ML20141J370

Addresses Two Sets of Concerns Re Proposed Licensing & Changes & Comments Re 1985 SALP Rept for Facility.Favorable Action Requested Re Petition for Concretely Demonstrated Improvements in Mgt Performance

ML20141J370
Person / Time
Site:	Palo Verde
Issue date:	04/23/1986
From:	Michael Scott COALITION FOR RESPONSIBLE ENERGY EDUCATION
To:	Kirsch D NRC COMMISSION (OCM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
CON-#286-909 2.206, NUDOCS 8604280120
Download: ML20141J370 (3)

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April 22, 1986 amesp. 4- $k'ff!' - a g,., United States Nuclear 3,e musar Regulatory Comission nket Nos. 50

'"E*!EdiUIncron Attn.t The Comission it - APR 2 31986* e5 and 50 c"g,ga D.F. Kirsch (Regic J %g ar e.a s.. n Washington, D.C. 20555 stancr saAncn ac 6

!EN!Non cosastnaTc" Dear Ccrnmissioners g cn naaan nr m a m an The purpose of this letter is to ress two related concerns

'"i":dO"k'"sueun affecting the issuance of a full-pcver operating license for

'"it:J:'"O, 6an nu, the Palo Verde Unit 2 facility. The first set of concerns

,,,y:,c,a.;;.aaa'> deals directly with the proposed licensing. The second

,,y:,;-ca"' aman addresses certain changes in and coments on the 1985 SALP u.-.-i= pav Report for Palo Verde Nuc1 car Generating Station; and a copy s ., , '.". ,j,. of this letter, accordingly, is being mailed to Mr. Kirsch.

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• • iid7J:". . .n,, the Coalition for Responsiblo Energy -

w aa=, On January Education ("17, 1986, CREE" or the " Coalition") filed a 2.206 petition e.S"U.*a""" with the Director, Office of Nuclear Reactor Regulation, alle,

"*".'" .~.!!P"' management incompetence and poor character of Arizona Nuclu r U".": UU."*i .U..i.:

Power Project / Arizona Public Service sufficient (in our view) i;ayn;ytt;!., to raise serious questions about the capability of that licensee to safely simultanceusly operate Palo Verde Units 1

,, 2 at this time. The relief requested was the temporary suspe

. .. a s . of the Unit 2 low-power operating license, deferral of any ac 10U.?d"J'? Qui, on the Unit 2 full-power license, and the impimentation of nu':l';"2"' special inspection activity designed to improve overall u.g.pu ian.coia= management performance. Said petition was supplemented on

• "*JT0!ne.o.,me: January 21. On February 1, CREE filed a special mergency petition to the Comission to consider these managunent ccrnpe concerns prior to acting on the full power license for Unit 2 Af ter certain delays, the issuance of a full-power operating license for Palo Verde Unit 2 is now before the Cemission.

Accordingh, CREE implores you to consider at this time wheth ending a deferral Director'sofDecision such licensing on these is in order,petitions.

various at least p(On February 18, Mr. Denton acknowledged the CREE petitions, expressed his reasons for believing imediate action was not required, and pledged subsequent action.) CREE realizes that the issues ra in its petition are manifold and complex, and we have no wish rush a deliberate consideration of all the points raised ther Neither, however, do we wish to see a licensing decision rush through unnecessarily, even on an interim basis, when these a other significant issues (i.e., the seismic qualification of certain structures at all three Palo Verde facilitien) rmnin undecided. Candidly, such last minute reprieves do not creat impression that this Cemission puts the public safety first.

8604280120 e60423 PDR ADOCK 05000528 (continued)

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. C& 23 86 16:31 NO.019 003

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l k'e also recognize that the NRC has imposed certain limitations on the simulata operation of the two operable Palo Verde units in the re:ne mode. For the ruas stated in our petition, we are unconvinced that this precaution - although it reflects scrnewhat our own concerns - adequately addresses the concerns we have raised. At the vary least, it would enhance public confidence in any licensin decision if these existing limitations were explicitly reviewed prior to lican and strengthened where necessary.

The special nature of those concerns should be considered more carefully than thus far occurred. In a preceding oaragraph, the word "overall" has been enth deliberately. It is CREE s contentlon that the continuirg and pervasive natur the management errors cited in its petitions gives rise to more concern about t managemart competence and character of the licenses than the individual incida:

might merit if taken separately. Any analysis of ANPP/APS performance that fa to account fer the cumulative nature of these problens misses the essence of oi concern.

It is in this light that we are disturbed by the observation, in Mr. Denton's February 18 response, that many of these issues we raise are based upon SAIP f:

which have led to NRC orders to correct deficiencies and improve overall perfs in some areas. All of that is true, and we are grateful to tra NRC for the act it has taken; Nt that response appears to ignore a major concern raised in om petition, to wit: That the SALP methodology is incapable of capturing patterns management error that cross the functional categories established in SALP and I continue to do so over time. Our concern is not so much with specific behavior or even with plant manangenent behavior within a 8 iven SALP functional categori with observable recurring behavior pattems; and we frankly do not believe NRC assessments to date have adequately addressed this concern.

khile these concerns can and should affect Cmenission action on the full-power license, they also affect the adequacy of the SALP report as a diagnostic tool.

Accordingly,weareprovidingacopyofthiscorrespondence,asnoted,toMr.

Kirsch, as constituting CRE s ecmnents on that Report. Therefore, we wish to call the following to Mr. Kirsch's attention, as well as to the attention of ti-Cct: mission.

On February 21, 1986, ANPP Executive Vice President and Project Director E. E.

Van Erunt, Jr., addressed a correspondemo regarding SALP to Region V Administr J. B. Martin, recorrnending an editorial change in the SALP Report on Palo Verde for 1985. Additionally, in his cover letter, Mr. Van Brunt addressed a few spo areas in which he believed managunent had identified problun areac prior to SAL taken affective corrective action. One of these areas was LER performance, who ANPP claims to have addressed SALP concerns via establishnent of a new manager position in October, 1985. On April 11, 1986, Mr. D. F. Kirsch, Dirmtor, Divi of Reactor Safety and Projects, Walnut Creek, addressed a letter to Mr. Van Bru noting the same editorial changes. In his letter, Mr. Kirsch states that no wri conments have been received frun ANPP. Both this apparent discrepancy and the editorial change itself, while not reviewed specifically by the Coalition, appa us to be of minimal significance. However, the centnents by Mr. Van Brunt on AN LER performance are another matter.

On March 18, 1986, a Region V Inspection Report of Units 2 and 3 at Palo Verde (Nos. 50-529/86-07; 50-530/86-06) included a Notice of Violation (Severity Imyn for a January 17, 1986, LER (#85-005-00) which violated 10 C R 50.73. The timit arxl February,1986 tridermines the ofthisviolation(betweenOctober,1?85 assertions contained in Mr. Van Brunt s lett

( continued )

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changes in the SALP Report could be affected by continued IIR underperfomence, those changes should be reconsidered.

The fact that the nature of the violation is repetitive of concerns about In priormance very thoroughly doc mented in SALP and various Inspection Reports and, moreover, follows ANPP assurances of adequate corrective action, is furthe evidence for the concerns about management competence and/or character expresse in CREE's petitions.

The impression is conmon amon6 local observers of Ah7P performance that the rearrangenent of management flow charts far too of ten is substituted for genuin management improvements. This violation is a caso in point, and we urge the NRC to demand more of 4NPP corrective actions in the future. k's similarly urge this Comission to act ' favorably on CREE's petitions requesting concretely demonstrated improvements in management perfccmance prior to issuance of a Palo Verde Unit 2 full-power license.

Sincerely, MYRON 5071T Intervention Coordi for the Coalition cc: D. F. Kirsch Harold R. Denton