ML17305B093
| ML17305B093 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/24/1990 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010090017 | |
| Download: ML17305B093 (30) | |
Text
~
'ILLIAM F. CONWAY EXECDTIVEVICE PRESIDENT NUCLEAR Arizona Public Service Company P.O, BOX 53999
~
PHOENIX, ARIZONA85072.3999
't'l lii3 102-01829-WFC/TRB/JJN September 24, 1990
~ Igq tII.; +' \\I V
U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Mail Station: Pl-37 Washington, DC 20555
Reference:
Letter from S.
A. Richards, Chief, Reactor Projects
- Branch, NRC to W. F.
- Conway, Executive Vice President Nuclear, Arizona Public
- Service, dated August 23, 1990
Dear Sirs:
Subj ect:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1, 2, and 3
Docket No.
STN 50-528 (License No. NPF-41)
Docket No.
STN 50-529 (License No. NPF-51)
Docket No.
STN 50-530 (License No. NPF-74)
Reply to Notice of Violations 50-528/90-23-01 and 50-528/90-23-03 File'0-070-026 This letter is provided in response to the inspection conducted by Messrs, D.
Coe, J. Ringwald, J.
- Sloan, and P. Narbut from May 27 through July 14, 1990.
Based upon the results of the inspection, two apparent violations of NRC requirements were identified.
The violations are discussed in Appendix A of the referenced letter.
A restatement of the violations and PVNGS's response are provided in Appendix A and,Attachment 1, respectively; to this letter.
In the referenced letter and subject Inspection Report, several instances were noted in which Operations personnel performance contributed to component operability problems; or highlighted areas in which Control Room practices needed improvement.
APS recognized these concerns and appreciated the frank and timely discussions that took place with the NRC during this time.
Although individually these events had minimal significance, APS recognized that collectively these events could have indicated that performance was not meeting management,'s expectations.
A summary of these events and lessons learned was distributed'o Unit operations personnel with a briefing from the shift or plant management.
0 As part of planned management involvement in the Unit 1 Restart
- Program, APS placed experienced management personnel on shift on June 23, 1990, prior to criticality."'anagers remained on shift until the Unit reached 100 percent
e
NRC Document Control Desk Page 2
102-01829-WFC/TRB/JJN September 24, 1990 power.
Management personnel who participated in this observation program represented all three units.
Each assigned individual observed operations crew performance.
This role was specifically chosen to strengthen and support the Shift Supervisor role during the plant startup period following a length outage and allowed full-time management observation of crew performance.
a eng y
Although there were minor deviations which were corrected, the observation results indicated that the vast majority of activities were conducted
- properly, crew briefings prior to testing or critical activities were well run and of high quality.
The plant startup was performed in a professional and conservative manner.
These overall conclusions were verified by the Plant Manager and other members of senior management during observation of the reactor startup and synchronization to the grid.
Should you have any questions regarding, this response, please contact me.
Very truly yours, WFC/TRB/JJN/dmn
~ Attachments cc:
J.
B.
D. H.
A. H.
A. C.
Martin Coe Gutterman Gehr
A
~
0 NRC Document Control Desk Appendix A, Page 1 of 2 102-01829-WFC/TRB/JJN September 24, 1990
~APPENDIX NOTICE OF VIOLATION Arizona Nuclear Power Project Palo Verde Unit 1 Docket Number 50-528 License Number NPF-41 During an NRC inspection conducted on May 27 through July 14,
- 1990, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure, for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1990),
the violations are listed below:
Unit 1 Technical Specifications, Section 6.11.1, requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10CFR Part 20 and to be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Licensee Procedure 75AC-9RP01, Radiation Exposure and Access Control, provides requirements'for radiation workers entering.radiation areas.
1 Step 3.5.2 of Procedure 75AC-9RP01 requires that "All personnel who enter the Radiological Controlled Area must read the REP [Radiation Exposure Permitj and sign-in on the appropriate REP sign-in sheet.
By signing in they indicate that they have read and understand the REP requirements and will comply."
Step 3.5.4 of. Procedure 75AC-9RP01 requires radiation ~orkers to "Discuss with Radiation Protection the job scope to... ensure that the appropriate radiological controls are exercised."
REP 1-90-4001D, among other radiation protection measures, requires personnel entering High Radiation Areas to wear an alarming dosimeter.
Contrary to the above,'n June 20, 1990, in Unit 1, a Mechanical Maintenance Foreman failed to comply with REP 1-90-4001D, which he had
- signed, when the Foreman entered a posted High Radiation Area without an alarming dosimeter.
Also, contrary to the above, on June 20,
- 1990, when the Mechanical, Maintenance Foreman discussed his entry with the Radiological Protection Shift Technician, the Mechanical Maintenance Foreman and the Radiological Protection Shift Technician had not discussed the fact that the area the Foreman was planning to work in was posted as a High Radiation area and the necessary radiological controls for that area.
This is a Severity Level IV violation applicable to Unit 1 (Supplement I).
NRC Document Control Desk Appendix A, Page 2 of 2 102-01829-WFC/TRB/JJN September 24, 1990 Unit 1=-Technical Specifications, Section 6.8.1, states in part: "Written Procedures shall be established, implemented, and maintained covering the activities.;. recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.
Regulatory Guide 1.33, Revision 2, states in part:
"Procedures for
- Startup, Operating and Shutdown of Safety-Related PWR Systems Instructions for... changing modes of operation should be prepared for the... Main Steam System."
I These procedures are implemented, in part, by licensee Procedure 41DP-
- 10POl, Manual Operation of Air Operated Valves, which states, in Appendix B, Step B.8, for SGB-HV-178:
"Slide the clevis onto the actuator shaft.
Ensure clevis is securely engaged... Tighten set screw to properly secure."
Contrary to the above, on June 21, 1990, licensee personnel failed to follow Procedure 41DP-10P01, Appendix B, Step B.8, in that in Unit 1, an Auxiliary Operator engaged the clevis on Atmospheric Dump Valve SGB-HV-178, but failed to tighten the set screw.
This is a Severity Level V Violation applicable to Unit 1 (Supplement I).
NRC Document Control'esk,
Page 1 of 6 102-01829-WFC/TRB/JJN September 24,1990 ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-528 90-23-01 I.
EASON FOR THE VIOLATION The reason for the violation was a personnel error on the part of a Unit 1
Radiation Protection Technician (RPT) and a maintenance mechanic.
During a briefing, the maintenance mechanic and the RPT discussed the proposed activities in the lower level of "A" LPSI pump room, the radiological survey, and radiological protective actions for the e
contaminated
- areas, prior to the maintenance mechanic entering the area.
At this time, the RPT should have recognized the fact that the lower level of the "A" LPSI pump room was a High Radiation Area (HRA) and assigned the appropriate radiological 'control (i.e., alarming dosimeter, dose rate meter, or continuous RP coverage) in accordance with APS procedures and the Radiation Exposure Permit.
- However, while reviewing radiological survey maps neither individual recognized that the proposed activities would occur in a High Radiation Area (lower level of the "A" LPSI pump room).
Contributing to the violation was the physical location of the posting to the HRA (lower level of the "A" LPSI pump room).
The posting was hung on the upper level of the "A" LPSI pump room between the railings
'I that surrounded the grating penetration and ladder to the lower level.
e NRC Document Control Desk,
Page 2 of 6 102-01829-MFC/TRB/JJN September 24,1990 The posting was hung away from the safety bar which is in front of the access to the ladder to avoid inhibiting egress from the area and the additional hazard of requiring a manipulation of the rope while climbing on a ladder..
The mechanic entered the lower level of the "A" LPSI pump room by backing down a ladder and did not see the HRA posting.
ZI.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The maintenance mechanic reported the incident to RP, the Mechanical Maintenance Supervisor and the Plant Manager.
The maintenance mechanic was temporarily prohibited from entering Radiologically Controlled Areas (RCAs) pending an investigation of this event and evaluation of his exposure.
The mechanic's exposure was evaluated and no excessive exposure occurred.
An investigation of this event was conducted.
A Radiological Control Problem Report documented the results of the investigation and the lessons learned.
This report was forwarded to Units 2 and 3 Radiation
- Protection personnel for their review.
The Unit 1 Radiological Protection Manager (RPM) personally reviewed this event with the onshift crews shortly after the event.
The balance of the Unit 1 RP staff was briefed by their supervision.
e P
e NRC Document Control Desk,
Page 3 of 6 102-01829;WFC/TRB/JJN September 24,1990 The RPT was relieved of duties at the control point for the RCA pending a review with the Unit 1 RPM.
The RPT voluntarily resigned (which APS believes was due to unrelated reasons).
Therefore, no further corrective action was required.
The maintenance mechanic briefed Unit 1 mechanical maintenance personnel on the lessons learned from this event.
The lower level of the "A" LPSI pump room area was reposted to reduce the area controlled as a HRA.
This eliminated the difficulty of posting the ladder access.
III.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID VIOLATIONS As noted in the inspection report, APS was revising the posting program at the time of this event to reduce the areas designated as HRA by eliminating overly conservative postings.
Additionally, the posting procedure will be revised to include a requirement that the posting for HRA obstruct an individual accessing the area.
This requirement to obstruct access is intended to mean that a rope, sign, or other physical object will confront, alter, or hinder an individual's reasonable access to 'that 'area.
These revisions are expected to be completed by October 5,
1990.
In addition, the'ite Radiation Protection General Manager will issue a memorandum by September 28,
- 1990, to RP personnel
NRC Document Control Desk Attachment 1,
Page 4 of 6 102-01829-WFCjTRB/JJN September 24,1990 stressing the importance that the High Radiation Area postings may also be functioning as a barricade.
IV.
ATE @HEN FULL CO PLIANCE %AS CHIEVED Full compliance was achieved on June, 20,
- 1990, when the maintenance, mechanic exited the HRA.
~
\\
NRC Document Control Desk,
Page 5 of 6 I
102-01829-VFC/TRB/JJN September 24,1990 REPLY TO NOTICE OF VIOLATION 50-528 90-23-03 I.
EASON FOR THE VIOLATION The reason for the violation was a personnel error by an operator manually operating the valve.
The operator omitted an action contained in a step of the procedure to tighten the set screw on the clevis pin.
IZ.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A Human Performance Evaluation (HPES) was conducted for this event.
'The effectiveness of the job performance measure (JPM) for the manual operation of the Atmospheric Dump Valve (ADV) was evaluated by unannounced testing of rece'ntly qualified operators from Units 1, 2 and 3.
These operators correctly operated the ADV, therefore, APS has concluded that the training is adequate.
.An evaluation of the procedure for the manual operation of the ADV was conducted which identified that the requirement to tighten the set screw on the clevis is contained in a step that requires another action.
The procedure has since been revised to include a separate step for the tightening of the set screw to decrease the possibility of missing the step.
The Human Performance Evaluation report was reviewed with operating crews in Unit l.
Units 2 and 3 conducted briefings with 'heir
OCT 89 '98 89:55 PVNGS ADMIH BLDG P.2 NRC Document Control Desk Attachment 1,
Page 6 of 6 102-01829-WFC/TRB/JJN S eptember 24, 1990 personnel.
The Unit 1 operator was counselled on the necessity for attention to detail and satisfactorily re-performed the JPM.
T WILL BZ AKE TO APS believes the actions taken as described above are adequate to prevent recurrence.
jv.
E N FULL COMPEL W
C EVED Fu].1 compliance was achieved on June 21,
- 1990, when the Atmospheric Dump Valve was restored its normal condition,
I ce l
l
ACCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM DOCKET ¹ 05000528 05000529 05000530
SUBJECT:
Responds to NRC 900823 ltr re violations noted in Insp Repts 50-528/90-23,50-529/90-23
& 50-530/90-23.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR t
ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9010090017 DOC.DATE: 90/09/24 NOTARIZED: NO ACIL".STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi AUTH.NAME AUTHOR AFFILIATION CONWAYiW.F.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
05000528 05000529 05000530 INTERNAL:
RECIPIENT.
ID CODE/NAME PDS PD TRAMMELL,CD ACRS AEOD/DEIIB DEDRO NRR SHANKMANgS NRR/DOEA DIR 11 NRR/DRIS/DIR NRR/PMAS/ILRB12 O~
REG FIL 02 COPIES LTTR ENCL 1
1 1
1 2
2 1
1 1
1 1
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1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME PETERSONiS.
AEOD AEOD/TPAD NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS1 RGN5 FILE 01 COPIES LTTR ENCL 1
1 1
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1 1
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NSIC 1
1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
~
PHOENIX. ARIZONA85072-3999 102-01829-WFC/TRB/JJN September 24, 1990 U.
S. Nuclear Regulatory Commission Attention:"
Document Control Desk Mail Station:
Pl-37 Washington, DC 20555
Reference:
Letter from S. A. Richards, Chief, Reactor Projects
- Branch, NRC to W. F.
- Conway, Executive Vice President Nuclear, Arizona Public
- Service, dated August 23, 1990 0
Dear Sirs:
Subj ect:
Palo-Verde Nuclear Generating Station (PVNGS)
Unit 1, 2, and 3
Docket No.
STN 50-528 (License No. NPF-41)
Docket No.
STN 50-529 (License No. NPF-51)
Docket No.
STN 50-530 (License No. NPF-74)
Reply to Notice of Violations 50-528/90-23-01 and 50-528/90-23-03 File'0-070-026 This letter is provided in response to the inspection conducted by Messrs, D. Coe, J. Ringwald, J.
- Sloan, and P. Narbut from May 27 through July 14, 1990.
Based upon the results of the inspection, two apparent violations of NRC requirements were 'identified.
The violations are discussed in Appendix A of the referenced letter.
A restatement of the violations and PVNGS's response are provided in Appendix A and Attachment 1, respectively, to this letter.
In the referenced letter and subject Inspection Report, several instances were noted in which Operations personnel performance contributed to component operability problems, or highlighted areas in which Control Room practices needed improvement.
APS recognized these concerns and appreciated the frank and timely discussions that took place with the NRC during this time.
Although individually these events had minimal significance, APS recognized that collectively these events could have indicated that performance was not meeting management's expectations.
A summary of these events and lessons learned was distributed to Unit operations personnel with a briefing from the shift or plant management.
As part of planned management involvement in the Unit 1 Restart
- Program, APS t
placed experienced management personnel on shift on June 23, 1990, prior to criticality.
Managers remained on shift until the Unit reached 100 percent hQh O,.t) ]
90i00900i7 900924 PDR ADOCK 05000528 8
PNU y+~0
I NRC Document Control Desk Page 2
102-01829-WFC/TRB/JJN September 24, 1990 power.
Management personnel who participated in this observation program represented all three units.
Each assigned individual observed operations crew performance.
This role was specifically chosen to strengthen and support the Shift Supervisor role during the plant startup period following a lengthy outage and allowed full-time management observation of crew performances Although there were minor deviations which were corrected, the observation results indicated that the vast majority of activities were conducted
- properly, crew briefings prior to testing or critical activities were well run and of high quality.
The plant startup was performed in a professional and conservative manner.
These overall conclusions were verified by the Plant Manager and other members of senior management during observation of the reactor startup and synchronization to the grid.
Should you have any questions regarding this response, please contact me.
Very truly yours, t
WFC/TRB/JJN/dmn Attachments cc:
J.
B. Martin D. H.
Coe A. H. Gutterman A. C. Gehr
0 0
4
0 NRC Document Control Desk Appendix A, Page 1 of,2 102-01829-WFC/TRB/JJN September 24, 1990 APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Palo Verde Unit 1 Docket Number 50-528 License Number NPF-41 During an NRC inspection conducted on May 27 through July 14,
- 1990, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1990),
the violations are listed below:
Unit 1 Technical Specifications, Section 6.11.1, requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10CFR Part 20 and to be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Licensee Procedure 75AC-9RP01, Radiation Exposure and Access Control, provides requirements for radiation workers entering radiation areas.
Step 3.5.2 of Procedure 75AC-9RP01 requires that "All personnel who enter the Radiological Controlled Area must read the REP [Radiation Exposure Permit]
and sign-in on the appropriate REP sign-in sheet.
By signing in they indicate that they have read and understand the REP requirements and will comply."
Step 3.5.4 of Procedure 75AC-9RP01 requires radiation workers to "Discuss with Radiation Protection the job scope to... ensure that the appropriate radiological controls are exercised."
REP 1-90-4001D, among other radiation protection measures, requires personnel entering High Radiation Areas to wear an alarming dosimeter.
II Contrary to the above, on June 20, 1990, in Unit 1, a Mechanical Maintenance Foreman failed to comply with REP 1-90-4001D, which he had
- signed, when the Foreman entered a posted High Radiation Area without an alarming dosimeter.
Also, contrary to the above, on June 20,
- 1990, when the Mechanical Maintenance Foreman discussed his entry with the Radiological Protection Shift Technician, the Mechanical Maintenance Foreman and the Radiological Protection Shift Technician had not discussed the fact that the area the Foreman was planning to work in was posted as a High Radiation area and the necessary radiological controls for that area.
This is a Severity Level IV violation applicable to Unit 1 (Supplement I).
NRC Document Control Desk Appendix A, Page 2 of 2 102-01829-WFC/TRB/JJN September 24, 1990 Unit 1 Technical Specifications, Section 6.8.1, states in part: "Written Procedures shall be established, implemented, and maintained covering the activities..
~
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.
Regulatory Guide 1.33, Revision 2, states in part:
"Procedures for
- Startup, Operating and Shutdown of Safety-Related PWR Systems Instructions for... changing modes of operation should be prepared for the... Main Steam System."
These procedures are implemented, in part, by licensee Procedure 41DP-
- 10P01, Manual Operation of Air Operated Valves, which states, in Appendix B, 'Step B.8, for SGB-HV-178:
"Slide the clevis onto the actuator shaft.
Ensure clevis is securely engaged... Tighten set screw to properly secure."
Contrary to the above, on June 21,
- 1990, licensee personnel failed to follow Procedure 41DP-10POl, Appendix B, Step B.8, in that in Unit 1; an Auxiliary Operator engaged the clevis on Atmospheric Dump Valve SGB-HV-178, but failed to tighten the set screw.
This is a Severity Level V Violation applicable to Unit 1 (Supplement I).
NRC Document Control Desk,
Page 1 of 6 102-01829-WFC/TRB/JJN September 24,1990 ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-528 90-23-01 I.
REASON FOR THE VIOLATION The reason for the violation was a personnel error on the part of a Unit 1
Radiation Protection Technician (RPT) and a maintenance mechanic.
During a briefing, the maintenance mechanic and the RPT discussed the proposed activities in the lower level of "A" LPSI pump room, the radiological survey, and radiological protective actions for the contaminated areas,.prior to the maintenance mechanic entering the area.
At this time, the RPT should have recognized the fact that the lower level of the "A" LPSI pump room was a High Radiation Area (HRA) and assigned the appropriate radiological control (i.e., alarming dosimeter, dose rate meter, or continuous RP coverage) "in accordance with APS procedures and the Radiation Exposure Permit.
- However, while reviewing radiological survey maps neither individual recognized that the proposed activities would occur in a High Radiation Area (lower level of the "A" LPSI pump room).
Contributing to the violation was the physical location of the posting to the HRA (lower level of the "A" LPSI pump room).
The posting was hung on the upper level of the "A" LPSI pump room between the railings that surrounded the grating penetration and ladder to the lower level.
0
NRC Document Control Desk Attachment 1,
Page 2 of 6 102-01829-VFC/TRB/JJN September 24,1990 The posting was hung away from the safety bar which is in front of the access to the ladder to avoid inhibiting egress from the area and the additional hazard of requiring a manipulation of the rope while climbing on a ladder.
The mechanic entered the lower level of the "A" LPSI pump room by backing down a ladder and did not see the HRA posting.
I II.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The maintenance mechanic reported the incident to RP, the 'Mechanical Maintenance Supervisor and the Plant Manager.
The maintenance mechanic was temporarily prohibited from entering Radiologically Controlled Areas (RCAs) pending an investigation of this event and evaluation of his exposure.
The mechanic's exposure was evaluated and no excessive exposure occurred.
An investigation of this event was conducted.
A Radiological Control Problem Report documented the results of the investigation and the lessons learned.
This report was forwarded to Units 2 and 3 Radiation Protection personnel for their review.
The Unit 1 Radiological Protection Manager (RPM) personally reviewed this event with the onshift crews shortly after the event.
The balance of the Unit 1 RP staff was briefed by their supervision.
4 4
e NRC Document Control Desk,
Page 3 of 6 102-01829-WFC/TRB/JJN September 24,1990 The RPT was relieved of duties at the control point for the RCA pending a review with the Unit 1 RPM.
The RPT voluntarily resigned (which APS believes was due to unrelated reasons).
Therefore, no further corrective action was required.
The maintenance mechanic briefed Unit 1 mechanical maintenance personnel on the lessons learned from this event.
The lower level of the "A" LPSI pump room area was reposted to reduce the area controlled as a HRA.
This eliminated the difficulty of posting the ladder access.
III.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID VIOLATIONS As noted in the inspection report, APS was revising the posting program at the time of this event to reduce the areas designated as HRA by eliminating overly conservative postings.
Additionally, the posting procedure will be revised to include a requirement that the posting for HRA obstruct an individual accessing the area.
This requirement to obstruct access is intended to mean that a rope, sign, or other physical object will confront, alter, or hinder an individual's reasonable access to that area.
These revisions are expected to be completed by October 5, 1990.
In addition, the Site Radiation Protection General Manager will issue a memorandum by September 28, 1990, to RP personnel
NRC Document Control Desk,
Page 4 of 6 102-01829-WFC/TRB/JJN September 24,1990 stressing the importance that the High Radiation Area postings may also be functioning as a barricade.
IV.
DATE WHEN FULL COMPLIANCE VAS ACHIEVED Full compliance was achieved on June '20,
- 1990, when the maintenance mechanic exited the HRA.
NRC Document Control Desk,
Page 5 of 6 102-01829-WFC/TRB/JJN September 24,1990 REPLY TO NOTICE OF VIOLATION 50-528 90-23-03 I,
REASON FOR THE VIOLATION The reason for the violation was a personnel error by an operator manually operating the valve.
The operator omitted an action contained in a step of the procedure to tighten the set screw on the clevis pin.
II.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 0
A Human Performance Evaluation (HPES) was conducted for this event.
The effectiveness of the job performance measure (JPM) for the manual operation of the Atmospheric Dump Valve (ADV) was evaluated by unannounced testing of recently qualified operators from Units 1, 2 and 3.
These operators correctly operated the ADV, therefore, APS has concluded that the training is adequate.
An evaluation of the procedure for the manual operation of the ADV was conducted which identified that the requirement to tighten the set screw on the clevis is contained in a step that requires another action.
The procedure has since been revised to include a separate step for the tightening of the set screw to decrease the possibility of missing the step.
The Human Performance Evaluation report was reviewed with operating crews in Unit l.
Units 2 and 3 conducted briefings with their
NRC Document Control Desk,
Page 6 of 6 102-01829-WFC/TRB/JJN September 24,1990 personnel.
The Unit 1 operator was counselled on the necessity for attention to detail and satisfactorily re-performed the JPM.
III.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID VIOLATIONS APS believes the actions taken as described above are adequate to prevent recurrence.
IV.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on June 21,
- 1990, when the Atmospheric Dump Valve was restored its normal condition".