IR 05000528/1994007
| ML17310B306 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/12/1994 |
| From: | Pellet J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17310B305 | List: |
| References | |
| 50-528-94-07, 50-528-94-7, 50-529-94-07, 50-529-94-7, 50-530-94-07, 50-530-94-7, NUDOCS 9405270058 | |
| Download: ML17310B306 (20) | |
Text
APPENDIX A U.
S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-528/94-07 50-529/94-07 50-530/94-07 Operating Licenses:
NPF-41 NPF-51 NPF-74 Licensee:
Arizona Public Service Company P.
0.
Box 53999, Station 9082 Phoenix, AZ 85072-3999 Facility Name:
Palo Verde Nuclear Generating Station, Units 1, 2,
and
Inspection At:
Maricopa County, Arizona Inspection Conducted:
March 28 through April 1, 1994 Inspectors:
G. Johnston, Senior Licensing Examiner J.
Lynch, SEA Inc. (Contractor)
Approved By:
Ins ection Summar e
et, C ie
,
Operations Branch Areas Ins ected Units
2 and
Routine, announced, inspection of the Palo Verde Nuclear Generating Station emergency operating procedures (EOPs)
revision process and procedures.
The inspection also included review of corrective actions taken by the licensee for previously identified inspection findings.
This inspection was to provide an evaluation of the overall adequacy and implementation of the licensee's program to write new EOPs conforming to the CE owners group format (CEN-152, Revision 3).
This included a review of the procedural incorporation and implementation of the Writer's Guide for EOPs.
Also reviewed was the licensee's schedule for milestones and completion dates, and plans for verification and validation of the new EOPs.
9405270058 940523 PDR
. ADOCK 05000528
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Results Units
2 and
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The operators were providing 'input and were participating in a process of using the EOPs during validation exercises on the simulator while on relief crews (Section 2.2).
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The licensee had put in place a steering committee to oversee the EOP revision project.
This provided each cognizant organization an opportunity to provide input to the project (Section 2.5).
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The quality systems review of the EOP revision process and EOPs was being conducted and planned in a manner to maintain independence for their function for oversight (Section 2.4).
The licensee did not consider the inclusion of NUREG-1358, Supplement
in the developmental documents for the Writer's Guide.
This inadvertent omission resulted in some Writer's Guide practices that were less than optimum (Section 2. 1).
The inspectors assessed the EOP revision project as an improvement over the licensee's previous efforts (Section 2.5).
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The initial drafts of EOPs were well prepared and supported the strategies and app'roach of, the CE Owners Group guidance (CEN-152, Revision 3) (Sections 2.1 and 2.5)
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Summar of Ins ection Findin s:
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There were no findings that were assigned a tracking number identified during the course of this inspection.
Attachment:
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Attachment - Persons Contacted and Exit Meeting
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DETAILS
EMERGENCY OPERATING PROCEDURES The licensee had internally committed to write new emergency operating procedures (EOPs)
in Hay 1993.
The licensee stated this intent to the NRC on August 2-6, 1993, during a root cause inspection ( Inspection Report 93-33)
focused on weak operator performance during requalification simulator examinations.
Later, in November 1993, during a management meeting in Reg'ion V,- the licensee discussed their EOP Re-write Plan.
The licensee had completed the Writer's Guide, the users guide and the verification and validation procedure at the time of this inspection.
The inspection focused on the implementation of these procedures and assessed the licensee's implementation of the EOP rev,ision process,
EMERGENCY OPERATING PROCEDURES REWRITE PROGRAM (42001)
Procedure 02PR-OOP01,
"Emergency Operating Procedures Program," established the policy for the organizational responsibilities for, structure of, and format of the emergency operating procedures (EOPs)
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The licensee had chosen to form an EOP steering committee to shepherd the process for the EOP revision project.
The procedure specified membership that included licensed operators from each unit, a shift technical advisor, a licensed operator training representative, and operations standards personnel.
guality systems also participated with an observer in attendance at each meeting.
The committee was established to facilitate clear direction and consistent operating philosophy for the use of the EOPs.
The determination of the nature of the procedures governing the EOP program and the resolution of issues about the EOPs were the primary functions of the committee.
2.1 Review of the EOP Writer's Guide Procedure 40OP-9AP15,
"Emergency Operating Procedure Writer's Guide," is the principal guidance used by the operations standards group to write the EOPs.
The inspectors examined the procedure and compared it to the guidance in NUREG-1358 Supplement 1,
"Lessons Learned from the Special Inspection Program for Emergency Operating Procedures,"
issued October 1992.
NUREG-1358 Supplement 1, Appendix B, "Checklists of Criteria for the Development of Emergency Operating Procedures and Support Procedures,"
describes criteria for the development of EOPs, and supporting procedures.
2,i. I EOP Writer's Guide Comparison with NUREG-1358 Supplement 1, Appendix B
Review of the EOP Writer's Guide showed numerous occasions of minor differences from the Appendix.
Additionally, while many Appendix B checklist items were addressed in plant documents other than the Writer's Guide, there were no references in the Writer's Guide to the appropriate informatio Qi
Twelve observations were provided to the EOP re-write coordinator and the manager of operations standards.
The most important of these were:
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NUREG-1358 Supplement 1, Appendix B, paragraph 1.2, thirteenth bullet stated that differentiation was to be made between sequentially performed lists and non-sequential lists.
The Writer's Guide in paragraph 4.4.7 provides only for non-sequential lists, but states the list should be written with the "preferred item first."
The licensee stated that lists would be non-sequential, and where sequential action was required, separate action steps would be used.
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NUREG-1358 Supplement 1 Appendix B, paragraph 1.3 stated that the Wri,ter's Guide is to differentiate among time-related, recurrent, concurrent, and equally acceptable action steps.
The Writer's Guide does not specify to differentiate among these types of steps.
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NUREG-1358 Supplement 1, Appendix B, paragraph 1 '
stated that when referencing or branching, the step number where the operator is to enter the referenced or branched procedure should be speci fied.
This guidance was not in the Writer's Guide.
The EOP Re-write Coordinator stated the licensee would consider each of the inspectors'bservations from the comparison between NUREG-1358, Supplement
and the Writer's Guide.
During discussions with the inspectors, the licensee representative indicated that NUREG-1358 Supplement 1 was not included in the developmental references and that their consultant did not consider the NUREG during their review.
The representative considered this an inadvertent oversight on the part of operations standards group and the steering committee.
He stated that further reviews of the developmental procedures would include NUREG-1358, Supplement
as a basis document.
2.1.2 EOP Writer's Guide Analysis The inspectors noted four specific inconsistences between sections of the Writer's Guide.
The most important was that the Writer's Guide, paragraph 4.4. 16 addresses the use of unit specific steps.
This concept was different from the philosophy addressed in paragraph 4,5. 16.
The use of unit specific steps may lead to difficulties in operation through operator confusion in high stress environments.
All of the inconsistencies were brought to the licensee's attention, Only two procedures had completed the first draft stage.
"Standard Post Trip Actions," and EOP 40EP-9E002,
"Reactor Trip."
The inspectors examined the structure of the procedures to determine how the Writer's Guide was used; however, the content of the procedure was not verified against CEN-152 'he inspectors noted that there was an identifiable deviation from the Writer's Guide in the use of a non-sequential list format of procedural steps when actions required a series of substeps.
The inspectors did not view this as a breakdown in the review process, as the
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licensee representative noted that the procedures had not undergone a
verification review.
The procedures were in the expected format and had conformed to the Writer's Guide, except for the above noted discrepancy.
The inspectors determined the writing process governed by the Writer's Guide would produce quality procedures.
2.2 Verification and Validation Procedure Procedure 40AC-90PII,
"Emergency Operating Procedures Verification and Validation [V&V],"governs the licensee's process of reviewing the accuracy and validity of the EOPs.
The inspectors examined the procedure and compared it to the guidance in NUREG-1358 Supplement 1 "Lessons Learned from the Special Inspection Program for Emergency Operating Procedures."
2.2.
EOP V&V Procedure Comparison with NUREG-1358 Supplement 1, Appendix B
NUREG-1358 Supplement 1 Appendix B, paragraph 3.4, second bullet stated that V&V "...ensures that actions can be physically performed (i.e., considers access, lighting and other environmental factors, availability of necessary equipment, and communications)."
This process should include retrieval of required tools and performing or simulating the actions with the minimum lighting available, including, if required, portable lighting.
Procedure Appendix 0,
"Walkdown," Step 11 did not provide for a review of directions to the location of equipment.
Also, there did not appear to be consideration of other environmental factors (such as heat, high moisture, or steam leaks).
Access was not addressed (includes need for a ladder, locked passages, and cbstructions such as pipes or cable trays).
There also was a lack of
'ssessment of communications factors, such as determining noise levels and preferred and alternate communications hardware.
NUREG-1358 Supplement 1 Appendix B, paragraph 3.5, second bullet stated that dynamic validation scenarios should address single, multiple, concurrent, and sequential failures.
V&V Procedure Section 3.6.2 did not state that all potential paths in the EOPs would be addressed.
The licensee stated that the intent was to exercise each possible path with emphasis on transitions within and out of each EOP.
NUREG-1358 Supplement 1 Appendix B, paragraph 3.5, fifth bullet stated that validation should be conducted using the minimum shift complement allowed.
Section 3.6.3 only required assumption of ".
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. the same number and job positions of qualified personnel required to perform the procedure under the conditions assumed by the procedure."
The licensee stated that the intent was to conduct all exercises with a varying complement of personnel.
The licensee representative further stated that the process in the past had included only the minimum shift crew complement.
The representative further stated that the licensee wanted to evaluate the procedures with a normal crew complement as well as a minimum complemen.2.2 EOP VIIV Procedure Analysis VSV Procedure, Appendix C,
appeared to be a generic procedure annotated for use on EOPs.
The licensee stated that the procedure also applies to the current procedures which were of a different format.
Therefore, the procedure was written to accommodate both the developmental EOPs and the EOPs that are currently in use.
Appendix D stated that the verification and validation coordinator would decide whether operations standards observation was required for a walkdown review.
The inspectors discussed this approach with licensee representatives, who stated that the policy was to have an operations standards observer for all walkdowns of this revision of the EOPs.
The procedure and checklists did not describe how to accomplish tasks for walkdowns or dynamic simulator validations.
However, the checklists gave gh information to deduce what will be required in most instances, The exception was for communications, where there was no specific guidance on what to do.
Some tasks require substantial communication and required communications VIIV.
The communication required for each procedure can be critical to the successful completion of the task.
The licensee representative stated that the issues relating to access, equipment required, and environmental conditions will be addressed.
The representative indicated that the issue of communications was not considered and that this was a significant oversight.
The representative indicated that he would consider adding communications to the Appendix 0 review.
Appendix F, "Operations Training VEY Checklist," required that the operations training department review job performance measures (JPHs)
and other Training Department documents.
The inspectors interviewed the operations training manager and the supervisor of operations continuing training to determine the f training involvement with verification and validation.
The training manager stated the JPHs will be updated on a case by case basis.
e is.
The inspectors asked if the lesson plans and job task analyses will also be updated to reflect changes to the EOPs.
The supervisor of continuing training indicated that the reviews will examine any changes necessary.
He elaborated on the task analyses by stating that they did not foresee substantial changes because the new EOPs were not expected to introduce new tasks.
The operators were participating in an ongoing devaIoomental validation program.
The operators were providing input and are participating in is ad two a process of using the EOPs during their time on relief crews.
This ha wo beneficial effects:
participation by a large number of operators in development of the EOPs, and familiarization with a
new format before substantial training is conducted.
The licensee representatives stated that the current high intensity training program for operator performance enhancement with the current EOPs will continue until the training on the new EOPs is initiate O I
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The inspectors concluded that the V&V procedure did not provide clear and urambiguous direction for the evaluation of environmental conditions'r physical access, and provided no direction for communications evaluation.
The inspectors noted that the procedure checklist specifies verifying that
"radiological conditions or, personnel hazards would not prevent performance of local operations,"
without providing actual criteria.
The guidance in NUREG-1358, Supplement 1 stated, in part, that VEV for in-plant activities should consider access, lighting and other environmental factors, availability of necessary equipment, and communications'he inspectors discussed this at length with the EOP coordinator, who indicated that the finding would be considered.
2.3 40DP-9AP16
"Emer enc 0 eratin Procedures Users Guide" The Users Guide was written in advance of writing the EOPs.
The inspectors determined that this ensured that the EOPs implemented the strategy of the Users Guide, rather than being a guide written to describe how an already complete set of EOPs should be used.
The licensee's prior practice had been to produce the Users Guide after the EOPs had been written.
The Users Guide was a description of how to use the EOPs beyond the basic conduct of operations procedure.
Section 3. 14.3 de'scribed using an "average reading" when using instrumentation affected by harsh containment conditions.
Licensee representatives described to the inspectors how the "average reading" was made by the operators.
The methodology that was taught to the operators discounted the high and low indications and averaged the remaining indications.
Section 4.1.2.2 specified that the control room supervisor (CRS) perform the event diagnosis.
The step, however, does not indicate that the CRS will seek concurrence from the shift supervisor or the STA in the diagnosis.
The licensee indicated that the safety function status checks performed by the STA will confirm the diagnosis.
The inspectors concluded that the guide implemented accepted methods for using EOPs.
The inspectors noted that a prepared Users Guide in place before the EOPs were written was a prudent step that would assist in making consistent interpretations, 2 '
EOP Re-write Pro 'ect Plan The inspectors reviewed the EOP re-write plan with the EOP coordinator to determine the licensee's expected schedule and the projected resource commitment.
Overall, the plan appeared to be within the capabilities of the current licensee resources applied.
The projected date for the approval of the EOPs was Hay 31, 1995, with the implementation projected date of August 25, 1995, following -,operator training.
Although no extra time was scheduled, the EOP Coordinator indicated that sufficient time was allocated for each phase of the development process to ensure timely completions The inspectors noted that the addition of a second simulator should further reduce any
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potential impact on other activities by the development process't the time of the inspection, two procedures were largely finished, pending completion of required reviews.
The inspectors discussed quality systems participation in the EOP re-write program with the assigned quality systems reviewer and the manager of quality systems.
The inspectors noted the description of the quality systems reviewer's responsibility in the EOP re-write plan "...provides independent oversight of the EOP re-write to assure that regulatory requirements are met..."
However, the description of the assignment for this responsibility stated,
"The quality systems reviewer will receive review copies of each procedure and be invited to observe all validations.
guality Systems will do an inline review of the re-written EOPs after the technical review is completed."
Therefore, the reviewer could be considered part of the review process, as an "inline" reviewer, rather than independent of the process.
However, internal quality systems planning documents indicated a close observation of the EOP re-write project was underway and that the reviewer would not be the only person assigned to the EOP re-write project.
The inspectors determined that the quality systems plans represent a concerted effort to monitor the project.
However, the inspectors noted that the description of the quality systems reviewer's responsibility was in conflict with the described assignment.
The licensee representative agreed with the inspectors and indicated that the plan would be addressed by the EOP steering committee.
2.5 Conclusions The inspectors concluded that the Writer's Guide provides the guidance necessary to produce EOPs that meet the expectations of the NRC
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The licensee's omission of NUREG-1358, Supplement 1 from the developmental documents for the Writer's Guide did not result in significant reduction of the quality of the program.
The EOP coordinator stated that NUREG-1358, Supplement 1 would be included in the reference documents for the EOP revision process.
The verification and validation portion of the EOP re-write project had not been implemented at the time of the inspection.
The inspectors review of the verification and validation procedure concluded that the licensee had considered most of the factors specified in NUREG-1358, Supplement 1, with the exception of human factor's involvement with the EOPs.
The most serious example of this was that the procedure did not address all possible impacts on local operations of the EOPs.
This was exemplified by the fact that the communication was not addressed as an item to be covered in the in-plant walkdowns.
The impact on operations training at the time of the inspection was minimal.
The availability of two simulators during the later phases of procedure development should ensure that little or no impact on either training or procedure development and validation occur,
The participation of relief crews and other operators in a developmental validation process provides considerable operations input to the project.
The inspectors concluded that their participation also will function to provide substantial familiarization for the operators.
The familiarization is important because of the significant format differences between the current EOPs and the developmental EOPs.
The inspectors concluded that licensee management was sensitive to the issue of quality systems independence in the oversight function.
The inspectors determined that the quality assurance organization has plans in place to independently monitor the EOP revision activitie I I
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ATTACHMENT
PERSONS CONTACTED Arizona Public Service Com an APS
- R. Bouquot, Supervisor, guality Audits tR.
Cherba, Manager, guality Systems
- P. Coffin, Engineer, Nuclear Regulatory Affairs tJ.
Dennis, Hanger, Operations Standards tL. Florence, Senior Advisor, Operations Standards (EOP Coordinator)
- R. Gouge, Director, Plant Support
- N. Henry, Supervisor, Operations Standards tJ.
Levine, Vice President, Nuclear Production
- R. Middleton, Supervisor, Operations, Unit 2 tF. Riedel, Manager, Operations, Unit
- G. Shanker, Manager, (}uality Assurance tP. Wiley, Manager, Operations, Unit 2 Others tR. Henry, Site Representative, Salt River Project tF.
Gowers, Site Representative, El Paso Electric
Denotes personnel in attendance at the Exit meeting on April 1, 1994.
t Denotes personnel in attendance at the pre-exit meeting on March 31, 1994.
In addition to the personnel listed above, the inspectors contacted other personnel during this inspection period.
EXIT MEETING An exit meeting was conducted on April 1, 1994.
During this meeting, the inspectors summarized the scope and findings of the report.
The licensee acknowledged the inspection findings documented in this report.
The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector I