ML17305B407
| ML17305B407 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/21/1991 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17305B408 | List: |
| References | |
| 102-01995-WFC-T, 102-1995-WFC-T, NUDOCS 9103270135 | |
| Download: ML17305B407 (6) | |
Text
ACCELERATED
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9103270135 DOC.DATE: 91/03/21 NOTARIZED:
NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 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 Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 910131 ltr re concerns noted in SALP Repts 50-528/90-53,50-529/90-53
& 50-530/90-53 for period Nov 1989 Nov 1990.Clarifications encl.
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NOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOivl Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
AL NUMBER OF COPIES REQUIRED:
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Arizona Public Service Company P.O, BOX 53999
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PHOENIX, ARIZONA85072-3999 WILLIAMF CONWAY EXECUTIVEVICEPRESIDENT NUCI.EIDER 102-01995-WFC/TRB/DAJ March 21, 1991 U.
S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station Pl-37 Washington, D.C.
20555 Re'ference:
Letter from Mr. J.
B. Martin, NRC, to Mr. W. F.
- Conway, APS, dated January 31, 1991,
Subject:
Systematic Assessment of Licensee Performance
Dear Sir:
Subj ect:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2,
and 3
Docket No.
STN 50-528 (License No.
NPF-41)'ocket No.
STN 50-529 (License No. NPF-51)
Docket No.
STN 50-530 (License No. NPF-74)
Response
to the Systematic Assessment of Licensee Performance (SALP) Report File'1-020-404 This letter is in response to the NRC Systematic Assessment of Licensee Performance (SALP) Report for the period November 1, 1989 through November 30, 1990.
The SALP Board noted improvement in performance and your letter transmitting the 'Report stated that "The Board considered your generally improved performance to be indicative of greater involvement in specific plant activities by senior management."
We are pleased by this overall conclusion, but, at the same time, recognize that continued improvement is needed in each area of plant performance and we will continue to focus our efforts toward that objective.
Your letter notes three principal areas of concern identified by the SALP Board.
In the area of Safety Assessment/Quality Verification, the Board noted that APS initiatives have led to improved results, but expressed concern that the difficulties experienced with emergency lighting and operator medical records "caused the Board to doubt [APS's] commitment to a lasting improvement in this area has depth."
Be assured that our commitment to lasting improvement is fundamental to our desire to progress.
It is demonstrated in many ways including the substantial additional management attention and resources devoted to this area.
Technical and managerial improvements in the Quality Assurance organization have been implemented and other quality oversight functions have been strengthened.
As a result, quality concerns are 9i03270i35 9i0=21 PDR Al?OCh'. 0500052'=:
9 PDP
'e'RC Document Control Desk Page 2 of 2 102-01995-WFC/TRB/DAJ March 21, 1991 1
now being identified and resolved on a more timely basis.
The two proble'ms cited by the SALP Board refer to instances in which APS has now corrected the deficiencies and instituted extensive programmatic corrective actions.'evertheless, the occurrenc'e of such events indicates that further improvements can be made in the manner in which we ensure that problems are identified prior to becoming self revealing or apparent to external sources.
We also conclude that additional attention to work planning and corrective actions will permit improvement in our Maintenance/Surveillance activities.
Changes to the'aintenance organization, procedural
- upgrades, increased emphasis'n personal accountability, and a continued program for assuring a
strong management presence in the plant, are principal features of our efforts to achieve these go'als.
In the area of Engineering, the SALP Board stated that management attention should focus on defining the roles of the various engineering groups and on finding and resolving significant technical problems.
That effort is well underway.
The various technical organizations have been realigned so that each reports to the Vice President, Engineering and Construction, and the positions of Director, Site Technical Services and Director, Site Engineering and Construction have been defined and filled with experienced technical managers.
This increased level of management attention and the associated organizational, procedural and programmatic improvements have resulted in a clearer definition of the roles of the engineering groups and increased assurance that significant technical problems are identified and resolved.
The attachment to this letter identifies, corrections and clarifications to information provided in the SALP Report. If you have any questions, please contact me.
Very truly yours, WRC/TRB/DAJ/dmn Attachment cc:
J.
B. Martin D. H.
Coe A. H. Gutterman A.
C. Gehr
NRC Document Control Desk Attachment, Page 1 of 3 102-01995-WFC/TRB/DAJ
. March 21, 1991 ATTACHMENT CLARIFICATION TO SALP REPORT 50-528 529 AND 530 90-53 Inspection Report Statement On page 5,Section III. A.l, paragraph 5, the SALP Report states:
r "The Emergency Operating Procedures rewrite program has been delayed by another year due to delays by. contractors providing the writer's guide.
This is the second significant delay to this program."
Clarification The Emergency Operating Procedures (EOP) rewrites are complete through verification.
They are awaiting completion of the simulator upgrades to perform validation.
The schedule for final implementation was revised from September 1991 to December 1991 to allow for effective training following the major simulator upgrades (Reference APS letter number 102-01946-WFC/TRB/JJN from W. F.
- Conway, Executive Vice President Nuclear, Arizona Public
- Service, to U.
S. Nuclear Regulatory Commission, dated January 3,
1991).
Minor problems were incurred in obtaining a writer's guide from a contractor for the Abnormal Operating Procedure (AOP) upgrade project.
These problems have been resolved and the AOP upgrade project is proceeding as originally scheduled.
)
NRC Document Control Desk Attachment, Page 2 of 3 102-01995-WFC/TRB/DAJ March 21, 1991 Inspection Report Statement On page 6,Section III, A.l, paragraph 7, the SALP Report states:
"However, facility procedures governing the licensee administered annual operating tests allowed an operator who failed the test to return to shift work prior to passing a
second test, which is contrary to NRC requirements."
Clarif'ication APS has not allowed an operator who failed a test to return to shift work prior to passing a second test.
The statement above could read:
"However, facility procedures
... [did not preclude]
an operator who failed the test to return to shift work prior to passing a second test..."
Inspection Report Statement
-On page 8,Section III. B. 1, paragraph 5, the SALP Report states:
"On two occasions, decision making was conducted at a management level that did not result in adequate reviews of activities prior to implementation.
This was exemplified by the use of junior radiation protection technicians for senior radiation protection technician tasks during a labor action."
Clarification APS is aware of no instances wherein a management decision was made to use junior radiation protection (RP) technicians for
NRC Document Control Desk Attachment, Page 3 of 3 102-01995-WFC/TRB/DAJ March 21, 1991 senior RP technician tasks.
APS programmatic controls should preclude this.
- However, APS acknowledges that case(s) may have o'ccurred wherein junior RP technicians were inadequately supervised.
Inspection Report Statement On page 23,Section IV. A - Unit 3, the SALP Report states:
"A reactor trip occurred on October 10, 1990 as a result of a 'sudden opening of all in-service steam bypass control valves."
t Cl'arification The subject reactor trip occurred on October 20, 1990.