IR 05000528/1996018
| ML17312B271 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/06/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17312B270 | List: |
| References | |
| 50-528-96-18, 50-529-96-18, 50-530-96-18, NUDOCS 9703050424 | |
| Download: ML17312B271 (39) | |
Text
e ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-528 50-529 50-530 NPF-41 NPF-51 NPF-74 50-528/96-1 8 50-529/96-1 8 50-530/96-1 8 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona December 29, 1996 through February 8, 1997 K. Johnston, Senior Resident Inspector D. Garcia, Resident Inspector D. Carter; Resident Inspector D. Corporandy, Project Inspector B. Olson, Project Inspector Dennis F. Kirsch, Chief, Reactor Projects Branch F ATTACHMENT:
Supplemental Information 9703050424 970206 PDR ADOCK 05000528
e EXECUTIVE SUMMARY Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report 50-528/96-1 8; 50-529/96-1 8; 50-530/96-1 8
~oeratione On two occasions, the inspectors noted excellent response to unexpected control room annunciators.
Operators implemented expectations regarding alarm acknowledgment and response procedure use (Section 01.1).
Operations had not provided clear expectations for auxiliary operator (AO) shift manning requirements, including AO relief requirements and the definition of an AO available to a unit (Section 06.1).
Maintenance The Unit 2 shift supervisor (SS) closely followed the performance of a routine turbine driven auxiliary feedwater pump test and took thorough and proper actions to resolve all issues (Section M1.3).
The auxiliary feedwater system engineer demonstrated mixed performance during a turbine driven auxiliary feedwater pump test.
The engineer stopped the vibration technician from taking readings prior to the required procedure step, but was not thoroughly familiar with the body-to-bonnet leak corrective action status (Section M1.33).
~
Regional managers, during a preoutage tour of Unit 3, observed excellent material condition and cleanliness.
Additionally, control room activities were professionally conducted and control room panels were in excellent condition (Section M2.1).
~
Nuclear Assurance performed an excellent audit of the Measuring and Test Equipment (MSTE) program, identifying several substantive issues, Licensee management expressed significant concerns regarding the program and pledged that necessary management attention would be focused on program improvements (Section M7.1).
~En ineerin
~
The licensee did not assure that actions were completed by the required dates for testing the spent fuel pool cooling (PC) system, assuring consistency between Updated Final Safety Analysis Report (UFSAR) descriptions and actual plant
.
operation, and resolving discrepancies between the UFSAR and PC system operations.
The licensee took action to revise the implementation dates after the issue was brought to their attention (Section E8.1).
e
-2-Although overall RP throughout the three units was good, the inspectors identified a number of minor examples concerning attention to detail in the radiological controls area (Section R2.1).
The licensee demonstrated highly positive initiatives in their emphasis placed on controlling the spread of contamination, the decontamination of contaminated areas, and the material condition of systems containing radioactive material (Section R2.2).
~
Two events during protected area ingress highlighted weaknesses in communications between security officers monitoring ingress.
Additionally, nitrate detector performance problems presented unnecessary challenges to security officers monitoring ingress (Section S4.1).
Re ort Details Summar of Plant Status Units 1 and 2 operated throughout the inspection period at full power with no significant events.
Unit 3 began the inspection period at 100 percent power.
Cn January 27, the unit began an end-of-core life power coastdown for Refueling Outage 3R6. At the end of the inspection period the unit was at approximately 88 percent power.
I. 0 erations
Conduct of Operations (71707)
01.1 General Comments Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations.
In general, the conduct of operations was professionally done and safety conscious.
As noted in the specific observations discussed below, the inspectors observed excellent response to unexpected control room annunciators.
01.2 0 erator Res onse to Unex ected Annunciators Unit 3 On January 21, the inspectors observed the control room staff respond to unexpected alarmed annunciators.
Instrumentation and control personnel were in the process of performing plant protection system (PPS) surveillance test Procedure 36ST-9SB21, "PPS Loop Calibrations."
Specifically, they were performing the Channel D, low pressurizer pressure parameter portion of the procedure when a spurious trip of the low departure from nucleate boiling ratio parameter for Channel D occurred.
The control room received alarmed annunciators in response to this anomaly..
The reactor operators (ROs) announced the annunciators and the control room supervisor acknowledged the alarms.
The control room supervisor stopped all work on the PPS, directed the ROs to complete the required actions of the associated alarm response procedures and to verify the status of other plant parameters.
A RO tripped the associated channel parameters in accordance with Technical Specification requirements.
The shift technical advisor initiated a condition report/disposition request (CRDR) to determine the root cause of the spurious trip.
The inspectors found that the operator actions in response to these annunciators met the expectations established in the conduct of shift operations procedure.
J 01.3 Diesel Generator Surveillance Test Observation Unit 2 On January 7, the inspectors observed the performance of monthly surveillance Test 42ST-2DG02, "Diesel Generator (DG) B Test 4.8.1.1.2.a."
Control room operators demonstrated verbatim procedural compliance with good commarid and
-2-control.
During the surveillance, the control board annunciator for DG room ventilation trouble alarmed.
This was caused by cold outside air temperature and the running DG room exhaust fan.
Operators properly referenced and followed the annunciator response procedure.
The inspectors determined these actions to be appropriate.
Operator performance was strong.
Operations Organization and Administration 06.1 Control Room Staffin a.
Ins ection Sco e 71707 On January 22, the inspectors questioned the SS about whether or not the operations staff met the administrative minimum staffing requirements for AOs.
b.
Observations and Findin s On January 22, the inspectors were aware that some of the AOs were attending training courses outside the protected area.
The inspectors had attended the morning shift brief in the Unit 3 control room earlier that day and during the brief, three of the four onshift AOs indicated that they would be attending training.
Upon questioning, the SS stated that they met the minimum staffing, requirements, although the AOs were not immediately available in the power block.
He indicated that, if needed, he had other qualified operators working in work control that could fillthe positions, and he could borrow manpower from the other units.
The inspectors reviewed Procedure 40DP-9OP02, "Conduct of Shift Operations," and determined that it clearly stated the requirements for minimum staffing.
However, the procedure did not define what constitutes an available AO, did not fully address AO relief, and was not clear as to the unit specific requirements.
The inspectors discussed this with the Unit 3 Operations Department Leader and he agreed that the procedure was not clear.
He stated that the procedure would be reviewed and revised as appropriate to clarify staffing requirements.
c ~
Conclusions Operations had not provided clear expectations for AO shift manning requirements, including AO relief requirements and the definition of an AO available to a uni h
-3-II. Maintenance M1 Conduct of Maintenance M1
~ 1 General Comments on Maintenance Activities a.
Ins ection Sco e 62707 The inspectors observed all or portions of the following work activities:
Work Order (WO) 786486:
Repair hydraulic fluid leak from Feedwater Isolation Valve 137 adtuator (Unit 1)
WO 780801:
Battery Charger BD inspect proper operation (Unit 3)
b.
Observations and Findin s The inspectors found the work performed under these activities to be professional and thorough.
Technicians were experienced and knowledgeable of their assigned tasks and demonstrated good communications betwe'en work groups.
During the troubleshooting to determine the source of the hydraulic fluid leak on Feedwater Isolation Valve 137, the maintenance engineer demonstrated a questioning attitude when he stopped work to question why seam welded tubing was used in one of the hydraulic fluid lines to the valve actuator.
'After researching the vendor specifications, the maintenance engineer confirmed that seam welded tubing could be used in lieu of seamless tubing. Work was then recommenced.
M1.2 General Comments on Surveillance Activities a.'ns ection Sco e 61726 The inspectors observed all or portions of the following surveillance activities:
'l
~
43ST-3DG02, Revision 25:
Diesel Generator B Test 4.8.1
~ 1.2.a (Unit 3)
~
73ST-9SP01, Revision 5: Essential Spray Pond Pumps-Inservice Test (Unit 3)
~
36ST-9SB21, Revision 6:
PPS Input Loop Calibration for parameter 6, Lo Pressurizer Press (Unit 3)
The inspectors found that these surveillance activities were performed acceptably and as specified by applicable procedures.
In addition, see the specific discussions of surveillance tests observed under 01.3 and M I
M1.3 Turbine Driven Auxiliar Feedwater Pum Surveillance Testin Unit 2 a.
Ins ection Sco e 61726 On January 21, the inspectors observed the performance of the routine inservice test of the Unit 2 turbine driven auxiliary feedwater pump (73ST-9AF02, Rev 5).
During the surveillance. test the inspectors observed the following WOs being performed:
~
WO 780710:
monitoring of turbine speed and governor control signals
~
WO 779244:
oil sampling
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WO 778599:
vibration monitoring-b.
Observations and Findin s During the start of the turbine driven auxiliary feedwater pump, the inspectors observed a body-to-bonnet steam leak on the trip/throttle valve.
The system engineer who was present stated that this leak was identified on an existing work request (WR) and was scheduled to be repaired at the next outage.
The inspectors questioned the SS about the leak and was informed that there was no existing WR for the repair of this leak.
The SS stated that he had written a new WR to address the body-to-bonnet leak observed on the valve, The inspectors and SS, who was making a tour of the area at the time, observed mechanics adding oil to the turbine bearing prior to drawing their oil samples.
The oil sampling WO stated that adding oil to the bearing was allowed if sampling would lower the oil level below the normal operating level.. The SS subsequently initiated CRDR 2-7-0029 to address the adding of oil to the turbine driven auxiliary feedwater prior to sampling.
Additionally, the SS had questioned the interpretation of the oil level indica'tor and had included this issue in the CRDR.
The inspectors observed the vibration technician ask the AO if he could take a vibration reading.
The AO acknowledged the vibration technician, who proceeded to take the readings.
The system engineer stopped the vibration technician and asked him if it was at the proper time in the procedure.
On further review, they determined that the vibration reading was not appropriate since it required steady
'tate turbine driven auxiliary feedwater conditions and the control room was still adjusting pump speed.
The SS stated he had talked to the AO after the surveillance and reviewed the procedure with him to clarify when a vibration reading can be taken during the procedure.
c.
Conclusions The Unit 2 SS closely followed the performance of a routine turbine driven auxiliary feedwater pump test and took thorough and proper actions to resolve all issue The auxiliary feedwater system engineer demonstrated mixed performance during the surveillance.
The engineer stopped the vibration technician from taking readings prior to the required procedure step, but was.-.ot thoroughly familiar with the body-to-bonnet leak corrective action status.
iVi2 Maintenance and IVlaterial Condition of Facilities and Equipment
.M2.1 Preouta e Tour'of Unit 3 71707 N
Members of regional management conducted an extensive tour of Unit 3. The managers found that the unit demonstrated an excellent material condition and cleanliness.
There were few leaks, all of which were provided with well implemented catch drains, and the contaminated areas had been minimized by extensive cleanup, including washdown of rooms, where warranted.
The managers found that control room activities were professionally conducted.
The control room panels had few tags and had essentially a 'black board'or annunciators.
IVI7 Quality Assurance in IVlaintenance Activities M7.1 Nuclear Assurance Audit of Control of M&TE a.
Ins ection Sco e 40500 The inspectors reviewed Nuclear Assurance Audit Report 96-019, documenting an audit of the control of M&TE, performed between November 5-16, 1996.
The inspectors discussed the results'of the audit with the audit team leader, the Director of Nuclear Assurance, and the Vice President, Nuclear Production.
b.
Observations and Findin s The inspectors found that the audit was very thorough and had identified substantive findings indicating areas requiring management attention..The audit identified the following issues:
~
Not all of the applicable UFSAR commitments concerning M&TEhad been implemented into M&TEprogram procedures.
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Procedures did not adequately establish that the impact of laboratory. and field environmental conditions were factored into the calibration and use of M&T M5TE inaccuracies were not consistently accounted for in the performance of tests and inspections that did not involve the calibration of permanent plant instruments.
Weaknesses were found in the evaluation of nonconforming and out of tolerance MSTE which had been previously used.
I As a result of the audit, Nuclear Assurance initiated 18 CRDRs to document the issues and assure corrective actions.
The line organization responded to a number of issues raised by the audit concerning their potential impact on the operability of plant equipment.
In all cases, the operability of plant equipment was found to have been maintained.
The inspectors discussed the audit with the Director of Nuclear Assurance and the Vice President, Nuclear Production, to determine the significance and priority placed.
on the program weaknesses identified by the audit.
Both the Director and Vice President expressed that they had significant concerns regarding the effectiveness of the MRTE program, that they were evaluating the line responses to the audit.
They stated that management attention would be focused on the MSTE program to assure improvements were effected.
The inspectors noted that Nuclear Assurance placed the M5TE program weakness on their "Top Ten" site issues list. The Senior Vice President, Nuclear, assured the inspectors that the program would receive the attention necessary to effect consistent improved performance.
The issues of the MME audit identified several failures to follow program procedure requirements.
Followup review of licensee corrective actions related to MARIE program weaknesses will be conducted and tracked as an inspection followup item (IFI 50-528/9618-01).
Conclusions Nuclear Assurance performed an excellent audit of the M&TEprogram, identifying several substantive issues.
Licensee management expressed significant concerns regarding the program and pledged that necessary management attention would be focused on program improvement 'I
-7-III. En ineerin E2 Engineering Support of Facilities and Equipmant E2.1 Review of Facilit and E ui ment Conformance to U dated Final Safet Anal sis Re ort UFSAR Descri tion 71707 37551 A recent discovery of a licensee operating a facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures, and parameters to the UFSAR description, While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected.
The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures, and parameters.
No anomalies between the UFSAR and operation of the facility were identified.
E8 E8.1 Miscellaneous Engineering Issues (92903)
0 en Ins ection Followu Item 50-528 96007-03: corrective actions associated with a survey of the Palo Verde spent fuel PC system.'.
Observations and Findin s In an August 6, 1996, letter to the NRC, the licensee stated their intent to:
1.
Implement routine monitoring of PC system performance by including the PC heat exchangers, pumps, and valves in appropriate plant monitoring programs by December 31, 1996.
2.
Correct the discrepancy between the UFSAR and Procedure 41OP-1PC01,
"Spent Fuel Pool Cooling," regarding the number of PC pumps needed for
~ various conditions, by January 31, 1997.
3.
Implement the clarifications to enhance the consistency between actual plant operation and UFSAR descriptions by January 31, 1997.
With regard to the first corrective action, the licensee had accomplished several actions involving component monitoring but had not fully developed a method for monitoring pump performance due to problems with measuring pump flow. The PC piping had not previously been instrumented to measure flow and the licensee was having difficultyobtaining consistent measurements using a clamp-on flowmeter.
This was thought to be due, primarily, to the piping configuration which lacked a sufficient length of straight run, a prerequisite for accurate flow measuremen With regard to the second and third corrective actions, the licensee had identified several inconsistencies between the UFSAR and actual plant operation but had not finished its review process to complete the actions.
On February 5, 1997, the licensee submitted a revised schedule for the implementation of these corrective actions.
This issue remains open pending evaluation of the licensee's corrective actions.
Conclusions The licensee did not assure that corrective actions were completed by the required dates for testing the PC system, assuring consistency between UFSAR descriptions and actual plant operation, and resolving discrepancies between the UFSAR and PC system operations.
The licensee took action to revise the corrective action implementation dates after the issue was brought to their attention.
Closed Ins ection Followu Item 50-528 94020-04: UFSAR not updated following two design changes.
The NRC project manager identified that the UFSAR had not been updated for two design changes which had been completed a year prior to the inspection.
In response to the inspectors'indings, the licensee initiated a CRDR to ascertain if the findings were indicative of a programmatic weakness.
The licensee's mechanism for incorporating pertinent information from design change packages (DCPs) into the UFSAR is a Draft Licensing Document Change Request (LDCR) ~ The licensee found that the LDCRs for the two DCPs in question had not been implemented, because the DCPs had not been sufficiently completed for the LDCR incorporation to have occurred.
However, further review by the licensee identified that LDCRs from some completed DCPs had not been incorporated in the UFSAR. This licensee identified issue is being treated as a noncited violation consistent with Section Vll of the NRC Enforcement Polic
.
(NCV 50-528; 50-529; 50-530/96018-02)
The licensee identified the root cause as human error due to noncompliance with procedural requirements.
The proposed corrective actions were:
(1) to review the design change documents back to 1988 that could change the UFSAR (1988 was the year of the first UFSAR issue) and (2) to require that Licensing be provided with the LDCR copy during DCP preparation in order that a tracking number be assigned.
The inspectors concluded that the licensee's root cause evaluation and proposed corrective actions appeared appropriate and verified that the corrective actions had been accomplished.
In a letter dated February 6, 1997, the licensee described their initiative to review the UFSAR. They planned to verify plant design, operating, testing, and configuration information and descriptions contained in the UFSAR against the as-built, as-operated, and as-tested plant, as well as the reconstituted design basis.
The inspectors considered that these actions, in addition to the corrective actions discussed above, were responsive to the issues of UFSAR accurac t
-9-E8.3 Closed Licensee Event Re ort LER 50-528 93011 Rev. 0: potential safety-related equipment problems due to degraded grid voltage.
This LER is being administratively closed.
Revisions 0 and 1 to the LER were reviewed in NRC Inspection Report 50-528/95-21; 50-529/95-21;and 50-530/95-21
~ Revision 2 to the LER remains open and was discussed in NRC Inspection Report 50-528/96-17; 50-529/96-17; and 50-530/96-17.
E8.4 Closed LER 50-528 95007 Revision 0: adverse affect of low bench set on Fisher air operated letdown/containment isolation valves.
This LER is being administratively closed.
Revisions 0 and 1 to the LER were reviewed in NRC Inspection Report 50-528/96-16; 50-529/96-16;and 50-530/96-16.
Revision 1 to the LER remains open.
E8.5 Closed LER 50-528 95010 Revision 0: equipment'qualification of air handling unit causes essential cooling water pump to become inoperable.
This LER is being administratively closed.
This issue will be reviewed through followup of Revision 1 to the LER, which remains open.
IV. Plant Su ort k
e R2 Status of RP and Chemistry Facilities and Equipment R2.1 S stem Walkdown Observations a.
Ins ection Sco e 71750 The inspectors conducted routine tours of the RCA in each unit, including tours of several high radiation areas (HRAs). The inspectors interviewed radiation protection technicians (RPTs) and reviewed RP procedures.
b.
Observations and Findin s In general, the inspectors found good conditions in the RCA's and noted general improvements since mid-1996. The inspectors noted the following minor deficiencies:
~
The inspectors questioned a RPT as to why the lower level of the Unit 1 Train B
'ow pressure safety injection pump room was posted as a HRA when the most current survey did not appear to indicate any 12 inch readings greater than 40 mrem/hr.
The previous months survey map indicated a 1500 mrem/hr hot spot adjacent to the pump.
The inspectors, accompanied by a RPT found a 1600 mrem/hr hot spot near the pumps vent piping. Upon conducting an interview with the RPT who performed the survey and further review of the survey maps, RP management determined that the hot spot had been surveyed, but was not clearly indicated on the map.
The inspectors concurred that the hot spot information did appear on the map.
However, given the lack of clarity of the information and the fact that this one hot spot was the reason the area
-1 0-was considered a HRA, the inspectors expressed concern that the survey map could be misleading.
RP management agreed and took appropriate corrective action.
The inspectors found two different radiological posting maps to the same heat exchanger, room at different doors.
One of the maps did not have a contamination area and a high contamination area clearly labeled even though the areas were marked off on the map.
This discrepancy was identified to RP who took appropriate action.
The inspectors toured the west containment piping penetration area where letdown exits containment with a RPT to verify dose rates.
Although only one small area on the letdown line indicated readings of 110 mrem/hr on contact and 20 mrem/hr at 12 inches, the entire area was posted as a HRA. While touring the area, the inspectorsfound a valve and its associated pipe cap leaking on to the floor inside a high contamination area.
The inspectors informed the control room and a WR was initiated. The inspectors found that the posting of this area was very conservative and considered that this type of posting could discourage routine operations and RP tours of the area and delay the identification of deficiencies similar to the identified leaking pipe cap.
RP management acknowledged this concern and stated that they planned to assess posting practices.
In the 140 foot elevation of the Unit 3 fuel handling building, the inspectors found a clear plastic bag which contained several new light bulbs that was stored with other equipment.
The inspectors noted that a sign was posted at the entrance to the fuel building stating: "No clear plastic beyond this point."
The purpose of this expectation was to ensure that clear plastic is not introduced into the spent fuel pool where it may not be visible. The inspectors discussed the observations with the operations director, who initiated actions to inspect for clear plastic and heighten worker awareness.
Additionally, the licensee planned to review the possibility of eliminating or reducing site use of clear plastic bags.
On the 140 foot elevation of the Unit 3 auxiliary building, near the containment personnel entrance, the inspectors found a white plastic glove attached to a decontamination station end pipe.
The glove was used as a drip catch for the upstream leaking, uncontaminated, demineralized water valve DWN-V060. The valve did not have a WR. The glove had a leak in one of the fingers and the water was dripping onto the floor. The licensee took appropriate actions in response to this finding.
c.
Conclusions Although overall RP throughout the three units was good, the inspectors identified a number of minor examples concerning weakness in attention to detail in the RC e R2.2 Contamination Control a.
Ins ection Sco e 71750 The inspectors conducted RCA tours and held discussions with RP,management on their initiatives to control the spread of contamination.
b.
Observations and Findin s I
The inspectors conducted tours of the RCA in all.three units and noticed absoibent material, labeled as a contamination control device, wrapped around several valve packing gland areas.
The inspectors questioned RP management on these new contamination control devices. 'The inspectors were informed that this new program was developed to help control the spread of contamination from minor valve stem leakage.
These devices prevent dried boron from flaking off and falling away from the valve.
The inspectors determined this to be a positive contamination control practice.
The inspectors also noticed entire rooms and components being wrapped in preparation to being washed down with high pressure water.
The inspectors were informed that this effort was being performed to remove any loose contamination from above and decontaminate large areas to reduce contaminated square footage.
RP had coordinated the wrapping'of equipment with the operations department when safety related components would be affected.
The licensee noted that these efforts had removed a substantial amount of surface contamination and foreign material, which had built up over time.
The licensee has reorganized portions of the Utilities department and the decontamination technicians have been transferred to the RP.department.
This effort, along with changes in responsibility in area ownership, was done to allow RP to quickly and effectively manage material and housekeeping deficiencies.
c.
Conclusions The licensee demonstrated highly positive initiatives in their emphasis placed on controlling the spread of contamination,.the decontamination of contaminated areas, and the material condition of'systems containing radioactive material.'8 Miscellaneous RP and Chemistry Issues R8.1 Com liance with 10 CFR 70.24 Re uirements for Criticalit Nlonitorin a.
Ins ection Sco e 71750 10 CFR 70.24 requires that licensee's provide monitoring systems capable of detecting
. a criticality in each area where special nuclear material is handled, used, arid stored.
Additionally, it requires that the licensee maintain emergency procedures which include
-1 2-the performance of evacuation drills for these areas.
It wd'nitially believed that PVNGS may not have had criticality monitors that satisfied the requirements of 10 CFR 70.24.
The inspectors reviewed the status of licensee's compliance with these requirements.
Observations and Findin s UFSAR Section 11.5.1.1.3 stated that area monitoring systems met the requirements of 10 CFR 70.24 requirements.
The licensee considered that the only area requiring the monitoring specified by 10 CFR 70.24 was the fuel handling building.
Detectors RU-19 (the new fuel area monitor) and RU-31 (the fuel pool area monitor)
were credited by the licensee as meeting the hardware requirements of 10 CFR 70.24 (a) (1). The inspectors noted that the detectors were included in the Technical Specifications and that the licensee had developed a calculation, which assured that these detectors met the requirements of 10 CFR 70.24.
10 CFR 70.24 also required that the licensee maintain procedures to ensure that all personnel withdraw to an area of safety upon the sounding of the alarm and that these procedures include the conduct of drills to familiarize personnel with the evacuation plan.
The licensee, in response to industry events, initiated a CRDR 9-6-0866 in August, 1996, to address their compliance with the procedure requirements of 10 CFR 70.24.
The licensee identified that although they had procedures in place and provided access training to ensure that all personnel withdraw to an area of safety upon the sounding of area radiation monitors, they did not include the conduct of drills in these procedures.
To determine appropriate corrective actions, the licensee reviewed Regulatory Guide 8.12, which provides guidance for compliance with 10 CFR 70.24. They determined that they had established appropriate geometric spacing to preclude accidental criticality, both in the new fuel storage*racks and in their handling procedures for new fuel, and that according to Regulatory Guide 8.12, Section C.1, it would be appropriate to request an exemption.
The licensee had initiated actions to submit an exemption request by the end of March 1997, which was consistent with
'he guidance provided in Regulatory Guide 8.12.
The inspectors concluded that the licensee met the requirements of 10 CFR 70.24 with the exception of having procedures requiring drills. The inspectors determined that the failure to have procedures requiring drills was a licensee identified noncited violation in accordance with Section Vll of the NRC Enforcement Policy (50-528;529;530/96018-03).
The licensee had accomplished several mitigative measures:
~
established appropriate geometric spacing making the chances of an accidental criticality remote,
-1 3-maintained radiation monitoring which would provide alarms in the event of an accidental criticality, established procedures and training to ensure personnel evacuate to a safe area in response to an alarm, In addition, the licensee planned to submit an exemption request from the requirements of 10 CFR 70.24 consistent with Regulatory Guide 8.12.
S4 Security and Safeguards Staff Knowledge and Performance S4.1 Securit Alarms Durin In ress a.
Ins ection Sco e 71750 On January 16, 1997, the inspectors observed security personnel respond to an alarm on a nitrates detector.
The inspectors observed security operations, conducted interviews, and reviewed security procedures.
b.
Observations and Findin s On January 16, 1997, at approximately 6:45 a.m., while processing through security ingress, the inspectors observed an alarm on nitrate detector 1, the detector he was waiting to enter.
The alarm was announced by the security. officer manning Post 3, the post inside the protected area monitoring ingress activities and equipment through security glass.
The inspectors were concerned that the alarm had been caused by the individual who had preceded them through the detector.
The inspectors did not observe an immediate response from th'e security officers to identify and prevent this individual from entering the protected area.
The inspectors discussed this concern with the security officer at Post 4, the post between the nitrate detectors and the turnstiles and the security sergeant responding to address these concerns.
The Post 4 security officer said he did not see the alarm as he was down at the other end of the detectors. The security sergeant subsequently proceeded to Post 3 and questioned the Post 3 security officer, whose station was in close proximity and in direct view of nitrate detector 1.
The security sergeant returned and informed the inspectors that the Post 3 security officer had indicated that the alarm was a "ghost alarm." The security sergeant then asked the inspectors to reprocess through another nitrate detector to ensure he'had cleared the detector properly.
The licensee wrote a CRDR on the event and performed an event investigation.
The inspectors was informed during followup activities that the Post 3 officer was confident that the alarm had not been caused by the individual
~
preceding the inspectors and that nitrate detector 1 had been experiencing numerous alarms that mornin '
-14-Additionally, on January 24, a security officer received an early-off alarm while processing through a nitrate detector, entered the protected area, and did not reprocess when directed to by the post security officer. The licensee wrote a CRDR on this event and also performed an event investigation.
The inspectors noted that both of these events indicated weaknesses in communications between the Post 3 and Post 4 security officers. Additionally, the nitrate detectors appeared to be alarming when not appropriate, presenting unnecessary challenges to the security officers. A review of the January 24, 1997, event will remain open pending further inspection.
(Unresolved Item 50-.528; 50-529; 50-530/9601 8-05)
Conclusion Two events during protected area ingress highlighted weaknesses in communications between security officers monitoring ingress.
Additionally, nitrate, detector performance problems presented unnecessary challenges to security officers monitoring ingress.
V. Mana ement Meetin s X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on February 13, 1997.
The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary.
No proprietary information was identifie ATTACHMENT SUPPLEMENTAL INFORMATION PARTIALLIST OF PERSONS CONTACTED Licensee D. Carnes, Department Leader, Operations R. Flood, Department Leader, System Engineering R. Fullmer, Director, Nuclear Assurance J. Hesser, Director, Design Engineering W. Ide, Vice President, Engineering D. Kanitz, Engineer, Nuclear Regulatory Affairs A. Krainik, Department Leader, Nuclear Regulatory Affairs D. Mauldin, Director, Maintenance R. Myrick, Department Leader, Mechanical Maintenance G. Overbeck, Vice President, Nuclear Operations M. Powell, Department Leader, Civil/Mechanical Design Engineering C. Seaman, Director, Emergency Services G. Shanker, Department Leader, Nuclear Assurance Maintenance D. Smith, Director, Operations J. Taylor, Department Leader, Operations M. Windsor, Section Leader, Mechanical Maintenance Engineering'.
Zell, Department Leader, Operations
-2-40500 61726 62707 71707 71750 92903
~Oened INSPECTION PROCEDURES USED Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observations Maintenance Observations Plant Operations Plant Support Activities Engineering Followup ITEMS OPENED CLOSED AND DISCUSSED 50-528; 50-529; IFI 50-530/9601 8-01 50-528; 50-529; NCV 50-530/9601 8-02 50-528;50-529;50-NCV 530/9601 8-03 50-528; 50-529; URI 50-530 9601 8-04 Closed 5'0-528/94020-04 'FI
'0-528/9301 1-00 LER 50-528/95007-00 LER 50-528; 50-529; NCV 50-530/9601 8-03 50-528/95010-00 LER 50-528;50-529;50-NCV 530/9601 8-03 MRTE audit identified several examples of failure to follow program procedures licensee identified that LDCRs from some completed DCPs had not been incorporated in the UFSAR failure of procedures to provide for criticality evacuation drills security officer entering protected area without proper search, UFSAR not updated following two design changes.
potential safety-related equipment problems due to degraded grid voltage adverse affect of low bench set on Fisher air operated letdown/containment isolation valves licensee identified that LDCRs fiom some completed DCPs had not been incorporated in the UFSAR equipment qualification of air handling unit causes essential cooling water pump to become inoperable failure of procedures to provide for criticality evacuation drills
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-3-ITEMS DISCUSSED AND REMAINING OPEN 50-528/96007-03 IFI commitments associated with a survey of the Palo Verde PC system
LIST OF ACRONYMS USED AO CRDR DG DCP HRA LDCR LER Auxiliary Operator Condition Report/Disposition Request Diesel Generator Design Change Package High Radiation Area Licensing Document Change Request Licensee Event Report MS.TE PC PPS RCA RO RP RPT
.SS UFSAR WO WR Measuring and Test Equipment Pool Cooling Process of Performing Surveillance Radiological Controls Area Reactor Operator Radiological Protection Radiation Protection Technician Shift Supervisor Updated Final Safety Analysis Report Work Order Work Request
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