee's radiation protection program has experienced some programmatic weaknesses in the respiratory protection program. There is a need to improve the technical content of the radiation protection training provided to plant worker Training / lesson plans have not been reviewed to ensure that regulatory-requirements are adequately addressed. Inadequate training can .

be traced as a root cause of problems identified in this are l Quality control audits are extensive, but lack a team member '

with technical expertise that could itentify technical or performance problems. There is no tecuical qualified oversight group within the licensee's organization that performs routine ;

performance based assessments of the radiological control l program The radioactive waste management area was inspected once during the assessment period. Operational events have been reduced in this area over the previous assessment period ,

The radiological environmental monitoring program was inspected once during the assessment period. This program was well documented and staffed. The licensee has been responsive to NRC issues in this area. The licensee has expended adequate resources to ensure that this program maintains high standards and performanc The licensee's radiochemistry program was inspected once during the assessment period. The licensee has continued to maintain a high performance level in this area with only minor problems being identified. The licensee's continuing t"ining program for radiochemistry technicians has fallen behinu schedule and is in need of attention. Again, as with the radiation protection section, the staffing in this section has experienced a high I

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turnover rate, but. staffing requirements are being met. The l licensee's approach to' resolution of technical issues was technically sound and thorough in almost all-cases. The licensee's performance'in'this area has been good as evidenced by the lack of problems and violations involving radioactive effluent releases. The licensee demonstrated 100 percent  ;

agreement during radiochemistry confirmatory measurement test The licensee's transportation program was inspected' once during the assessment period. The licensee continues to maintain a high level of. performance in this are No problems were identified in'the radiological controls area regarding resolution of technical issues and responsiveness to NRC initiative . Performance Rating

.The licensee's performance in the radiological controls area.was classified as a Category 1 during the last assessment perio However, performance during the latter part of this assessment period has been less effective in the.- diological controls are Staffing in this area is marginal in technical expertis The number of violations identified is viewed as a programmatic weakness in the radiation protection progra The licensee is considered to be in Perfctmance Category 2 in this functional are . Board Recommendations Recommended NRC Actions

. The NRC inspection effort in the radiation protection area should be consistent with the Fundamental Inspection Progra . Inspections in other radiological controls areas should be at a reduced leve Recommended Licensee Actions

. Provide increased technical oversight of radiological ;

protection training program !

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. Increase the experience level of personnel assigned to the radiation protection and radiochemistry section !

l . Improve the technical oversight and assessment of the audit team.

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,, .c 12 Maintenance / Surveillance L Analysis This functional area includes all activities associated with either diagnostic, predictive, preventive or' corrective maintenance of plant structures, systems', and components. Also  !

included was procurement, control, and storage of components,  ;

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modifications, and maintenance of the plant modifications;'and maintenance of the plant physical condition. It includes conduct of all surveillance (diagnostic). testing activities as well as all inservice inspection and testing activitie Examples of activities included.are instrument calibrations; equipment operability tests; postmaintenance, postmodification,-

and postoutage. testing; reactor vessel penetration interspace leak rate tests; water chemistry controls; and'special test This area was inspected on a routine basis by the NRC resident inspectors, periodically by NRC regional. inspectors, and by the NRC Operational Safety Team Inspection (OSTI).

The maintenance program in past assessments was found to be very informal with virtually no preventative maintenance progra The most recent assessment noted significant improvement and credited the licensee for the efforts to improve in this functional are During this assessment period, the licensee i continued to work at implementing the formal' maintenance progra The licensee's efforts to implement the maintenance program and improve maintenance procedures were impeded by the series of major maintenance outages experienced during this assessment period. The licensee resources required to improve the maintenance program were utilized to perform major outage activities. Consequently, only minimal improvement was noted during the assessment period in maintenanc !

The OSTI addressed maintenanc.e from the. standpoint of the support provided to operation Problems were identified with the  !

quality of maintenance instructions and with maintenance personnel working outside of instructions. Many procedures did not contain adequate information for performance. Craftsmen did not stop work when instructions were found to be inadequate and  ;

often performed work outside the original scope of the work authorize l l

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Several aspects of maintenance administrative control contributed to the problem !

The station service request system (system used to authorize and document maintenance) provided the potential for field-made changes to be omitted from postmaintenance testing and engineering review Documentation of maintenance activities was poor with a number of significant maintenance problems not documented in work package The maintenance department did not always involve engineering and quality support groups in the development or solution of problem maintenance tasks. This resulted in maintenance personnel either compounding the problem or working outside of the bounds permitted by the plant design and code Of the 6 violations and 17 reportable events in this functional area, most were due to inadequate procedures or personnel erro Although there are problems in maintenance, the experience and ability of the maintenance personnel is a strength. The licensee is improving the preventative maintenance program and maintenance procedures are being modified as problems are identifie The NRC has recognized that maintenance management is working to improve the program of formal controls. However, a sustained period of operation without a major maintenance outage is needed to free the licensee's limited resources to improve the formal program in this functional are The management and conduct of the Technical Specification surveillance program was strong. The extension of surveillance testing to determine operability of con.ponents and subsystems not explicitly listed in the Technical Specifications was considered to be an enhancement to safety. The licensee's methods for scheduling and accounting for test completion and problems were particularly effectiv Several problems were identified regarding secondary water chemistry confirmatory measurements. The licensee's analytical results for comparative measurements performed on prepared water chemistry standard indicated only 64 percent agreement between the licensee's results and the known values; expected industry

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i results would be about 80 percent agreement. Several NRC'

inspector observations concerning program improvement items were made in this area during the assessment perio One violation concerning use of quality control measures in secondary water chemistry was identified. Due to the nature and length of time this violation was in existence, there is reason to question the quality assurance and management oversight applied to this are In the overall surveillance program there are weaknesses resulting partly from the uniqueness of the facility. The licensee in the absence of an approved ASME code for gas cooled reactors, is working to develop a formal inservice inspection progra Some aspects of inservice testing have been incorporated in the facility Technical Specification The licensee does take exception to valve stroking normally operated valves as part of an inservice tes However, this licensee had not instituted a followup tracking and logging program to verify that valves excepted from valve stroke tests are indeed exercised during the test interva The licensee has a program for reviewing safety-related applications of test and measuring equipment found out of tolerance. The licensee has not always documented these reviews sufficientl ,

The licensee has reorganized these functional areas during the assessment perio Some new managers and supervisors have been assigned to assist in this functional are The program developed in the previous assessment period is being implemented but was not fully implemented during this assessment perio . Performance Rating The licensee is considered to be in Performance Category 3 in this functional are The licensee has assigned additional management to this functional area. The basis of a good program is in place and craftsmen are talented and dedicated. Administrative controls and task procedures are not yet sufficient to support the )

quality of work required from this organizatio '

The licensee has a strong surveillance program with some i problems. Conversely, the maintenance program is weak and needs ,

increased formality and procedure enhancement. Workers need to )

adopt a philosophy of not working outside procedures even when l the worker knows how to proceed without the procedur j I

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EngineeringLreview and documentation requirementsidictate that the procedure must'be correct before the work:is'don . Recommendations Recommended NRC Actions

. . Inspection of the surveillance program should be maintained consistent with the_ Fundamental Inspection Progra . .we

. ' Increased NRC attention should be focused on th .? y: ,

maintenance program with attention to the develop'ing' '

pre'ventative maintenance progra . A, maintenance team inspection in the'next assessment period would be a good measure of licensee progress:

since the Operational Safety Team _ Inspection conducted late in this assessment-perio . Recommended -Licensee Actions

. Conduct comprehensive performance based quality assurance audit . Increase management oversight and technical'

assessment .- Increase management support for~ development of a comprehensive preventative maintenance progra . Increase quality of maintenance procedure . Require compliance with approved procedure . Stop unauthorized or out of-scope maintenance wor . Provide better review of station service requests to

- assure identification of plant modifications performed as maintenance activitie Emergency preparedness l

1. Analysis This functional area includes activities related to the establishment and implementation of the emergency plan and implementing procedures, such as onsite and offsite plan development and coordination; support and training of onsite and offsite emergency response organizations; licensee performance during exercises and actual events that test emergency plans;

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adtrinistration and implementation of the plan (both during drills and actual events); notification; radiological exposure j control; recovery; protective actions; and interactions with .i

onsite emergency response organizations during exercises and l actual events, i During the assessment period, region-based NRC inspectors and contractor personnel conducted five routine emergency preparedness inspections and one reactive inspection. The reactive inspection examined the implementation of the emergency plan and procedures in response to the October 2,1987, fir One of the inspections consisted of the evaluation of the annual emergency response exercis The licensee performance since the last SALP has been considered to be in a continual positive trend in the emergency preparedness area. During this assessment period, a management reorganization was implemented that increased involvement and l attention by corporate and onsite organizations in the emergency preparedness area. A strong management commitment and involvement in program improvement has been demonstrated by the completion of all short-term improvements. Prior to the annual 1 emergency preparedness exercise on August 5,1987, the licensee l revised about half of their emergency plan implementing procedures, improved training, implemented a radiopager system, and made facility improvements to the forward command pos The effectiveness of improvements was observed during the August 5, 1987, emergency preparedness exercise, which demonstrated a better capability for responding to emergency events and corrected previously identified deficiencies. The stronger management attention to emergency preparedness during this period was also evidenced by the creation of an emergency preparedness coordinator position in the plant organizatio After the violation n the onsite training area identified in-the April 25-29, 1988, inspection, the licensee committed to a more comprehensive training program, retrain key emergency response personnel, review and revise emergency implementing procedures, and maintain a continuous effort to requalify their staff through classroom training and drill During the reactive inspection, one deviation was identifie This resulted from a fire in the turbine building on October 2, 1987, in which the licensee failed to staff and activate the forward command post (emergency operations facility) within 90 minutes. During an actual airborne release that occurred on April 4, 1988, from the core support area, operations and health physics personnel were unable to calculate the proper released airborne concentrations. The emergency exercise identified four deficiencies. One violation identified was due to weaknesses in t personnel proficiency during the April 25-27, 1988, inspectio l l

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Another. violation was due to the delayed notification occurring during an actual radiological release on April 4,1988. These violations indicated a weakness in the-licensee's' training progra . Performance Rating-The nature of the, violations, the number of. deficiencies, and-the deviation identified during the. inspections, along with problems occurring during actual events, are indicative that improvement is needed in this area. However, the inspection findings for this evaluation period indicate that the licensee's emergency preparedness program meets basic requirements to protect the' health and safety of the publi The licensee is; considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Action The NRC inspection effort in this area should be consistent with the Fundamental Inspection Program focusing on areas where specific weaknesses were identifie Recommended Licensee Action Licensee management should continue the present level of-attention to the correction of identified weaknesses; and ensnre that problem root causes are identified and correcte Security

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i This functional area includes all activities that ensure the

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security of the plant including all aspects of access control, security checks, safeguards, and fitness-for-duty activities and controls.

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four security inspection Six violations of the physical 1

, security plan (PSP) were identified. Four of the violations l

were Security Level IV violations and two were Security Level V violation Licensee management has demonstrated a strong commitment to the j implementation'of an excellent security program. Management has l committed the necessary resources to ensure that an adequate -

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staff is available and that security equipment is as close to state-of-the-art as possible. The licensee has increased the numbers of security management personnel from one to six during the assessment period. Additionally, the number of security-officers per shift has increased by approximately 25 percent.

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The perimeter security upgrade was completed during this s assessment period. The licensee's perimeter security system has ,

been recommended by NRC security inspectors to other licensee's I within Region IV as a model perimeter security system. Security management personnel have excellent backgrounds and experienc The licensee is continuously evaluating emerging security technology as a method to improve their program. The licensee has received approval by NRC Headquarters for the upgrade of the security systems backup power supply and are well advanced toward meeting their May 1989 completion of this program. The

licensee's security plan changes have been submitted and are-awaiting NRC approval. The licensee's response to NRC initiatives has been outstanding during the assessment period as evidenced by the security force increases and the backup power supply initiatives. Their review and submission of security plans and procedures is excellent. One violation was identified involving compensatory measures; the licensee's followup corrective action significantly changed their PSP and enhanced their capabilities in this are While the licensee's security audit plan appeared to be-comprehensive, it did not appear that the audit team included members with sufficient expertise to identify technical or-programmatic problems in the security area. The licensee has increased emphasis on the training and qualification program and improvements in th'.s area are evident. The licensee is in the process of expanding the training program and apparently will continue to improve the progra . Performance Rating The licensee has made considerable improvement in this area since the previous assessment period. Licensee management has demonstrated excellent support for the security program to ensure the plant has a high quality progra The licensee is considered to be in Performance Category 1 in this functional are . Board Recommendations , Recommended NRC Actions The NRC inspection effort in this area should be consistent with the Fundamental Inspection Progra .

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h Recommended Licensee Actions Licensee. management should continue to provide strong-support for the secur.ity program. Licensee management-should ensure that audits are conducted by personnel with security e.'perti se. . Continued emphasis should be placed on trair Ing and qualifications of the security forc '

F. Engineering / Technical Support Analysis The purpose of-this functional area is to address the adequacy of the technical and engineering support for all plant activitie It includes all licensee act'vities associated with the design of plant modifications; eng*r.aering and technical support for operations, outages, mair;tenanca, testing, surveillance, and procurement activities; training; and configuration managemen Plant Modifications and Outages The NRC has conducted several inspections in the area of engineering activities in support of design changes and

" modifications to the plant during this assessmen In'one-of the inspections, it appeared that all engineering requirements involving new installations, related to the facility' fire protection system, had not been fully accomplished. _It was found that fire detectors had not

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been installed in some areas as committed and that the spacing of the detectors in other areas was not in accordance with the manufacturer's recommendation In another inspection conducted early in the assessment period, it was found that over one hundred temporary facility modifications done under the licensee's temporary configuration report program had in fact remained in place for several years without conversion to permanent design changes. Therefore, the appropriate design reviews had not been performed and the changes had not been incorporated into facility drawing The findings of this inspection involving the temporary configuration report program resulted in the only enforcement conference conducted during this assessment period. As a result of these findings, the NRC resident inspectors following the Temporary Configuration reports have observed extensive licensee action to eliminate existing temporary changes by converting long standing 1 changes to permanent changes with appropriate evaluations f and physical changes when require ,

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Another inspection identified that batteries in the emergency lighting system had been effectively destroyed by a test that.was not properly conducted because of inadequacies in the related controlled work package, which, in turn, was based on information supplied by the engineering organizatio An NRC inspector observed that the' design chat.ga process, as documented, was very complex and that it appeared that the various' groups involved had little awareness of s, hat the other groups di During a review of change notices, an NRC inspector noted that the engineer.ing evaluation of a. change in the steam leak rupture detection and isolation system (SLRDIS) was less than thorough in that the change provided additional load on one of the uninterruptible power supply systems (UPS) that took'the UPS to an overload conditio During recent inspections of the design change process, there has been some improvement in the thoroughness of the engineering data provided and the reviews appear to have'

also been more thorough. One inspection involving the refurbishment of the reactor helium circulators noted that change notices issued by the engineering organization to document design changes complied with NRC requirements in that all applicable reviews had been accomplished properl Change notices were well detailed and contained necessary information for making the change The licensee also has made revisions in the procedures governing the change process in an effort to make the process better able to function properly, and to decrease the response time of engineering to perceived plant need However, the procedures remain comple b. Procurement Activities In the area of engineering and technical support for procurement activities, two inspections identified that purchase orders placed for fasteners to be used as an essential element of the helium recirculator refurbishment were not current in their references to engineered drawings and, further, the orders did not require appropriate quality documentation. Although not firmly established, it ap' pears that the purchase requisitions prepared by the engineering organization, upon which the purchase orders were based, were inadequate in that they did not consider prior commitments made in correspondence to the NR _

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!There were indications in this area-that the licens'ee's-engineering group was dependent on receiving current .

engineering information from the NSSS vendor from whom the were purchasing the material before the procurement documents could be updated properly. It appeared that the vendor was' determining the technical requirements:for what he was to furnish rather than the licensee making the o determination and insisting on complianc It appears that the procurement process was hampered by the lack of well defined engineering requirements for plant component Successful procurement at FSV requires significant, engineering input and evaluatio It was also noted th'at the procedures governing procurement activities, particularly;in the engineering area, were not clear relative to-the dedication process by which commercial grade components could be used in.nfety-related applications. It was also noted that the procurement specification requirements for replacement components were

. vagu In one noted instance, the licensee ordered a. valve and required that the valve be tested hydrostatically for seat:

leakage, but did not specity any licensee QC acceptance values. When the valve was received, the receiving QC inspector had to find a vendor catalog which provided the advertised values of pressure rating and seat leakage'in order to determine the acceptability of the valv In another instance, the receiving inspectors had placed a receiving. inspection hold tag on a major component that was too-large and too inconvenient from a handling standpoint to place in'the receiving inspection area. The purpose of the hold tag'was to identify to others that component had not been receipt inspected and that no work was to be done on the component until the inspection had been done. Plant personnel,-nonetheless, proceeded to install the component

, without exercising a method of allowing the action with engineering and quality assurance groups' consen Inspection of the receiving inspection process and the storage of components indicated that both functions were generally satisfactory. In the storage area in particular, stocked item identification was considered to be very satisfactor Operations, Maintenance, Testing, Surveillance The engineering and technical support of active plant functions has improved during the assessment perio The

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inplant engineering into one organization. Engineerin support now comes from'two organizations, the nuclear ]

engineering division outside the plant, and the plan s systems engineering department inside the plan l Though performance has improved, .there are still obvious- ,

weaknesses in this functional area. In addition to these l weaknesses discussed in the maintenance section of this i report, there have been seven_ violations in this~ functional l area during the assessment period.that were due to personnel error or inadequate procedures. There were also l

four LERs during the assessment period that were due to .

personnel errc U While engineering and technical support has become more j involved in day-to-day functions, more diligence is .

required to assure a high quality of support to operators and technicians, and to assure that personnel errors and i the effect-of inadequate procedures are minimized. In addition, there were twofinstances during this assessment period which indicated the need for closer engineering and technical support. In the first instance, information concerning battery capacity was prematurely reported to the NRC resident inspector.without proper, involvement-of the licensee engineering organization. The batteries were subsequently shown by engineering to meet criteria previously accepted by the NRC. In the second instance the procedure for evaluation of reactor penetration leakage had not been maintained current or properly reviewed, this resulted in the reporting of inaccurate leakage rates to  ;

the resident inspectors which initially appeared to exceed Technical Specification (TS) limits. Subsequent correction 4 of the leakage calculation indicated the leakage rate to be  !

within T i Clearly more attention to detail is required to support facility operations and to verify proper facility operation to the NR d. Trainino The assessment of this area includes all activities of the training programs conducted by the licensee's staff. This area was inspected on a continuing basis by the NRC resident inspectors. This area wa:. also the subject of two insps.ctions conducted by NRC region based inspectors in late 1987 and late 1988. During the assessment period, licensing examinations were administered by the NRC to six

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reactor operator (RO) candidates and three senior. reactor

- operator (SRO) candidates. Two of the R0 candidates. failed the examinatio As a result, FSV has.10 reactor operators,19 senior reactor operators, and 8 senior reactor operators (limited i to fuel handling) license <

. A pilot requalification program evaluation was performed at i FSV during the. weeks of May 11 and 18, 198 The evaluation consisted of: (1)~a detailed. review of the-facility developed written requalification. examinations, (2) observation of facility administered operating examinations,-(3) observ'ation of facility administration of the written examinations, and (4) co grading of several-written and operating examinations. Significant problems were encountered'during review of the facility written examinations that threatened examination validity. LThese problems were in.the areas.of examination construction and examination security. Additionally,' minor problems in o coverage and evaluation were observed.on the operating examina91ons. As a result of this-evaluation, the FSV requalification program was evaluated as margina The. licensee achieved full INPO accreditation for the licensed training program in the previous assessment period. 'The nonlicensed training program was accredited in 198 The NRC inspections identified that the licensee has a system in place to modify training programs based on significant plant events, the result of annual requalification examinations, and training development requests (TDRs), which.were submitted by licensee personne The training request process was also utilized to incorporate into the training program industry operating experience and plant modification packages. Incoming documents were assigned a TDR. The first inspection identified a severe backlog of TDRs which had not been i dispositioned and needed to be incorporated into the training program. The. second inspection verified that the backlog of TDRs has been reduced from approximately 600 in Ma ch 1988 to 58 in August 1988. However, the second ,

inspection revealed that approximately 49 TDRs, some dating from 1985 and all older than 90 days, had not been assigned to a lesson pla !

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The training request program would be more effective if better administrative controls and required corrective actions identified by the QA Division were implemente '

As previously described, reviews of TDRs were not timel The licensee was in the process of upgrading and updating the training records management system. The QA Division had identified ir March 1987 that the training department could not provide records nor did they have a method of controlling procedures to certify that personnel met the requirements of ANSI N18.1-197 The second inspection-determined that after 18 months the QA department concerns still had not been addressed. The resolution of these issues had been delayed and only the minimum requirements were me All training programs were defined by training procedures in which key requirements were identifie Responsibilities for the implementation of training programs were specified in the training administrative manual. Sufficient expertise was usually available within the staff, but staffing was marginal as indicated by the backlog of TDR The training c.anager reports directly to the Vice President Nuclear Operations, which indicated corporate management's involvement in site training activitie Training policies were well stated and understandabl The inspections verified training department personnel strictly adhered to policies and procedure Overall the training program was well defined and in the process of being upgraded to implement the INP0 accredited programs. Means had been established to provide for feedback of operating experience from both within and outside the utilit Configuration Management Although engineering and technical support of configuration management was found to be acceptable during this assessment period, examples were found where piping and instrument drawing (P& ids) were not consistently and correctly updated to reflect the existence of engineering change notices and temporary configuration reports. Also, examples were found which indicate that engineering personnel preparing or reviewing new changes did not always consider the effect of other changes on their current i

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25 effor These examples are considered to indicate weaknesses in the licensee's configuration management program where licensee attention is reede . Performance Rating The licensee is considered to be in Performance Category 2 in this functional are . Recommendations Recommended NRC Actions

. The NRC inspection effort in this area be consistent with the Fundamental Inspection Progra . The NRC should selectively review significant changes or modifications that licensee might propose, particularly if the change or modification directly affects the reactor or its operating auxiliarie . A Region IV team inspection of engineering and technical support should be conducted in the next assessment period, Recommended Licensee Actions The Board recommends that licensee management focus attention and resources to:

. Assure thorough complete technical detail in change notice packages

. Assure change notice packages include all required reviews and that these reviews are completely documented

. Assure that controlled work packages include all requirements of the associated change notice

. Significantly increase design engineering involvement in procurement activities

. Assure that procurement documents contain sufficient detail to adequately require those actions contemplated by the licensee's engineers

. Assure the issuance of correct, current design documents to the users of such documents

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( Safety Assessment /0uality Verification Analysis This functional area includes all licensee review activities ,

associated with the implementation of licensee policies; I licensee activities related to amendment, exemption and relief-requests; response to generic letters, bulletins, and information. notices; and resolution of TMI items and other  !

regulatory initiative It also includes licensee activities {

related to resolution of safety issues, 10 CFR 50.59 reviews, 1 10 CFR 21 assessments, safety committee and self-assessment ]

activities, analyses of industry's operational experience root j cause analyses of plant events, use of feedback from plant )

quality assurance / quality control (QA/QC) reviews, and '

participation in self-improvement programs. It includes the effectiveness of the licensee's quality verification function in identifying and correcting substandard or anomalous performance, in identifying precursors of potential problems, and in monitoring the overall performance of the. plan Licensing Activities and Safety Assessments During the assessment period there were_nine license -

amendments granted. These are summarized in Table II of.- )

Section V (Supporting Data and Summaries). The submittals j have been timely and are considered to be of average  ;

qualit The licensee has undertaken several initiatives in this l period which have resulted in improved performance in this functional area. The licensee has been steadily increasing and improving the use of industry operating experience. A-reorganization in this period has clearly defined organizational responsibility for industry operating experience evaluation. In addition, the licensee has continued to make progress in the Technical Specification upgrade program. The program is now at the point of implementation and the licensee has indicated a desire to phase the implementation. This is currently being discussed between the NRC staff and the licensee. The NRC staff has also noted that licensee responsiveness to NRC initiatives is greatly 1mprove Two inspections were made in the area of the effectiveness of the licensee's conduct of 10 CFR 50,59 assessment During the first inspection, five engineering change l notices were reviewed for the purpose of determining the .

thoroughness of the licensee's design review process in I terms of whether a contemplated change would generate an j unreviewed safety question or would require a change to the l l

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-Technical Specifications. The NRC inspec' tors found'that none of the changes required that the licensee' gain NRC acceptance of the change,.but in three cases.the overall design reviews were less than thorough. Upon further inspection,,it was determined that the actual' safety evaluation was correct but was incompletely documente That is,'the licensee did not list all references and supporting documents in the written safety evaluatio Some of these supporting documents were necessary~ for the NRC inspectors to reach the same conclusion as the

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The second _ inspection reviewed _four change notices-and the related controlled work packages for each. In addition,-

four temporary configuration reports were examined. The required reviews were done in an acceptable manne 'These inspections indicated that the performance of 10 CFR 50.59 reviews by the licensee were satisfactor However, the. licensee should improve the thoroughness of safety evaluation documentation in support of modification In the area of the licensee's conduct of 10 CFR 21-

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assessments, the NRC conducted one inspection directed toward reviewing the' licensee's program. The NRC inspector-noted that the licensee's procedures were fully satisfactory in terms of the posting, evaluation, and reporting requirements of the regulation, but were weak in the area of the development and maintenance of record It was also found that the licensee's engineering function was, on occasion, excessively slow in performing requested evaluations. Several other inspections of the licensee's evaluation process have generally indicated that the

, process has functioned satisfactoril In addition to evaluating Part 21 reports received from outside sources, the licensee filed two Part 21 reports

. during the assessment period. Both of these reports were filed on June 5, 1987. The first report identified potential defects in certain Limitorque valve operator The second identified potential defects in Wolf and Swichard air start ~ motors for emergency diesel generator The Part 21 reports were technically adequate and filed in accordance with NRC requirements. The NRC staff also noted that on February 2,1988, the licensee's reactor vendor, GA Technologies, filed a Part 21 report identifying quality assurance deficiencies concerning replacement parts for the helium circulators.

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NRC regional inspectors conducted two inspections of the onsite plant operations review committee (PORC) and one inspection of the off-site nuclear facility safety committee (NFSC). The inspections involved attendance at one or more committee meetings and review of committee meeting minutes. In general, the NRC inspectors found that both committees accomplished the elements contemplated by the Technical Specifications and the committee charter However, the committees do not utilize subcommittees, thus requiring substantial management time to meet Technical Specification requirement It appears that more efficient committee process would make management time available for other matter Assessment of all ramifications of deviating from operations procedures and standard plant configurations should be improved to assure undesirable plant configurations are avoided. A false loss of bearing water signal emphasized the importance of such reviews. When a false loss of bearing water signal was received on Loop 1, Helium Circulator B tripped as designed, and Helium Circulator A did not. The licensee's followup revealed that the speed valve to Helium Circulator A was manually jacked open and could not close. Had bearing water actually been lost, Helium Circulator A could have been damage b. Quality Verification Activities An inspection in the design control area indicated that the licensee is slow in responding to QA/QC findings. The case in point was in the area of temporary configuration reports changes to the facility that, in effect, had become permanent changes as previously discussed in Plant Modifications and Outages. The NRC inspectors noted that the licensee's QA/QC group had developed concerns in this area prior to the NRC's inspection, but that little or no action had been taken to correct the matte The licensee's quality verification functions are working to identify and document problems requiring resolutio However, continuing problem in this assessment period was the backlog of problems identified that required resolution. In 1986,. an NRC inspection found that the licensee had a substantial backlog of QA/QC findings for which little or no action had been taken. A recent inspection indicated that while the apparent backlog has j j

been reduced, it still exists to a substantial degree with j

' several old nonconformances not corrected even though some had been issued several years ago.

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The QA/QC group has issued correc+.ive' action requests acoui

..every six months, since early- 1987, requesting ina management make improven ants .in the corrective action program. The NRC staff believes that part of the problem is the slow response of the licensee's engineering organization to QA/AC findings. The NRC staff recognizes the' tremendous workload under which the: licensee's engineering organization has labored. .The engineerin . organization, like the maintenance organization, has.had an overload of plant problems continuing over several year This inordinate workload has prevented work on items considered less pressing by licensee management. However, this does not excuse the delays'in closing audit finding The NRC staff notes that there are improvements in the licensee's overall performance that reflect management initiatives and involvement in this functional area. This is particularly evident'in the operation of the senior planning team (SPT). The SPT serves as a forum for integration of.each division's activities. . Integration it-also. evident in-the. team or project approach used to-address major problem areas, such as the failure of the helium circulator in 1987. These activities' support quality work by assuring that all factors are carefully considered in the activities of the licensee or its contractor Quality organization activ ties were found to be in place i

and generally functioning adequately. However, detailed quality checks on many' internal activities appear lackin For example, there is little evidence of the QA organization reviewing internal documents, such as 50.59 reports. Problems-noted in other functional areas with procedures such as maintenance and operations would benefit from quality assurance revie . Performance Rating The licensee is considered to be in Performance Category 2 in this functional are l l

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3. Recommendations Recommended NRC Actions .

. NRC attention to the programmatic aspects of the licensee's quality verification fur.ctions should be increased. Specific attention should be focused on the timeliness and quality of licensee corrective actions,

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E . Recommended Licensee Actions

. The licensee should reduce the backlog of open corrective action request . The licensee should impros9-the timeliness of ,

responses,to corrective at ion request '

. The licensee should give greater management attention to QA/QC findings', particularity in the area of timely response on the part of the engineering organizatio . The licensee should involve QA in the review of internal documents, such as 50.59 report V Supporting Data and Summaries

. Meetings Held During This Assessment Period An enforcement conference-was held at the Region IV office on-September 10, 1987, to discuss design control and the use of temporary change requests. Additional meetings were held at the Region IV office on March 3 and April 6, 1988, on design control and configuration ma'nagemen A management' meeting was held at the Region IV office on September 11, 1987, to' discuss the failure of.the "D" Helium Circulator and the planned recover A management meeting was held at the Region IV office on May 5, 1988, to' discuss licensee proposals for compliance with the requirements of the miscellaneous amendments rul The licensee met with NRR ten times during the assessment period on a variety of topic ,

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ENFORCEMENT ACTIVITY'

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Number of Violations 'i FUNCTIONAL In Each Leve l

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AREA DEFICIENCIES DEVIATIONS V: I . (1)~. Plant Operations 1 7 B. ._ Radiological Control '2- 4' a-(2) Maintenance / Surveillance 1 3-q f ,

, Emergency Preparedness- 9 Security 3 '3

' Engineering / Technical Support-- 5

- Safety Assessment / Qualit Verification TOTALS 9 2 6 '22-Footnotes:

- (1).. Includes two violations with examples applicable to Maintenance / Surveillance and one violation applicable to Engineering / Technical _ Suppor (2) Includes one violation with examples applicable to Engineering / Technical Suppor ~ --

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TABLE II LICENSE AMENDMENTS

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54 May 20, 1987 Modified surveillance requirements for emergency diesel generators  !

55 June 29, 1987 Required economizer, evaporator, superheater.of both steam generators to .

be available for decay heat removal

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56 July 13, 1987 Modified administrative controls and operation of Plant' Operations Review Committee 57 November 23, 1987 Revised LCO to assure sufficient flow of helium coolant in low power or shutdown mode 58 January 22, 1988 Revised surveillance and calibration requirements of plant protective system (PPS)

59 April 7, 1988 Deleted tabular listing of safety-related saubbers from Technical Specifications 60 June 20, 1988 Revised PPS setpoints to allow for instrument error 61 August 5, 1988 Deleted requirement to monitor temperature in dewpoint moisture monitor reactor vessel penetrations 62 August 5, 1988 Deleted obsolete reference in Appendix B of Technical Specifications l

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SALP MEETING SUMMARY

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Date: - January 25,.1989 Licensee:- Public~ Service Company.of Colorado (PSC)

Facility: Fort St. Vrain Nuclear Generating Statin (FSV)

License: DPR-34-Docket:- '50L267 Subject: SALP MEETING AT FSV-VISITORS' CENTER-On_ January 25, 1989, the Regional Administrator, NRC, Region IV, members of the Region IV staff,; and NRR representatives net'with representatives of PSC in an open . meeting at the Fort.St. Vrain Visitors' Center to discuss the SALP Board. Report covering the period.May~1, 1987, through August 31, 198 After opening remarks' by'.the Regional Administrator, the Director, Division of Reactor Projects, presented each of the functional areas evaluatedtin the SALP Board Report'using Attachment 1. as an outline. The PSC President and Chief Executive Officer, and other licensee representatives presented the PSCL Eresponse'using Attachment 2 as an, outline.<1 he1PSC T responselincluded discussion of planned actions to improve performance in functional areas

. judged by'thesSALP Board to exhibit declining performanc Attachments:

1. ~ NRC Material Presented at Meeting-2. PSC Material Presented at Meeting; 3. Attendance List (Principal Attendees)

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ROBERT D.' MARTIN, REGIONAL r INTRODUCTION ADMINISTRATOR, NRC REGION IV H

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SALP PRESENTATION L. J. CALLAN, D'IRECTOR, ,

DIVISION OF REACTOR PROJECTS'

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NRC REGION IV-L,

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PUBLIC SERVICE COMPANY ~ LICENSEE MANAGEMENT AND STAFF CF COLORADO RESPONSE

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AND C0ftENTS-

CLOSING REMARKS- ROBERT D. MARTIN I

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... . 1 c-o UNITED STATES NUCLEAR REGULATORY C0lt11SSION:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE-

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MEETING'

. PUBLIC SERVICE COMPANY OF COLORADO-FORT ST. VRAIN NUCLEAR GENERATING STATION MAY 1, 1987-AUGUST 31,1988-

' FORT ST, VRAIN NUCLEAR GENERATING STATION JANUARY 25,1988

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l SALP PROGRAM OBJECTIVES IMPROVE NRC REGULATORY PROGRAM PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES IMPROVE LICENSEE PERFORMANCE MECHANISM TO FOCUS ATTENTION ON OVERALL EFFECTIVENESS OF MANAGEMENT

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PERFORMANCE ANALYSIS AREA FOR FORT ST. VRAIN:

NUCLEAR GENERATING STATION- PLANT OPERATION RADIOLOGICAL CONTROL . ~ MAINTENANCE / SURVEILLANCE D; EERGENCY PREPAREDNESS: SECURITY ENGINEERING / TECHNICAL SUPPORT -

t-G.- SAFETY ASSESSENT/0UALITY-VERIFICATION-

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I FUNCTIONAL AREA PERFORMANCE CATEGORY CATEGORY I LICENSEE MANAGB OlT ATTENTION AND INVOLVEMENT ARE READILY EVIDENT AND PLACE EMPHASIS ON SUPERIOR PERFORMANCE OF

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NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES, WITH THE RESULTING PERFORMANCE SUBSTANTIALLY EXCEEDING REGULATORY REQUIRBdENT LICENSEE RESOURCES ARE AMPLE AND EFFECTIVELY USED S0 THAT A HIGH LEVEL OF PLANT AND PERSONNEL PERFORMANCE IS BEING ACHIEVE REDUCED NRC ATTENTION MAY BE APPROPRIAT :

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LICENSEE MANAGEMENT ATTENTION TO AND ItNOLVEENT IN THE WRFORMANCE OF NUCLEAR SAFET/ OR SARGUARDS ACTIVITIES IS GOOD. THE LICENSEE HAS ATTAINED A LEVEL OF ERFORMANCE ABOVE THAT NEEDED TO MEET REGULATORY

' REQUIREMENTS, LICENSEE RESOURCES ARE ADEQUATE AND REASONABLY ALLOCATED S0 THAT GOOD PLANT AND RRSONNEL-WRFORMANCE IS BEING ACHIEVED.. NRC ATTENTION MAY E-MAINTAINED AT NORMAL LE'EL i

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CATEGORY 3 l LICENSEE MANAGEE NT ATTENTION T0 AND. INVOLVEMENT IN THE-

. PERFORMANCE OF NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES ARE NOT SUFFICIENT. THE LICENSEE'S PERFORMANCE DOES NOT:

SIGNIFICANTLY EXCEED THAT NEEDED TO MEET MINIMAL

REGULATORY RECUIRETENTS,- LICENSEE RESOURCES APPEAR TO BE STRAINED OR NOT EFFECTIVELY USED.' NRC ATTENTIO SHOULD BE INCREASED ABOVE NORMAL LEVELS,

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EVALUATION CRITERIA L

L 1. .MANAGEENT INVOLVEENT AND CONTROL IN ASSURING QUALITY

, APPROACH TO TECHNICAL ISSUES FROM A SAFETY. STANDPOINT e RESPONSIVENESS TO NRC INITIATIVE . ENFORCEENT HISTORY OPERATIONAL EVENTS (INCLUDING RESPONSE TO,' ANALYSIS OF, AND CORRECTIVE ACTIONS FOR) STAFFING (INCLUDING MANAGEENT)

.7, EFFECTIVENESS OF TRAINING CRITERIA AND QUALIFICATION PROGRNi I;

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i STRENGES MANAGEMENT'S INVOLVE NT IN PLANT OPERATIONS PROFESSIONALS 10F CONTROL ROOM OPERATORS MANAGEMENT'S' SUPPORT OF THE SECURITY AREA STRONG SAFE 1Y ASSESSMENT CAPABILITY THE OVERALL SURVEILLANCE PROGRAM i

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WEAKNESSES WEAK MAINTENANCE PROCEDURES-TURNOVER OF EXPERIENCED PERSONNEL IN'-

lliE RADIOLOGICAL' CONTROL AREA PROGRAft1ATICWEAKNES'5INTHERESPIRATOR PROTECTION AREA.-

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DEFICIENCIES'IN THE CHANGE NOTICE PROGRAM

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CATEGORY 2

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THE OPERATIONS STAFF APPEARED KNOWLEDGEABLE AND CAPABLE, AND DEMONSTRATED A POSITIVE ATTITUDE TOWARD SAFE PLANT OPERATIONS OPERATOR MORALE AND PROFESSIONALISM APPEARED HIGH ,

C0fffROL ROOM OPERATORS DEMONSTRATED THE ABILITY TO RESPOND TO COMPLEX SYSTEM CHALLENGES THE STATION MANAGER AND OPERATIONS MANAGER t

DEMONSTRATED A HIGH LEVEL OF INVOLVEMENT IN ALL ASPECTS OF OPERATIONS LICENSED REACTOR OPERATORS HAVE HAD TO WORK-EXCESSIVE OVERTIME DUE TO SHORTAGES OF PERSONNE THE CURRENT LICENSED OPERATOR CLASS SHOULD RELIEVE CURRENT OVERTIME PRESSURES IN THIS AREA PROCEDURES WERE NOT ALWAYS ADEQUATELY DETAILED AND THOROUGH SEVERAL MODIFICATIONS HAVE BEEN PLANNED TOWARD ACHIEVING A " BLACK BOARD CONCEPT" (ALL ANNUNCIATORS DARK WHEN PLANT CONDITIONS ARE ALL NORMAL)

NEW LARGE, EASY TO READ SIGNS HAVE MADE MAINTENANCE, OPERATI0tlS, AND TESTING EASIER AND FORE ERROR FREE

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PLANT OPERATIONS REC 0ftENDED LICENSEE ACTION'

LICENSEE MANAGEMENT IS ENCOURAGED TO CONTINUE IMPROVEENT EFFORTS

, IN THIS FUNCTIONAL AREA, INCLUDING:-

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REVISION AND IMPROVEMENT OF PLANT OPERATING PROCEDURES

IMPROVED OPERATOR TRAINING ON EMERGENCY 0PERATING PROCEDURES WITH SPECIAL ATTENTION TO

, EMERGENCY CONDITION IDENTIFICATION AND CLASSIFICATION

REDUCTION OF THE BACKLOG OF EQUIPENT DEFICIENCIES-INDICATED BY'THE HIGH NUMBER OF DEFICIENCY-TAGS IN THE CONTROL ROOM

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INCREASE NUMBER OF LICENSED OPERATORS TO FULLY MAN ALL CREWS

REDUCTION OF NUISANCE ALARMS BY WORKING TOWARD A BLACKBOARD CONCEPT

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RADIOLOGICAL CONTROLS CAEGORY 2 THE LIC8iSEE HAS MAINTAINED AN ADEQUATE STAFF IN THE RADIATION PR01ECTION SECTION DESPITE A HIGH

- TURNOVER RATE THE EXPERIENCE LEVEL IN THE RADIATION PROTECTION-SECTION IS LOW, BUT APPEARS ADEQUATE

. THE LICENSEE HAS EX RIENCED SOME PROGRABfiATIC hEAKNESSES IN THE-RESPIRATORY PROTECTION PROGRAM

~THERE IS NO TECHNICALLY OUALIFIED OVERSIGHT GROUP TO ERFORM ROUTINE EPFORMANCE BASED ASSESSMENTS-0F;THE RADIOLOGICAL CONTROL PROGRAMS REC 0ftENDED LICENSEE ACTION

. PROVIDE INCREASED TECHNICAL.0VERSIGHT OF RADIOLOGICAL PROTECTION. TRAINING PROGRAMS INCREASE THE EXERIENCE LEVEL OF PERSONNEL ASSIGNED TO THE RADIATION PROTECTION AND RADI0 CHEMISTRY SECTIONS

. IMPROVE THE TECHNICAL 0VERSIGHT AND ASSE3EUT

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MAINTENANE/ SURVEILLANCE-CATEGORY 3 SIGNIFICANT IMPROVEENT WAS NOTED IN THE PREVENTIVE MAINTENANE PROGRAM

~ MAINTENANE PERSONNEL WERE FOUND TO BE WORKING OUTSIDE OF '

SON PROCEDURES DUE TO INADEQUATE WORK INSTRUCTIONS DOCUE NTATION OF MAINTENAN E ACTIVITIES WAS POOR WITH A NtfBER OF.SIGNIFICANT MAINTENANCE PROBLEMS NOT DOCUT NTED IN WORK PACKAGES THE MAINTENANE DEPARTMENT DID NOT ALWAYS INVOLVE ENGINEERING AND QUALITY SUPPORT GROUPS IN THE DEVELOPMENT

0R SOLUTION OF PROBLEM MAINTENANCE TASKS ALTHOUGH THERE ARE PROBLEMS IN MAINTENANE THE EXPERIENE OF THE MAINTENANE PERSONNEL-IS A STRENGTH SURVEILLANCE TESTING OF COMPONENTS AND SUBSYSTEMS NOT EXPLICITLY LISTED IN THE TECHNICAL SPECIFICATIONS WAS CONSIDERED AN ENHANCE R NT TO SAFETY THE LICENSEE'S METHODS FOR SURVEILLANCE SCHEDULING AND ACCOUNTING WERE PARTICULARLY EFFECTIVE PROGRAMMATIC NEAKNESS IN CONTROL OF TEST AND E ASURING EQUIPMENT

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MAINTENANCE / SURVEILLANCE REC 0ltENDED LICENSEE ACTION-CONDUCT COMPREHENSIVE PERFORMANCE BASED QUALITY-

-ASSURANCE AUDITS INCREASE MANAGBENT OVERSIGHT AND TECHNICAL

- ASSESSMENTS CONTINUE MANAGEMENT SUPPORT FOR DEVELOPMENT OF A

- COMPREHENSIVE PREVENTIVE MAINTENANCE PROGRAM

- INCREASE QUALIT/ OF MAINTENANCE PROCEDURES

- REQUIRE COMPLIANCE WITH APPROVED PROCEDURES I

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EMERGENCY PREPAREDNESS CATEGORY 2

LICENSEE PERFORMANCE SINCE THE LAST SALP HAS EEEN CONSIDERED IMPROVING

, INCREASED ItNOLVETENT AND ATTENTION BY CORPORATE AND ONSITE ORGANIZATIONS WAS EVIDENT IN THE EMERGENCY PREPAREDNESS AREA STRONG MANAGEMENT COMITENT AND INVOLVEMENT IN PROGRAM IMPROVEENT HAS EEEN DEMONSTRATED BY THE COMPLETION OF ALL SHORT-TERM IMPROVEMENTS THE AUGUST 5, 1987, EXERCISE DEMONSTRATED THE EFFECTIVENESS OF THESE IMPROVEMENTS THE LICENSEE HAS COMITTED TO A MORE COMPREHENSI\E TRAINING AND QUALIFICATION PROGRAM THE LICENSEE HAS COMMITTED TO REVIEW AND REVISE EMERGENCY IMPLEMENTING PROCEDURES REC 0 WENDED LICENSEE ACTI0tl LICENSEE MANAGEENT SHOULD CONTINUE THE PRESENT LEVEL OF ATIENTION TO T!E CORRECTION OF IDENTIFIED WEAKNESSE3 AND ENSURE THAT PRCELEM ROOT CAUSES ARE IDENTIFJED AND CORRECTED i

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SECURITY

. CATEGORY 1 THE LICENSEE HAS DEMONSTRATED A COMMITMENT TO TE IMPLEMENTATION OF AN EXCELLENT SECURIH PROGRAM

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ETE LICENSEE HAS INCREASED THE OVERALL SECURITY

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~ STAFF THE PERIETER SECURITY SYSTD1 IS CONSIDERED A MODEL SYSTBi:-

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THE LICENSEE'S RESPONSE TO NRC INITIATIVES HAS' "

BEEN OUTSTANDING DURING THIS ASSESSMENT PERIOD AS EVIDENCED BY THE SECURIT( FORCE INCREASES AND THE-l BACKUP POWER SUPPLY INITIATIVES THE SECURIT/ AUDIT TEAM DID NOT INCLUDE MEMBERS dlITH SUFFICIENT EX RTISE TO IDENTIFY TECHNICAL OR'

PROGRAft1ATIC PROBLEMS IN THE SECURITY- APEA

REC 0 MENDED LICENSEE ACTION i

LICENSEE MANAGBENT SHOULD CONTINUE:TO PROVIDE STRONG SUPPORT FOR THE SECURITY PROGRAM MANAGEMENT SHOULD ENSURE THAT AUDITS INCLUCE PERSONNEL WITH SECURITY EXPERTISE CONTINUED EMPHASIS SHOULD BE PLACED ON TRAINING AND QUALIFICATIONS OF THE SECURITY FORCE l

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. . ENGINEERING /ECHNICAL SUPPORT CATEGORY 2 EARLY IN TE ASSESSMENT PERIOD IT WAS DISCOVERED THAT.0VER ONE HUNDRED TEMPORARY FACILITY

. MODIFICATIONS HAD REMAINED IN PLAE FOR SEVERAL

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-YEARS WITHOUT CONVERSION TO WRMANENT DESIGN CHANGES

- THE DESIGN CHANGE PROESS IS VERY~ COMPLEX PURCHASE REQUISITIONS PREPARED BY THE ENGINEERING ORGANIZATION WERE IDENTIFIED THAT DID NOT CONSIDER PRIOR COMITENTS MADE TO THE NRC -

THE PROCURE E NT PRO ESS'IS HAMPERED BY THE LACK OF WELL DEFINED ENGINEERING REQUIREE NTS FOR PLANT COMPONENTS PROCEDURES GOVERNING PROCURE E NT ACTIVITIES WERE NOT CLEAR RELATI'E TO THE DEDICATION PROCESS FOR C0ftERCIAL GRADE COMPONENTS THE LIENSEE HAS REORGANIZED TO CONENTRATE INPLANT ENGINEERING INTO ONE ORGANIZATION P8 IDS WERE IDENTIFIED THAT HAD NOT BEEN CORRECTLY UPDATED

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RECOPENDED LICENSEE ACTICN

. IMPROVE THE COMPLETENESS OF TECHNICAL DETAIL IN CHANGE NOTICE PACKAGES AND ASSOCIATED CONTROL'-

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h0RK PACKAGES ASSURE THAT CHANGE NOTICE PACKAGES' INCLUDE ALL REQUIRED REVIEWS AND PROPER. DOCUMENTATION O R REVIEWS INCREASE DESIGN ENGINEERING'S INVOL'EMENT IN-PROCUREMENT ACTIVITIES AND THE DESIGN DETAIL

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CONTAINED IN PROCUREMENT DOCUMENTS IMPROVE THE DOCUMENT CONTROL OF DESIGN' DOCUMENTS

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SAFETY ASSESSMENT /0UALITY VERIFICATION f_AIGDRYZ A

THE LICENSEE HAS BEEN STEADILY INCREASING AND IMPROVING THE USE OF INDUSTRY OPERATING EXPERIENC THE LICENSEE HAS CONTINUED TO MAKE PROGRESS IN THE TECHNICAL SPECIFICATION UPGRADE PROGRA ,

TE ONSITE PLANT CERATIONS REVIEW COPNITTEE (PORC)

AND THE OFFSITE NUCLEAR FACILITY SAFELY COMITTEE (NFSC) DO NOT UTILIZE- SUBC0mITTES. THIS REQUIRES SUBSTAffflAL MANAGEENT TIE TO EET TECHNICAL SPECIFICATION' REQUIREMENT .THERE WAS A SUBSTANTIAL BACKLOG OF OA/0C FINDINGS THAT REQUIRED RESCLUTION, PARTICULARLY IN TE DESIGN CONTROL ARE 'MANAGEENT INITIATIVE AND INVOLVEMENT WAS EVIDENT IN THE OPERATION OF THE SENIOR PLANNING TEA ,

DETAILED QUALITY CHECKS ON MANY INTERNAL ACTIVITIES APPEARED LACKING. FOR EXAMPLE, THERE WAS LITTLE EVIDENCE OF THE QA ORGANIZATION REVIEWING INTERNAL DOCUMENTS, SUCH AS 10 CFR 50.59 EPORTS REC 0FNENDED LICENSEE ACTION

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THE LICENSEE SHOULD IMPROVE THE TIMELINESS OF RESPONSES TO CCRRECTIVE ACTION REQUESTS AND REDUCE THE BACKLOG T 0T0 CFi NS T L N THE ;

AREA 0F TI E LY RESPONSE ON THE PART OF THE ENGINEERING ORGANIZATION l THE LICENSEE SHOULD INVOLVE QA IN THE REVIEW OF INTERilAL DOCUMENTS, SUCH AS 50.59 REPORTS i l

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'2:00 . .SALP Meeting

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'NRC'SALP Presentation PSC Response introductory Remark .

Del' Hock Maintenance Chuck Fulle : Engineering _ Support Don' Wa rembou'rg :

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Radiological Controls- Frank Novachek x

Closing Remarks NRC/PSC -

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l ASSESSMENTS OF MAINTENANCE ACTIVITIES )

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• SALP/OSTI

• INPO EVALUATION

MAINTENANCE SELF ASSESSMENT (APRIL 1988)

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PERFORMANCE T3ASED QA AUDIT (OCT - DEC 1988)

• MONTHLY QA MONITORING l

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• MAINTENANCE STRENGTHS

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= Positive Attitude of Craft a Talented and. Qualified Individuals a Good Foundation for Program a Good Material / Equipment Condition a Desire to improve

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= Common Understanding of the Need to improve l

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• MAINTENANCE WEAKNESSES l

= Work Outside the Scope of Work Packages  !

a Coordination of Support u Understanding of Documentation Requirements

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a Material Availability i

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Work Outside the Scope of Work Packages i

Assessment:

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• . Quality of work package weak  ;

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• Inappropriate procedure detail

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• Cumbersome process for revising work package

• History of inadequate maintenance support Status:

• Planning and scheduling strengthened, up-front preparation improved -

• Craft feedback established, past work packages reviewed

• Rewrite programs complete, first time use validation

• . Communication of management expectations and increased supervision in the field Staying on Track:

• Increase Central Planning and Scheduling time in field i

e incorporate / enhance craft feedback

• Real time technical writer support

• Validation efforts  !

- * Increase understanding, streamline process l

• Continue management attention l

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i Coordination of Support 1 I

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Assessment:

• Poor communications

• . Inefficient organization

• Lack of centralized responsibility Status:

• Plan of the week meetings

• Plan of the day (P.O.D.) meetings

• Reorganization

• Assigned responsibility to Central Planning and Scheduling Staying on Track:

• Continue efforts e Evaluate success

• Revise as necessary

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Understanding Documentation Requirements ,

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• " Broke / fixed" attitude

• Lack of training ,

• Low expectations

• Related work package / coordination weaknesses Status:

• Increased review

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o Trained all levels e Management expectations redefined a Work package / coordination enhancements Staying on Track:

• Respond to feedback and review  ;

• Maintain management attention l

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.c Material Availability i

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Assessment:

• Needs not identified up front

• Needs not communicated for procurement

• Organizational inefficiencies q

• Lack of consistency in procurement practices Status:

• Planning / engineering coordinated up-front

• Communications centralized through planning and scheduling process

's - Material Management Unit established in reorganization

• Increased use of recurring requisitions

• - Staff trained in requirements Staying on Track:

• Increase management attention

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CONCLUSION

• Significant Progress Has Been Made

• Management Attention Has Been Effective

• Utilize Craft Feedback l

• Self-Monitor Progress

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ENGINEERING TECHNICAL SUPPORT l-

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'OVERALL ASSESSMENT  !

e LICENSEE PERFORMANCE IS CATEGORY 2 WITH A  ;

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DECLINING TREND AREAS OF CONCERN e- PLANT MODIFICATIONS / OUTAGES h

e TCR CONTROL l l

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• - PROCUREMENT / MATERIAL MANAGEMENT

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• O P E R ATIO N S/M AINTE N A N C E/ TESTING /S U RV EI LLA N C E e CONFIGURATION MANAGEMENT i

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Plant Modifications / Outages Assessment:

• CN review process not completely documented

• Control work packages do not include all requirements of the change notice (CN)

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• Technical detail not adequate in some cases

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• Modification / design process was more thorough for tl.e recent circulator outage l

Status:

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• Engineering Nuclear Directive finalized and will be issued with essential elements to improve the quality of the engineering design product

= Modification follow group

= Engineering assurance function

= Pre-construction walkdown l

= As built verification  ;

= Design / operational feedback j Staying on Track:

• Develop "G" procedure to replace Nuclear Directive

• Develop additional engineering supporting procedures

• Continue development / emphasis on engineering assurance function e incorporate feedback as appropriate i

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• Temporary modifications remained in place for several years without conversion to a permanent design status

• Appropriate design reviews not made and documents not revised-I * Extensive licensee action taken Status:

• - All open TCR's evaluated for impact on continued operation and JCO's developed

• All safety' related TCR's requiring permanent status rolled into CN process and closed during circulator outage

• Future control of TCR's identified by SMAP-18 which provides control and elevated management visibility of open TCR's Staying on Track:

• Continued management attention in the implementation of SMAP-18 l

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Procurement / Material Manacjement Assessment:

'* Design engineering involvement in procurement activities not consistent / inadequate level of involvement .l

• Procurement documents do not contain sufficient detail in some !

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• Insufficient material control Status:

• All materials management functions consolidated in the Site Engineering organization

= - Procurement review (new/ replacement)

e Material control (warehousing, issuance)

= Material staging (coordinated with Central Planning and '

Scheduling)

s Consumables

= Spare parts (inventory / control)

Staying on Track:

• Continue development / implementation of centralized material l management program

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• Performance has improved but there are identifiable weaknesses

= More diligence required to assure high quality technical support

= More attention to detail

. Status:

• Systems F .gineering concept in place and developing

• Work priorities / systems control and consequently system design facilitated by system engineers  !

• Design Engineering / Systems Engineering interface facilitated by follow group concept

• Work package development / coordination facilitated by follow group concepts

• Follow-up by Engineering Assurance to provide operational /

maintenance feedback  !

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• Continued management attention in the development / )

implementation of Systems Engineering and Design Engineering  ;

support  !

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Configuration Management Assessment: l

• Design documents need to reflect current design for document users I l

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• . Reorganized and defined Configuration Management program

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= Met with INPO

= Developed draft overall design basis document (DBD)

= Defined scope / content of design basis documents and system ,

walkdown program

• With FSV limited future, the program has been redefined

= Finalize overall DBD based on users needs (meeting scheduled February 8)

= Evaluating reconstitution of safe shutdown cooling system and  !

associated design data base

=- Program to define mechanisms of change is underway focusing j

. primarily on the use of NCR's and SSR's

As Built Verification (ABV) effort

= Have launched (September 1988) a significant dedicated ABV effod i to update design documents

= Thus far the group has processed 123 ABV's,60 CN reissues,54 AR's and 82 NCR's

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Staying on Track:

• Continue management support for redirection in the development of design basis documents

• Continue ABV effort i

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a RADIATION PROTECTION PROGRAM i

SUMMARY OF CONCERNS il

• Respiratory Protection Program I

= Delineation of responsibilities (RAD vs. Non-RAD)

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= Training technical content and instructor expertise

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• Radiation Protection Program Oversight

= Inadequate performance based assessments i

a Evidence of insufficient attention to detail

• Turnover of Experienced Personnel i

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SUMMARY OF ACTIONS UNDERWAY TO RETURN i TO "SALP 1"

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• IMPROVE THE RESPIRATORY PROTECTION PROGRAM l i

• ENHANCE PERFORMANCE BASED ASSESSMENTS

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• ADDRESS HEALTH PHYSICS TECHNICIAN

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EXPERIENCE LEVEL l

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improve the Respiratory Protection Program

• ' Upgrade procedures a Clearly delineate responsibilities .

= Ensure that regulatory requirements are addressed-a Address all available . respiratory protection equipment i at FSV

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• Upgrade Training

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= Improve technical content of training

= Ensure that regulatory requirements are addressed a Improve instructor technical expertise

• Provide early retraining on the enhanced program ,

requirements

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• Place emphasis on integration of Radiation Protection Program into overall organizational activities e improve utilization of QA Monitoring process Address Health Physics Technician Experience Level

• Continue to staff with quality, experienced, Health .

Physics professionals

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ATTACHMENT 3 PRINCIPAL ATTENDEES

'Name Affiliation

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.j R. Martin i NRC - RIV i L.'Rubenstein NRC,-'NRR I L. Callan NRC - RIV

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R. Bangart NRC --RIV l

J. Jaudon NRC - RIV T. Westerman NRC - RIV-K. Heitner NRC - RIV-R. Farrell, NRC - RIV-J. Gilliland NRC - RIV D. Hock PSC H. Brey PSC C. Fuller .PSC P. Tomlinson- PSC

.D. Warembourg PSC R.'Sargent PSC J. Eggebroten PSC F.. Borst' PSC-

.M. Block PSC M. Cappello

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PSC R. Craun- PSC D. Goss PSC M. Holmes PSC  ;

L. McBride PSC i M. Niehoff PSC F. Novachek PSC J. Rees PSC F Rnd;a s PSC L. Scott'- PSC N. Snyder PSC '

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D. Alps PSC P. Anderson PSC P. Burok PSC 0. Clayton PSC

.M. Deniston PSC P. Moore PSC H. O'Hagan PSC ,

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T. Schleiger PSC L. Sutton PSC 0. Williams PSC W. Woodard PSr l

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P.o. Box B40 Denver. CO 80201-0840

February 23, 1989 D.D. HOCK Fort St. Vrain PRESl0ENT i Unit No. 1 P-89068

$hb U. S. Nuclear Regulatory Commission ATTN: Document Control Desk dMi N _ g jggg 4I

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Washington, D.C. 20555 _ . . ~

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_ . _ Docket No. 50-267 SUBJECT: Response to the Systematic Assessment of Licensee Performance (SALP) 87-35 REFERENCE: 1) NRC Letter, Martin to Williams dated -

December 22, 1988 (G-88509)

2) PSC Letter, Williams to Document Control *

Desk, dated January 27, 1989 (P-89024)

Gentlemen:

This letter is in response to the Category 3 rating which was received in the functional area of Maintenance / Surveillance as a result of the Systematic Assessment of Licensee Performance (SALP)

for Fort St. Vrain (FSV) Nuclear Generating Station (Reference 1). l The SALP Board evaluation of performance of FSV was for the period May 1, 1987 through August 31, 198 A meeting was held on January 25, 1989, at FSV, to review the results of the SALP Board Report. All functional areas of the SALP Report were presented and discussed by the NRC at that meeting. PSC presented a verbal response at that meeting to the functional area of Maintenance / Surveillance and to the functional areas of Radiological Controls and Engineering / Technical which had ratings indicating declining performance trends. This letter responds only to the Category 3 Maintenance / Surveillance ratin PSC actions and programs in the other functional areas have been addressed in previous inspection report responses, at previous management meetings, and at the Performance Enhancement Program meeting also held on January 25, i 1989.

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. P-89068 -2- February 23, 1969^

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The foll'owing ' response to the Category 3 Maintenance / Surveillance {

rating is hereby submitted:

GENERAL RESPONSE The full implementation o f' quality activities at FSV, particularly in the functional area of Maintenance / Surveillance, is -an issue of key importance to Public. Service Company of Colorado's (PSC) Nuclear Operations organizatio _

In general, PSC has implemented Maintenance / Surveillance procedure rewrites, training, program changes, and improved communications to enhance performance of its personnel and equipment. We believe considerable progress is being echieve PSC is -committed to using the results of the SALP Board assessment and-the results of other inspections and assessments to continue improvements of Fort St. Vrain's operations. Many of j the assessment issues which resulted in the Category 3 rating in the functional area of Maintenance / Surveillance were recently .;

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addressed in our response to the Operational Safety Team -l Inspection findings (Reference 2). j

SPECIFIC RESPONSES I

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Based on PSC's actions recently undertaken to resolve previously identified maintenance and surveillance concerns, PSC is able to {

address the specific Recommended Licensee Actions of the SALP I Report with programs which are, for the most part, already i established and being implemente k l Recommended Licensee Action: I Conduct comprehensive performance based quality assurance audit Corrective Action To Improve Performance:

Comprehensive Quality Assurance (QA) audits of maintenance have i been performed. Preventive Maintenance was audited in 198 '!

Corrective Maintenance was audited in 1988. The audit program is i supported by QA monitoring of ongoing activitie I Quality Assurance audits, including the 1988 Corrective l Maintenance audit, and monitoring activities use 1 performance-based methods of evaluation. Emphasis will continue i to be placed on these method )

Performance-based methods include direct observation of activities or, if observation is not possible, discussions with personnel involved and review of documents for performance-based I informatio _ _ - _

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SchGdule For fmpicmentation Of Corrective Action:

The Quality Assurance Operations Department conducts biennial .s

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audits of Preventive Maintenance and Corrective Maintenanc Corrective Maintenance was audited in October of 198 Preventive Maintenance will be audited in October of 198 In addition, a Quality Assurance audit is scheduled ~to be-conducted for. Instrumentation and Controls Maintenance in March of 198 Quality Assurance monitoring will continue to place added emphasis on maintenance work activities in the futur . Recommended Licensee Action:

Increase management oversight and technical assessment Corrective Action To Improve performance:

Efforts to enhance the communications of management expectations

'and improve the. coordination of groups which. support the functional area of Maintenance / Surveillance have been implemented. These efforts have enhanced oversight and provided assurance that the expertise needed to provide technical support for maintenance activities is availabl The Nuclear Operations organization was reorganized in mid-198 The reorganization resulted in the redefinition of the responsibilities of the groups which perform maintenance and the groups which suppart maintenance activities at FS New middle management and first line supervision positions were create The positions have been filled with qualified personnel.

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A Systems Engineering Department was establishe System engineers have been assigned to each major system in the plan System engineers are responsible for being aware of selected work activities underway on their respective systems and providing engineering assistance which may be required. A counterpart representative from the Operations Department has also been assigned to each major system in the plan i The foundation for achieving the Nuclear Operations organization's goals and objectives is communication enhancement Nuclear Operations has established communication paths for information flow both up and down organizational line i One communications vehicle is the regularly held staff meetings for personnel at the division, department, unit, and performance levels. These meetings provide effective forums , with the appropriate personnel present, for the identification and resolution of problems associated with plant maintenance as well as other activities.

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P-89068

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The Executive Leadership Team (ELT) was established in May 1987

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to provide specific focus on strategic and broad organizational

,. issues.- ELT -membership includes the Senior Vice President Nuclear Operations, Assistant to the Senior Vice President Nuclear Operations, Manager Nuclear Production Division, Manager Nuclear Licensing and Resource -Management Division, Manager Quality Assurance Division, Manager Nuclear Engineering Division,

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Training Manager and Technical Projects Manager. The ELT meets

'every two weeks or more frequently as necessar The Senior Planning Team (SPT) meets to review plant performance, discuss progress made toward specific milestones' and resolve issues that may impact future performance of the plant. The SPT is comprised of the Senior Vice President's staff, Division Managers, Department Managers and individuals responsible for key activities under way in the plant. The SPT also meets every two weeks alternating with the ELT meeting Two daily plant planning and scheduling meetings have been established to enhance communications and improve .the coordination of groups which support maintenance at FS The first daily meeting is the Plan of the Week (POW) meetin The POW meeting is attended by Nuclear Production Division

' Department Managers, the Nuclear Engineering Division Site Manager, the Site Licensing Supervisor and the QA Services Manager., . The meeting is chaired by the Manager, Nuclear Production Division and Station Manage This . group addresses

" big picture issues," current and planned plant transitions, and

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major. work issues. Activities of the POW meeting are immediately communicated to first line supervision at the following Plan of the Day meetin The Day (prioritization of work activities occur in the Plan of the P0D) meeting. POD meetings are coordinated by the Central Planning and Scheduling Department. The meeting is attended by the following personnel: Central Planning and Scheduling Manager, Superintendent of Operations, Systems Engineering Supervisors, Maintenance Superintendents and Supervisors, Material Management Supervisor, Health Physics Supervisor,  !

Chemistry Supervisor, Nuclear Engineering Supervisor, Maintenance L QC Supervisor, and Site Licensing Supervisor.- The objective of j these meetings is to review the current work activities and those i activities planned to work in a subsequent three day window, l identify and coordinate support activities, and provide briefings on plant status to ensure good communication l l

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'. Issues of the POW and P0D. meetings are communicated to field

' personnel following daily session First line maintenance supervisors have been directed to, increase'the amount of time

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spent'in the field overseeing actual work in progress. Support-developed through the series 'of meetings discussed above is available to first line supervisors for the resolution of any problems which occur in the fiel Planning personnel are assigned the responsibility to follow up on problem areas identified at the P0D meeting and coordinate the assignment of additional resources-as require Schedule For Implementation Of Corrective Action:

Corrective actions have been fully implemented. The Maintenance quality assurance audit indicated that improved communications are helping to resolve long-standing problems. The effectiveness-of the corrective actions noted above are under constant-evaluatio The communications and development of support will be enhanced as necessar . Recommended Licensee Action:

Increase management support for development of a comprehensive preventive maintenance progra {

' Corrective Action To Improve Performance:

A new Preventive Maintenance (PM) Unit was established within the Systems Engineering Department during the recent reorganizatio The new unit was staffed with a supervisor and qualified performance level personne Enhancements were also made to the functional structure of the ,

Instrumentation and Controls (IAC) Department. An I&C supervisor '

was assigned responsibility for I&C PM activitie New administrative procedures have been prepared to formalize the PM program. Regular preventive maintenance activities have been <

defined and integrated into the work schedules established for the plan Schedule For Implementation Of Corrective Action:

Continued development of the PM program is an ongoing process. A good foundation to support the program has been implemente Improvements to the PM program at FSV are currently being

. re-evaluated relative to the recent r<nouncement to end nuclear operations at the plant by June, ILO. PM activities are being redefined to support the planned period of plant operation, defueling/ decommissioning activities, and a possible conversion of the plant to a fossil fueled facilit .

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P-89068 -6- February M , 1989

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> - Recommended Licensee Action:

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. Increase the quality of Maintenance Procedure Corrective Action To Improve Performance:

The subject of procedure adequacy was addressed during the recent Maintenance Self Assessment (MSA) performed using INP0 guideline The MSA was completed in April of 1988. Specific, ongoing actions to address this subject were developed as a result of the MS Actions include: ongoing reviews and procedure enhancements, verification and validation efforts for revised procedures, and development of craft ownership of procedure adequac Major rewrite programs for maintenance procedures were completed in 1988. The majority of the procedures involved in those programs have received a first time use validatio Identified problems are being corrected. Technical writing resources have been redirected from the rewrite prcgrams to "real-time" procedure support. Procedures are now being revised as soon as craft personnel identify working problem At the request of plant management, a review of Procedure Deviation Reports (PDR's) generated relative to maintenance procedures was performed during the recent maintenance a: di The purpose of this review was to determine if the PDR's were valid or if they were generated due to the initial issuance of inadequate procedure The review results indicated that approximately 90% of the PDR's were due to changes in program requirements or program clarifications as opposed to being necessary to correct procedure inadequacie This review

. indicates that procedure rewrite programs have been effectiv A procedure review subcommittee of the Plant Operations Review Committee (PORC) has been partially implemente The subcommittee currently assesses the need, quality, and proper documentation of proposed procedure change Schedule For Implementation Of Corrective Action:

Corrective actions have been implemented. Efforts to improve procedures are ongoing through action plans identified in the Maintenance Self Assessmen . Recommended Licensee Action:

Require compliance with approved procedure Corrective Action To Improve Performance:

Efforts implemented to improve procedure adequacy and provide support for maintenance activities, as previously discussed, will serve to make procedures more workable. Craftsmen will therefore be less likely to deviate from approved procedure I

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Numerous sessions have been held with craftsmen cnd supervisors to' sensitize them to this issue. Some-disciplinary actions have been initiated in accordance with the station progressive

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discipline policy for cases of failure to follow procedure Administrative procedures which govern work activities have been revised to cla rify requirements for procedure complianc Specific training efforts have been undertaken to address this issue and provide assurance that craftsmen are aware of procedure compliance requirement A procedure compliance review group has been established to determine the fundamental causes of incidents involving failure to follow procedure This group is chartered to identify and avoid situations which place craftsmen in positions where they may consider working outside of established procedure Critical complicated work activities are being staffed with additional personne These additional personnel are specifically assigned to read ahead in the procedures and coordinate with the craftsmen to prevent the inadvertent deviation from procedure steps or the misinterpretation of required action Schedule For Implementation Of Corrective Action:

Corrective actions have been implemented in the area of procedural complianc QA inspections and QA monitoring activities, specific to this issue, are conducted on an ongoing basis for key maintenance activities in the plant. The first of several maintenance work control monitoring activities was conducted for the reserve shutdown boron ball removal outage '

which is currently underwa Instances of failure to follow procedures identified in the course of QA inspections and QA monitoring activities are being rectified on a case by case basi . Recommended Licensee Action:

Stop unauthorized or out of scope maintenance wor Corrective Action To Improve Performance:

Efforts implemented to improve procedure adequacy, provide support for maintenance activities, and require compliance with approved procedures, as previously discussed, will also help eliminate this proble The cumbersome process which previously existed for revising procedures and work packages has been improved. Provisions have been made to assist the craftsman in formally revising work scope if necessary or for providing the craftsman the support needed to accomplish the defined work scop ;

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New work packages are now reviewed against completed packages in an effort to eliminate recurring problem The review of

, completed work packages has also been enhance I Revisions to ' administrative controls which provide Quality l Control and Quality Assurance (QA/QC) inspectors with "stop work" authority have been implemented. QA/QC personnel have received specific training on~ the revised procedures and this issu Maintenance personnel have also been instructed with regards to the authority of QA/QC personnel to stop work when appropriat Management expectations regarding unauthorized or out of scope maintenance work have been reinforced to supervisors and performance level personne l Schedule For Implementation Of Corrective Action:

Corrective actions have been implemented to stop unauthorized or out of scope maintenance , activitie . Recommended Licensee Act1oy!:

Provide better review of station service requests to assure identification of plant modifications performed as maintenance

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activitfe Corrective Action To Improve Performance:

Controls established in Administrative Procedure P-7,'" Station Service Request provide multipurpose reviews of station service Processing,("SSR's).

requests Included in the P-7 process are requirements for reviews of Environmental Qualification, failure trending, equipment trending, PM program modification,

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i Nuclear Plant Reliability Data System (NPRDS) deportability, overall package requirements, and SSR trackin Improvements made in coordinating the activities of groups which support maintenance, as previously discussed, have made the established process more effectiv SSR's being worked eacn day are reviewed during the POD meetin Personnel from Nuclear Licensing, Nuclear Engineering and Systems Engineering who attend that meeting are able to determine if the solutions to problems encountered in daily maintenance activities represent actual plant modifications.

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A Techni_ cal Equivalence Assessment (TEA) process is being established at FS The TEA process provides a means to identify and correct 'those maintenance activities involving the replacement of- components / parts / materials which could be considered- to be plant modifications. The. process also provides a means to correct disparities between field conditions and plant documentatio The process includes a series of questions, -

answered by appropriate engineering personnel, which determine if the required work can continue as maintenance work or whether the proposed solutions to parts replacement ~or plant documentation problems require a 10CFR50.59 safety evaluation and an associated design change notic Schedule For Implementation Of Corrective Action:

Corrective actions have been implemente The recent maintenance quality assurance audit indicated that no unauthorized design changes were found in a sample of corrective maintenance work packages which were reviewe The TEA process will be formalized by the issuance of Administrative Procedure G-26, " Technical Equivalence Assessment." G-26 will be issued by April 1, 198 SUMMARY PSC's approach to addressing the issues of the SALP Board Report is to coordinate the SALP assessment with other assessments to enhance and integrate corrective actions which are underwa To further enhance these efforts, PSC intends to draw upon the identified strengths of FSV's maintenance program ' including: the positive attitude of craft personnel, talented and qualified individuals, the good foundation which has been established, the good material / equipment condition of the plant, a desire to improve, and a comon understanding of the need to improv Should you have an further questions, please contact Mr. M. H. Holmes at (303) y480-696

Sincerely,

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D. D. Hock President and Chief Executive Officer DDH:DLW/dje

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l cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westennan, Chief I Projects Section B Mr. Robert Farrell Senior Resident Inspector l Fort St. Vrain I i

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