ML20127B396

Responds to Re Misused Diagnostic Evaluation Findings.Nrc Believes That 1989 Mgt Changes Combined W/ Numerous Initiatives Underway Have Shown Progress in Resolving Facility Mgt Issues

ML20127B396
Person / Time
Site:	Palo Verde
Issue date:	07/13/1990
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML20126G704	List: ML20126G700 ML20127B396 ML20127B401 ML20127B457
References
FOIA-92-88 NUDOCS 9007190067
Download: ML20127B396 (2)

Text

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Mr. William F. Conway Executive Vice President Nuclear Arizona Public Service Company P. O. Box 53999 Phoenix, Arizona 85072-3999

Dear Mr. Conway:

I am responding to your letter dated May 22, 1990, in which you refer to recent instances where you believe that diagnostic evaluation findings associated with Palo . Verde have been taken out of context and misused. Your letter also requested clarification on information documented in the Palo Verde Diagnostic EvaluationTeam(DET) report. The purpose of this letter is to respond to these areas.

As background, and as discussed in the Palo Verde report, a primary objective of the evaluation was to determine the probable root causes for any performance -

problems observed by the DET at the time of the evaluation. Knowledge of the probable root causes enables the Comission staff to evaluate the adequacy and completeness of the ongoing or planned corrective actions and thus the likelihood for sustained and permanent performance improvement.

The two observations contained in the DER cover letter and in the report that you find troublesome are:

(1) insufficient technical and management depth to support startup and operation of a three-unit facility, and (2) during startup, management and technical resources were focused on-the next unit to go on line at the expense of the operational-units resulting in a backlog of technical and programmatic issues.

In retrospect, I would agree that the statements would be clearer and more useful if placed in an overall context. During the startup and operation of the Pain Verde units, the question of management depth and technical capability was a topic of discussion.' Improvements were made by Palo Verde during the course of this progression; however, with each additional unit, the demands grew as well. Except=for the scale of the Palo Verde project, there is nothing snusual about this compared to other new plants going through the initial startup and operation. Although the issue of improvements in management and technical depth was discusses during this period, the staff repeatedly found that the capability was satisfactory. Comparing the startup and initial operation of Palo Verde with others in the Region such as San Onofre,. Diablo Canyon, and WNP-2, Palo Verde is considered about average.

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• Concerning item (2), we agree that there was, in general, a diligent effor resolve startup ofproblems subsequenton each unit and forward fit these resolutions prior to units.

But in the context of continually increasing management and technical challenges, essociated with the magnitude of the increasing project, the staff believes there were some areas that were not dealt programs, with completely and subsequently became urgent (system enginee maintenance).

unit sites.

The problem was that at the end of the startup phase, reoganization in 1987 did not position the utility well to complete resolution of the backlog of technical and programatic issues expeditiously.

Another "instabilit area you requested be reconsidered was the coments regardin situation. y" and " insecurity" at Palo Verde due to the Pinnacle West business '

The staff agrees that this is not a significant concern and would not appear to be having any adverse affect on plant personnel. As you point out, the staff made this clear in the report.

The staff agrees that any attending management changes and improvements. insecurit Finally, the evaluations. NRC has expressed its concern regarding the misuse of staff This concern has principally been directed at the potential safety effects Comissions of performance for nuclear power plants. incentives established by State Pualic U this issue, the Comission, following a briafing on April, directed staff to develop a policy statement on the 3,1990In the order to m 30tential impacts of the policies and actions either a positive oforstate regulatory negative im bodies, emplasizing that such actions can h system to monitor proposals for, pact on safety and to establish a tracking applicaole to nuclear power plants. and implementation of, performance incentives ,

In conclusion, as I stated in my March 16, 1990 the major performance problems affecting Palo Verde.Palo V shown progress in resolving Palo Verde management issue receiving your formal response to the DET report. I look forward to.

Sincerely,0riginal Signed By:

James M. Taylor James M. Taylor Distr _ibution + Executiva Director for Operations diaylor ~ ,

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