IR 05000528/1993022

Insp Repts 50-528/93-22,50-529/93-22 & 50-530/93-22 on 930426-0514.Major Areas Inspected:Followup on Emergency Preparedness Program Issues Identified in AIT 50-529/93-14

ML20045C165
Person / Time
Site:	Palo Verde
Issue date:	05/27/1993
From:	Pate R, Qualls P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20045C161	List: IR 05000528/1993022
References
50-528-93-22, 50-529-93-22, 50-530-93-22, NUDOCS 9306220147
Download: ML20045C165 (8)

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i U. S. NUCLEAR REGULATORY COMMISSION

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REGION V

Report Nos.

50-528/93-22, 50-529/93-22, and 50-530/93-22 License Nos.

NPF-41, NPF-51, and NPF-74 Licensee:

Arizona Public Service Company P. O. Box 53999, Station 9082 Phoenix, Arizona 85837 Facility Name:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Inspection at:

Palo Verde Site, Wintersburg, Arizona Inspection Dates: Ap 'l 26-May 1 1993 Inspector:

5/27/93 P. M. Quails, Reactor Inspector Dale Signed Other Inspectors: J. B. O'Brien R/D s PEPB Approved By:

tj f/27 J

R.J. Pate, IChj,6f,/ Safeguards, Date S'igned Emergency Preparedness, and Non-power Reactor Branch Summary:

Areas Inspected:

Announced special inspection to followup on the Emergency Preparedness Program issues identified in the AIT (50-529/93-14).

Inspection Procedure 92701 was covered.

Results: Overall, the licensee's program is adequate in the area of cmergency preparedness.

However, during this inspection, five apparent violations concerning event classification, ERDS activation, assembly and accountability, and procedural adequacy (see paragraphs 3.a 3.c, 3.e, and 5) were identified.

9306220147 930528 PDR ADOCK 05000528 G

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DETAILS

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1.

PERSONS CONTACTED The below listed persons were contacted during the course of the inspection.

Licensee

• P. Caudill, Director, Site Services

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• H. Bieling, Manager, Emergency Planning

• T. Barsuk, EP Onsite Supervisor

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• B. Wolfe, EP Offsite Supervisor

• R. Bouquot, Supervisor, QA Audits C. Bolle, Sr. EP Coordinator G. Daunoy, QA Engineer D. Douglas, QA Technical Assistant K. Parish, Sr. Engineer, Nuclear Fuels and Analysis Dept.

T. Sundeen, QA Auditor

• J. Napier, Engineer, Nuclear Regulatory Affairs G. Ceakas, EP consultant M. Pioggia, EP Coordinator

• D. Elkinton, QA, Senior Technical Specialist

• R. Fountain, QA&M Supervisor L. Spieght, Unit 2 Shift Supervisor H. Lines, EP Coordinator M. Koudelka, EP Coordinator

• B. Grabo, Supervisor NRA

• S. Bauer, Sr. Engineer, NRA

• M. Baughman, Supervisor, Ops Training J. Hues, Security Shift Supervisor D. Branson,-Security Supervisor

• F. Gowers, EPE Site Representative

• R. Henry, SRP Site Representative

• J. Draper, SCE Site Representative

• R. Adney, Plant Manager, Unit 3

• R. Flood, Plant Manager, Unit 2

• R. Prabhakar, Manager,.ISQE

• M. Fallon, Media Representative, Communications

• C. McClain, Manager, Technical ~ Training

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NRC

• R. Pate, Chief, Safeguards, Emergency P1anning, and Non-Power Reactor Branch, Region V

• J. Sloan, Senior Resident Inspector

• J. 0'Brien, Emergency Preparedness Specialist, NRR/DRSS/PEPB

• Attended Exit Meeting o_n April 30, 1993.

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2.

SUMMARY OF EVENT On-Sunday, March 14,1993, at 0502, MST, following the rupture of a tube in Steam Generator #2 (SG-2), Palo Verde Unit 2 declared an Alert. The unit had been operating at about 100% power when, at about 0435, the operators observed pressurizer level and pressure decreasing. The operators manually tripped the reactor and followed the Emergency Operating Procedures (E0Ps) to stabilize plant conditions. NRC Region V dispatched an Augmented Inspection Team (AIT) to evaluate the event.

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The event description and the sequence of events are detailed in AIT Inspection Report (50-529/93-14), issued on April 16, 1993.

3.

FOLLOWUP 0F AIT IDENTIFIED ISSUES (MC 92701)

a.

Event Classification (1)

Event Classification Concern Identified in the AIT Report The operators observed RCS leakage, as indicated by a rapid decrease in pressurizer level, which caused them to start all charging pumps and isolate letdown. The operators noted that RCS cold leg temperature was unchanged prior to the trip.

Seven minutes after isolating letdown and starting the charging pumps, level had decreased until pressurizer heaters were threatened, so the operators tripped the unit due to low pressurizer level.

Prior-to the trip, Reactor Coolant System (RCS) leakage exceeded charging pump capacity.

Emergency Plan Implementing Procedure (EPIP),

EPIP-02, Emergency Classification, requires that RCS leakage in excess of charging pump capacity be classified by Appendix B, Tab 2, as a Site Area Emergency (SAE).

After the trip, the operators observed that (1) pressurizer level was slightly increasing while all three charging pumps were operating, (2) the High Pressure Safety Injection (HPSI) pumps were running, and (3) RCS pressure was at the shutoff head pressure of the HPSI pumps. After a plant trip, EPIP-02 requires that the event be classified using the barrier criteria of Appendix A.

This procedure consists of a checklist of various plant conditions. A box is marked on the checklist for each event which is in progress or has occurred.

One check is an Alert, two checks are a Site Area Emergency, and three checks are a General Emergency. After the trip, RCS leakage exceeded 44 gpm, which was a condition that required a mark on the checklist resulting in an Alert classification. However, prior to the trip, RCS leakage had exceeded available charging pump capacity.

EPIP-02 required the licensee to mark on the checklist any conditions listed on it that are in progress or have occurred to determine the appropriate emergency classification. This was a condition which had occurred and thus should have been marked on the checklist, resulting in two checks on the checklist and thus

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in a classification of Site Area Emergency in accordance with the licensee's procedure.

(2)

Event Classification Followup The inspectors interviewed the Shift Supervisor (SS) and the Assistant Shift Supervisor separately. The Assistant SS told the inspectors that he had recognized that RCS-leakage was greater than charging pump capacity prior to the trip and advised the SS of this condition prior to the trip.

However, the SS could not recall that the Assistant SS had provided him with this information. The SS told the inspector that he had classified the Alert based on RCS leakage greater than 44 gpm in accordance with EPIP-02. The SS stated that the classification was made without considering that the RCS leak rate had exceeded charging pump capacity.

Licensee Technical Specification (TS) 6.8.1 states that

" written procedures shall be established, implemented, and maintained covering...

Emergency' Plan implementation".

EPIP-02 requires the classification.to be based on current conditions (leakage greater than 44 gpm) and conditions which "have occurred" (leakage greater than charging pump capacity), and because both conditions had occurred,_the event should have been classified as a Site Area Emergency (SAE).

The failure to classify the event in accordance with the Emergency Plan Implementing Procedures is an apparent violation of TS 6.8.1 (93-22-01)

b.

EPIP-02 Procedure (1)

EPIP-02 Procedure Concern Identified in the AIT Report The licensee's procedures classify a steam generator tube rupture (SGTR) event at a more significant incident than required by NRC guidance. The AIT concluded that the excessively conservative classification was "a weakness in the licensee's classification process."-

(2)

EPIP-02 Procedure Followup The inspector reviewed UFSAR Chapter 15.6.3, " Steam Generator Tube Rupture", and licensee document 93-005-419.05, "LDCR for Proposed UFSAR Section 15.6.3.3, ' Steam Generator Tube Rupture With a loss of Offsite Power,' With Supporting Changes to 15.6.3.1".

Both studies demonstrated that for the worst case SGTR, no core thermal limits would be exceeded, indicating that the fuel barrier would be protected.

Using the guidance in NUREG-0654, the inspector concluded that the actual ' conditions at the facility, during the March 14 STGR event, met the conditions required for an

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• Alert rather than a SAE. The licensee stated that EPIP-02 was being revised.

The inspector will follow up the EPIP-02 revisions as part of the routine inspection program. This item is OPEN (93-22-02).

c.

ERDS Activation (1)

ERDS Activation Identified in the AIT Report The licensee did not activate the Emergency Response Data System (ERDS) until one hour and ten minutes after the Alert was declared rather than within the sixty minutes required by 10 CFR 50.72.

(2)

EROS Activation Followup The inspector verified that the licensee's evaluation also concluded that the ERDs was not activated within 60 minutes.

The failure to activate the ERDS appeared to be due to procedural weakness and to communications informality during the event. The inspector was told that the SS instructed the STAS to activate the ERDS while the SS was performing the EPIPs. This action did not occur, as there were three STAS in the Control Room and each apparently thought that the other was told to activate the system. The ERDS was activated when the SS was rechecking his procedure and found that all required steps had not been completed. The ERDS i

activation was, at the time of the event, not on the STA's procedural checklist.

This is an apparent violation of 10 CFR 50.72 (93-22-03).

d.

Emeraency Response Facility (ERF) Activation (1)

ERF Activation Concern Identified in the AIT Report The licensee did not activate the Emergency Operations Facility (EOF) until one hour and forty minutes after the Alert was declared and did not activate the Technical Support Center (TSC) until one hour and forty three minutes after the Alert was declared. The licensee's EPIPs and-approved Emergency Plan specify a goal of one hour for each facility.

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(2)

ERF Activation Followup While the findings of the licensee evaluation were consistent with NRC findings on TSC and E0F activation, the licensee also concluded that the ERF activation times were nearly optimum for a fast-breaking event.

However, one hour is the time specified in NUREG-0654 to augment the facility staff. The licensee provided information concerning an expected response timeline and estimated that under some

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offshift conditions, two hours could elapse from the event declaration to ERF activation due to the remote location of the site. The licensee is reviewing the one hour goal for the activation of the ERFs after the event declarations.

(93-22-04) OPEN.

e.

Accountability and Assembly (1)

Accountability and Assembly Concerns Identified in the AIT Report During the SGTR event, assembly was sounded at 0517, but, due to reported questions by unaffected unit personnel, it was repeated at 0547.

EPIP-20, requires that non-essential personnel go to their assembly areas when assembly is sounded, so accountability can be completed within 30 minutes.

Contrary to EPIP-20, three nonessential persons r

apparently did not go to the assembly areas outside of the PA as required.

EPIP-20 required that a list of unaccounted for personnel, by name, be provided to the Emergency Coordinator (EC).

Instead, a list of ACAD numbers with no names was provided to the EC at 0605. The list provided to the EC contained 114 open ACADs for the PA and provided no way to determine whether any of these represented persons in need of assistance. A later review by the licensee of this area showed that of the 114 ACADs listed as open-in the area, most were test ACADs, open emergency visitor ACADs, onsite security force ACADs, open emergency response ACADs for the fire department, and open ACADs for persons who had, in some cases, not been onsite for several weeks.

Also while EPIP-20 required that checks of the Owner Controlled Area (OCA) be conducted to ensure that there were no unaccounted persons in the OCA, no checks of the OCA were conducted at the time of accountability.

Finally, while EPIP-20 required that the licensee complete Assembly and Accountability within 30 minutes, Assembly and Accountability took 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 44. minutes.

(2)

Accountability and Assemb1v Followup As noted above, the SS was provided a list of 114 open ACAD numbers instead of a list of names of unaccounted personnel.

In response to an AIT request for identification of these open ACADs, the licensee determined that three non-essential personnel had not left.the Protected Area'(PA). During the followup inspection, at the inspector's request, the licensee contacted the three individuals to determine why they had not responded.

The licensee determined that one

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assembly but had been allowed into the PA with no assembly -

instructions, the second person was a Unit Auxiliary Operator and was an essential person who made the list due to a mixup _in names, and the third person went to the unit-control room instead of his assembly area. The licensee also concluded that it had failed to accomplish accountability within 30 minutes-of the request by the

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Emergency Coordinator and that the Security Director failed to provide a list, by name, of unaccounted personnel to the Emergency Coordinator. This last failure contributed to the length of time required to accomplish accountability. This is an apparent violation of TS 6.8.1. (93-22-05).

During the event the security force did not conduct a check

of the Owner Controlled Area (OCA) at the time that accountability was requested. The Security Director used i

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the available security staff for redirecting incoming.

traffic to enter the site through.the Water Reclamation i

Facility gate.

The licensee evaluation also concluded that no check was made at this time. This is an apparent violation of TS 6.8.1. (93-22-06).-

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4.

0A Audit of Assembly and Accountability l

Subsequent to the AIT inspection, the; inspector noted that the.

licensee's Quality Assurance audit of the EP program for 1992, QA&M--

Audit Report 92-007, issued in July 1992, had identified a lack of '

knowledge concerning assembly and accountability.

The report _ stated that:

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"Of the fifty-five ~(55) employees interviewed, seventeen (17) knew where their assembly area was.

Twenty-four (24) individuals knew -

j they were responsible to assemble within 30 minutes...Some-i individuals, including supervision,. were notlaware that EPIP-20-requires that supervisory personnel perform initial' accountability

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at their assembly. area.

Individuals requiring access' to the

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Protected Area' receive E-Plan indoctrination; however, individuals who only require Owner Controlled Area ' access do not receive this

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indoctrination."

i As noted in paragraph 3.e above, the EC sounded Assembly a.second time

due to reports received from the operating units of personnel confusion -

as to the proper response'to the siren. The AIT also identified' that-three persons. failed to respond to the assembly sirens.

Of the three

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persons ' identified, one failed to properly' respond. This audit provided the licensee with reasonable-indication of potential accountability

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problems before this event, and provided the licensee with prior-

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opportunity to' take effective corrective actions to prevent the problems

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encountered.

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5.

Review of EPIP-20 The inspector reviewed the licensee's assembly and accountability procedure and noted the following deficiencies when compared to the approved emergency plan.

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a.

The inspector reviewed the licensee's approved Emergency Plan and found that Section 6.6.1.3, Security Access and Control, prohibits entry of nonessential personnel into the PA after assembly has been called.

The inspector reviewed the relevant EPIP-20 requirements in effect at the time of the event, but could find no guidance in EPIP-20 prohibiting entry of non-essential personnel into the PA after assembly is called.

The inspector reviewed EPIP-24, Security, and found the procedure to be confusing on this issue.

Step 4.3.2.1 allows entry only of " personnel possessing a normal protected area keycard or personnel required to assist in stabilizing plant conditions," but did not exclude non-essential personnel and appeared to permit any badged person to enter the PA as during normal operations.

During the course of this inspection, the licensee identified to the inspector that one non-essential employee entered the PA after assembly was sounded and

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before accountability was reported.

b.

Section 6.6.1.2 of the approved Emergency Plan requires the dispatch of a team to search for and rescue unaccounted personnel.

This requirement was not incorporated into EPIP-20.

c.

Section 6.6.1.2 of the approved Emergency Plan provides a goal of one hour to accomplish OCA accountability. This guideline is not mentioned in EPIP-20.

The above procedural deficiencies appear to have contributed to the failure of the licensee to accomplish accountability within the required thirty minutes during the event.

Since TS 6.8.1 requires that licensee procedures implement the Emergency Plan, the failure of the procedures to implement the plan is an apparent violation of TS 6.8.1-(93-22-07).

6.

Exit Meetina An exit meeting was held on April 30, 1993, with members of the licensee staff identified in Paragraph 1 of this report. The items identified in this report were discussed at that time. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during the inspection.

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