ML17305A463

Documents Util Revised Policy Governing Use of Procedures at Plant,Per Observation Made by NRC That Util Operators Did Not Refer to Plant Operating Procedures During Performance of Routine & Off Normal Plant Evolutions on Simulator

ML17305A463
Person / Time
Site:	Palo Verde
Issue date:	11/17/1989
From:	Bailey J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17305A462	List: ML17305A463
References
102-01525-JNB, 102-1525-JNB, NUDOCS 9001030064
Download: ML17305A463 (8)

Text

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Arizona Public Service Company'.O.

BOX 53999 ~ PHOENIX. ARIZONA 850?2-3999 102-0>5i? 5rAABZTDS/GEC November 1-74 4389gj) .

JACK N. BAILEY VICE PAESIOENT

~~

NUCLEAR SAFETY AND LICENSING Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission Region V l450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368

Reference:

(a) Letter from R. P. Zimmerman (NRC Region V) to W. F. Conway (APS) dated, September 29, 1989 (b) Telephone conversation between R. P. Zimmerman (NRC Region V) and T. D. Shriver (APS) on November 3, 1989

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket No. STN 50-528 (License No. NPF-41)

STN 50-529 (License No. NPF-51)

STN 50-530 (License No. NPF-74)

'Replacement Examination Report File: 89-002-419 05 89-056-026 The referenced letter documents a concern regarding an observ'ation made by the NRC examiners that some PVNGS operators did not refer to plant operating procedures during performance of some routine and off normal plant evolutions on the simulator during the examination and requests APS review its policy for the use of and reference to procedures. This concern was rei,terated during an NRC/APS Exit meeting held on November 3, 1989, Accordingly, APS has reviewed and is revising its policy governing the use of procedures. The results of the review are provided in the attachment to this letter. This letter is being submitted in accordance with the schedule agreed to during reference (b)

Should you have any questions regarding this response, please contact me.

Very truly yours, JNB/TDS/GEC/kj Attachment 90010"-"00~4 0500052 ADOCYi 1

c o-Ze PDR t-'DC

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Mr. John B. Martin Page 2 cc: R. P. Zimmerman D. F. Kirsch L. F. Miller M. J. Royack T. L. Chan M. J. Davis T. J. Polich A. C. Gehr A. H. Gutterman

ATTACHMENT 1 USE OF PROCEDURES existang guidance governing the use of procedures is contained in PVNGS The Nuclear Administrative and Technical Manual proceduree 40AC-90P02 - 'n

, "Co d uct of This procedure provides management guidance as well as pe a zons.

specific direction regarding the use of procedures. Section 3.3.2 of procedure 4QAC-90P02 states:

Procedure Adherence - Approved written procedures are provided to help ensure safe plant operation. Compliance with procedures is a requirement of station policy.

Section 3.3.2 of 40AC-90P02 also states: k Procedures sh'all be available and may be present when performing the activities which they address.

APS management has reviewed this guidance. anguagee rrequires The langua clarification to ensure there is no misunderstanding with regard to management-expectations. Accordingly, the following actions are being taken:

Administrative Procedure 40AC-90P02 "Conduct of Shift Operations" will be revised. The revision will include:

a. Plant activities are directed by approved, written procedures.

Procedures shall be followed exactly as written.

b. " Procedures that perform operations on safety-related equipment, non-routine operations, extensive or complicated operations, or sequence dependent operations shall be in the possession of the user and followed by the user when being performed.

C. For routine or frequently performed evolutions, procedures shall be out and referred to by the user.

d. The requirement to have procedures out when in use does not preclude qualified operators from taking the appropriate time dependent or emergency actions required to place the plant in a stable or safe condition. After'hese actions have ave been comp l eted een co t d and a stable or safe condition established, the appropriate procedure(s) shall be consulted to verify that all actions were properly accomplished.

2. Training will be developed and provided to all shift crews on the foregoing revision.

Other administrative controls will be reviewed to assure that they are consistent with the principles of revised administrative control procedure 40AC-90P02.

4. An overall policy will be promulgated by the Uice President Nuclear Production addressing management's expectations regarding the use of procedures and procedural compliance.

5. bservers Ob e assigned to evaluate simulator exercisees w'll i eva 1 uate t h e PUNGSS operations o e for both the use of procedures and strict adherence to procedural controls.

PVNGS management recognizes the need to concentrate on communicating its expectations to all employees concerning the use of and adherence to procedural guidance and consistently enforcing those requirements. The corrective actions discussed above are designed to ensure that all em lo ees are aware of these expectations. However, responsibility for compliance with established requirements rests with the individual employee. Therefore, PVNGS management will evaluate the established disciplinary policy and take actions as appropriate to ensure that consistent disciplinary action is taken when procedural noncompliances are identified.

The following implementation schedule has been developed for the corrective actions discussed in this attachment:

Issue a memorandum to all Operations Shift Supervisors and Assistant Shift S S upervisors reiterating management' expectations concerning the use of procedures.

Complete by: Completed. Memorandum issued November 17, 1989 Revise 40AC-90P02 Complete by: December 15, 1989 Develop training Complete by: January 15, 1990 4, Conduct initial on-shift training Complete by: January 30, 1990

. 5. Conduct training during Requalification Cycle Complete by: March 31, 1990

6. Evaluate other administrative controls Complete by: January 15, 1990

7. Promulgate policy Complete by: December 15, 1989

8. Evaluate disciplinary policy Complete. by: January 15, 1990