ML17305A478

Forwards Response to SALP Rept for Period Nov 1988 - Oct 1989.Program Established to Review Infrequently Performed or Important to Safety Tasks Assigned to Licensed Operators.Hot Particle Survey Training Improvements Under Development

ML17305A478
Person / Time
Site:	Palo Verde
Issue date:	12/29/1989
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
161-02728-WFC-G, 161-2728-WFC-G, NUDOCS 9001190371
Download: ML17305A478 (29)

Text

ACCELERATED DISHUBUTION DEMONSTjRATION SYSTEM I

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ih REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) ii ACCESSION'BRo9001190371 DOC DATEo 89/12/29

~ NOTARIZED: NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 I

t'~W STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529

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STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION CONWAY;W.F. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME 'ECIPIENT AFFILIATION MARTIN,J.B. Re'gion 5, Ofc of the Director P,

SUBJECT:

Forwards response to SALP rept for period Nov 1988 Oct 1989.

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DISTRIBUTION CODE: IE40D COPIES RECEIVED:LTR l ENCL / SIZE:

'- ht TITLE: Systematic Assessment of Licensee Performance (SALP) Report C

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\ NOTES: 05000528 Standardized plant. 05000529 i

Standardized plant. 05000530 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5,PD 1 1 CHAN,T 1 1 DAVIS,M. 1 1 PETERSON,S. 1 1 INTERNAL: ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 COMMISSION 5 5 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 1 1 i

NRR/DOEA/OEAB11 1 1 'RR/DREP/PEPB9D 1 1

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NRR/DREP/PRPB11 1 1 NRR/DRIS/RSGB9D 2 2 NRR/DRIS/RSIB9A 1 1 NRR/PMAS/ILRB12 1 1 Ph 8~

NUDOCS-ABSTRACT 1 1 OE-DIR 1 1 OGC/HDS1 1 1 REG F 02 1 1 hg RGN5 FILE 01 1 1 t

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EXTERNAL: L ST LOBBY WARD 1 1 LPDR 1 1

-'i NRC PDR 1 1 NSIC 1 1 NOTES: 1 C

NOTE TO ALL "RIDS" RECIPIENIS:

P~ HELP US TO REDUCE WASTEI CONTACI'HE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME PROM DISIRIBUTION ~

TOTAL NUMBER OF COPIES REQUIRED: LTTR 35 ENCL 34

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Arizona Pub1ic Sermce Company P.O. BOX 53999 ~ PHOENIX. ARIZONA 85072-8999 WILLIAMF. CONWAY EXECVTIVEVICEPAESIDENT 161-opp8$ Fggs l[j '.

pL NUCI.EAII Docket Nos. STN 50-528/529/530 Mr. J. B. Martin Region V, Regional Administrator U. S. Nuclear Regulatory Commission 1'450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368

References:

(1) Letter from Mr. J. B. Martin, NRC, to Mr. W. F. Conway, ANPP, dated November 22, 1989,

Subject:

Systematic Assessment of Licensee Performance (2) Maintenance Team Inspection Report

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Response to the Systematic Assessment of Licensee Performance (SALP) Report File: 89-056-026 As requested by Reference 1, the attachment to this letter is the response of Arizona Public Service Company (APS) to the Systematic Assessment of Licensee Performance (SALP) Report for the period November 1, 1988, to October 31, 1989. The Attachment describes the steps which have been taken to improve perfoimance in the three functional areas assessed by the SALP Board as Category 3 as well as the other functional areas assessed by the SALP Board. It also provides the APS response to the programmatic issues identified by Reference 2.

We ar'e encouraged by the statement in NRC's cover letter, noting the overall improvement in performance over the last six months of the SALP period and your suggestion that this improvement can continue, "assuming that senior management successfully implements the various corrective action programs and initiatives laid out during this SALP period."

One of our top priorities over the past year has been to add personnel experienced in nuclear power into key management and staff positions. We have been generally successful in achieving that goal. During the last SALP period, in addition to myself, we 9001190371 S912"-'9 PDZ ADaCV, 0S0OOS-"e p8c

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'F ll' Mr. J. B. Martin 161-02728-WFC/GS U. S. Nuclear Regulatory Commission December 29 1989

'I Page 2 were able to hire experienced personnel with records of successful

.51 performance in the nuclear industry to President, Nuclear Production; Vice fillthe positions of: Vice President, Nuclear Safety and Licensing; Plant Director; Director of Quality Assurance; Director of Site Services; Plant. Manager for Unit 2 and Assistant Plant Managers for all three units; Relief Plant Manager; Manager of

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Training; and Radiation Protection and Chemistry Manager. The Attachment to. this letter identifies additional staffing enhancements at other levels in the A'NPP organization, particularly in the Quality Assurance department. These additions include a number of new positions which were created during the SALP period in order to increase the level of management attention and supervision of plant activities.

Although the management team is now largely in place with only a few key positions, such as the permanent Director of Standards and Technical Support position yet to be filled, APS is continuing to reassess the adequacy of staffing for each of the various plant

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staff functions and the appropriateness of current organizational arrangements.

l As I mentioned during our meeting on December 1, in discussing Operations, one of our principal objectives in the year ahead will be to assure, through improved supervision, critical self-assessment and especially enhanced training, that operations are conducted at all units in a formal, conservative manner to.ensure

'A lg that no one proceeds in the face of uncertainty.

The Attachment to this letter also identifies a number of programmatic changes initiated during the SALP period including p

( several with the primary objectives of improving the process of identifying problems and assuring their timely correction. A revised Incident Investigation Program (IIP) was implemented in March which resulted in more formal, better controlled event

'1 investigations. The revised IIP has facilitated the identification of the root causes of events. Corrective action specification and

'l assignment is covered through the newly implemented Quality Deficiency Reporting System. Root cause identification has also been improved through special training and the use of the Human Vl Performance Evaluation System (HPES) and the Management Oversight

)i and Risk Tree (MORT) techniques. ' new Material Nonconformance Report system was implemented in October 1989 to assure that deficiencies in plant equipment are separately identified, assigned the proper priority for correction and tracked to completion.

Improvements have also been made to the 'program for analyzing trends in the identification 'of plant problems. The revised

.t program, which was implemented in October 1989, utilizes information from various problem identification programs, including Failure Data Trending, as well as NRC and INPO identified concerns.

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i Identified adverse trends are documented through the Corrective Action Report system to assure appropriate management attention and

,) timely. correction. The Employee Hotline program was also revised in September 1989 to enhance management understanding of, and C'.

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response to, employee concerns.

To improve the timeliness of corrective action, improvements are being made to the Commitment Action Tracking System (CATS) and the V

tracking of corrective action by the Quality Assurance Department.

Implementation of the action plan for the coordination and effectiveness of oversight groups is well underway, and management is devoting significant attention to reduction of backlogs and assuring timely completion of required actions. Clear expectations have been issued for timely completion of work assignments

>>i I (including EERs, CARs, IIRs, and PMs), and for reducing backlogs to acceptable levels. Implementation of these guidelines is receiving increased attention from management up to, and including

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I myself .

The Attachment to this letter also describes a number of other I

programs that have been initiated to improve performance at Palo Verde'. APS management now faces the challenge of managing these new programs, and integrating them into a coherent system for maintaining and operating the plant. Frequent meetings between I

managers and special committees are being used to assure common understanding and proper coordination. There are regularly

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scheduled meetings between managers of the System Engineering and Nuclear Engineering groups; between Work Control, Maintenance, and

~ 'i among the senior managers and officers; and at various 'ngineering; II

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>~I other inter-department and intra-department levels.

$ One example of the effectiveness of such meetings is the Management Review Committee that has been providing an added level of

,i management oversight during the preparations to restart Unit 3.

This. Committee has proven to be effective in assuring that Unit 3

i restart, activities are properly controlled and performed in a I'I conservative, formal manner. Perhaps just as important, however,

>C il has been the added understanding each participant in the Committee has gained of the roles of the various programs and personnel in I

the safe operation of Unit 3, and of the plant.

As we discussed at the meeting on December 1, 1989, and as noted I>

in the SALP Report, there has been some noticeable improvement in

~I performance at Palo Verde in the last few months, but it will require a determined effort from APS management and the Palo Verde

~, staff to assure that progress continues. APS is committed to A devoting that effort and to periodic assessment of the

'I effectiveness of its programs. We will provide strong management

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,'J Mr. J. B; Martin 161-02728-WFC/GS U. S. Nuclear Regulatory Commission December 29, 1989

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'J:1 support and direct management observation of plant activities to I+ assure that any needed corrections are identified and made on a I timely basis.

If you have any questions, please contact me.

Sincerely, V

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WFC/WFQ/GS/jle LJ Attachment g.'!

'I'j CC A. H. Gutterman

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A. C. Gehr T. J. Polich G. W. Knighton T. L. Chan M. J. Davis 1

ATTACHMENT Res onse to the S stematic Assessment of Licensee Performance SALP Re ort Ao PLANT OPERATIONS V

The Systematic Assessment of Licensee Performance (SALP) l during this period resulted in the assessment of performance in the Plant Operations area as a Category 2. This is a marginal improvement from the assessment of performance in thi's area during the prior SALP period which was rated as a Category 3 improving. The SALP Board noted that increasing management experience and staffing are considered positive accomplishments,. however the ability of the new management team to improve plant operations has not yet been fully demonstrated. Additionally, the SALP Board noted there was a reduction of significant events directly attributable to the operations department.

The SALP Board recommendations, in the Plant Operations area are the following:

Licensee should strive to ensure that all operations, especially valve and system manipulations, are conducted .in a formal, conservative manner at all units.

Licensee management should continue actions initiated to assure that'. there is both sufficient management staffing and appropriate management involvement in problem evaluations and resolution.

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Priority attention should be given to conducting

(: thorough evaluations of problems and establishing a working atmosphere which encourages thoughtful, critical assessments of all phases of plant operation.

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Management's response to these recommendations has included

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major changes in staffing and leadership. A new Executive

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Vice President-Nuclear and a new Vice President-Nuclear "I

Production have been appointed. In the operations area new management positions created during this SALP period were Jl filled with experienced personnel, including the Plant

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5 Director, relief Plant Manager and Assistant Plant Managers hired for each unit. In addition, two new Plant Managers were appointed and new operations supervisor positions were created. These changes as well as others were initiated to achieve the following objectives which address a number of concerns and recommendations in the SALP Report:.

qC Tg Raise standards and expectations for involvement and direct observation of activities to ensure that C~

management expectations are understood and met at all levels of the site organization; that operations

+I are conducted in a conservative, formal manner; and that problems are promptly addressed.

,i Raise standards and expectations for management involvement to ensure that priority attention is given to conducting thorough evaluations of problems

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and that. a working environment is maintained which

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encourages .critical assessment of all phases of

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Allow improvement and greater management attention to training.

achieve these desired goals o>e of the top priorities over

,,e To the past year has been to inject new personnel experienced in

}~ nuclear power into key positions. They have brought both

~ t experience and.enthusiasm to their new jobs. The principal task now is to forge them into an effective team.

The approach to the restart of Unit 3, for example, has

, 1 required an interactive blending of the skills and diverse

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'experience of many of these new team members working as a unit

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in our Management Review Committee.

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A number of management changes in operations has significantly

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increased the experience level of the staff and enhanced their ability to participate in the evaluation and resolution of problems. There is also an increased level of management involvement in operations as well as more direct observation of work activities. A management observation program was implemented in'uly to increase management and supervisory direct observation of plant activities.

A program has been established to review infrequently performed or important to safety tasks assigned to licensed operators. Initial review of the task list and training materials was completed by General Physics Corporation and a licensed operator. The immediate training actions identified are being accomplished by the responsible training section and plant department. The changes to existing task lists and the.

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.~ training recommendations to incorporate the results of this I~

b) review are underway. Non-licensed operator training has been

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enhanced by videotape presentations on watchstanding technique and principles. Supervision is required to monitor and verify proper performance of each operator. To address =the need to

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achieve greater ownership and involvement by operators in

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,1 I training, an experienced Senior Reactor Operator has been assigned in each unit as training coordinator. Four Senior

<<I Reactor Operators have been transferred to the Training Depar'tment and two Reactor Operators have been transferred to

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~i the simulator I upgrade program. Management has also established an integrated schedule to enhance the prompt "1 completion of the simulator upgrade program. A configuration management procedure has been implemented, along with the I

r purchase of hardware and software to support it. For the period until the upgraded simulator is available for training, improved procedures have been established to assure adequate training of operators.

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To address the concern that the Emergency Operating Procedures (EOPs) were usable but, were overly complex and were poorly (g

written from a human engineering point of view, a program has been established to develop and implement a process for maintaining high quality EOPs. This program identifies and implements the procedures necessary to upgrade and maintain high quality EOPs and supporting administrative control procedures using human engineering techniques and a multidisciplined review.

written procedures are provided to help ensure safe plant operation. Compliance with procedures is a requirement

,I'pproved

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of station policy. The Plant Director has communicated management's expectations on standards for personnel 11

'I performance directly .to Shift Supervisors. Additionally, disciplinary actions will be (and have been) taken for failure

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to comply with approved written procedures. Self verification techniques have been added into Conduct of Shift Operations procedures.

'he fire protection program is being reviewed by an independent contractor to help in preparing a job functions vs. skill matrix to improve performance in this area. A task force of five engineers was established to expedite closeout of inadequate fire door design, and a corrective action plan has been developed to address identified concerns.

BE RADIOLOGICAL CONTROLS The assessment of performance in the area of Radiological Controls improved to Category 2 in the last SALP period from Category 3 during the preceding period. The SALP Board

'recommendations in the Radiological Controls area are:

Need for continued improvement in this area.

The licensee needs to be aggressive in maintaining radiation monitoring equipment, instrumentation, and practices for chemistry control and analysis.

APS Management should take a more pro-active role in assuring that basic occupational radiation protection measures are accomplished.

APS will continue to develop and implement the processes necessary to maintain a strong Radiation Protection (RP)

Program. Intended are efforts to continue to improve both program performance and the performance of the radiological worker. APS believes that to be successful the RP program must be everyone s responsibility. The Advanced Radiation Work Practices (RWP) Training undertaken during 1989 for

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worker requalification and greater efforts towards more realistic goal establishment help demonstrate this. During 1989, Radiation Protection (RP) goals were developed not just for the individual Unit, but for the various discipline work groups and for the planned outages. While much of the goal development and measurement was difficult during the first year, the effort was instructional, and facilitates an improved goal setting process for 1990.

The RP organization has undertaken the development of a new "RP Manual," which will 'include revised RP procedures as 41

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recommended by the overall assessment of the RP program which was completed at the beginning of the current SALP review period. This manual is projected to be completed by the end 7

of 1991.

Organizational changes for the Radiation Protection,

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Radioactive Waste, and Chemistry Groups are presently in the final stages of review and approval by APS senior management.

The Chemistry and Effluents responsibilities will be under the Site Chemistry Operations Division. The Chemistry Operations Division will feature a Radiation Monitoring Group to act as a focal point for technical resolution of radiation monitoring

'I system issues. The Site Radiation Protection Operations I'1 Division will feature centralized authority for the direction I

'I of site RP and Radioactive Waste Departments under the Site RPM, directly reporting to the Vice President, Nuclear 4

Production. Both organizational changes will include significant additional resources to support continued improvements in performance.

Several examples were identified by the SALP Board in which corrective actions were sometimes delayed and may not be effective in correcting the root cause of the problem, as

indicated by occasional event repetition and events which indicated' need for more pro-active management involvement.

Discussions concerning these examples are provided in the following paragraphs.

The aspect of resolving our own problems in a timely and complete manner is one of our highest priorities. Efforts in this regard will continue to improve as the more centralized organizational changes take final form. This is evidenced by recent efforts to comprehensively address Locked High Radiation. Area access violations.

Intrusion of sodium into the condensate polishing demineralizer effluent in Unit 1 was resolved through the dedication of a multi-discipline task group to investigate the source of'the problems from both a technical and human factors perspective. This effort identified numerous maintenance and design issues with respect to in-line instrumentation, as well as operational problems, and was successful in resolving a chronic problem.

Efforts to reduce skin/clothing contamination event, frequency continue to be pursued. The efforts have been focused under a "Quality Circle" Task Team specifically chartered to investigate means to reduce contamination event frequency.

The team is composed of individuals from the Unit and the RP Standards organizations. Similar efforts by a "Quality Circle" Task Team have been initiated to reduce the radioactive waste volume.

Improvements in Hot Particle Survey Training are under development for implementation in Unit 2 prior to its upcoming outage. This training will be given to the balance of the RP Technicians, as well. More detailed gridded survey techniques

are also being formalized, as well as the review and assessment of job TLD/SID data. Industry Events Training is being expanded to ensure contract RP technician awareness of significant operating events.

The site exposure for the recent SALP reporting period, while not entirely within established goals, did demonstrate

'improvements over past performance. Pending improvements in ALARA outage planning, job control, and job history are expected to further improve APS performance in this regard.

PVNGS is a "young" facility, and recognizes the need to make every effort to reduce the sources of exposure from the onset.

Efforts are underway to begin a cobalt reduction program and the efforts to maximize dose reduction based upon past work history continue to be refined. Centralized job history files are being developed for the site, and extensive job video libraries are being established.

Difficulties encountered in the Unit 1 steam generator eddy current testing and tube plugging activities did have a major effect on the jobs ALARA goals, and were significant contributors in not meeting the Unit's outage exposure goal.

Lessons learned from the Unit 1 refueling outage will be applied to future refueling outages to prevent recurring problems.

Weaknesses in the Instrument Calibration Facility personnel training have been resolved in the near-term by use of offsite training programs, and is being permanently resolved by the development of required onsite training programs in accordance with approved Training Program Descriptions.

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<l The Radiation Monitoring (RM) Group will coordinate the surveillance and maintenance of Radiation Monitoring Systems, including coordinating upgrades of calibration and functional test procedures, interfacing with maintenance unit leads and work control personnel for prioritizing or expediting system work, and interfacing with system engineers on reliability and improvement issues. The RM Group will also supervise the operation of systems and programs through the Unit RM leads and technicians.

A detailed review of the 'content and implementation of the Laboratory Analytical Control Program (LAC) has been completed. The review considered applicable industry and regulatory guidance. Significant procedural changes have been accomplished to include an expanded scope "blind analysis" process. A LAC coordination group, comprised of members from the Units'hemistry and Chemistry Standards organization, has been established to provide recommendations for corrective actions for identified deficiencies. Improvements in LAC performance have been demonstrated as a result of these efforts.

Site RP and Chemistry management involvement in daily activities and program development is one of the salient features of the pending RP and Chemistry reorganizations.

I More accessible management, with senior management more

'V available to interface with the performance personnel is one of the key elements that is expected to continue to improve the radiological controls enforcement history.

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C~ MAINTENANCE SURVEILLANCE The SALP Board assessed the performance in Maintenance and

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Surveillance as a Category 3. The previous SALP rating in this area was a Category 2. The SALP Board recommendations in the Maintenance/Surveillance areas are as follows:

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Management should strive to ensure work control

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, i instructions are clear and complete.

41 Maintenance craft should ensure they follow procedures and request management and engineering gS

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assistance when problems are encountered.

Planner Coordinators should be more aggressive in enlisting the system engineer support in the correction of non-routine equipment. problems.

Management should increase efforts to observe ongoing work and provide corrective feedback into the maintenance program.

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The fundamental concerns from the Maintenance Team Inspection (MTI) are also addressed in this section. MTI concerns were inadequate problem resolution, inadequate work planning, and inadequate attention to detail in work implementation. An additional concern from the MTI regarding the system engineers is addressed in Section F (Engineering/Technical Support) of C this report.

'F A Model/Blanket Work Order Instruction Program is being developed to enhance the transfer of lessons learned and to create a standard set of work instructions. This program CA should enable work instructions to be more clear and complete.

'll l~.i As the foundation of Model/Blanket Work Instructions expands, 10

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a substantial reduction in the time required for planning and J' development of corrective maintenance work order packages

'1 should be realized. Standardization of work methods and preapproval of work packages will allow more efficient and r>

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>t consistent work packages. Approximately 475 Model/Blanket Work Orders are being developed.

S A 12-Week Integrated Schedule has been developed and is being implemented in Unit 2. Its effectiveness is currently being evaluated. Similar schedules will be implemented in Units 1 and 3, 90 days after completion of their respective refueling outages. Implementation of a 12-Week Integrated Schedule is expected to establish work schedules, reduce safety system outages and provide better management of backlogged items.

Work groups and support groups will use the integrated tj schedule to coordinate resources in support of the scheduled

'r work. The schedule will be used by Materials Management to help ensure availability of parts and by Engineering to C

prioritize their work.

The Planner/Scheduler Training Program has been initiated to provide Planner/Schedulers more expertise and skills in the development of work packages. The classes will also enhance the planner/scheduler's knowledge of equipment and plant operation resulting in more technically consistent work packages. APS is currently in the process of systematically evaluating training effectiveness and its relationship to job performance to ensure planner/scheduler training is fully and effectively implemented.

Instructions concerning the proper use of controlled documents and adherence to procedures were given to maintenance personnel in the form of documented briefings by each maintenance manager emphasizing the importance of attention

'o detail during work performance.

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Written performance standards were provided to APS Nuclear V

personnel and a policy statement was issued to employees which defines the mission of the organization, responsibility, accountability, voicing of concerns to management, and

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maintaining a questioning attitude during the execution of activities.

Weekly management meetings have been initiated between Work

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Control, Maintenance, and Engineering to develop consistency "I

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in methods, processes, and communications relating to unit

'I interaction with Engineering concerning work planning and maintenance activities. These meetings will encourage

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enhancement of engineering support for maintenance activities.

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Root cause of failure training is being developed for maintenance craft personnel and is planned to be implemented in the third quarter of 1990. This course will be focused C toward the practical aspects of root cause analyses and will include case, studies. It will also cover the mechanical, electrical and instrument. and control areas and will be centered on the recognition of the importance of as-found conditions and basic analyses techniques.

The Management Observation Program, which requires managers to perform documented field observation using an observation checklist, has been implemented. The observation checklist contains specific items for verification of adherence to work instructions and serves as a mechanism to provide corrective feedback to maintenance management.

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The SALP report states that APS intends to establish a basis

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file for all maintenance tasks. Clarification of this statement is as follows:

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At the September 12, 1989 meeting APS stated its intention to establish a basis file for preventive maintenance tasks. Currently the scope of this program is under evaluation.

ri D. EMERGENCY PREPAREDNESS i,4 Tpe SALP Board assessment: of performance in the functional l

C area of Emergency Preparedness (EP) resulted in a rating of

,1 2 with a determination of improving performance near the close

?v' of the assessment period. The rating was 2 in the previous assessment period. The SALP Board made the following

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recommendations in this area:

The licensee needs to continue management. support

. I of the EP Program to assure the program continues

(('I to improve. The Board recommended active I(,

involvement by the new members of the new management I team. In addition, the Board recommends licensee ll management attention to accomplishment of corrective actions in a timely manner.

APS intends to ensure continued improvement in the Emergency Preparedness Program. Most new members of the management team, and new management members of the unit operations teams, have been assigned emergency response organization positions.

With the appointment of the new Director, Site Services, increased management'. attention has been directed toward accomplishing corrective actions in a timely manner.

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I The Emergency Planning Department has realized improvements in several areas during the assessment period.

, The effectiveness of the offsite Field Monitoring Teams was l

enhanced by new (replacement) dedicated vehicles and the implementation of a geographical orientation system for use by the Field Monitoring Team members. In addition, radio channel 4 was dedicated for emergency communication (during events) outside the units and the channel 4 base station was converted to a repeater to improve radio communications within the 10-mile Plume Exposure Pathway Emergency Planning Zone.

Upgraded personal computers (PCs), used for dose projection, replaced the previous PCs to allow more rapid dose projection calculations. Uninterruptible power supplies were added for PCs in Units 1, 2, and 3 that are used to perform initial dose assessments. Card readers were added in the Operations Support Center in each unit and in the Technical Support Center to expedite personnel accountability. A program of quarterly job performance measures was initiated for radiation protection technicians in each unit who would potentially be involved in performing manual dose projections. The Corporate Emergency Center (CEC) was relocated to the new APS Corporate Headquarters Building in Phoenix, and incorporated into this move were enhancements to the CEC (e.g., additional telephone lines, upgraded equipment) to enhance the operation of this facility. New (replacement) telecopy machines were added in the emergency response facilities to upgrade performance in this area of data transmission. These improvements further

'I demonstrate management support of the Emergency Preparedness Program at PVNGS.

Emergency plan training has been provided to Water Reclamation Facility .(WRF) employees not normally given Site Access Training (SAT).

14

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,I Two vacancies existed in the Emergency Planning Department early in the assessment period. One of these vacancies was filled. In addition, one vacancy occurred in mid-1989.

Efforts to staff'hese two positions have focused on obtaining 5,'J personnel with specific qualifications to enhance overall department quality. Staffing of Emergency Planning Department

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positions continues to be a high priority and is the subject of continuing management attention.

To clarify an apparent error in the SALP Report, the following

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C is offered. As stated 'n Section D.l, "There were no violations of NRC requirements observed in the areas of emergency preparedness during this SALP period." Table 2, however, identifies violations arising from Report Number 88-39 in Unit 2 and 88-38 in Unit 3 attributed to emergency preparedness. This information is further carried forward to 1

Table 1 where Units 2 and 3 are each shown to have received one Severity Level.IV violation. Inspection Report Nos. 50-528/88-40, 50-529/88-39, and 50-530/88-38, dated December 2, 1988, in which this violation is reported, was an Inspection of Environmental Protection and, as such, the cited violations should .not properly be attributed to Emergency Preparedness.

ED SECURITY

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The SALP Board assessment of performance in the functional area of Security resulted in a rating of 2. The rating was 2 in the previous assessment period. The SALP Board made the following recommendations in this area:

Licensee management is encouraged to expeditiously

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i, complete their review of CCTV camera coverage and illumination necessary for adequate protected area 15

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barrier alarm assessment and to limit overtime effects on guard alertness, to include expediting the expanded implementation of their planned security training program.

The engineering review of closed circuit television (CCTV) camera coverage and illumination necessary for an adequate protected area barrier alarm assessment has been completed and a program of modifications to resolve this concern is under

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development.

A pool of contract security personnel have been trained and assigned to security operations. This is expected to result in significantly reduc'ed security personnel overtime.

Additional security personnel have been assigned during construction of the operations support buildings to minimize the impact of construction on the normal security force.

Additional contract security personnel have been included in the 1990 budget to provide increased security operations, personnel for compensatory posts. and other security assignments as needed. Zn . addition, compensatory post rotation schedules have been standardized with the objective of reducing the fatigue factor associated with these assignments.

The review of the Security Maintenance Program and procedures has been completed. The need for additional procedures was identified during this review. A program of modifications to existing procedures and generation of new procedures is underway.

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4,3 The adequacy of past corrective actions for a licensee-

' identified problem related to the security access control J

computer has been evaluated. As a result, additional corrective actions have been implemented by a software change 1 intended to eliminate the potential for. human error.

14"5 The engineering evaluation of roll-up doors serving as vital area barriers has been completed and the . recommended modification to the doors has been implemented on two of the units. This effort will be completed following the completion of fuel movement in Unit 1.

Engineering has developed camera quality standards to address the concern for image quality of closed circuit television cameras and these are in the process of being incorporated I~

into the appropriate security procedure. An engineering l'

evaluation of the vulnerabilities of the personnel access hatches to containment has been performed and is presently 4'g being reviewed.

'4' Numerous plant security system computer changes have been implemented during the assessment, period to enhance reliability and facilitate report availability and timely alarm assessment. Modifications were made in the keycard system to reduce nuisance alarms. Postings and procedure changes have been implemented to alert plant personnel who are performing modifications to protected/vital area barriers to notify Security prior to the start of work.

Frequent meetings between the new Director; Site Services and Security Department representatives, as well as additional Security Department management presence in the field, highlight management support of the Security program to encourage continued program improvement.

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F~ ENGINEERING TECHNICAL SUPPORT The SALP Board assessed the performance in the Engineering/

Technical Support area as Category 3. Its recommendations in this area were:

Define the scope of the system engineer responsibilities and provide the. system engineers with clearly defined and prioritized tasks focused on ensuring the reliable operation of their systems.

Permanently fillthe position of Director, Standards and Technical Support.

Continue the emphasi's being placed on reacting conservatively, deliberately, and comprehensively to plant engineering problems.

The types of problems that initiated these recommendations were also noted in the Maintenance Team Inspection Report.

APS has recognized that these areas are ones in which improvement. is needed and currently has several ongoing programs to upgrade the standard of performance of both the Nuclear Engineering and Engineering Evaluation Departments.

specific actions taken to address the Board's recommendations and to correct the programmatic deficiencies identified in the Maintenance Team Inspection Report are described below.

One of the most important issues raised by the SALP Board is the lack of focus . by the system engineers. . Their responsibilities have been concluded to be too broad to allow a clear prioritization of tasks. System engineering 18

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management has undertaken positive action to correct this condition by redefining the engineer s role in modification, procurement, and maintenance activities. This redefinition will reduce the administrative burden on the system engineers and allow the necessary time for overview of system performance and comprehensive followup on corrective action on system problems. System engineering management is conducting regular meetings with the unit management staff to assure plant technical problems are being thoroughly addressed and the system engineers are being involved in only those areas which require their attention. This is intended to eliminate unnecessary requests for system engineering assistance and ensure system engineering involvement when necessary in plant technical problems. These actions result in the system engineers focusing on plant performance and problems and allows management to hold the system engineers accountable for the performance of their assigned systems.

A System Engineering Program is expected to be drafted by February 1990 and finalized by May 1990 with key actions in progress at that time. The program will include measures necessary for implementation of the system engineer "program document" as well as other action needed to assure its long-term success.

APS is actively recruiting a Director, Standards and Technical Support. Candidate interviews are currently being conducted and it is anticipated that a permanent Director will be retained during the first quarter of 1990. This will further assist in the development of the System Engineer Program by providing continuity in management goals and expectations.

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The Nuclear Engineering Department is increasing its involvement in, plant problems. Nuclear Engineering management has set the standards and expectations including:

The recognition that plant problems are Nuclear Engineering's problems.

The need to provide whatever support is required to comprehensively address plant engineering issues.

The need for Nuclear Engineering to be pro-active and intrusive with respect to all plant engineering issues.

Activities 'in progress to provide more involvement include Engineering interface meetings with the site engineering groups at all,management levels and the re-establishment of the Resident Engineering group located at the site to provide design support for site activities.

Noted by the SALP Board were several good examples of thorough technical work observed late in the reporting period. This improvement in performance is a result of the programs previously (or currently) in place and our expectation is that continued improvements in the Engineering and Technical Support area will be realized.

Go SAFETY ASSESSMENT UALITY VERIFICATION The SALP Board assessed a performance rating of Category 3 areas.'0 Improving Trend in the Safety Assessment/Quality Verification

The SALP Board recommendations in the Safety Assessment/Quality Verification area are the foll'owing:

Licensee management should continue to demand aggressive and technical].y competent reviews by the QA and oversight organizations.

Strong management support and insistence in the thorough implementation of changes to the QA program, such as the new nonconforming condition reporting and corrective action procedures and the new corrective action request procedure is encouraged to assure effective confirmation, of corrective actions that have commenced.

Further strengthening of the root cause analysis program should be performed to provide greater depth II and scope and in turn result in more meaningful corrective actions.

h The root cause analysis process underwent a major revision in

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~ early 1989, and resulted in improvements as pointed out by the I

SALP Board. However, we recognize that additional 11 improvements in the process are necessary, as indicated by the examples noted by the SALP Board, and will continue to seek ways to make this process most effective.

During the assessment period APS has emphasized the need for ihI improvement in the Safety Assessment/Quality Verification I~

4 Functional Areas. Management recognized early in the SALP period that several weaknesses existed and that significant

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attention was warranted.

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To support thorough implementation of changes to the QA program, over 200 man-years of technical experience in the areas of Engineering, Licensed Reactor Operations, Operations QA, and Health Physics have been added to the QA organization.

Significant management changes have been made to better focus QA activities and to assure that QA/QC is a major contributor to improving our performance at PVNGS.. We will continue to staff our QA organization with a high level of technically experienced personnel. A permanent Deputy Director-QA is being actively recruited and we expect to resolve this viewed weakness in the very near future. This will allow APS to eliminate several temporary assignments.

The objective of APS is to assure that the QA organization has the proper focus, is significantly critical and aggressive in its activities, and is capable to detect problems before they become self evident. APS agrees with SALP Board's conclusion that progress was made towards meeting these objectives during the last half of the SALP period. APS will continue. the initiatives and efforts that have been developed to improve performance in this .area and APS fully expects to see continued improvement throughout the next SALP period.

AFS has recognized that although the Nuclear Safety Group (NSG) and the Independent Safety Engineering Group (ISE) had provided assessments of various Palo Verde areas, those recommendations had not been effective in accomplishing change, particularly during the first half of the SALP assessment period. As a result, senior APS management has placed additional emphasis on the roles, importance and effectiveness of these oversight groups, and on the necessity for line management to respond promptly to their concerns and recommendations.

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In addition, APS intends to implement a Safety Committee, to include outside industry experts. Their reviews will focus on nuclear safety with emphasis on using the work product from r

ISE and NSG. This group is expected to first meet during the p first quarter of 1990.

jc During the SALP assessment period, senior management directed

',I a contractor to complete an independent self-assessment of rP these oversight groups (QA, NSG, ISE and PRB), which resulted in program changes in the second half of the assessment period to clarify their respective charters and improve coordination.

As a result, the oversight groups developed and implemented a layered oversight procedure and increased interaction by conducting formal meetings as a Project Self Assessment Group (PSAG); The Nuclear Safety Group (NSG) has been given clear responsibility for annual programmatic reviews of the effectiveness of the Plant Review Board, Independent Safety Engineering (ISE), Quality Assurance, Operating Experience Program and Safety Review Program (10 CFR 50.59 reviews). The if shift from individual technical reviews to programmatic review

'5 by NSG is further promoted by the implementation of the Project Self Assessment Group (PSAG) to both coordinate the

,P activities of the oversight groups, as well as ensure that I

they are conducting appropriate activities. APS intends to r ~

increase staffing of NSG during the coming year.

In order to increase the effectiveness of the Plant Review Board (PRB) with regard to safety oversight, the makeup and

'n function of the PRB is being modified and will be transmitted 55

'I via a Technical Specification change. The effectiveness of

'i r5 these changes will be carefully monitored.

23

0,,"l'>>g,, %.4 6 ~ J \, b ' 'Apl.k 4 1- ') ~ I C ~ ~ l l pdl( 6 ~ b 8 1'4 w (~ 4'>> eel A%A J h:NPLV. t4 pC During the second half of the SALP assessment period, the ISE procedures underwent substantive changes in order to improve performance. In addition, a formal tracking system has been established to track ISE concerns and recommendations. This r~

system provides 'scheduled response times, completion dates and an escalation process for ISE assigned actions. New

'C procedures have been developed to give direction and I guidelines on ISE field evaluations and investigations. The ISE personnel have received formal training in root cause analysis to assure that consistent in-depth root cause I

analyses are performed. Three additional positions have been budgeted for ISE in 1990. The Operating Experience Review (OER) program has been re-assigned from ISE to reduce ISE collateral duties. ISE engineers now spend 40~ to 504 of their'time in the plant on field evaluations. As noted in the Palo Verde inspection conducted by the NRC during September 11 through October 15, 1989 (Inspection Report dated November 21, 1989), the quality of ISE investigatory reports appears to be improving in both scope and depth. Although improvements are being achieved in the NSG and ISE performance, their overall effectiveness and progress requires and will receive further review in 1990.

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